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.

FracTracker Alliance

A Fresh Look at Oil and Gas Drilling from Europe

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By Ted Auch, Kyle Ferrar, and Samantha Rubright with Max Gruenig

Fourteen days is not nearly enough time to fully understand the complex differences between oil and gas drilling issues and policies in the United States and several European Union countries. The EU’s drilling policies, geography, and the industry’s level of activity are quite distinct from those of the States in some cases. Still, as part of the Our Energy Solutions project, four staff from FracTracker Alliance and Ecologic Institute attempted to understand and share as many lessons-learned in Europe as we could in the first two weeks of September. Our interest covered all aspects of oil and gas development, but focused on those relating to the use of stimulation techniques (hydraulic fracturing – fracking) in unconventional reservoirs. Even with significant differences between the US and EU, there is still much to be gleaned in sharing our regulatory approaches, community concerns, and environmental challenges.

“Chaos is merely order waiting to be deciphered” ― José Saramago, The Double 

London, England Meetings

The House of Commons meeting was held in Parliament, just below London's Big Ben

The House of Commons meeting was held in Parliament, just below London’s Big Ben. Photo by Sam Rubright

Our European tour started in London with Ecologic Institute’s Max Gruenig. The first stop was a meeting with University of Salford Professor of Regeneration and Sustainable Development Erik Bichard outside of The Palace of Westminster. Erik has worked extensively to understand and chronicle common threads that weave together community response(s) to hydraulic fracturing (fracking) proposals. Much of Erik’s research in the UK has focused on the efforts of the leading shale gas extraction company in the EU, Cuadrilla Resources, to employ hydraulic fracturing technologies, as well as local oppositions to this development. The major points of contention are in Lancashire County, Northwest England and Balcombe in West Sussex. Erik pointed to the fact that Cuadrilla admitted their claims that the 4% decline in UK energy cost was a result of Lancashire oil and gas exploitation were significantly overstated. Such manipulative statements appear to be cut directly from North American energy’s playbook.

House of Commons meeting, London

House of Commons meeting, London. Photo by Sam Rubright

We then attended a spirited Fracking with Nature Meeting at The House of Commons hosted by 21st Century Network and convened by MP Cat Smith (photo right). Many, if not all, of the attendees were concerned about the negative impacts of fracking and oil and gas development in general, but perhaps the event’s purpose self-selected for those attendees. We found the conversations to be very advanced considering that the UK has not seen nearly the same level of oil and gas activity as the US. Most questions centered on the potential for fracking to negatively impact ground water, followed by the induction of earthquakes. Air quality was not discussed as often, despite the serious risks that oil and gas air pollutants pose to health, and the frequency and severity of ambient degradation reported in the US. With the UK’s move to cut subsidies for renewables and a push toward fracking, these concerns may soon become a reality.

We later met with one of the speakers at the House of Commons meeting, Damien Short LLB, MA, PhD, Director of the University of London’s Human Rights Consortium[1] and the Extreme Energy Initiative.[2] NGO’s, we learned, are on the forefront of the issue, debating the need to prioritize community health over corporate profits. They have had quite a lot of success on this front, despite Tory projections.[3] The past state of UK politics under the direction of PM David Cameron, was supportive of extractive industries and corporate interests, blocking any attempt to introduce regulations. Even with the defeat of David Cameron’s administration, new “fast-tracking” rules to accelerate permits for fracking passed in August.[4] The overwhelming victory of democratic socialist Jeremy Corbyn as the leader of the opposition Labour Party – means that the tenure of the current fracking moratoria in North Yorkshire, as well as in Scotland, Wales, and Northern Ireland[5] could be brief.

Our time in London was filled with several other meetings, including one with Greenpeace UK’s new fracking coordinator, Hannah Martin. During our meeting she indicated that while Greenpeace was sympathetic to the views and tactics of Mr. Corbyn, they were concerned that his election would further divide Labour. In her opinion this change could allow the oil and gas sympathetic – and united – Tories to expedite their vision for fracking in the UK.

Regardless of the similarities between community concerns and industry tactics, however, one difference between the UK and US was crystal clear; no matter their view on the use of fracking, Brits support a substantial Petroleum Revenue Tax (PRT) rate to the tune of 50-60%. The PRT will fall to 35% in January, 2016, however. This latter figure is a sizeable decrease but would still be 40% higher than the average in the US.  California for example, the fourth largest producing state, does not and has never levied a severance tax.[6] Unfortunately, the UK is seeing similar conflict of interest issues and deliberate attempts to de-democratize the rule-making around fracking, as demonstrated in a recent move to prevent a proper parliamentary debate about drilling under protected areas in the UK.

Brussels, Belgium Workshop and Meeting

After the European Commission meeting

Geert, Max, Kyle, and Ted after our meeting with the European Commission in Brussels. Photo by Sam Rubright

The next phase of OES Europe took us to Brussels to host a community workshop and meet with members of the European Commission’s Directorate-General for Environment. Both events brought to light many concerns and questions about drilling’s safety.

The European Commission is currently drafting a best available techniques reference document (BREF) regarding hydrocarbon extraction for the European Union to consider in December 2015. The recommendations will build upon the “Minimum Principles,” published in January, 2014.[7] Representatives from the European Commission asked us about a variety of concerns that have arisen from drilling in the US, and how Europe might have similar or different experiences. The Commission was most interested in environmental health risks and research focused on exposure to air pollutants, as well as other degraded environmental media (drinking water, soil, etc.). We also shared figures about water consumption, land use, and waste management. It was immediately apparent that the lack of high quality publicly accessible data in the US is making it very difficult for the Commission to make well-informed decisions or policy recommendations. This meeting was arranged by Geert De Cock, of Food and Water Europe, and – interestingly – was one of the first times that the European Commission met with non-industry representatives. (Several major oil and gas players have offices near the European Commission’s in Brussels.)

Rotenburg (Wümme), Germany Workshop

Presentations during Rotenburg Germany workshop, Sept 2015. Photo by Kyle Ferrar

Max presenting during the Rotenburg Germany workshop, Sept 2015. Photo by Kyle Ferrar

Our next stop in Germany was Rotenburg. Lower Saxony also has a long lineage of drilling, with the first well drilled in 1953 and the majority of natural gas development dating back to the mid 1980’s. Currently, this is an area were unconventional oil and gas drilling (fracking) is being heavily proposed and lobbied.

This workshop was by far the most well attended event. A variety of groups and stakeholders, including the town’s mayor, were in attendance and extremely well informed about environmental and public health risks that drilling could pose. They’ve been dealing with a series of environmental health concerns for some time, including high mercury levels in drilling waste and cancer clusters of questionable origin. A systematic statistical analysis has even suggested that cases of Non-Hodgkin lymphoma are higher in an area heavy with oil and gas wells and development.

See maps below for more information about drilling in Germany and Europe at large.

Unconventional gas production, conventional gas drilling, fracking and test boring in Europe
Map by Gegen Gasbohren (Against Gas Drilling)

View Gegen Gasbohren’s map fullscreen

A dynamic map similar to the one above was created by us to show simply where unconventional drilling is occurring in the UK and Netherlands:
View FracTracker’s map fullscreen

Rotenburg Field Tour

The following morning we set out with a local advocate, Andreas Rathjens, to tour over eight different oil and gas drilling sites and facilities in and around Rotenburg. This area is vey rural and a major agriculture hub, hosting 162k people, 200k cows, and 600k pigs according to our guide.

In recent years Germany has received very positive scores for its environmental policies and shift toward renewables. However, this tour highlighted some of the country’s lingering and poorly-regulated drilling history, which experienced a sharp increase in development here in the 1980’s. The pictures below will give you an idea of the issues that German residents are is still seeing from the country’s older oil and gas drilling operations. Click to enlarge the photos:

Rotenburg, Germany surface water runoff pond on a gas well pad in production

This pit is used to capture rainwater and runoff from the well pad. Since runoff from the pad will carry with it any contaminants spilled on the site, runoff must be quarantined for removal and proper disposal. Unfortunately, these tanks are rarely pumped and drained, and the runoff instead spills into local streams in small watersheds. Such is the case with this tank, with the spillway visible in the lower left corner of the photo.

