A white paper by Columbus Community Rights Coalition (CCRC) will inform resident stakeholders of risks to the water associated with oil & gas production activities occurring within their watershed region of Columbus, Ohio.
A hazardous byproduct of oil & gas operations, called “brine,” poses a problem because of its radioactivity and the volumes produced.
David Hess reports on the pervasive & dangerous practice of waste disposal at oil and gas well drilling sites via “dusting.”
Sen. Muth and Dimock, PA residents are fighting a permitted Eureka Resource Susquehanna facility that puts their water at risk.
The story of Victoria Switzer, a Dimock resident who is leading the charge to protect Burdick Creek and Dimock from toxic fracking waste.
Though a 2018 legal win resulted in a statewide ban on the practice, unauthorized brine spreading in PA continues. Guest post by Fair Shake.
Water at Risk
A Digital Atlas Exploring the Impacts of Natural Gas Development in
the Lycoming Creek Watershed of Pennsylvania
Coursing through lush valleys of the Allegheny Plateau, Lycoming Creek flows over 37 miles to its confluence with the West Branch Susquehanna River in Williamsport, Pennsylvania. The 272-square-mile watershed includes idyllic tributaries like Pleasant Stream and Trout Run, names reflecting the intrinsic beauty and bounty of the area. Rock Run in Loyalsock State Forest by some accounts is, “one of the most beautiful streams in all of Pennsylvania.”
The mightier Pine Creek to the west perhaps carries greater notoriety, as does the enchanting Loyalsock to the east. But make no judgement about Lycoming Creek’s smaller stature. Forest covers 81% of the basin and only one percent is developed, with the rest of the land used for agriculture. Through the heart of this rugged terrain, a picturesque waterway beckons anglers and other revelers of the wilds.
The Lenape people called the watershed home before European occupation. They knew the creek as Legani-hanne, meaning “sandy or gravelly stream.” The native residents and those who displaced them used it as a means of transportation, whether traveling by canoe or walking the Sheshequin Path that runs north and east along the shores.
Lumber fueled the regional economy of the 19th century, and Lycoming’s forests fell. By rail and by water, saw logs were sent to Williamsport for milling. Wood-powered wealth gave rise to the city’s “Millionaire’s Row,” but prosperity apexed in the early 20th century. Today, the Williamsport area is home to nearly 30,000 people, down from a peak of around 45,000 in 1950. Comparatively, about 20,000 persons live within the Lycoming Creek watershed.
These days, Williamsport buzzes with breweries, bookstores, and the vitality of an urban hub. The Little League World Series still comes to town every summer, ushering memories of simpler, quieter times.
Nearby, the serene creek surges with life, including the Eastern hellbender—North America’s largest amphibian. But the same water can turn tempestuous and destructive. Notable floods in 1972, 1996, 2011, and 2016 caused loss of life and property damage. As climate change intensifies, heavy downpours and rapid snowmelt exacerbate flood risks.
Unconventional drilling brought new threats to the area: congested truck traffic, exorbitant consumptive water use, myriad air pollution sources, extensive land clearing, and ecological disturbance; and, the dangers of spills, leaks, and water contamination.
This report explores these impacts, underscoring the heavy footprint of extraction—and related activities—on public and private lands throughout the Lycoming Creek watershed.
The Lycoming Creek watershed provides ample opportunities for nature-based recreation. While there are no state parks in the watershed, a 507-acre (0.8 square miles) portion of the Tioga State Forest occupies the northern boundary of the watershed in Tioga County. Further south lies 45,022 acres (71.1 square miles) of the Loyalsock State Forest. This includes 332 acres (0.52 square miles) of the Devil’s Elbow Natural Area, a site known for its many wetlands—home to carnivorous sundew and pitcher plants—waters that feed the stunning Rock Run. The McIntyre Wild Area covers a 7,226 acre (11.3 square mile) expanse of the Loyalsock State Forest, situated entirely in the Lycoming Creek watershed. It includes spectacular waterfalls on streams that feed the aforementioned Rock Run, a tributary known for its vibrant trout population.
The Lycoming Creek watershed provides ample opportunities for nature-based recreation. While there are no state parks in the watershed, a 507-acre (0.8 square miles) portion of the Tioga State Forest occupies the northern boundary of the watershed in Tioga County. Further south lies 45,022 acres (71.1 square miles) of the Loyalsock State Forest. This includes 332 acres (0.52 square miles) of the Devil’s Elbow Natural Area, a site known for its many wetlands—home to carnivorous sundew and pitcher plants—waters that feed the stunning Rock Run.
The McIntyre Wild Area covers a 7,226 acre (11.3 square mile) expanse of the Loyalsock State Forest, situated entirely in the Lycoming Creek watershed. It includes spectacular waterfalls on streams that feed the aforementioned Rock Run, a tributary known for its vibrant trout population.
To the west of Lycoming Creek and State Route 14 is Bodine Mountain, another sweeping feature of the Loyalsock State Forest. Bodine Mountain is a north-to-south ridge rising over 1,300 feet above the Lycoming Creek valley.
In addition to state forests, the watershed contains 238 acres of State Game Land 335 at the northern boundary, and 2,430 acres (3.8 square miles) of State Game Land 133, situated southeast of Bodine Mountain. These conserved lands are designated to protect wildlife—a goal that seems at odds with current oil and gas leasing practices.
Fishing and enjoying mountain streams
Pennsylvania has two separate designations for streams with excellent water quality: exceptional value (EV) and high quality (HQ). The Department of Environmental Protection (DEP) explains that the quality of HQ streams can be lowered, “if a discharge is the result of necessary social or economic development, the water quality criteria are met, and all existing uses of the stream are protected.” The water quality of EV streams cannot be lowered.
Sadly, there are no streams in the beautiful Lycoming Creek watershed with an EV designation, however deserving. On the other hand, 412 miles of streams in its drainage are designated as HQ, representing 76% of the watershed’s 542 total stream miles, according to the state’s official designated use inventory. Statewide, 3,838 out of 86,473 miles (4.4%) of inventoried streams are categorized as EV, while 58,748 miles (67.9%) are HQ, making the Lycoming Creek watershed below average for the former, and above average for the latter.
Prior to industrialization, native brook trout populations were widespread in small, forested streams across Pennsylvania. While many streams are now stocked with several species of trout, the combination of pollution and deforestation has decimated the areas where trout—especially native brook trout—thrive in sustainable wild populations. Suitable streams are designated as Class A trout streams, and they are rare, accounting for just 3,037 miles, or 3.5% of streams across the Commonwealth. The Lycoming Creek watershed contains slightly fewer Class A streams than is typical, with 17.5 miles, representing just 3.2% of all streams in the drainage. Nevertheless, it remains an important respite for trout species and the anglers who seek them.
Split estates and the Clarence Moore lands
Hundreds of thousands of acres of Pennsylvania state forest are under lease agreements for fracked gas extraction, diminishing outdoor experiences and posing ongoing environmental threats. In those situations, the state Department of Conservation and Natural Resources (DCNR) clearly controls the surface and the gas that lies beneath. However, in some areas of the state forest, private interests claim mineral ownership, even in gaseous form—a situation called “split estate.” Loyalsock State Forest contains about 25,000 split estate acres, known as the Clarence Moore Lands.
