Though a 2018 legal win resulted in a statewide ban on the practice, unauthorized brine spreading in PA continues. Guest post by Fair Shake.
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.
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.
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.
| Asked For | Received |
| Well Name | Yes |
| 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 |
| Well latitude | Yes |
| Well longitude | Yes |
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 |
| Allegheny | 003-21223 | SEDAT 3A | Y | Y | |
| 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) |
| Venango | 121-44484 | LATSHAW 9 | Y | Y | |
| 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.
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
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.
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/
Fracking produces more than just oil and gas — billions of gallons of highly toxic waste are also created in the process. Regulatory loopholes have led to limited oversight into how this waste is tracked and treated, putting public health and safety at risk.
The maps below explore issues related to fracking waste from the Marcellus and Utica Shale regions of Pennsylvania, Ohio, New York, and West Virginia.
This mapping platform is an evolving tool based on available data — yet the opaqueness of the fracking industry limits our ability to map and analyze the full scope of the problem of fracking waste in the Appalachian Basin.
Unfortunately, even after sifting through thousands of data points, we’re left with many outstanding questions — what are the chemical components of the waste created? Where is it all sent? Where are its byproducts sent? What facilities are being planned and proposed? How much illegal dumping occurs?
The production of fracking waste in the Appalachian Basin will continue to create environmental and public health threats for decades after the industry leaves the region. Wells can continue to generate wastewater for years and contaminated equipment sent to landfills will leach toxins into the environment. Furthermore, with the industry’s history of failing to restore land after it has been used for oil and gas operations, we can expect abandoned fracking sites to become an increasing source of pollution in the Appalachian Basin in the coming decades. It’s imperative that the public have access to accurate and detailed data on fracking waste to protect the health of workers and residents.
By Erica Jackson, Community Outreach & Communications Specialist, FracTracker Alliance
In this article, we’ll take a look at the current trend in “re-branding” incineration as a viable option to deal with the mountains of garbage generated by our society. Incineration can produce energy for electricity, but can the costs—both economically, and ecologically—justify the benefits? What are the alternatives?
In today’s world of consumerism and production, waste disposal is a chronic problem facing most communities worldwide. Lack of attention to recycling and composting, as well as ubiquitous dependence on plastics, synthetics, and poorly-constructed or single-use goods has created a waste crisis in the United States. So much of the waste that we create could be recycled or composted, however, taking extraordinary levels of pressure off our landfills. According to estimates in 2017 by the US Environmental Protection Agency (EPA), over 30 percent of municipal solid waste is made up of organic matter like food waste, wood, and yard trimmings, almost all of which could be composted. Paper, glass, and metals – also recyclable – make up nearly 40 percent of the residential waste stream. Recycling plastic, a material which comprises 13% of the waste stream, has largely been a failed endeavor thus far.
Why say NO to incinerators?
Figure 1: A breakdown of the 267.78 million tons of municipal waste that were generated in the US in 2017. Source: figure developed by FracTracker Alliance, based on 2017 EPA data. Source: https://www.epa.gov/facts-and-figures-about-materials-waste-and-recycling/national-overview-facts-and-figures-materials
Nevertheless, of the approximately 400 million tons of plastic produced annually around the world, only about 10% of it is recycled. The rest winds up in the waste stream or as microfragments (or microplastics) in our oceans, freshwater lakes, and streams.
Figure 2: Increase in global plastics production, 1950-2015, Source: Geyer, R., Jambeck, J. R., & Law, K. L. (2017). Production, use, and fate of all plastics ever made. Science Advances, 3(7), e1700782. Available at: http://advances.sciencemag.org/content/3/7/e1700782 Referenced in https://ourworldindata.org/plastic-pollution
According to an EPA fact sheet, by 2017, municipal solid waste generation increased three-fold compared with 1960. In 1960, that number was 88.1 million tons. By 2017, this number had risen to nearly 267.8 million tons. Over that same period, per-capita waste generation rose from 2.68 pounds per person per day, to 4.38 pounds per person per day, as our culture became more wed to disposable items.
The EPA provides a robust “facts and figures” breakdown of waste generation and disposal here. In 2017, 42.53 million tons of US waste was shipped to landfills, which are under increasing pressure to expand and receive larger and larger loads from surrounding area, and, in some cases, hundreds of miles away.