IMG_0063

This site was recently renovated to improve the drainage off of the wellpad. The drainage leads to an excavated waste pit used as an overflow catchment.[8] In these types of waste pits pollutants evaporate into the air and percolate into groundwater sources. The waste from drilling in this region is known for its high levels of mercury.

Andreas showing us the site where he says 80,000 metric tonnes of solid waste from oil and gas drilling was mixed with residential waste and then disposed of in a field on top of a hill. Residents have tested the site and found troubling levels of arsenic and radioactive elements, but to Andreas’ knowledge no governmental or company testing has been done to-date.

Andreas showing us the site where he says 80,000 metric tonnes of solid  drilling waste was mixed with residential waste and then disposed of in a field on a hilltop. Residents have tested the site and found troubling levels of arsenic and radioactive elements, but to Andreas’ knowledge no governmental or company testing has been done to-date.

View more photos from Germany

Andreas and community members all conveyed their support of domestic energy production but said they were disappointed in how the oil and gas industry has conducted itself historically in the region. They are very frustrated with how difficult it is to get their concerns heard, a sentiment echoed in many boomtowns across the US. One local politician even discussed the intentionally misleading statements made by the German state governments around environmental health issues. These residents are dedicated and driven despite the barriers, however. They are investigating and studying the problems directly at times, as well as searching for other technologies that can help improve their methods – such as the use of drones to measure air quality.

Badbergen, Lower Saxony, Germany Workshop

Fracking-freies Artland hosted our next workshop in Badbergen Germany. In addition to our presentation about drilling experiences in the US, these community gatekeepers led a presentation summarizing the work and struggles that have been occurring in their region due to both historic and modern drilling. The level of community engagement and activism here was quite impressive, mirroring that of NY State’s anti-drilling groups. These members help to inform the rest of the community about environmental and drilling issues, as Exxon is now considering fracking here again.[9]

Schoonebeek Tour, Netherlands

Our final border crossing brought us to the Schoonebeek region in the Netherlands. While the Groningen gas field is by far the largest of the fields in this Western European country, Schoonebeek is the only active field being drilled unconventionally in the Netherlands.

OES-Europe-Home

Interestingly, the entire field was recently shut down by NAM Shell/Exxon JV to fix this wastewater pipeline. It was discovered that the pipeline was leaking wastewater in nine places due to corrosion caused by the high sulfur content of the wastewater.

Upon starting our tour we were informed of the fact that the Dutch have an even higher extraction tax than the UK! The Netherlands retains a 50% State Profit Share for revenue and taxes the remaining production at a rate of 20% on the first $225,000 in revenue and “25% on the excess.” In comparison, the highest production tax rate on oil and gas drilling in the US is in Alaska at 35%. Most states have significantly lower severance taxes.[10]

Political support for higher taxes on the extractives industry may be explained by the fact that the state owns all subsurface mineral rights in these European countries. Regardless of other influences on perception, such high taxes disproves the notion here in the US that energy companies “won’t do business in a state [or country] with a newly-enacted punitive severance tax.” What do the states do with this extra revenue? The Netherlands and many Northern European countries have invested these monies for the rainy day when the oil and gas supply is depleted or extraction is no longer justifiable. The best examples are Norway’s $850 billion Government Pension Fund and Netherland’s $440 billion pension fund or $169,000 and $26,000 per capita, respectively.

Additional support for severance taxes is likely due to these countries’ history with oil and gas exploration. They are familiar with the boom-bust cycles that come with the initial expectations and long-term reality on the ground. When the music stops, Europeans are determined not to be the ones left standing.

About the Our Energy Solutions Project

This trip to Europe and our previous expeditions to Florida, North Carolina, Argentina, and Uruguay are part of a larger, collaborative project with Ecologic Institute US called Our Energy Solutions. OES is creating an informed global community of engaged citizens, organizations, businesses, governments, and stakeholders to develop ideas and solutions to keep our society moving forward while preserving our planet for the future. Learn more at: ourenergysolutions.org.

On a more personal note, our sincerest thanks goes out to the many groups and individuals that we met on our Europe tour, including those we did not directly mention in this article. We are forever indebted to all of the people with whom we met on these OES trips for sharing their time and knowledge with us.

Endnotes and References

  1. Dr. Short is currently advising local anti-fracking groups in the UK and county councils on the human rights implications of unconventional (extreme) energy extraction processes such as fracking.
  2. Dr. Short and collaborators were recently granted an opportunity to put fracking on trial at hearings to be held by The Permanent Peoples’ Tribunal (PPT) in the UK and the US.
  3. Much of the ammunition used by the anti- or undecided fracking community in the UK – and the EU writ large – is coming from proofs of concept in states like Pennsylvania, Ohio, New York, and North Dakota.
  4. Gosden, Emily. 8/13/15. Fracking: new powers for ministers to bypass local councils. The Telegraph. Accessed 10/25/15.
  5. Strachan, Peter. Russell, Alex. Gordon, Robert. 10/15/15. UK government’s delusional energy policy and implications for Scotland. OilVoice. Accessed 10/25/15.
  6. California, instead, imposes a statewide assessment fee.
  7. European Commission. 1/22/14. Fracking: minimum principles for the exploration and production of hydrocarbons using high-volume hydraulic fracturing. Eur-Lex. Accessed 10/26/15.
  8. A practice that is supposedly now being investigated for soil contamination issues.
  9. Exxon originally wrote in the local/regional paper that there was to be no unconventional shale drilling (fracking), but now the company is reconsidering.
  10. Please note that the cited article was last updated in 2012. Some tax rates have changed since the time that the article was published, but the table still adequately represents an estimation of production taxes by state.
FracTracker Alliance

About FracTracker Alliance [video]

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Learn more about FracTracker Alliance and why we do what we do in this snazzy new video produced by Stony Creek Films.

Oil wastewater pit
Kyle Ferrar, MPH

Wastewater Pits Still Allowed in California

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By Kyle Ferrar, Western Program Coordinator

Above-ground, unlined, open-air sumps/ponds

It is hard to believe, but disposing of hazardous oil and gas wastewaters in unlined, open-air pits – also known as sumps or ponds – is still a common practice in California. It is also permitted in other states such as Texas and West Virginia. Because these ponds are unlined and not enclosed, they contribute to degraded air quality, are a hazard for terrestrial animals and birds, and threaten groundwater quality. A 2014 report by Clean Water Action, entitled In the Pits provides a thorough summary of the issue in California. Since the report was released, new data has been made available by the Central Valley Regional Water Quality Review Board identifying additional locations of wastewater pits.

With the increase of oil and gas development in unconventional reservoirs, such as the Monterey Shale Play in California, the size of the resultant waste stream of drill cuttings, produced brines, and wastewater has skyrocketed. Operators now drill larger, deeper wells, requiring larger volumes of liquid required for enhanced oil recovery methods, such as steam injection, and stimulations such as hydraulic fracturing and acidizing. While California is the 4th largest oil-producing state, it is 2nd only to Texas in wastewater production. This boom of unconventional development, which may still in its infancy in California, has resulted in an annual waste stream of over 130 billion gallons across the state, 80 billion (62%) from Kern County alone.1

Results of the state mandated California Council on Science and Technology Report found that more than half of the California oil industries waste water is “disposed” in pits.2 As outlined by Clean Water Action, the massive waste-stream resulting from drilling, stimulation, and production is one of the most significant and threatening aspects of oil and gas operations in terms of potential impacts to public health and environmental resources.

Wastewater Facility Details

Last February, the LA Times reported on the pits, identifying a total of 933 in California.3 The most recent data from the Regional Water Quality Control Board of the Central Valley shows:

  • A total of 1,088 pits at 381 different facilities
  • 719 pits are listed as “Active.” 369 are “Idle.”
  • 444/939 (47.3%) ponds do not list a permit.
  • 462 pits are operated by Valley Water Management Corporation.

In Table 1, below, the counts of Active and Idle facilities and pits are broken down further to show the numbers of sites that are operating with or without permits. The same has been done for the operator with the most pits in Table 2, because Valley Wastewater operates nearly 9 times as many pits as the second largest operator, E & B Natural Resources Management Corporation. These two operators, along with California Resources Elk Hills LLC, all operate the same number of facilities (28). The other top 20 operators in Kern County are listed in Table 3, below.