In the Lycoming Creek watershed, most of the Clarence Moore lands lie east of US Highway 15, occupying areas that drain into Rock Run and Pleasant Stream, including some of the area’s few remaining Class A wild trout waters. Another section of the Clarence Moore lands extends west of Highway 15, on Bodine Mountain’s eastern flank. In their current state, the lands provide invaluable ecological services and—coupled with the Loyalsock Creek to the east—comprise critical source waters for two major watersheds.
Gas drilling requires a significant amount of infrastructure, including multiacre well pads, miles of gathering pipelines, retention ponds, waste processing facilities, and compressor and metering stations. Allowing surface disturbance in the Clarence Moore lands could have lasting, devastating consequences.
Nearly a decade ago, the Anadarko Petroleum Corporation approached DCNR with extensive plans for dozens of fracked gas wells and all the disruptive destruction that accompanies them in a large swatch of the Loyalsock State Forest and the Clarence Moore lands. Over the years, the Clarence Moore players have changed significantly. Southwestern Energy scored a stake, while Anadarko sold their interest to Alta Resources, a privately-held company scheduled for purchase by EQT, the nation’s largest fracked gas company. While the operators play their game of musical chairs, the situation remains a serious threat to some of the few remaining portions of the region that haven’t been spoiled with industrial gas drilling.
Ironically, modern horizontal drilling enables access to Clarence Moore’s reserves from miles away—from well pads on private land. There is no need—nor social license—to expunge the forest for future generations for short-lived, selfish gain. Organizations near and far, led by the Responsible Drilling Alliance and Save PA Forests Coalition, have rallied tirelessly to save this land from development, a truly special place deserving permanent protection.
Figure 2. The Clarence Moore Lands are a complicated split estate situation in the Loyalsock State Forest, including parts of the Lycoming, Loyalsock, and Schrader Creek watersheds.
Unique wetland biomes
Countless wetlands feed Lycoming Creek’s headwaters, providing a unique opportunity to observe aquatic flora and fauna beneath the forested canopy of Penn’s Woods. The US Fish and Wildlife Service (USFWS) explains their importance, as well as their precarious state:
“Wetlands provide a multitude of ecological, economic and social benefits. They provide habitat for fish, wildlife and plants—many of which have a commercial or recreational value—recharge groundwater, reduce flooding, provide clean drinking water, offer food and fiber, and support cultural and recreational activities. Unfortunately, over half of America’s wetlands have been lost since 1780, and wetland losses continue today. This highlights the urgent need for geospatial information on wetland extent, type, and change.”
The geospatial data referred to above is the National Wetland Inventory (NWI), which seeks to document all the wetlands in the United States, based primarily in aerial imagery. According to NWI data, there are 3,136 acres (4.9 square miles) of wetlands in the Lycoming Creek watershed. However, further field research is necessary to properly identify wetland boundaries, particularly in the case of ephemeral wetlands, for example, where the presence of aquatic plants help determine boundaries. All of this suggests that while there is every reason to believe the USFWS’ claim that over half of the nation’s wetlands have been lost since around the time of the Revolutionary War, it is believed the NWI discounts the total acreage.
A University of Vermont team developed another model for calculating wetlands, based primarily on, “2006-2008 leaf-off LiDAR data, 2005-2008 leaf-off orthoimagery, 2013 high-resolution land-cover data, and moderate-resolution predictive wetlands maps, incorporating topography, hydrological flow potential, and climate data.” This model calculates 6,943 wetlands acres (10.8 square miles) in the Lycoming Creek drainage, more than double the NWI’s estimated acreage.
Five trails traverse the Lycoming Creek watershed, crossing 152 miles total. This includes nearly 44 miles of the Loyalsock State Forest Cross-Country Ski Trail system south and east of the McIntyre Wild Area, suitable for hiking, biking, equestrian pursuits, and of course, cross-country skiing. The watershed also contains 33 miles of Bicycle PA Route J, which runs along Lycoming Creek from the confluence with the West Branch Susquehanna River on the southern end, all the way to the wetland border that feeds Lycoming Creek and neighboring Towanda Creek to the northeast. The watershed’s most popular trail may be the famous Old Loggers Path, a coveted backpacking route that meanders nearly 23 miles. The Hawkeye Cross-Country Ski Trail—frequented by hikers, bikers, and skiers—loops over seven miles in the northeastern corner of the watershed. Yet another watershed trail is the Lycoming Creek Bikeway, a mostly straight five-mile stretch from Hepburnville to the West Branch Susquehanna River.
Figure 3. Rock Run in Loyalsock State Forest’s McIntyre Wild Area. Photo by Ann Pinca.
Figure 4. A flyfisher casts in Lycoming Creek right beside Sheshequin Campground in Trout Run. Photo by Rebecca Johnson.
Figure 5. This wetland lies just beyond the northeastern boundary of the Lycoming Creek watershed and is similar to those feeding the headwaters of Rock Run near Devil’s Elbow Natural Area in Loyalsock State Forest. Photo by Shannon Smith.
The commercial oil and gas industry got its start in Pennsylvania in 1859 with the famous Drake Well, followed by a frenzy of drilling in the central and western portions of the state. The DEP has records of over 185,000 conventional oil and gas wells throughout the Commonwealth, and—because the industry preceded permitting requirements by almost a century—yearly estimates range between 480,000 and 760,000 conventional wells have punctured Pennsylvania’s surface. The Lycoming Creek watershed was further east than most of the conventional oil and gas pools, so it has seen very little conventional drilling. Of the 185,000 known well locations, only 25 (0.01%) are within the watershed. Of those, 11 (44%) have a status of “proposed but never materialized,” or “operator reported not drilled.” Eight wells (32%) are plugged, four (16%) have active status, one (four percent) is considered being in a regulatory inactive period, and one (four percent) is on the DEP’s orphan list—awaiting funding to be plugged properly.
The commercial oil and gas industry got its start in Pennsylvania in 1859 with the famous Drake Well, followed by a frenzy of drilling in the central and western portions of the state. The DEP has records of over 185,000 conventional oil and gas wells throughout the Commonwealth, and—because the industry preceded permitting requirements by almost a century—yearly estimates range between 480,000 and 760,000 conventional wells have punctured Pennsylvania’s surface.
The Lycoming Creek watershed was further east than most of the conventional oil and gas pools, so it has seen very little conventional drilling. Of the 185,000 known well locations, only 25 (0.01%) are within the watershed. Of those, 11 (44%) have a status of “proposed but never materialized,” or “operator reported not drilled.” Eight wells (32%) are plugged, four (16%) have active status, one (four percent) is considered being in a regulatory inactive period, and one (four percent) is on the DEP’s orphan list—awaiting funding to be plugged properly.
While drillers had long known about the Marcellus Shale, it wasn’t until 2004 that drilling in the formation became a profitable enterprise, through the combination of industrial-scale hydraulic fracturing and horizontal drilling. Soon thereafter, the Lycoming Creek watershed was no longer on the periphery of oil and gas exploration, but part of a densely drilled cluster of new unconventional wells in northeastern Pennsylvania.