On average, in 2017, Americans recycled and composted 35.2% of our individual waste generation rate of 4.51 pounds per person per day. While this is a notable jump from decades earlier, much of the gain appears to be in the development of municipal yard waste composting programs. Although the benefits of recycling are abundantly clear, in today’s culture, according to a PEW Research Center report published in 2016, just under 30% of Americans live in communities where recycling is strongly encouraged. An EPA estimate for 2014 noted that the recycling rate that year was only 34.6%, nationwide, with the highest compliance rate at 89.5% for corrugated boxes.
Figure 3. Percent of Americans who report recycling and re-use behaviors in their communities, via Pew Research center
Historically, incineration – or burning solid waste – has been one method for disposing of waste. And in 2017, this was the fate of 34 million tons—or nearly 13%– of all municipal waste generated in the United States. Nearly a quarter of this waste consisted of containers and packaging—much of that made from plastic. The quantity of packaging materials in the combusted waste stream has jumped from only 150,000 tons in 1970 to 7.86 million tons in 2017. Plastic, in its many forms, made up 16.4% of all incinerated materials, according to the EPA’s estimates in 2017.
Figure 4: A breakdown of the 34.03 tons of municipal waste incinerated for energy in the US in 2017
Sadly, the answer is this: The oil and gas industry produces copious amounts of ethane, which is a byproduct of oil and gas extraction. Plastics are an “added value” component of the cycle of fossil fuel extraction. FracTracker has reported extensively on the controversial development of ethane “cracker” plants, which chemically change this extraction waste product into feedstock for the production of polypropylene plastic nuggets. These nuggets, or “nurdles,” are the building blocks for everything from fleece sportswear, to lumber, to packaging materials. The harmful impacts from plastics manufacturing on air and water quality, as well as on human and environmental health, are nothing short of stunning.
FracTracker has reported extensively on this issue. For further background reading, explore:
A report co-authored by FracTracker Alliance and the Center for Environmental Integrity in 2019 found that plastic production and incineration in 2019 contributed greenhouse gas emissions equivalent to that of 189 new 500-megawatt coal power plants. If plastic production and use grow as currently planned, by 2050, these emissions could rise to the equivalent to the emissions released by more than 615 coal-fired power plants.
Figure 5: Projected carbon dioxide equivalencies in plastics emissions, 2019-2050. Source: Plastic and Climate https://www.ciel.org/plasticandclimate/
Incineration is now strongly critiqued as a dangerous solution to waste disposal as more synthetic and heavily processed materials derived from fossils fuels have entered the waste stream. Filters and other scrubbers that are designed to remove toxins and particulates from incineration smoke are anything but fail-safe. Furthermore, the fly-ash and bottom ash that are produced by incineration only concentrate hazardous compounds even further, posing additional conundrums for disposal.
Incineration as a means of waste disposal, in some states is considered a “renewable energy” source when electricity is generated as a by-product. Opponents of incineration and the so-called “waste-to-energy” process see it as a dangerous route for toxins to get into our lungs, and into the food stream. In fact, Energy Justice Network sees incineration as:
… the most expensive and polluting way to make energy or to manage waste. It produces the fewest jobs compared to reuse, recycling and composting the same materials. It is the dirtiest way to manage waste – far more polluting than landfills. It is also the dirtiest way to produce energy – far more polluting than coal burning.
Waste incineration has been one solution for disposing of trash for millennia. And now, aided by technology, and fueled by a crisis to dispose of ever-increasing trash our society generates, waste-to-energy (WTE) incineration facilities are a component in how we produce electricity.
But what is a common characteristic of the communities in which WTEs are sited? According to a 2019 report by the Tishman Environmental and Design Center at the New School, 79% of all municipal solid waste incinerators are located in communities of color and low-income communities. Incinerators are not only highly problematic environmentally and economically. They present direct and dire environmental justice threats.
Click here to view this map full-screen
Activate the Layers List button to turn on Environmental Justice data on air pollutants and cancer occurrences across the United States. We have also included real-time air monitoring data in the interactive map because one of the health impacts of incineration includes respiratory illnesses. These air monitoring stations measure ambient particulate matter (PM 2.5) in the atmosphere, which can be a helpful metric.