Table 1. Wastewater Pit and Facility Counts by Category
Counts Active Idle
Facilities 180 201
Unpermitted Facilities 102 179
Facility Permitted prior to 1985 37 11
Individual Pits 719 369
Unpermitted Individual Pits 187 257
Pit Permitted prior to 1985 252 63

 

Table 2. Valley Water Wastewater Pit and Facility Counts by Category
Counts Active Inactive
Facilities 21 7
Unpermitted Facilities 2 2
Facility Permitted prior to 1985 9 1
Individual Pits 356 78
Unpermitted Individual Pits 5 9
Pit Permitted prior to 1985 166 35

 

Table 3. Top 20 Operators by Facility Count, with Pond Counts.
Rank Operator Pond Count Facility Count
1 Valley Water Management Company 462 28
2 E & B Natural Resources Management Corporation 53 28
3 California Resources Elk Hills, LLC 31 28
4 Aera Energy LLC 67 25
5 California Resources Corporation 31 23
6 Chevron U.S.A. Inc. 40 14
7 Pyramid Oil Company 21 12
8 Macpherson Oil Company 14 9
9 Schafer, Jim & Peggy 8 8
10 Crimson Resource Management 20 6
11 Bellaire Oil Company 11 6
12 Howard Caywood 11 6
13 LINN Energy 10 6
14 Seneca Resources Corporation 9 6
15 Holmes Western Oil Corporation 6 6
16 Hathaway, LLC 22 5
17 Central Resources, Inc. 15 5
18 Griffin Resources, LLC 13 5
19 KB Oil & Gas 8 5
20 Petro Resources, Inc. 6 5

Maps of the Pit Locations and Details

 

The following maps use the Water Authority data to show the locations details of the wastewater pits. The first map shows the number of pits housed at each facility. Larger markers represent more pits. Zoom in closer using the [+] to see the activity status of the facilities. Click the link below the map to open a new webpage. View the names of the facility operators by turning on the layer in the “Layers” menu at the top of the page. The second and third maps show the activity and permit status of each facility. The fourth map allows you to view both activity status and permit status simultaneously by toggling the layers on and off (Open the map in its own webpage, then use the layers menu at the top of the screen to change views).

Map 1. Facility Pit Counts with the top 10 operators identified as well as facility status

Map 1. To view the legend and map full screen, click here.

Map 2. Facility Activity Status

Map 2. To view the legend and map full screen, click here.

Map 3. Facility Permit Status

Map 3. To view the legend and map full screen, click here.

Map 4. Facilityhttps://maps.fractracker.org/lembed/?appid=7385605f018e437691731c94bb589f0a” width=”800″ height=”500″>
Map 4. To view the legend and map full screen, click here.

References

  1. USGS. 2014. Oil, Gas, and Groundwater Quality in California – a discussion of issues relevant to monitoring the effects of well stimulation at regional scales.. California Water Science Center. Accessed 10/1/15.
  2. CCST. 2015. Well Stimulation in California. California Council on Science and Technology. Accessed 9/1/15.
  3. Cart, Julie. 2/26/15. Hundreds of illicit oil wastewater pits found in Kern County . Los Angeles Times. Accessed 9/1/15.
FracTracker Alliance

Parked Oil Trains in Berks County, PA

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By
Matt Kelso, Manager of Data & Technology
Kirk Jalbert, Manager of Community Based Research & Engagement

The Risks of Crude Oil Trains

As new oil fields boomed across North America in recent years, drillers looked for ways to get the product to refineries thousands of miles away. One solution was to use the nation’s rail infrastructure to ship hundreds of thousands of barrels of crude oil per day. The flow of oil was so great that thousands of additional tanker cars were ordered to get the oil to market. And yet, this solution of transporting crude by rail brought additional problems. Shipping large quantities of highly volatile and combustible crude oil on often antiquated rail lines has resulted in numerous accidents, at times spectacular in scale. In recent months, however, thousands of these oil tankers have been sitting idle on the tracks around the country, partially due to dropping oil prices, leading refineries to opt for cheaper imported oil and less expensive ways to get the domestic product to market such as through pipelines.

Communities Along the Tracks

The interactive story map below investigates a stretch of oil trains that have been parked for months in close proximity to homes, schools, and busy intersections in Berks County, Pennsylvania. Altogether, 30,494 people live in the seven communities through which the tracks in question pass. We began this project in response to concerns from residents who contacted FracTracker for assistance in understanding why these trains were located in their community, what hazards they might pose, and to help people bring this story to the public to foster meaningful discussions about the risks of parked oil trains.

Click to Enter the Interactive Story Map

Berks_staticmap

FracTracker has covered the risks of oil trains in a series of other articles. Click here to learn more.

Guest Author

Maps of Updated Central Penn Pipeline Emphasize Threats to Residents and Environment

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By Sierra Shamer, Guest Author

The Atlantic Sunrise Project or Central Penn Line is a natural gas pipeline Williams Companies has proposed for construction through eight counties of Central Pennsylvania. Williams intends to connect the Atlantic Sunrise to their two Transco pipelines, which extend from the northeast to the Gulf of Mexico. FracTracker discussed and mapped this controversial project as part of a blog entry in June of 2014; since then, the Atlantic Sunrise Project has been, and continues to be, a focus of unprecedented opposition. While supporters of the pipeline stress how it may enhance energy independence, economic growth, and job opportunities, opponents cite Williams’ poor safety records, their threats of eminent domain, and environmental hazards. This article provides details and maps pertaining to these threats and concerns.

Atlantic Sunrise: Project Overview

The Atlantic Sunrise Project would add 183 miles of new pipeline through the construction of the Central Penn Line North and the Central Penn Line South. The proposed Central Penn Line North (CPLN) begins in Susquehanna County, continues through Wyoming and Luzerne counties, and meets with the Transco Pipeline in Columbia County. With a 30 inch in diameter, it would allow for a maximum pressure of 1,480 psi (pounds per square inch). The proposed Central Penn Line South (CPLS) begins at the Transco Pipeline in Columbia County, and continues through Northumberland, Schuylkill, and Lebanon counties, ending in Lancaster. It would be 42 inches in diameter with a maximum pressure of 1,480 psi. The Atlantic Sunrise project also involves the construction of two new compressor stations, one in Clinton Township, Wyoming County, and the other in Orange Township, Columbia County. Finally, to accommodate the daily 1.7 million dekatherms (1 dekatherm equals 1,000 cubic feet of gas or slightly more than 1 million BTUs in energy) of additional natural gas that would flow through the system, the project proposes the expansion of 10 existing compressor stations along the Transco Pipeline in Pennsylvania, Maryland, Virginia, and North Carolina. Although the Atlantic Sunrise Pipeline would be entirely within Pennsylvania, it is permitted and regulated by the Federal Energy Regulatory Committee (FERC) because through its connection to the Transco Pipeline, it transports natural gas over state lines.

Updated Central Penn Pipeline Route

On March 31, 2015, Williams filed their formal application to FERC docket #CP15-138. Along with the formal application came changes to the pre-filing route of the pipeline that was submitted in the spring of 2014. The route of the Central Penn Line North has been modified since then by 21%, while the Central Penn Line South has been rerouted by 57%.

Williams’ application comprised of hundreds of attached documents, including pipeline alignment sheets for the entire route. Here is one example: 

alignment_sheet_example

These alignment sheets show the extent of William’s biological investigation, the limits of disturbance, the occurrence of stream and wetland crossings, and any road or foreign pipeline crossings. Absent from the alignment sheets, however, is the area around the right-of-way that will be endangered by the presence of the pipeline. This is colloquially known as the “burn zone” or “hazard zone”.

What are “Hazard Zones”?

A natural gas pipeline moves flammable gas under extreme pressure, creating a risk of pipeline rupture and potential explosion. The “potential impact radius” or “hazard zone” is the approximate area within which there will be immediate damage in the case of an explosion. Should this occur, everything within the hazard zone would be incinerated and there would be virtually no chance of escape or survival. Based on pipeline diameter and pressure, the hazard zone can be calculated using the formula: potential impact radius = 0.69 * pipeline diameter * (√max pressure ).

Based on this formula, the hazard zone for the Central Penn Line North, with its diameter of 30 inches and maximum pressure of 1,480 psi, is approximately 796 feet (243 meters) on either side of the pipeline. The hazard zone for Central Penn Line South, with its diameter of 42 inches and maximum pressure of 1480 psi, is 1,115 feet (340 meters) on either side.