The first unconventional well in the Lycoming Creek watershed was permitted by Range Resources at the Bobst Mountain Hunting Club on May 31, 2007, and drilling started less than two months later.
In the years that followed, 592 unconventional wells have been proposed for the watershed, 586 (99%) of which received permits, with 384 (65%) drilled as of June 28, 2021. Some wells had a short life, with 41 (10.6%) already plugged—a figure slightly higher than the statewide average of 8.7%. Fifteen operators have been active in the watershed.
As with the rest of Pennsylvania, the total number of drilled wells peaked in 2012, with 100 wells drilled that year. In the past seven years, the highest annual total was only one-fourth of that, with 25 wells drilled in 2019. However, these trends do not foretell an end to drilling in the region. The reduced number of wells drilled is offset by drilling each well more intensively, using five times as much water per well for hydraulic fracturing.
Gas production has flooded markets, reducing gas prices and profit margins. At the very start of the Marcellus boom in October 2005, gas prices were $13.42 per million British Thermal Units (BTUs), but have fluctuated between $1.75 and $4.00 per million BTUs in recent years. Many of the 202 wells permitted but not drilled in the watershed are located on existing well pads and can easily be drilled and brought into production as market forces dictate. For these reasons, the area is unlikely to see an end to drilling, pipeline construction, truck convoys—and all the other ancillary activities—any time soon.
Figure 6. Active fracking operation in May 2021 on ARD Operating’s COP Tract 551 A well pad, originally planned by Anadarko E&P in 2014. Photo by Ted Auch.
Figure 7. This video was taken at the same site as Figure 6, capturing ARD Operating’s well pad and the incessant noise it makes during hydraulic fracturing activities. Video footage captured by Brook Lenker.
Figure 8. Permitting, drilling, and plugging summary of unconventional wells in the Lycoming Creek watershed by year. Data through June 28, 2021.
Figure 9. Proposed unconventional wells by current operators in the Lycoming Creek watershed. Data through June 28, 2021. Note that wells that were proposed but not drilled are still associated with the original operator, which are not always still active in the watershed.
Figure 10. FracTracker’s partners at LightHawk provided aerial assistance to fly our photographer over the Lycoming Creek watershed. This video offers a glimpse at the oil and gas industry’s expansion in the watershed, juxtaposed with houses, farms, forests, wetlands, and numerous waterways. FracTracker’s Ted Auch captured still images while LightHawk pilot David Hartnichek gathered video footage, captured May 2021.
TimeSlider of Bodine Mountain
On the right, we see imagery from June 2021, with a substantial number of well pads, impoundments, compressors, pipelines, and access roads. Imagery on the left is from June 2014, with significantly less infrastructure. Users can zoom, pan, and choose different dates to explore the impacts of the industry over time.
In the Lycoming Creek watershed, unconventional wells and the well pads they operate on have been issued 634 violations between 2008 and June 28, 2021. This works out to 1.65 violations per drilled well, considerably above the statewide average of 1.3 violations per well.
Most of the violations (545, or 86%) are considered to negatively impact environmental health and safety, with the remaining 89 (14%) assessed for administrative infractions. However, the distinction between the two categories is murky at best. For example, the most common administrative violation is, “pits and tanks not constructed with sufficient capacity to contain pollutional substances,” an infraction documented 18 times in the watershed—presenting obvious hazards to health, safety, and the environment.
Altogether, there are 66 different violation codes cited within the watershed. The ten most frequent are seen in Figure 11.
For these 634 violations, the DEP has collected fines totaling $2,460,700 from four operators. Range Resources leads the way with $1,461,000 in fines, followed by Seneca Resources with $600,000, East Resources with $380,700, and Chief Oil & Gas with $19,000. For comparison, the average cost of drilling a single well in the Marcellus Shale is $8.3 million, according to 2017 financial data from a major operator in the region. At this rate, while assuming no inflation, the watershed will have to suffer 2,138 violations before the DEP’s penalties equal the cost of drilling and fracking one well.
Clearly, operators are not cowed by receiving violations, nor do they look at the occasional fine as anything more than the cost of doing business. It seems that in practice, the DEP’s regulatory role is chronicling the industry’s misdeeds, instead of protecting the environment and the people who live among the hundreds of wells in the area.
Figure 11. The ten most frequent violations for unconventional wells and well pads in the Lycoming Creek watershed through June 28, 2021.
Fracking’s aquatic impacts
The DEP maintains a statewide list of water resource sites. In the Lycoming Creek watershed, 76 out of 128 (59%) listed water resource facilities are associated with oil and gas activity, including 13 surface water withdrawal sites and 63 interconnections—large impoundments where water is collected and stored for future use. As excessive as these figures are, the state’s water resources data is incomplete. By examining aerial imagery, FracTracker found six impoundments adjacent to oil and gas operations that were not listed in the inventory. The DEP was aware of these facilities and provided data upon request. Multiacre lined impoundments can be identified from such imagery, but the inventory might be missing smaller withdrawal sites occluded from view by the tree canopy.
Overall, 259 wells reported using between 891,900 and 33,193,599 gallons of water as a base for their fracking chemical cocktail.
These numbers only represent the water consumed for hydraulic fracturing and don’t include any water used for pipeline hydrostatic testing, dust suppression on dirt and gravel roads, or any other purpose. For example, the voluminous 33,193,599 gallons used to frack Alta Resources’ Mac North B-3H well pad represents only a fraction of its permitted capacity for fracking operations.
Figure 12. A lined impoundment that does not appear on DEP’s Water Resources inventory. Photo by Karen Edelstein.
The unconventional oil and gas industry dominates water extraction, distribution, and use throughout the watershed. The amount of water used per fracked well has increased dramatically over the years, according to data from the industry’s frack fluid registry, FracFocus.
However, the registry is riddled with some obvious data inaccuracies—perhaps stemming from the fact that the registry is self-reported by the various operators.
For example, there are 272 well reports with latitude and longitude coordinates placing them inside the Lycoming Creek watershed, excluding wells where operators left the water usage field blank. There are some problematic data points with those remaining.
Five wells reported a negative number of gallons used to stimulate wells, including four from Seneca Resources’ Gamble K well pad—with quantities ranging from -214.7 million to -1.18 billion gallons of water—and one well from EXCO Resources’ Emig Unit well pad that registered -859.0 million gallons. At the other end of the spectrum, eight wells reported water consumption over 100 million gallons, including four from Rockdale Marcellus’ Cochran well pad, two from Seneca Resources’ Gamble K well pad, and two from EXCO Resources’ Emig Unit well pad.
As water consumption data of these 13 wells is obviously erroneous, they were excluded from the following analysis.
These withdrawal allowances are truly staggering.
Based on observations of consumptive use permit signs across the watershed, these water withdrawal limits are typical. Taking the 7.62 billion gallons per well pad average from Figure 15, this equates to about 716 billion gallons of permitted water consumption for the 94 well pads in the watershed that have at least one well with an active, regulatory inactive, or plugged well status. Given the average household consumes about 300 gallons of water per day—and that Pennsylvania has just over 5 million households—this volume is nearly equal to the entire residential consumption of the state for 628 days. If this is applied to each of the 125 proposed well pads, that figure rises to about 953 billion gallons, or a little less than the full capacity of Florida’s vast Lake Okeechobee.