These trash incinerators capture energy released from the process of burning materials, and turn it into electricity. But what are the costs? Proponents of incineration say it is a sensible way to reclaim or recovery energy that would otherwise be lost to landfill disposal. The US EIA also points out that burning waste reduces the volume of waste products by up to 87%.
The down-side of incineration of municipal waste, however, is proportionally much greater, with a panoply of health effects documented by the National Institutes for Health, and others.
Dioxins (shown in Figures 6-11) are some of the most dangerous byproducts of trash incineration. They make up a group of highly persistent organic pollutants that take a long time to degrade in the environment and are prone to bioaccumulation up the food chain.
Dioxins are known to cause cancer, disrupt the endocrine and immune systems, and lead to reproductive and developmental problems. Dioxins are some of the most dangerous compounds produced from incineration. Compared with the air pollution from coal-burning power plants, dioxin concentrations produced from incineration may be up to 28 times as high.
2,3,7,8-Tetrachlorodibenzo-p-dioxin
2,3,7,8-Tetrachlorodibenzofuran
3,3′,4,4′,5,5′-Hexachlorobiphenyl
Figures 6-11: Dioxin chemical structures via US EPA. Source: https://www.epa.gov/dioxin/learn-about-dioxin
Federal EPA regulations between 2000 and 2005 resulted in the closure of nearly 200 high dioxin emitting plants. Currently, there are fewer than 100 waste-to-energy incinerators operating in the United States, all of which are required to operate with high-tech equipment that reduces dioxins to 1% of what used to be emitted. Nevertheless, even with these add-ons, incinerators still produce 28 times the amount of dioxin per BTU when compared with power plants that burn coal.
Even with pollution controls required of trash incinerators since 2005, compared with coal-burning energy generation, incineration still releases 6.4 times as much of the notoriously toxic pollutant mercury to produce the equivalent amount of energy.
Energy Justice Network, furthermore, notes that incineration is the most expensive means of managing waste… as well as making energy. This price tag includes high costs to build incinerators, as well as staff and maintain them — exceeding operation and maintenance costs of coal by a factor of 11, and nuclear by a factor of 4.2.
Figure 12. Costs of incineration per ton are nearly twice that of landfilling. Source: National Solid Waste Management Association 2005 Tip Fee Survey, p. 3.
Energy Justice Network and others have pointed out that the amount of energy recovered and/or saved from recycling or composting is up to five times that which would be provided through incineration.
Figure 13. Estimated power plant capital and operating costs. Source: Energy Justice Network
Waste is a “renewable” resource only to the extent that humans will continue to generate waste. In general, the definition of “renewable” refers to non-fossil fuel based energy, such as wind, solar, geothermal, wind, hydropower, and biomass. Synthetic materials like plastics, derived from oil and gas, however, are not. Although not created from fossil fuels, biologically-derived products are not technically “renewable” either.
ZeroWasteEurope argues that:
Biogenic materials you find in the residual waste stream, such as food, paper, card and natural textiles, are derived from intensive agriculture – monoculture forests, cotton fields and other “green deserts”. The ecosystems from which these materials are derived could not survive in the absence of human intervention, and of energy inputs from fossil sources. It is, therefore, more than debatable whether such materials should be referred to as renewable.
Although incineration may reduce waste volumes by up to 90%, the resulting waste-products are problematic. “Fly-ash,” which is composed of the light-weight byproducts, may be reused in concrete and wallboard. “Bottom ash” however, the more coarse fraction of incineration—about 10% overall—concentrates toxins like heavy metals. Bottom-ash is disposed of in landfills or sometimes incorporated into structural fill and aggregate road-base material.
Trash incineration accounts for a fraction of the power produced in the United States. According to the United States Energy Information Administration, just under 13% of electricity generated in the US comes from burning of municipal solid waste, in fewer than 65 waste-to-energy plants nation-wide. Nevertheless, operational waste-to-incineration plants are found throughout the United States, with a concentration east of the Mississippi.
According to EnergyJustice.net’s count of waste incinerators in the US and Canada, currently, there are:
Figure 14. Locations of waste incinerators that are already shut down. Source: EnergyJustice.net)
Precise numbers of these incinerators are difficult to ascertain, however. Recent estimates from the federal government put the number of current waste-to-energy facilities at slightly fewer: EPA currently says there are 75 of these incinerators in the United States. And in their database, updated July 2020, the United States Energy Information Administration (EIA), lists 63 power plants that are fueled by municipal solid waste. Of these 63 plants, 40—or 66%—are in the northeast United States.