Many residents are unaware that their homes, workplaces, and schools are located within the hazard zone of the proposed Atlantic Sunrise Pipeline. Williams does not inform the public about this risk, primarily communicating with landowners along the right-of-way. The interactive, zoomable map (below) of the currently proposed route of the Atlantic Sunrise, Central Penn North and South pipelines depicts the pipeline right-of-way, as well as the hazard zones. The pipeline route was digitized using the alignments sheets included in Williams’ documents submitted to FERC. You can use this map to search home, work, and school addresses to see how the pipeline will affect residents’ lives and the lives of their communities.

Click in the upper right-hand corner of the map to expand to full-screen view, with a map legend.

Affected Communities

Landowners & Eminent Domain

Landowners along the right-of-way are among the most directly and most negatively impacted by the Atlantic Sunrise Pipeline, and other similar projects. Typically, people first become aware that a pipeline is intended to pass through their property when they receive a notice in the mail. Landowners faced with this news are on their own to negotiate with the company, navigate the FERC permitting and public comment process, and access unbiased and pertinent information. They face on-going stress, experiencing pressure from Williams to sign easement agreements, concern about the effects of construction on their property, and fear of living near explosive infrastructure. They must also consider costs of legal representation, decreases in property value, and limited options for mortgage and refinancing.

Sometimes, landowners in a pipeline’s right-of-way choose to not allow the company onto their property to conduct a survey. Landowners may also refuse to negotiate an agreement with the pipeline company. In response, the pipeline company can threaten to seize the property through the power of eminent domain, the federal power allowing private property to be taken if it is for the “public use.”

The law of eminent domain states that landowners whose properties are condemned must be fairly compensated for their loss. However, most landowners feel that in order to be fairly compensated by the company, they must hire their own land appraiser and attorney. This decision can be costly, however, and may not be an option for many people. The legitimacy of Williams’ intent to use eminent domain is contested by opponents of the project, who cite how “public use” of the property provides no positive local impacts. The Atlantic Sunrise Pipeline is intended to transport gas out of Pennsylvania through the Transco, so the landowners in its path will not benefit from it at all. Further, it connects to a network of pipelines leading to current export terminals in the Gulf of Mexico, as well as controversial planned export facilities like Cove Point, MD .

Throughout Pennsylvania, communities have responded to the expansion of pipelines, and to the threats of large companies like Williams. The need for landowner support has been addressed by organizations such as the Shalefield Organizing Committee, Energy Justice Network, the Clean Air Council, the Gas Drilling Awareness Coalition, and We Are Lancaster County. These organizations have worked to provide information, increase public awareness, engage with FERC, and develop resistance to the exploitation of Pennsylvania’s resources and residents. Director Scott Cannon of the Gas Drilling Awareness Coalition has documented firsthand the impacts of unconventional drilling in Pennsylvania through a short film series called the Marcellus Shale Reality Tour. The most recent in the series relates the stories of two landowners impacted by the Atlantic Sunrise Pipeline in the short film Atlantic Sunrise Surprise.

Environmental Review

Theoretically, environmental review of this proposed pipeline would be extensive. Primary decision-making on the future of the Atlantic Sunrise rests with FERC. Due to the National Environmental Policy Act of 1969 (NEPA), all projects overseen by federal agencies are required to prepare environmental assessments (EAs) or environmental impact assessments (EIAs). Because FERC regulates interstate pipelines, EA’s or EIA’s are required in their approval process. These assessments are conducted to accurately assess the environmental impacts of projects and to ensure that the proposals comply with federal environmental laws such as the Endangered Species Act, and the Clean Air and Water Acts. On the state level, the Pennsylvania Department of Environmental Protection (PA DEP) issues permits for wetlands and waterways crossings and for compressor stations on regional basis.

Core Habitats, Supporting Landscapes

The route of the Atlantic Sunrise Pipeline will disturb numerous areas of ecological importance, including many documented in the County Natural Heritage Inventory (CNHI). The PA Department of Conservation and Natural Resources conducted the inventory to be used as a planning, economic, and infrastructural development tool, intending to avoid the destruction of habitats and species of concern. The following four maps show the CNHI landscapes affected by the current route of the Atlantic Sunrise pipeline (Figures 1-4).

Figure 1

Figure 1. Columbia & Northumberland counties

Figure 3. Lebanon County

Figure 2. Lebanon & Lancaster counties

Figure 3. ddd

Figure 3. Threatened Core Habitats

Figure 4. Schuyklill

Figure 4. Schuyklill & Lebanon counties

The proposed pipeline would disrupt core habitats, supporting landscapes, and provisional species-of-concern sites. According to the Natural Heritage Inventory report, core habitats “contain plant or animal species of state or federal concern, exemplary natural communities, or exceptional native diversity.” The inventory notes that the species in these habitats will be significantly impacted by disturbance activities. Supporting landscapes are defined as areas that “maintain vital ecological processes or habitat for sensitive natural features.” Finally, the provisional species of concern sites are regions where species have been identified outside of core habitat and are in the process of being evaluated. The Atlantic Sunrise intersects 16 core habitats, 12 supporting landscapes, and 6 provisional sites.

Active Mine Fires

Map5-GlenBurn

Figure 5. Glen Burn Mine Fires

The current route of the Atlantic Sunrise intersects the Cameron/Glen Burn Colliery, considered to be the largest man-made mountain in the world and composed entirely of waste coal. This site also includes a network of abandoned mines, three of which are actively burning (Figure 5).

The pipeline right-of-way is roughly a half-mile from the closest burning mine, Hickory Swamp. These mine fire data were sourced from a 1988 report by GAI Consulting Inc. The time frame for the spread of the mine fires is unknown, and dependent on environmental factors. Mine subsidence — when voids in the earth created by mines cause the surface of the earth to collapse — is another issue of concern. Routing the pipeline through this unstable area adds to the risk of constructing the pipeline through the Glen Burn region.

Looking Ahead

The Atlantic Sunrise Project has received an unprecedented level of resistance that continues to grow as awareness and information about the threats and hazards develops. While Williams, FERC, and the PA DEP negotiate applications and permits, work is also being done by many non-profit, research, and grassroots organizations to investigate the environmental, cultural, and social costs of this pipeline. We will follow up with more information about this project as it becomes available.

This article was written by Sierra Shamer, an environmental mapper and activist. Sierra is a member of the Shalefield Organizing Committee and holds two degrees from the University of Maryland, Baltimore County: a B.A. in environmental studies and an M.S. in geography and environmental systems.

Ted Auch, PhD

The Curious Case of the Shrinking Utica Shale Play

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Oil, Gas, and Brine Oh My!
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

It was just three years ago that the Ohio Geological Survey (OGS) and Department of Natural Resources (DNR) were proposing – and expanding – their bullish stance on the potential Utica Shale oil and gas production “play.” Back in April 2012 both agencies continue[d] to redraw their best guess, although as the Ohio Geological Survey’s Chief Larry Wickstrom cautioned, “It doesn’t mean anywhere you go in the core area that you will have a really successful well.”

What we found is that the OGS projections have not held up to their substantial claims. And here is why…

Background

The Geological Survey eventually parsed the Utica play into pieces:

  • a large oil component encompassing much of the central part of the state,
  • natural gas liquids from Ashtabula on the Pennsylvania border southwest to Muskingum, Guernsey, and Noble Counties, and
  • natural gas counties, primarily, along the Ohio River from Columbiana on the Pennsylvania-West Virginia border to Washington County in the Southeast quarter of the state.
Columbus Dispatch Utica Shale "play" map

Columbus Dispatch Utica Shale “play” map

Fast forward to the first quarter of 2015 and we have a very healthy dataset to begin to model and validate/refute these projections. Back in 2009 Wickstrom & Co. only had 53 Utica Shale laterals, while today Ohio is host to 962 laterals from which to draw our conclusions. The preponderance of producing wells are operated by Chesapeake (463), Gulfport (118), Antero Resources (62), Eclipse Resources (41), American Energy Utica (36), Consol (35), and R.E. Gas Development (34), with an additional 13 LLCs and 10 publicly traded companies accounting for the remaining 173 producing laterals. A further difference between the following analysis and the OGS one is that we looked at total production and how much oil and gas was produced on a per-day basis.