Contamination from spills and leaks can affect more than just surface water. In 2014, 75 water wells in Lycoming County—which includes most of the Lycoming Creek watershed—were tested for various contaminants by the United States Geologic Survey (USGS). Six wells with the highest methane concentrations were further analyzed for their ratio of chloride to bromide, with half of that smaller subset showing water chemistry indicative of mixing with oilfield brine. Although the study posited that it could be mixing deep in the aquifer, it did not mention the frenzied drilling in the region at the time of sampling.
Stemming from thousands of complaints across the Marcellus Shale region, there are 378 private water supplies where DEP determined the loss of water quality or quantity was because of oil and gas activities. The public isn’t provided with the exact location of these fouled wells due to privacy concerns of impacted residents, but it is known that 18 incidents occurred in municipalities wholly or partially within the Lycoming Creek watershed.
According to Pennsylvania’s Act 13—an instrumental law governing various aspects of unconventional drilling in the state—oil and gas operators are presumed responsible for water wells negatively affected within 12 months and 2,500 feet of operations. Of course, the actual spread of a pollution plume depends on the characteristics of the aquifer itself, rather than definitions from Act 13, so it is possible that wells further than 2,500 feet from an incident could be negatively impacted—potentially years after the leak or spill occurred.
Of the 18 determination letters issued by DEP, one occurred in Fox Township in Sullivan County, six in Liberty Township in Tioga County, and two in Union Township. In Lycoming County, Eldred Township received three, Hepburn Township got one, Jackson Township received two, and McNett Township got two.
As previously mentioned, DEP also tracks violations of various state oil and gas regulations. The vast majority of incidents in the Lycoming Creek watershed resulted in an impact to surface or groundwater. Of the 634 total citations associated with unconventional wells and well pads: 41 (six percent) related to erosion and sedimentation concerns, which could harm aquatic life; 379 (60%) citations were for spills, leaks, or pollution discharges that degraded surface or groundwater; and 41 (six percent) were for other water issues. The remaining 173 (27%) violations were for various other shortcomings—most issued for improper handling of waste materials. Depending on what happened in the field to merit these violations, many of these incidents may also have had an impact on Pennsylvania’s waters.
Water is a defining characteristic for any watershed. From the expansive wetlands uphill to the brisk trout streams around Rock Run and the McIntyre Wild Area, down to the steep ravines of the Lycoming Creek, water makes this area special. In the rush to accommodate the thirsty and pollutive oil and gas industry, the state has allowed vast portions of the region to be spoiled.
Figure 13. Water consumption per well in the Lycoming Creek watershed has increased nearly five-fold in less than a decade, from 3,679,467 gallons in 2011 to 17,512,356 gallons in 2020, according to FracFocus data downloaded April 28, 2021.
Figure 14. Water consumption postings for six ARD (Alta Resources Development) well pads. Of the five visible signs, water consumption was permitted at 3 to 4 million gallons per pad, per day, for over five years. Photo by Erica Jackson.
Figure 15. The five visible signs in Figure 14 show that well pads are permitted to withdraw over 38.1 billion gallons of water, or an average of 7.62 billion gallons per well pad.
When fossil fuel companies portray fracked gas as “clean,” they better hope the public doesn’t notice the enormous stream of liquid and solid waste. In the Lycoming Creek watershed, operators reported 9,064,377 barrels (380.7 million gallons) of liquid waste and 416,248 tons of solid waste were generated in the drainage between January 2011 and April 2021. As a point of comparison, this volume of liquid waste—from 362 wells in the watershed—is equal to about 577 Olympic-sized swimming pools, or an acre of land covered in toxic waste 1,168 feet deep. In terms of solid waste, disposal of drill cuttings and other substances equals the garbage left behind after 8,672 Kenny Chesney concerts—like having about 2.3 concerts every day. This estimation is based on 330 wells reporting solid waste generation in the watershed.
When fossil fuel companies portray fracked gas as “clean,” they better hope the public doesn’t notice the enormous stream of liquid and solid waste. In the Lycoming Creek watershed, operators reported 9,064,377 barrels (380.7 million gallons) of liquid waste and 416,248 tons of solid waste were generated in the drainage between January 2011 and April 2021.
As a point of comparison, this volume of liquid waste—from 362 wells in the watershed—is equal to about 577 Olympic-sized swimming pools, or an acre of land covered in toxic waste 1,168 feet deep. In terms of solid waste, disposal of drill cuttings and other substances equals the garbage left behind after 8,672 Kenny Chesney concerts—like having about 2.3 concerts every day. This estimation is based on 330 wells reporting solid waste generation in the watershed.
Problems with oil & gas waste
To compare chemical-laden flowback fluid and radioactive brines to pool water based on volume alone does little to communicate the dangers of liquid waste—just as comparing drill cuttings and filter socks to beer cans and food wrappers is insufficient.
Oil and gas waste is much more harmful to human health and the environment than normal household refuse.
Flowback fluid includes a portion of the liquid injected into a wellbore during hydraulic fracturing. As presented in the Water section, the volume of water injected into each well averaged over 17.5 million gallons in 2020. The industry’s chemical registry site FracFocus estimates that between one-half percent and two percent of the injected volumes are composed of various chemical additives. To get an accurate estimate of the volumes of these chemicals, it is necessary to add the water volume and the non-water volume together, then calculate the above range. Unfortunately, only 18 out of the 259 wells in the watershed that provide believable water volumes also provide non-water volumes.
Approximately 25% of these chemical additives could cause cancer, according to recent studies—while others may inflict skin or respiratory damage.
What is now the Marcellus Shale formation was an ancient, shallow seabed around 384 million years ago in the Middle Devonian epoch. As this sea dried out, organic content concentrated, which would eventually be the source of hydrocarbon gasses. Other components saturated with this organic matter—including barium, benzene, chloride, radium, thallium, and more. These contaminants resurface with the oil and gas, either dissolved or suspended in fluid waste called brine. Brine will continue to rise to the surface in significant quantities during a well’s operating lifespan.
Drill cuttings comprise most of the solid waste from oil and gas sites in Pennsylvania. As with brine, these cuttings contain concentrations of the same toxic and radioactive chemicals. Whether used onsite or sent to landfills, these cuttings are problematic when precipitation causes contaminants to leach, posing risks to aquifers and surface waters. Traditionally, landfill leachate is taken to water treatment facilities. However, these facilities are ill-equipped to handle oil and gas waste and cannot effectively remove the contaminant load.
What happens to the waste?
In 2019, FracTracker analyzed and mapped the destination of Pennsylvania’s oil and gas waste from 2011 through 2018 in a project with Earthworks. Most waste stays in Pennsylvania and neighboring states, but this still requires thousands of heavy tankers travelling tens or even hundreds of miles to reach their destinations. The industry ships some waste as far as Texas, Utah, and Idaho, despite enormous transportation costs. The project underscored Pennsylvania’s incapacity to deal with this noxious and problematic waste stream.