Regardless, advocates of clean energy, waste reduction, and sustainability argue that trash incinerators, despite improvements in pollution reduction over earlier times and the potential for at least some electric generation, are the least effective option for waste disposal that exists. The trend towards plant closure across the United States would support that assertion.
Let’s take a look at the dirty details on WTE facilities in three states in the Northeastern US.
In NYS, there are currently 11 waste-to-energy facilities that are operational, and two that are proposed. Here’s a look at some of them:
The largest waste-to-energy facility in New York State, Covanta Hempstead Company (Nassau County), was built in 1989. It is a 72 MW generating plant, and considered by Covanta to be the “cornerstone of the town’s integrated waste service plan.”
According to the Environmental Protection Agency’s ECHO database, this plant has no violations listed. Oddly enough, even after drawing public attention in 2009 about the risks associated with particulate fall-out from the plant, the facility has not been inspected in the past 5 years.
Other WTE facilities in New York State include the Wheelabrator plant located in Peekskill (51 MW), Covanta Energy of Niagara in Niagara Falls (32 MW), Convanta Onondaga in Jamesville (39 MW), Huntington Resource Recovery in Suffolk County (24.3 MW), and the Babylon Resource Recovery Facility also in Suffolk County (16.8 MW). Five additional plants scattered throughout the state in Oswego, Dutchess, Suffolk, Tioga, and Washington Counties, are smaller than 15 MW each. Of those, two closed and one proposal was defeated.
In Pennsylvania, six WTE facilities are currently operating. Two have been closed, and six defeated.
And in New Jersey, there are currently four operating WTE facilities. Essex County Resource Recovery Facility, is New Jersey’s largest WTE facility. It opened in 1990, houses three burners, and produces 93 MW total.
Union County Resource Recovery Facility, which opened in 1994, operates three burners, producing 73 MW total. Covanta Camden Energy Recovery Center opened in 1991. It has 13 burners, producing a total of 46 MW. Wheelabrator Gloucester LP (Westville, NJ) opened in 1990. The two burners there produce 21 MW of power. Covanta Warren Energy is the oldest and smallest WTE facility in New Jersey. It produced 14 MW of energy and opened in 1988. Operations are currently shut down, but this closure may not be permanent.
Looming large above the arguments about appropriate siting, environmental justice, financial gain, and energy prices, is a bigger question:
How can we continue to live on this planet at our current rates of consumption, and the resultant waste generation?
The issue here is not so much about the sources of our heat and electricity in the future, but rather “How MUST we change our habits now to ensure a future on a livable planet?”
Professor Paul Connett (emeritus, St. Lawrence University), is a specialist in the build-up of dioxins in food chains, and the problems, dangers, and alternatives to incineration. He is a vocal advocate for a “Zero Waste” approach to consumption, and suggests that every community embrace these principles as ways to guide a reduction of our waste footprint on the planet. The fewer resources that are used, the less waste is produced, mitigating the extensive costs brought on by our consumptive lifestyles. Waste-to-energy incineration facilities are just a symptom of our excessively consumptive society.
Dr. Connett suggests these simple but powerful methods to drastically reduce the amount of materials that we dispose — whether by incineration, landfill, or out the car window on a back-road, anywhere in the world:
Connett’s Zero Waste charge to industry is this: “If we can’t reuse, recycle, or compost it, industry shouldn’t be making it.” Reducing our waste reduces our energy footprint on the planet.
In a similar vein, FracTracker has written about the potential for managing waste through a circular economics model, which has been successfully implemented by the city of Freiburg, Germany. A circular economic model incorporates recycling, reuse, and repair to loop “waste” back into the system. A circular model focuses on designing products that last and can be repaired or re-introduced back into a natural ecosystem.
This is an important vision to embrace. Every day. Everywhere.