Analysis

Using an interpolative geostatistical technique known as Empirical Bayesian Kriging and the 962 lateral dataset, we modeled total and per day oil, gas, and brine production for Ohio’s Utica Shale between 2011 and Q1-2015 to determine if the aforementioned map redrawing holds up, is out-of-date, and/or is overly optimistic as is generally the case with initial O&G “moving target” projections.

Days of Activity & Brine Production

The most active regions of the Utica Shale for well pad activity has been much of Muskingum County and its border with Guernsey and Noble counties; laterals are in production every 1 in 2.1-3.4 days. Conversely, the least active wells have been drilled along the Harrison-Belmont border and the intersection between Harrison, Tuscarawas, and Guernsey counties.

Brine is a form of liquid drilling waste characterized by high salt loads and total dissolved solids. The laterals that have produced the most brine to date are located in a large section of Monroe County and at the intersection of Belmont, Monroe, and Noble counties, with total brine production amounting to 23,292 barrels or 734,000-978,000 gallons (Fig. 1).

Total Ohio Utica Shale Production Days 2011 to Q1-2015

Total Ohio Utica Shale Oil Production 2011 to Q1-2015

Total Ohio Utica Shale Gas Production 2011 to Q1-2015

Total Ohio Utica Shale Brine Production 2011 to Q1-2015

Figure 1. Total Ohio Utica Shale Oil, Gas, and Brine Production 2011 to Q1-2015

This area is also one of the top three regions of the state with respect to Class II Injection volumes; the other two high-brine production regions are Morrow and Portage counties to the west and southwest, respectively (Fig. 2).

Layout & Volume (2010 to Q1-2015, Gallons) of Ohio’s Active Class II Injection Wells

Figure 2. Layout & Volume (2010 to Q1-2015, Gallons) of Ohio’s Active Class II Injection Wells

However, on a per-day basis we are seeing quite a few inefficient laterals across the state, including Devon Energy’s Eichelberger and Richman Farms laterals in Ashland and Medina counties. Ashland and Medina are producing 230-270 barrels (8,453-9,923 gallons) of brine per day. In Carroll County, one of Chesapeake’s Trushell laterals tops the list for brine production at 1,843 barrels (67,730 gallons) per day. One of Gulfport’s Bolton laterals in Belmont County and EdgeMarc’s Merlin 10PPH in Washington County are generating 1,100-1,200 barrels (40,425-44,100 gallons) of brine per day.

Oil & Gas Production

Since the last time we modeled production the oil hotspots have shrunk. They have also become more discrete and migrated southward – all of this in contrast to the model proposed by the OGS in 2012. The areas of greatest productivity (i.e., >26,000 barrels of oil) are not the central part of the state, but rather Tuscarawas, Harrison, Guernsey, and Noble counties (Fig. 1). The intersection of Harrison, Tuscarawas, and Guernsey counties is where oil productivity per-day is highest – in the range of 300-630+ barrels (Fig. 3). The areas that the OGS proposed had the highest oil potential have produced <600 barrels total or <12 barrels per day.

Per Day Ohio Utica Shale Oil Production 2011 to Q1-2015

Per Day Ohio Utica Shale Gas Production 2011 to Q1-2015

Per Day Ohio Utica Shale Brine Production 2011 to Q1-2015

Figure 3. Per-Day Ohio Utica Shale Oil, Gas, and Brine Production 2011 to Q1-2015

The OGS natural gas region has proven to be another area of extremely low oil productivity.

Natural gas productivity in the Utica Shale is far less extensive than the OGS projected back in 2012. High gas production is restricted to discreet areas of Belmont and Monroe counties to the tune of 947,000-4.1 million Mcf to date – or 5,300-18,100 Mcf per day. While the OGS projected natural gas and natural gas liquid potential all the way from Medina to Fairfield and Perry counties, we found a precipitous drop-off in productivity in these counties to <1,028 Mcf per day (<155,000 Mcf total from 2011 to Q1-2015) or a mere 6-11% of the Belmont-Monroe sweet spot.

Conclusion: A Shrinking Utica Shale Play

Simply put, the OGS 2012 estimates:

  • Have not held up,
  • Are behind the times and unreliable with respect to citizens looking to guestimate potential royalties,
  • Were far too simplistic,
  • Mapped high-yield sections of the “play” as continuous when in fact productive zones are small and discrete,
  • Did not differentiate between per day and total productivity, and
  • Did not address brine waste.

These issues should be addressed by the OGS and ODNR on a more transparent and frequent basis. Combine this analysis with the disappointing returns Ohio’s 17 publicly traded drilling firms are delivering and one might conclude that the structural Utica Shale bubble is about to burst. However, we know that when all else fails these same firms can just “lever up,” like their Rocky Mountain brethren, to maintain or marginally increase production and shareholder happiness. Will these Red Queens of the O&G industry stay ahead of the Big Bank and Private Equity hounds on their trail?

Digging into Waste Data
Matt Kelso, BA

Pennsylvania’s Drilling Waste Distributed to Eight States

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By Matt Kelso, Manager of Data & Technology

According to data published by the Pennsylvania Department of Environmental Protection (DEP), Pennsylvania’s unconventional oil and gas waste that was generated in the first half of 2015 found its way to treatment facilities, disposal wells, and landfills in eight different states. While the majority of the waste stayed in-state, neighboring Ohio, New York, and West Virginia all received significant quantities of both solid and liquid waste, and additional disposals were made in the non-contiguous states of Michigan, Texas, Utah, and Idaho.


Waste generated by Pennsylvania’s unconventional oil and gas wells was disposed of in a variety of ways and over a large geographic area. Click on a facility to learn more, or zoom in to access waste generated by individual wells. Click here to access the full screen map with a legend and additional controls.

Unconventional drillers in the state are now required to report production data monthly, rather than in six month increments, but waste quantities generated by the wells is still supposed to be reported biannually. However, a small number of operators have been reporting waste monthly, as well, and those figures have been included in this analysis, after spot-checking for duplication. Each record includes data on how the waste was processed and where it was shipped, so we were able to map the receiving facilities as well, and aggregate their waste totals.

Types of Waste

Waste generated by unconventional wells in Pennsylvania from January to June 2015.

Waste generated by unconventional wells in Pennsylvania from January to June 2015 by type.

There are eight types of waste detailed in the Pennsylvania data, including:

  • Basic Sediment (Barrels) – Impurities that accompany the desired product
  • Drill Cuttings (Tons) – Broken bits of rock produced during the drilling process
  • Flowback Fracturing Sand (Tons) – Sand used to prop open cracks made during hydraulic fracturing that return to the surface
  • Fracing Fluid Waste (Barrels) – Fluid pumped into the well for hydraulic fracturing that returns to the surface. This includes chemicals that were added to the well.
  • Produced Fluid (Barrels) – Naturally occurring brines encountered during drilling that contain various contaminants, which are often toxic or radioactive
  • Servicing Fluid (Barrels) – Various other fluids used in the drilling process
  • Spent Lubricant (Barrels) – Oils used in engines as lubricants
  • General O&G Waste (Tons) – Solid waste types other than drill cuttings or fracturing sand

For the sake of simplicity, this analysis will at times aggregate the waste types into two categories, with all types reporting in tons as solid waste, while those listed in 42 gallon barrels will be considered liquid waste.

Waste Disposal

Waste disposal method for unconventional wells in PA, January to June 2015

Waste disposal method for unconventional wells in PA, January to June 2015

This PA waste gets disposed of in a variety of ways. About 93 percent of all solid waste ends up in landfills. 29 of the 58 operators reporting waste during this cycle reported drill cuttings. In a separate report, the DEP has records for unconventional wells drilled by 28 different operators during the same time frame, so these results seem reasonable, since drill cuttings are generated during the drilling process, whereas other types of waste are produced throughout the life cycle of the well.

Statewide, there over 596,000 tons of drill cuttings produced during a period which saw 422 wells spudded, an average of 1,412 tons of cuttings per well. Not all operators generated the same amount of cuttings per well, however. Vantage Energy reports 3,089 tons of cuttings per well, while Hilcorp Energy manages to average just 119 tons over 23 wells drilled in the six month period. It is worth noting that some wells that were spudded just prior to the reporting period likely still generated drill cuttings during the six months in question, and some wells spudded during the cycle will continue to produce cuttings into the next one.