This waste is handled in various ways, with about 54% reused at other fracking sites, 30% sent to residual waste processing facilities, and ten percent disposed in injection wells. Most of the remaining six percent is sent to surface impoundments—but it is not clear what happens to the waste from there.
For solid waste, 56% goes to landfills, 34% is reused at well pads, and eight percent goes to residual waste processing facilities—with the rest handled by other methods.
There is record of 124 waste facilities in the Lycoming Creek watershed, including 121 well pads, one landfill, one residual waste processing facility, and one temporary storage site, pending future reuse or disposal.
The Clean Earth facility—a landfill and drilling mud processing facility—has taken 157,457 tons of solid oil and gas waste and 315 barrels of liquid waste from 2013 to 2016. Between 2012 and 2013, the facility operated as Clean Streams, LLC, and accepted 10,610 additional tons of solid waste and 513,894 barrels of liquid waste. At the watershed’s northern border in Tioga County is Rockdale Marcellus’ Harer Beneficial Reuse facility. Beech Resources proposed an additional facility in currently forested land across US Highway 15 from the Clean Earth facilities.
Figure 16. Estimated chemical components of fracking fluid for the 18 wells in the Lycoming Creek watershed that provide non-water volumes. The minimum estimate is 965,434 gallons, based on 0.5% chemical concentrations, while the maximum estimate is 3,861,737 gallons, based on two percent concentrations.
Figure 17. Disposition method of liquid waste from unconventional wells in Pennsylvania in 2020, based on DEP waste reports. The total liquid waste volume was 61,832,431 barrels, or about 2.6 billion gallons.
Figure 18. Disposition of solid waste from unconventional wells in Pennsylvania in 2020. Total statewide mass was 1,397,678 tons.
Mountains of waste
As drilling continues in the Lycoming Creek watershed and nearby, enormous waste streams will continue to be a conundrum. Even reused material might contaminate the land, streams, and groundwater, and harm human health. As wells are fracked with ever-increasing volumes of fluid, they will return ever-increasing volumes of waste, requiring more and more resources to process.
To see more footage & photos from this project:
Field Day Description
On a sunny and brisk Thursday in May 2021, a group of 11 FracTracker staff members and volunteers gathered in the Lycoming watershed outside Williamsport to find and document unconventional oil and gas activities and infrastructure. This field day was in part informed by insights from members of the Responsible Drilling Alliance, a regional organization, and the knowledge and experiences of Peter Petokas, a biology and environmental science professor at Lycoming College who has explored and kept tabs on the area’s hellbender habitats for years. FracTracker’s Matt Kelso used DEP data to develop maps illustrating various infrastructure, including 384 drilled wells on 96 different pads, nine compressor and metering stations, and 67 water facilities related to oil and gas extraction—including 12 surface water withdrawal sites and 55 storage reservoirs. He then divided an area of about 272 square miles into five sections, and at least two participants explored each section. Using Matt’s maps, FracTracker’s mobile app, cameras, decibel and distance measuring apps, and other tools, the group visited and documented various infrastructure—while observing significant truck traffic and other evidence of the industry’s pervasiveness. As the groups navigated rural back roads and small state highways, many were struck by the juxtaposition of a bucolic landscape of rolling hills, green forests, and peaceful farmland with imposing, pollutive, and sometimes noisy and smelly fracking sites. Additional fieldwork was conducted with assistance from Earthworks’ staff and their FLIR technology, as well as aerial photography and videography captured by FracTracker’s Ted Auch—with flying assistance from partners at LightHawk. FracTracker then used the geolocated photos, video, and site-specific descriptions—coupled with variable datasets, research, and other literature—to compile this Story Atlas, an educational tool for concerned residents of the Lycoming Creek watershed, and an insightful resource for others living near fracking activity. The mobile app reports from this reconnaissance—and from locations across the U.S.—are visible on the FracTracker mobile app, available for download on your iOS or Android device, or by visiting the web app at https://app.fractracker.org/.
On a sunny and brisk Thursday in May 2021, a group of 11 FracTracker staff members and volunteers gathered in the Lycoming watershed outside Williamsport to find and document unconventional oil and gas activities and infrastructure.
This field day was in part informed by insights from members of the Responsible Drilling Alliance, a regional organization, and the knowledge and experiences of Peter Petokas, a biology and environmental science professor at Lycoming College who has explored and kept tabs on the area’s hellbender habitats for years.
FracTracker’s Matt Kelso used DEP data to develop maps illustrating various infrastructure, including 384 drilled wells on 96 different pads, nine compressor and metering stations, and 67 water facilities related to oil and gas extraction—including 12 surface water withdrawal sites and 55 storage reservoirs. He then divided an area of about 272 square miles into five sections, and at least two participants explored each section.
Using Matt’s maps, FracTracker’s mobile app, cameras, decibel and distance measuring apps, and other tools, the group visited and documented various infrastructure—while observing significant truck traffic and other evidence of the industry’s pervasiveness. As the groups navigated rural back roads and small state highways, many were struck by the juxtaposition of a bucolic landscape of rolling hills, green forests, and peaceful farmland with imposing, pollutive, and sometimes noisy and smelly fracking sites.
Additional fieldwork was conducted with assistance from Earthworks’ staff and their FLIR technology, as well as aerial photography and videography captured by FracTracker’s Ted Auch—with flying assistance from partners at LightHawk.
FracTracker then used the geolocated photos, video, and site-specific descriptions—coupled with variable datasets, research, and other literature—to compile this Story Atlas, an educational tool for concerned residents of the Lycoming Creek watershed, and an insightful resource for others living near fracking activity.
The mobile app reports from this reconnaissance—and from locations across the U.S.—are visible on the FracTracker mobile app, available for download on your iOS or Android device, or by visiting the web app at https://app.fractracker.org/.
Figure 19. The field day volunteers gathered before exploring the Lycoming Creek watershed. Photo by Shannon Smith, FracTracker Alliance.
Figure 20. This FLIR footage was recorded by Earthworks at NFG Midstream Trout Run LLC’s Hagerman gas processing and metering facility in Trout Run, Pennsylvania in June 2021. This recording captures visible air pollution from combustion and fugitive emissions at the facility.
Much has changed in the Lycoming watershed since unconventional oil and gas exploration ramped up over the last 15 years—in terms of ecological deterioration, as well as the deterioration of locals’ attitudes toward the industry.
At first welcomed by many as a chance for financial gain through mineral rights leasing, some community members—especially those whose families have lived in the area for generations—watched their land drastically degenerated and their sovereign land rights eclipsed by industrial encroachment they did not foresee.
Between 2011 and 2018, unconventional oil and gas drilling—notably, hydraulic fracturing—transformed sections of forest and farmland into comparatively gritty industrial zones.
“They were assured that, after the drilling phase was completed, they would hardly know the wells were there. They were also told that they had to decide quickly, and that everyone around them had already leased. A local anti-drilling advocacy group tried to warn them, but many locals distrusted environmentalists.”
As author and professor Colin Jerolmack references in his recent article for The New Republic, some landowners who willingly leased their mineral rights to oil and gas companies now view the industry’s activities with consternation. Incessant noise, traffic congestion, and foul odors have tarnished the once peaceful countryside. Even more disconcerting for property owners, the industry often operates however they please, with little consultation or consent—making some feel that they have lost their decision-making power and agency.
This disaffection potentially makes room for environmentalists to find common ground with those who embraced the industry, couched not in anti-fracking sentiments—and not necessarily in the essential need to mitigate the climate crisis—but in their shared love for the land.
Another big ecological concern in the punctured watershed centers on the fragile Eastern hellbender populations. Five conservation groups filed a lawsuit on July 1, 2021, challenging a 2019 decision to deny the amphibian protection under the Endangered Species Act.
“The hellbender is an ancient species that deserves better protections,” said Betsy Nicholas, Executive Director of Waterkeepers Chesapeake, one of the groups involved in the lawsuit. “The hellbender reminds us that we all live downstream. As the upstream tributaries are disturbed and polluted, the hellbender disappears. And the same pollution flows downstream to our populated areas, threatening the use and enjoyment of our rivers. We need to pay attention to what happens to the hellbender.”
Once widespread across 15 states, Eastern hellbenders have been eliminated from most of their historic range and continue to face many threats, including low water flow and poor water quality, increasing water pollution, deforestation, residential development, mining—and of course—oil and gas development.
Peter Petokas has been studying Eastern hellbender populations in the Lycoming watershed for 16 years. He is very concerned for the future of the species in the watershed, which holds one of the richest populations in Pennsylvania, concentrated in one of the few remaining streams with optimal water quality. Even so, a drought in 2020 left the area’s waterways with very low flows, which constrains the hellbender’s habitat and stresses the population. Because they lack protection under endangered species status, agencies may be remiss to implement enhanced regulations on discharges and withdrawals in the basin. Petokas remains hopeful that the pending lawsuit against the US Fish & Wildlife Service will restart an assessment for federal endangered/threatened species protection.
“If there’s ever a spill of anything, it’s the end, it would wipe out one of the best hellbender populations in Pennsylvania,” Petokas said.
Besides concerns about low water levels, the watershed is losing tree cover along streams to invasive insects and erosion. Riparian species like ash, sycamore, and river birches provide shade and keep the water cool enough for hellbenders to thrive.
Figure 21. A pipeline path cuts through forest in McNett Township, Lycoming County. Photo by Shannon Smith.
What does the future hold?
Figure 22. Miner’s Run, a stream in the Lycoming Creek watershed. Photo by Tim Palmer.
Thank you to all the inspiring and persistent environmental stewards who have contributed to the creation of this digital atlas:
Project funding provided by:
Clarence Moore Controversy in the Loyalsock – FracTracker Alliance
Karen Melton, Sierra Club, Fracking and a Community Turned Upside-down, June 2021
Colin Jerolmack, This Could Be the Start of a Rural Anti-Fracking Coalition, May 2021
Center for Biological Diversity, etc. lawsuit, July 2021
Middle Susquehanna Riverkeeper, Lawsuit Filed to Overturn Denial of Endangered Species Protection to Eastern Hellbenders, July 2021
[ii] Colin Jermolmack, Up to Heaven and Down to Hell. P. 261
[iii] Colin Jermolmack, Up to Heaven and Down to Hell. P. 266
[iv] Colin Jermolmack, Up to Heaven and Down to Hell. P. 258
[v] Colin Jermolmack, Up to Heaven and Down to Hell. P. 270
[vi] Colin Jermolmack, Up to Heaven and Down to Hell. P. 272
Insights on Ohio’s massive fracking waste gap, Class II injection well activity, and fracking waste related legislation
Over the past decade, New York State has seen a steep decline in the quantity of waste products from the fracking industry sent to its landfills for disposal. Explore FracTracker’s 2020 updated data.
Access to reliable data is crucial to our understanding of risky fracking waste disposal, and in turn, our ability to protect public health. But when it comes to oil and gas liquid waste disposal wells in Pennsylvania, despite monitoring by two separate agencies, we are left with an incomplete and inaccurate account.
If we were to emulate the Charles Dickens classic, this article might begin, “It was the best of datasets, it was the worst of datasets.” Unfortunately, even that would be too generous when it comes to describing available data around oil and gas liquid waste disposal wells in Pennsylvania. To fully understand the legacy and current state of these wells, it is necessary to query the two agencies that have a role in overseeing them, the United States Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (DEP).
Given the relatively small inventory of these wells compared to other oil and gas producing states, the problems with the two datasets are enormous. Before jumping into these issues, however, it would be useful to review the nature of these wells, why there are two regulatory agencies involved, and why there are so few of them in Pennsylvania in the first place, relatively speaking.
Disposal Wells Categories
To further our industrial exploits of the planet, humans have found it useful to inject all kinds of things into the earth. In the United States, this ultimately falls under the jurisdiction of EPA’s Underground Injection Control (UIC) program, and the point of injection is known as an injection well. Altogether, there are six classes of injection wells, with those related to oil and gas operations falling into Class II.
There are three categories of Class II injection wells, including waste disposal, enhanced recovery, and hydrocarbon storage. There is also an infamous exemption known as the “Haliburton Loophole,” which has allowed oil and gas companies to inject millions of gallons of hydraulic fracturing fluid into oil and gas wells in order to stimulate production without any federal oversight at all.
When most people speak of “injection wells” in an oil and gas context, they are usually referring to waste disposal wells, and this is our focus here. This well type is also referred to as Class II-D (disposal) and salt water disposal wells (SWD). This latter term is used by a majority of state regulators, so we will use that abbreviation here, even though considering this type of toxic and radioactive fluid “salt water” is surely one of the industry’s most egregious euphemisms.
Dealing with Dangerous Fluids
There are two main types of liquid waste that are disposed of at SWD injection wells. As always, these waste types have a number of different names to keep everyone on their toes but for the sake of simplicity will call them “flowback” and “brine,” and both are problematic materials to handle. Additionally, the very act of industrial-scale fluid injection presents problems in its own right.
As mentioned above, when operators pump a toxic stew of water, sand, and chemicals into a well to stimulate oil and gas production, that mixture is known as hydraulic fracturing fluid, or fracking fluid. Some of these chemicals are so secretive that even the operators of the well don’t know what is included in the mix, let alone nearby residents or first responders in the event of an incident.
Between 10% and 100% of this fluid will return to the surface, and is then known as flowback fluid, becoming a waste stream. In Pennsylvania, the average amount of fracking fluid injected into production wells exceeds 10 million gallons in recent years according to data from the industry’s self-reporting registry known as FracFocus. With more than 12,000 of these wells drilled statewide, disposing of this waste stream becomes an enormous concern.
In addition to flowback fluid, there are pockets of ancient fluids encountered by the drilling and fracking processes that return to surface as well. These solutions are commonly referred to as brine due to their extremely high salt content, although this is not the type of fluid that you’d want to baste a Thanksgiving turkey with. Total salt concentrations can reach up to 343 grams per liter, roughly ten times the salt concentration of sea water. These brines include but are not limited to the familiar sodium chloride that we use to season our food, but include other components as well, including significant bromide and radium concentrations.