In terms of liquid waste, nearly two thirds of the amount reported is reused for purposes other than road spreading. This is, unfortunately, a dead end in terms of being able to follow the waste stream in the data, as there are no facilities associated with the 13.8 million barrels of waste that falls into this category. 225,000 barrels are specified as being reused for hydraulic fracturing, while the remainder is simply destined for, “Reuse without processing at a permitted facility.”

The amount used for road spreading, 147 barrels, is relatively small, and all of this waste is reported as going to private roads in Greene County. The total amount of liquid waste produced in the six month period is almost 879 million gallons, or enough to fill 1,331 Olympic-sized swimming pools.

PA Waste Receiving Facilities

Altogether, we know where roughly 7 million of the nearly 21 million barrels of reported liquid waste wound up, as well as 640,000 of the 647,000 tons of solid waste. The top ten destinations for each waste type are as follows:

Top 10 reported recipients of unconventional O&G waste produced in PA during the first half of 2015.

Top 10 reported recipients of unconventional O&G waste produced in PA during the first half of 2015.

Six of the top destinations for liquid waste were located in-state, while seven of the top ten facilities for solid waste stayed in Pennsylvania. The only facility to appear on both lists is Patriot Water Treatment in Warren, Ohio.

FracTracker Alliance

Public Herald’s #fileroom Update

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Crowdsourcing Digital PA Oil & Gas Data

FracTracker Alliance worked with Public Herald this spring to update and map oil and gas complaints filed by citizens to the Pennsylvania Department of Environmental Protection (PA DEP) as of March 2015. The result is the largest release of oil and gas records on water contamination due to fracking in PA. Additionally, Public Herald’s investigation revealed evidence of Pennsylvania state officials keeping water contamination related to fracking “off the books.”

View Report

Project Background

The mission of Public Herald, an investigative news non-profit formed in 2011, is two-fold: truth + creativity. Their work uses investigative journalism and art to empower readers and hold accountable those who put the public at risk. For this project, Public Herald aims to improve the public’s access to oil and gas information in PA by way of file reviews and data digitization. Public Herald maintains an open source website called #fileroom, where people can access a variety of digital information originally housed on paper within the PA DEP. This information is collected and synthesized with the help of donors, journalists and researchers in a collective effort with the community. To date, these generous volunteers have already donated more than 2,000 hours of their time collecting records.

The site includes complaints, permits, waste, legal cases, and gas migration investigations (GMI) conducted by the PA DEP. Additionally, there is a guide on how to conduct file reviews and how to access information through the “Right-to-Know” law at the PA DEP. They have broken down complaints and permits by county; wastes and GMI categories by cases, all of which include test results from inspections; and correspondence and weekly reports.

Some partners and contributors to the file team include Joshua Pribanic as the co-founder and Editor-in Chief, Melissa Troutman as co-founder and Executive Director, John Nicholson, who collects and researches for several databases, Nadia Steinzor as a contributor through Earthworks, and many more. Members of FracTracker working on this project include Matt Kelso, Samantha Rubright, and Kirk Jalbert.

#fileroom’s update expands the number of complaint data records collected to 18 counties – and counting!


View Map Fullscreen

View Report
FracTracker Alliance

Oil Train Response 2015

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November 13-15, 2015

Wyndham Pittsburgh University Center, Pittsburgh, Pennsylvania
Coordinated by FracTracker Alliance and ForestEthics

Couldn’t make it?
Watch Friday’s Presentations
Or check out the conversation on Twitter: #oiltrain15

About the Event

Over the past few years, oil train traffic across the continent has increased rapidly with more than 500,000 rail cars moving oil in 2014 alone, according to the Association of American Railroads. The recent Lac-Mégantic, Quebec disaster and subsequent accidents illustrate the severity of this issue. There is a pressing need to determine true hazards facing our communities and to develop solutions to prevent further disasters. Across the United States and Canada, the issue of oil trains has quickly risen onto the agenda of community leaders, safety experts, researchers, and concerned citizens. There is much to discover and share about protecting people and vulnerable places from the various risks these trains pose. Oil Train Response 2015 provides two invaluable forums on this most pressing problem and provides information and insights for every audience.

November 13, 2015

Community Risks & Solutions Conference
Presented by The Heinz Endowments

November 14 & 15, 2015

Activist Training Weekend
Presented by ForestEthics

 

Conference – November 13th

Friday, Nov 13th: 7:30 AM – 5:00 PM. View Agenda

The one-day conference presented by The Heinz Endowments invites all interest groups to hear from experts about the scale and scope of this challenge, as well as updates on the current regulatory and legal frameworks; consider case studies about the actions/measures taken by various communities in response; and, participate in discussion sessions to explore solutions to better safeguard communities. Elected officials, regulators, and emergency response professionals from Pennsylvania and beyond are especially encouraged to attend to take advantage of this important learning and networking opportunity.

Training – November 14-15th

Saturday, Nov. 14th: Training 7:30 AM – 5:00 PM. Reception 6:00 – 8:00 PM
Sunday, Nov. 15th: Training 7:30 AM – 2:00 PM

A two-day training presented by ForestEthics will equip grassroots and NGO leaders from across the nation with better skills to take back to their communities, and provide critical opportunities for attendees to share winning strategies with each other. In the process of sharing, the conference will help to build both the oil train movement and support the broader environmental and social justice movements. Areas of strategic focus will include: organizing, communications, spokesperson training, data management for organizers, legal strategies, and crowd-sourced train tracking. It will also provide a structured forum for advocates fighting specific oil terminal proposals in places like Philadelphia, Baltimore, and Albany to develop shared strategies and tactics and provide all participants with the skills, knowledge and contacts they will need to carry on this work once they return home.

Oil trains are a major environmental justice issue. The conference and training will speak directly to environmental justice concerns and be inclusive of communities of color, economically disadvantaged urban and rural regions, and communities already experiencing environmental inequities. To this end, need-based travel scholarships will be provided. We are committed to developing the agenda in close consultation with our allies and attendees so that it meets their needs.

Please contact us with questions or requests: anne@forestethics.org.

Many thanks to Paul Heckbert & Randy Sargent of CMU for supplying the oil train photo (top).

Landfill disposal of drill cuttings
FracTracker Alliance

Landfill Disposal of WV Oil and Gas Waste – A Report Review

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By Bill Hughes, WV Community Liaison

As oil and gas drilling increases in West Virginia, the resulting waste stream must also be managed. House Bill 107 required the Secretary of the West Virginia Department of Environmental Protection to investigate the risks associated with landfill disposal of solid drilling waste. On July 1, 2015, a massive report was issued that details the investigation and its results: Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

While I must commend the State for looking into this important issue, much more needs to be done, and I have serious concerns about the validity of several aspects of this study. Since the report is almost 200 pages long, I will summarize its findings and my critiques below.

Summary of Waste Disposal Concerns in Report

The page numbers that I reference below refer to the page numbers found within the PDF version of the full study.

  1. Marcellus shale cuttings are radioactive: pgs. 17, 139, 142, 154
  2. We do not know if there is a long term problem: pg. 19
  3. About 30 million tons of waste in next few decades: pg. 176
  4. Landfill liners leak: pg. 20
  5. Owning & operating their own landfill would be expensive & risky for gas companies: pgs. 186-7
  6. Toxicity and biotic risk from drill cuttings is uncharted territory: pg. 78
  7. Landfill leachate is toxic to plants & invertebrates: pgs. 16, 95, 97
  8. Other landfills also have radioactive waste: pgs. 14-15
  9. We have no idea if this will get worse: pgs. 96, 154
  10. If all systems at landfills work as designed, leachate might not affect ground water: pg. 41

Introduction

WV Field Visits 2013

Drilling rig behind a wastewater pond in West Virginia

Any formal report comprised of 195 pages generated by a reputable school like Marshall University with additional input from Glenville State College – supported by over 2,300 pages of semi-raw data and graphs and charts and tables – requires some serious investigation prior to making comprehensive and final conclusions. However, some initial observations are needed to provide independent perspective and to help reflect on how sections of this report might be interpreted.

The overarching perspective that must be kept in mind is that the complete study was first limited by exactly what the legislature told the WV Department of Environmental Protection DEP to do. Secondly, the DEP then added other research guidelines and determined exactly what needed to be in the study and what did not belong. There were also budget and time constraints. The most constricting factor was the large body of existing data possessed by the DEP that was provided to the researchers and report writers. Because of the time restrictions, only a small amount of additional raw data could be added.

And most importantly, similar to the WVU Water Research Institute (WVU WRI) report from two years ago, it must be kept in mind that these types of studies, initiated by those elected to our well-lobbied legislature and funded and overseen by a state agency, do not occur in a political power vacuum. It was surely anticipated that the completed report might have the ability to affect the growing natural gas industry – which is supported by most in the political administration. Therefore, we must be cautious here. The presence and influence of political and economic factors need to be considered. Also, for universities to receive research contracts and government paid study requests, the focus must include keeping the customer satisfied.

My comments below on the report’s methods and findings are organized into three broad and overlapping categories:

  • GOOD  –  positive aspects, good suggestions, important observations
  • GENERAL  –  general comments
  • FLAW  –  problems, flaws, limitations
  • MOVING FORWARD  – my suggestions & recommendations

I. Water Quality: EPA Test Protocols & Datasets

Marcellus Shale (at the surface)

Marcellus Shale (at the surface)

GENERAL  It is obvious that a very smart and well-trained set of researchers put a lot of long, detailed thought into analyzing all of the available data. There must be tens of thousands of data points. Meticulous attention was put into how to assemble all of the existing years’ worth of leachate chemical and radiological information.

GOOD  There is an elaborate and detailed discussion of how to best analyze everything and how to utilize the best statistical methods and generate a uniform and integrated report. This was made difficult with non-uniform time intervals, some non-detect values, and some missing items. The researchers used a credible process, explaining how they applied the various appropriate statistical analysis methods to all the data. They provided some trends and observations and draw some conclusions.

FLAW 1  The most glaring flaw and the greatest limitation pertaining to the data sets is the nature of the very data set, which was provided to the researchers from the DEP. It is to the commendable credit of the DEP that the leachate at landfills receiving black shale drill cuttings from the Marcellus and other shale formations were, from the beginning, required to start bi-monthly testing of leachate samples at landfills that were burying drill waste products. And in general, when compared to on-site disposal as done for conventional wells, it was initially a good requirement to have the drill cuttings put into some type of landfill; that way we could keep track of where the drill cuttings are located when there are future problems.

To the best of my knowledge, until the states in the Marcellus region started allowing massive quantities of black shale waste material to be put into local landfills, we have never knowingly deposited large quantities of known radioactive industrial waste products into generic municipal waste landfills. The various waste products and drill cuttings of Marcellus black shales have been known for decades by geologists and radiochemists to be radioactive. We know better than to depose of hazardous radioactive waste in an improper way. Therefore, it is very understandable that we might not know how to best solve the problems of this particular waste product. This was and still is new territory.

FLAW 2  All of the years of leachate test samples were processed for radioactivity using what is called the clean drinking water test protocols, also referred to as the EPA 900 series. Three years ago, given the unfamiliarity of regulatory agencies with the uniqueness of this waste problem, we chose the wrong test protocol for assessing leachate samples. We speculated that the commonly used and familiar clean drinking water test procedure would work. So now we have a massive set of test results all derived from using the wrong test protocol for the radiologicals. Fortunately, all of the chemistry test results should still be reasonably useful and accurate.

At first, three years ago, this was understandable and possibly not an intentional error. Now it is widely known by hydrogeologists and radiochemists, however, that the plain EPA 900 series of test methods for determining the radioactivity of contaminated liquids do not work on liquids with high TDS — Total Dissolved Solids. Method 900.0 is designed for samples with low dissolved solid like finished drinking water supplies.

Despite this major and significant limitation, the effort by Marshall University still has some utility. For example, doing comparisons between and among the various landfills accepting drill waste might provide some interesting observations and correlations. It is clearly known now, however, that the protocols that were used for all samples from the start when testing for gross alpha, gross beta and radium-226 and radium-228 in leachate, can only result in very inaccurate, under-reported data. Therefore, it is not possible to draw any valid conclusions on several very important topics, including:

  • surface water quality,
  • potential ground water contamination,
  • exposure levels at landfills and public health implications,
  • and policy and regulations considerations.

Labs certified to test for radiological compounds and elements are very familiar with the 900 series of EPA test procedures. These protocols are intended to be used on clean drinking water. They are not intended to be used on “sludgy” waters or liquids contaminated with high dissolved solids like all the many liquid wastes from black shale operations like flowback and produced water and brines and leachate. The required lab process for sample size, preparation, and testing will guarantee that the results will be incorrect.

In no place in the final 195 page report have I seen any discussion of which EPA test protocol was used for the newer samples and why was it used. It has also not yet been seen in the 2,300+ pages of supportive statistical and analytical results, either. The fact that the wrong protocol was used three years ago is very understandable. However, this conventional EPA 900 series was still being used on the additional very recent (done in fall of 2014 and spring of 2015) samples that were included in the final report. The researchers, without any justification or discussion or explanations continued to use the wrong test protocol.

The clean drinking water procedures should have been used along with the 901.1M (gamma spec) process, for comparison. It is understandable for the new data to be consistent and comparable with the very large existing dataset that a case could be made for using the incorrect protocol and the proper one also. There should have been a detailed discussion of what and why any test method was being used, however. That discussion is usually one of the first topics investigated and explained in the Methods section. Having that type of discussion and justification seems to represent a basic science method and accepted research process – and that omission is a serious flaw.

MOVING FORWARD  We all know that if we want to bake an appetizing and attractive cake we must use the correct measuring cups for the ingredients. If we want to take our child’s temperature we need an accurate thermometer. When our doctor helps us understand our blood test results, we all want to be confident the right test was used at the lab. The proper test instrument, recently calibrated and designed for the specific sample, is crucial to get useable test results from which conclusions can be drawn and policy enacted.

It seems that the best suggestion so far to test high TDS liquids similar to leachate would be to use what is referred to as Gamma-ray Spectrometry with a high purity germanium instrument with at least a 21-day hold period (30 days are better), while the sample is sealed then counted for at least 16 hours. Many of the old leachate test results indicate high uncertainties that might be attributed to short hold times and short counting times. This procedure is referred to as the 901.1 M (modified). If the sample is sealed, the sample will reach about 99% equilibrium after 30 days. Radon 222 (a gas) must not be allowed to escape.

The potential environmental impacts to water quality section of this report seems to demonstrate that if you do not want to find out something, there are always justifiable options to avoid some inconvenient facts. Given the very narrow scope as defined, some the Marshall University folks did not seem to have the option to stray into important scientific foundational assumptions and, for the most part, just had to work with the stale data sets given to them. All of which, as we have known for close to a year now, have used the wrong test protocol. Therefore we have incorrect results of limited value.

II. Marcellus is Radioactive

GOOD 1  Of course, geologists have known that the Marcellus Shale is radioactive for many decades, but also for decades there has been great reluctance by the natural gas exploration and production companies to acknowledge this fact to the public. And finally we now have a public report that clearly and unambiguously states that Marcellus shale is radioactive. Interestingly enough, it was not much more than a year ago that some on the WV House of Delegates Judiciary Committee, seemed to be echoing the industry’s intentional deception by declaring that:

…it was only dirt and rock…

So this report represents progress and provides a very valuable contribution to beginning to recognize some of the potential problems with shale wastes and their disposal challenges.

GOOD 2  Another very important advance is that finally after eight years of drilling here in Wetzel County, we now have a test sample from near the horizontal bore. The WVU WRI study researchers were never given access to any samples taken from the horizontal bore material itself, however. That was, of course, what they were supposed to have been allowed to do, but they were only given access to study material from the vertical section of the well bore. This report describes how we are getting closer to actually testing good samples of the black shale. It seems that we have gotten closer – but let’s see how close.

Page 11 describes that only three Antero wells in Doddridge County were chosen as the place to try to obtain samples from the horizontal bore. Considering that over 1,000 deviated/horizontal wells or wells with laterals have been drilled in the past few years, that number represents a very small fraction of wells drilled: less than .3%. Even if a high quality sample could have been obtained it might be a challenge to extrapolate test results to the waste being produced from the other wells in WV. These limitations are completely ignored in the report, however. Given the available documentation from the DEP, this seems to be a serious flaw that compromises the reliability of the entire report.