When Pennsylvania experimented with our public health by authorizing disposal of these fracking brines in municipal plants designed to treat sewer sludge, the bromides in that drilling waste stream became problematic as they interacted with disinfectants to cause a cancerous class of chemicals known as trihalomethanes. This ended the practice of surface “treatment” from these sites into streams in 2011, and along the way caused many water authorities to switch from chlorine to chloramine disinfectant processes. This, in turn, may have exacerbated lead exposure issues in the region, as the water disinfected with chloramine often eats away at the calcium scale deposits covering lead pipes and solder in the region’s older homes.
Figure 1. Radium-226 Decay Chain. Source: National Institute of Standards and Technology
Marcellus and Utica wastewater are also very high in a radioactive isotope of radium known as Ra-226, which has a half-life of 1600 years. After that amount of time, half of the present radium will have emitted an alpha particle, which can cause mutations in strands of DNA when introduced inside the body, through contaminated drinking water, for example. After the hazardous expulsion of the alpha particle, the result become radon gas, which is estimated to cause 20,000 lung cancer deaths per year in the United States. Further down the decay chain is Polonium 210, which was infamously used in the assassination of Russian spy Alexander Litvinenko in London in 2006.
None of this should be injected into formations beneath people’s homes, near drinking water supplies, streams, or really anywhere that we aren’t comfortable sacrificing for the next few thousand years.
Figure 2. Earthquakes in California and Oklahoma by year. Source: United States Geological Survey
On top of all the problems with the water chemistry of both produced water and brine, the very act of injecting these fluids into the ground has triggered a large number of earthquakes in areas with frequent or large volumes of waste injection. This human-caused phenomenon is known as induced seismicity. The most well-known example of this is the previously stable state of Oklahoma which surged to have more magnitude 3.0+ earthquakes than California for a number of years during a drilling boom in that region. The largest of these was the magnitude 5.8 Pawnee earthquake in 2016.
Figure 3. PA Earthquakes and Potential Causes: 1/2000 – 2/2021, Magnitude 2.0 or Greater. Most earthquakes in the eastern portion of the state are associated with Quaternary faults. In the western portion, the causes are less straightforward, and include zipper fracking, mine blasting or collapse, and faults that are more ancient and deeper than the Quaternary faults, many of which remain unmapped. As the use of SWD wells increases, seismic activity may increase as well.
Manmade earthquakes are not limited to Oklahoma. For example, there were approximately 130 seismic events in one year period in the Youngstown, Ohio area due to SWD activity, including one measuring 4.0 on the last day of 2011. Over the years, the regulatory reaction to induced earthquakes seems to walking along the slippery slope from “that can’t happen” to “that can’t happen here” to “they’re all small earthquakes” to “we can mitigate the impact,” despite all evidence to the contrary.
So who gets to be in charge of this dumpster fire? As mentioned above, this is ultimately under the umbrella of EPA’s Underground Injection Control program. However, they have a complicated arrangement with the various states defining who has primary enforcement authority for this type of well.
In Pennsylvania, such wells must obtain a permit from EPA before obtaining a second permit from DEP. In a 2017 hearing in Plum Borough, Allegheny County, furious residents concerned with a variety of issues with a proposed SWD well were told that in Pennsylvania, EPA could only consider whether or not the well would violate the 1972 Clean Water Act when considering the permit, and that the correct audience for everything else would be DEP. Both permits for this well that is near and undear to me were ultimately issued, and operations are expected to begin in the next month if Governor Wolf does not instruct the DEP to reconsider their permit.
There is some precedent for overturning such a permit. In March of 2020, DEP yanked a permit for a SWD well in Grant Township, Indiana County, suddenly respecting a home-rule charter law that the agency had previously sued the Township over.
Without the prospect of royalties or impact fees, no community wants these wells and regulators know that they are nothing but problems. However, the reality is that the regulators oversee an industry that produces a tsunami of this toxic waste – more than 61.8 million barrels of it from unconventional wells in Pennsylvania in 2020 according to self-reported data, which is almost 2.6 billion gallons of the stuff, or slightly more than the capacity of Beaverdam Run Reservoir in Cambria County, a 382 acre lake with an average depth of 20 feet.
Nationally, injection wells are quite common, with over 740,000 such wells in the EPA inventory for 2018 and Class II (O&G) wells represent about a quarter of this figure. Of these Class II injection wells, roughly 20% are for fluid disposal, giving us an estimated 37,000 SWD wells nationwide. This number is expected to go up, as more than three-quarters of the 8,600 permits issued in 2018 were for oil and gas purposes.
However, in Pennsylvania, there have been quite few of these, compared to other states. The primary reason for this is its geology, which has largely been considered unsuitable for this type of activity. For example, a 2009 industry analysis states:
“The disposal of flowback and produced water is an evolving process in the Appalachians. The volumes of water that are being produced as flowback water are likely to require a number of options for disposal that may include municipal or industrial water treatment facilities (primarily in Pennsylvania), Class II injection wells [SWDs], and on-site recycling for use in subsequent fracturing jobs. In most shale gas plays, underground injection has historically been preferred. In the Marcellus play, this option is expected to be limited, as there are few areas where suitable injection zones are available.”
I discussed this topic in a phone call with an official from EPA, who largely confirmed this point of view, but preferred the phrase, “the geology is complicated” instead of the word “unsuitable.” When the UIC program was established from the 1974 Safe Drinking Water Act, there were only seven such wells in operation, and according to EPA’s data, there were still just 11 active SWD wells in the Commonwealth but with more on the way. I was cautioned that the geology wasn’t the only reason, however. Neighboring Ohio had hundreds of these wells, many of which are clustered close to the border with Pennsylvania. The two states have different primacy and permitting arrangements, which is a factor as well.
I have not come across sources mentioning why Pennsylvania’s geology was so unsuitable – or complicated, if we are being generous. However, there are numerous widespread issues that could be a factor, including voids created by karst and legacy coal mines, and formations that might have otherwise trapped gasses and fluids being punctured with up to 760,000 mostly unplugged oil and gas wells and more than one million drinking water wells.
Even when these fluids have been pumped deep underground, they are not necessarily out of sight and out of mind. For example, an abandoned well in Noble County Ohio suddenly began spewing gas field brine just a few weeks ago, resulting in a fish kill in a nearby stream. The incident is believed to be related to SWD wells in the general vicinity even though the closest of these is miles away from the toxic geyser. The waste fluids injected beneath the surface will exploit any pathway available through crumbling or porous rocks to alleviate the pressure built up from the injection process. These fluids don’t care whether the target is an old gas well, mine void, or drinking water aquifer.
Of course, we could ask the question in reverse, and ask what makes the injection of oil and gas fluids suitable in other locations, and the aggregated evidence would lead us to “nothing” as our answer. Nothing, other than the fact that drilling and fracking produces billions of gallons of liquid waste, and that it has to go somewhere.
Although EPA play a major role in permitting and regulating SWD wells in Pennsylvania, they do not publish data related to these wells on their website. FracTracker started hearing rumors about a spate of new SWD permits all over the state that were not accounted for in DEP data. As it turns out, many of these turned out to be other oil and gas wastewater processing facilities, and the public’s confusion about these is completely understandable because these facilities lacked the proper public notice process. These facilities are concerning in their own right – and residents of Pennsylvania should look here to see if one of these 49 facilities are in their neighborhoods – but these are not disposal wells.
To clear up the confusion, I submitted a Freedom of Information Act request to EPA for a spreadsheet of their Class II injection wells in Pennsylvania. This was apparently an onerous task that would require more than ten hours of labor on their behalf. When I mentioned that I was mostly interested in disposal wells, that sped the process up considerably.
Ultimately, I received a portion of the data fields that I had asked for.
|Well API Number||Yes|
|Class II Category (disposal, recovery, storage)||No|
|Date application received||No|
|Application status (e.g., pending, complete)||Yes|
|Application result (e.g., approved, rejected)||No|
|Application result date (date of EPA’s decision)||No|
|Well status (e.g., active, plugged)||Yes|
|Well county name||Yes|
|Well municipality name||No|
Table 1 – Summary of fields requested and received in FracTracker’s FOIA submission with EPA.
I started to compare the EPA dataset to DEP’s SWD well dataset, which is a part of its conventional well inventory. Each source had 23 records. We were off to a good start, but this data victory turned out to be limited in scope as the discrepancies between the two datasets continued to grow. Inconsistencies between the two datasets are as follows:
|County||DEP API||DEP Well Name||EPA API Match||EPA Name Match||Notes|
|Armstrong||005-21675||HARRY L DANDO 1||Y||Y|
|Beaver||007-20027||COLUMBIA GAS OF PENNA INC CGPA5||Y||Y|
|Bedford||009-20039||KENNETH A DIEHL D1||N||N||Not on EPA List|
|Cambria||021-20018||THE PEOPLES NATURAL GAS CO 4627X||N||N||Not on EPA list|
|Clearfield||033-27255||FRANK & SUSAN ZELMAN 1||N||Y||DEP / EPA API Number mismatch|
|033-27257||POVLIK 1||N||Y||No EPA API No.|
|033-00053||IRVIN A-19 FMLY FEE A 19||Y||Y|
|033-22059||SPENCER LAND CO 2||Y||Y|
|Elk||047-23835||FEE SENECA RESOURCES WARRANT 3771 38268||Y||Y|
|047-23885||FEE SENECA RESOURCES WARRANT 3771 38282||N||Y||DEP / EPA API Number mismatch|
|Erie||049-24388||NORBERT CROSS 2||Y||Y|
|049-20109||HAMMERMILL PLT 1||N||N||Not on EPA List|
|049-00013||HAMMERMILL 3||N||N||Not on EPA List|
|049-00012||HAMMERMILL 1||N||N||Not on EPA List|
|Greene||N||N||Not on DEP list. EPA Permit PAS2D210BGRE – no API to match|
|Indiana||063-31807||MARJORIE C YANITY 1025||Y||Y|
|063-20246||T H YUCKENBERG 1||Y||Y|
|Somerset||111-20059||W SHANKSVILLE SALT WATER DISP 1||Y||N|
|111-20006||MORRIS H CRITCHFIELD 1||Y||N|
|Potter||105-20473||H A HEINRICK RW-55||CA||Y||Category Anomaly – Not on DEP SWD list – does appear as Plugged OG Well (consistent w/ EPA status notes)|
|Warren||123-39874||BITTINGER 4||N||Y||API Mismatch (But does match Bittinger #1) Lat/Long match site name|
|123-33914||JOSEPH BITTINGER 1||N||Y||API Mismatch (But does match Bittinger #4) Lat matches site name, Long slightly off|
|123-33944||JOSEPH BITTINGER 2||Y||Y|
|123-33945||JOSEPH BITTINGER 3||CA||Y||Category Anomaly – Not on DEP SWD list – does appear as “Injection”|
|123-34843||SMITH/RAS UNIT 1||CA||Y||Category Anomaly – Not on DEP SWD list – does appear as “Observation”|
|123-22665||LEROY STODDARD & FRANK COFFA 1 WELL||N||N||Not on DEP list of all wells. Does appear on eFACTS. No location data|
Table 2 – Discrepancies between EPA and DEP data for SWD wells in PA.
Altogether, there was at least one data discrepancy on 17 out of 28 wells (61%) on the combined inventories, and this is allowing for significantly different formatting of the well’s name. The DEP list contained five records that were not on the EPA dataset at all, four records where the well’s API number did not match, three instances where the DEP well type was different from EPA’s listing, two wells with matching API numbers but different well names, two wells that were missing the API number on the EPA list, and one well that was on the EPA list that I have not been able to find in any of DEP’s inventories. These last two wells could not be mapped due to the lack of location data.
It isn’t always possible to know which dataset is erroneous, but the EPA list has several obvious omissions and one instance where the API number and well name are in the wrong columns. The quality of DEP data has improved over the years and appear to have some data controls in place to avoid some of these basic errors. For that reason, I suspect that most of the problems stem from the EPA dataset, and I have used DEP coordinates to map these wells.
Waste Disposal Wells in Pennsylvania
This map contains numerous layers that explore the current state of Class II-D Salt Water Disposal (SWD) injection wells for oil and gas waste in Pennsylvania. View the map “Details” tab below in the top left corner to learn more and access the data, or click on the map to explore the dynamic version of this data.
View Full Sized Map | Updated 2/21
The Take Away
In the early 1970s, it was recognized that industrial injection of oil and gas waste underground could lead to risks to human health and the environment, so several major protective laws were put in place, including the Clean Water Act of 1972, the Safe Drinking Water Act of 1974, and the Pennsylvania’s 1971 Environmental Rights Amendment. Decades later, it feels like the Pennsylvania Department of Environmental Protection and the United States Environmental Protection Agency don’t take their regulatory responsibilities very seriously when it comes to oil and gas liquid waste disposal wells. While the state does have fewer of this type of well than other states, there are five that are currently under construction, according to the EPA dataset. Many of these, like the Sedat 3A well in Allegheny County, have come after significant community opposition, and many of the residents’ concerns have not been addressed by either agency.
There will undoubtedly be more of these disposal wells proposed in the near future. Residents would do well to hassle their municipalities to update their ordinances for this type of well if they happen to live in a place where such ordinances are possible. Solicitors should be instructed to regularly scour the Pennsylvania Bulletin and be in contact with EPA for the earliest possible notification of a proposed site, so that there is time to respond within the comment periods.
Additionally, the sloppiness of the datasets calls all sorts of questions into play regarding the co-regulation of these wells. In the case of an incident, it’s not even clear that both agencies have the information on hand to even locate the site in the field. Meanwhile, a 61% error rate between the sites name, API number, and status does not inspire confidence that agencies are keeping a close eye on these facilities, to say the least.
Above all, we must all realize that it isn’t safe to assume that someone will let us know when these types of facilities are proposed. Regulators have shown us through their actions that they are thinking far more about the billions of gallons of waste that needs to be disposed of than of the well-being of dozens or even hundreds of neighbors near each toxic dump site.
References & Where to Learn More
Data supporting this article, as well as the static map in Figure 3, can be found here.
FracTracker Pennsylvania articles, maps, and imagery: https://www.fractracker.org/map/us/pennsylvania/
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