III. Samples From Vertical vs. Horizontal Well Bores

FLAW  The actual samples tested from at least two of the three wells used in the study do not seem to be from the horizontal bore material. The sample from the third well might have come from the horizontal bore, but just barely. There is no way to know for sure. I will try to show this within the below chart using information provided by Antero to DEP Office of Oil & Gas. This information is in state records on Antero’s well plats, which become part of the well work application and also part of the final permit.

Table 1. Details about the samples taken from three Antero wells in Doddridge County, WV – and my concerns about the sampling process*

Antero well ID API # Sample’s drilling depth Marcellus depth** Horizontal bore length** Comments / Issues
Morton 1H 47-017-06559 6,856 ft. 7,900 TVD*** 10,600 ft. ~1,044 ft. short of reaching Marcellus formation
McGee 2H 47-017-06622 6,506 ft. 6,900 TVD 8,652 ft. ~394 ft. short of reaching Marcellus
Wentz1 H 47-017-06476 8,119 ft. 7,900 TVD 8,300 ft. Just drilled into Marcellus by 219 ft.
* Original chart found on page 11 of report
** Based on information from Antero’s well plat
*** TVD = Total Vertical Depth

Antero is an active driller in Doddridge County. If any company knows where to find the Marcellus formation it is that company. Well plats are very detailed, technical documents provided to the DEP by the operator regarding the well location, watershed, and leased acres and property boundaries. We need to trust that the information on those plats is accurate and has been reviewed and approved by the permitting agency. Those plats also give the depth of the Marcellus and the length and heading of the lateral or horizontal bore. The Marshall University report gives the drilling depth when the sample was taken on the surface. Using these available well plat records from the DEP it appears that at two of the wells the sample (and its test results included in the report) came from material produced when the experienced drilling operator was not yet into the shale formation.

On the third well, Wentz 1H, the numbers seem to indicate that the sample was taken when the driller said that they were just barely within the shale layer – by 219 feet. Since the drill cuttings take some time to return to the surface from over 7,000 feet down, drilling just a few hundred feet would not at all guarantee that the returned cuttings were totally from the black shale. The processing of the drill cuttings at the shaker table and separator and centrifuge and the mixing in the tubs all cast some doubt on whether the sample, wherever it was taken from, was truly from the horizontal bore material.

On page 11 there is a clear and unambiguous statement:

Three representative sets of drill cuttings from the horizontal drilling activities within the Marcellus Shale formation were collected.

A successful attempt to get three such samples might have then allowed an appropriate waste characterization to be done as needed to accomplish the five required research topics listed in the report’s cover letter. Only an accurate chemical and radiological waste characterization would have allowed scientifically justifiable conclusions to be formulated and then allow for accurate legislation and regulations. It does not seem that West Virginia yet has the required scientific data upon which to confidently formulate laws and regulations to protect public health with regard to shale waste disposal.

Would it not seem prudent – if one wanted a good, representative sample – to make absolutely sure that the operator was, in fact, drilling in the black shale and that the cuttings returning to the surface were, in fact, from the Marcellus bore? That approach would have been eminently defensible and easily accomplished by just waiting for drilling to progress into the lateral bore far enough that the drill cuttings returning to the surface were in fact from the black shale. There might be plausible explanations for this apparent inconsistency or error. Of course, it might be speculated that the Antero-provided information on the well plats is incorrect and not intended to be accurate, or perhaps the driller is not really sure yet where the Marcellus layer starts. There may be many other possible scenarios of explanations. Time will tell.

IV. Research Observations Review

Landfill disposal of drill cuttings

Landfill disposal of drill cuttings

GOOD There are a number of recommendations and suggestions in the study on landfills and leachate related conditions. It seems that a number of these proposals are very accurate and should be implemented. For example:

The report clearly restates that drill cuttings are known to contain radioactive compounds. Since all landfill liners will eventually leak, and since landfills already have ground water test wells for monitoring for potential ground water contamination due to leaking liners, then the well samples should be tested for radiological isotopes. Good idea. They are not required to do that now, but this recommendation should be implemented immediately (pgs. 17 and 21).

GOOD The report recommends that the Publicly Owned Treatment Works (POTW) or in the case of Wetzel County, the on-site wastewater treatment plants, should also test their effluent for radioactive isotopes. This is very important since there is no way to efficiently filter out many of the radioactive isotopes. Such contaminants will pass through traditional wastewater treatment plants.

It is also very useful that the report recommends that all the National Pollution Discharge Elimination System (NPDES) limits at the POTWs be reviewed and required to take into consideration the significantly more challenging chemical and radiological makeup of the shale waste products.

V. Economic Considerations on an Industry Supported Mono-Fill

The legislature asked that the DEP evaluate the feasibility of the natural gas industry to build, own, or operate its own landfill solely for the disposal of the known radioactive waste. This request seems to be a very reasonable approach, since for decades we have only put known radioactive waste products into dedicated landfills that are exclusively and specifically designed for the long term storage of the special waste material.

The discussion of the economic considerations is extremely complete and detailed. They are given in Appendix I and take into consideration a very thorough economic feasibility study of such a proposed endeavor. This section seems to have been compiled by a very talented professional team.

FLAW  However, some of the basic assumptions are a bit askew. For example:

The initial Abstract of the financial analysis states that two new landfills would be needed because we do not want to have the well operators to drive any further than they do now. Interesting. This seems to be not too different than a homeowner while in search for privacy and quiet, builds a home far out into the country and then expects the public sewage lines to be extended miles to his new home so he would not have to incur the cost of a septic system. Homebuilders in rural settings should know they will have to incur expenses for their waste disposal needs. Should gas companies expect that communities to provide cheap waste disposal for them?

More than 15 pages later, the most important aspect is clearly stated that, “…the most salient benefit of establishing a separate landfill sited specifically to receive (radioactive) drill cuttings would be the preservation of existing disposal capacity of existing fills for future waste disposal”. Meaning for my (our) grandchildren. See page 175.

Comprehensive and sound financial details later explain that having the natural gas operators build, operate, and eventually close their own radioactive waste depository landfill would involve a lot of their capital and involve some risk to them. It is stated that their money would be better used drilling more wells. The conclusion then seems to be that, all around, it is simply cheaper and less risky for the gas industry to put all their waste products into our Municipal Waste Landfills, and later residents should incur the costs and risk to build another land fill for their household garbage when needed.

VI. Report Omissions

  1. Within the report section dealing with the leachate test results, it is casually mentioned that not only do the landfills receiving shale waste materials have radioactive contaminated leachate, but the other tested landfills do, as well. However, rather than raising a very red flag and expressing concern over a problem that no one has looked into, the report implies we should not worry about any radioactive waste because it might be in all landfills (pg. 139).
  2. Nowhere within the radiological discussion is there any mention of what might be called speciation of radioactive isotopes. The report does state that the test for both gross alpha and gross beta, are considered a “scanning procedure.” The speciation process is sort of a slice and dice procedure, showing exactly what isotopes are responsible for the activity that is being indicated. This process, however, does not seem to have been done on the landfill leachate test samples. The general scanning process cannot do that. Appendix H, pages 141-142, contains detailed facts on radiation dose, risk, and exposure. This might have been a good place to also discuss the proper EPA testing protocols, used or not used, and why.
  3. A short discussion of the DEP-required landfill entrance radiation monitors is included on page 146. The installed monitors are the goalpost type. Trucks drive between them at the entrance and when they cross the scales. It seems that the report should have emphasized that that type of monitor will primarily only detect high-energy gamma radiation. However what is omitted on page 144 is that the primary form of decay for radium-226 is releasing alpha particles. The report is ambiguous in saying the decay products of radium-226 include both alpha particles and some gamma radiation, but radium-266 is not a strong gamma emitter. It is very unlikely that a normal steel enclosed roll-off box would ever trip the alarm setting with a load of drill cuttings. However those monitors are still useful since they will detect the high-energy gamma radiation from a truck carrying a lot of medical waste (pg. 17).
  4. It is stated on page 144 that the greatest health risk due to the presence of radium-226 is the fact that its daughter product is radon-222. Radium-226 has a half-life of 1,600 years, compared to radon’s 3.8 days. This difference might seem to imply that radon is less of a concern. Given the multitude of radium-226 going into our landfills means that we will be producing radon for a very long time.

VII. Resource Referenced in Article

Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.