Figure 17: Illustration of common waste streams from “The Story of Plastic” (https://www.storyofplastic.org/)
By Karen Edelstein, Eastern Program Coordinator
On August 3, 2020, New Yorkers rejoiced in Governor Cuomo’s signing of legislation to protect the Empire State from Pennsylvania’s fracking waste. Although New York State has banned high-volume, horizontal hydraulic fracturing, or “fracking” within its borders, a fracking waste loophole allowed numerous landfills to received both solid and liquid waste products from drilling operations just south of its border, according to records from the Pennsylvania Department of Environmental Protection (PA DEP).
A regulatory loophole in New York State’s laws exempted drilling waste from scrutiny as hazardous materials. Therefore, solid and liquid wastes from drilling operations — including many constituents which are considered secret or “proprietary” — were sent to landfills, and in some cases, spread on roads and walkways in the state. Municipalities were provided with very little understanding of the risks those materials might be posing to air and water quality in and around landfills. Until the signing of this legislation, New York State Department of Environmental Conservation has considered road-spreading of waste brine from both conventional and unconventional oil and gas wells that was spread on roads a “BUD,” or a beneficial use determination.
Nevertheless, research has shown that produced water from fracking operations can contain tens to thousands of times the allowable drinking water concentration limit of radium, strontium, barium, lead, arsenic, and other elements. Human health impacts of all phases of drilling operations were explored in a recent paper by Wollin et al. (May 2020).
Water that flows to the surface from oil and gas wells, so-called ‘produced water’, represents a mixture of flow-back, the injected frac fluid returning to the surface, and the reservoir water present in natural oil and gas deposits. Among numerous hazardous compounds, produced water may contain bromide, arsenic, strontium, mercury, barium, radioactive isotopes and organic compounds, particularly benzene, toluene, ethylbenzene and xylenes (BTEX). The sewage outflow, even from specialized treatment plants, may still contain critical concentrations of barium, strontium and arsenic. Evidence suggests that the quality of groundwater and surface water may be compromised by disposal of produced water.
Carcinogenic and radioactive wastes that are brought to the surface with both conventional and unconventional drilling technologies can have toxic impacts on human health and the natural environment, impacting the endocrine, nervous, cardiovascular, and respiratory systems, as well as air and water quality. According to the Natural Resources Defense Council, more than 75 percent of the chemicals used in fracking are associated with harm to human organs, while 25 percent are tied to cancer and other genetic mutations.
Although the federal Resource Conservation and Recovery Act (RCRA)—passed in 1976—specifically safeguards human and environmental health, an amendment to the Act in 1980 exempted from regulation all waste from oil and gas exploration, development, and production. Despite close to 40 years of federal oversight of pollution created by countless industries, oil and gas operations have been subject to far more lax regulations. And although states can pass their own regulations to supplement the federal rule-making, this had not occurred in New York State.
The recent legislation to close the fracking loophole in New York State was sponsored in 2019 by Senator Rachel May and Assemblyman Steve Engelbright. Lawmakers had been deadlocked on the issue since 2011, but through much hard work, political and public will, and a favorable complement of elected officials, after the bills finally passed both the New York State Senate and Assembly, they could move to Governor Andrew Cuomo’s desk, where they were signed into law in early August, 2020. According to EarthWorks, all oil and gas waste will be
In addition, the law ensures that waste is disposed of only at facilities equipped to safely handle it.
Now, even wastes like brine from conventional drilling operations must undergo laboratory analysis to determine whether they have characteristics consistent with hazardous materials.
Here’s a look back at our history of accepting fracking waste from Pennsylvania into New York State.
FracTracker has annually mapped the flow of drilling waste from Pennsylvania to New York State.
To view the map a full screen, click here
Since 2011, nearly 29,000 barrels of fracking liquid waste (drilling fluids, fracturing fluids, produced waters, etc.), along with close to 645,000 tons of solid waste (drill cuttings—some of it radioactive, sludge, contaminated soils, etc.) from Pennsylvania drilling operations have been disposed of in New York State. For more references on radioactivity in drilling materials, explore this resource. Drilling waste reports available from 2010 through the present show a steady decline in waste sent to New York State, beginning in 2011. Nonetheless, New York’s landfills have received as much as 11,548 barrels of drilling waste, and 214,168 tons of solid waste in a given year.
PA DEP’s records are far from complete prior to 2016, however, with disposal destinations unknown for close to 2/3 of liquid waste (see yellow portions of the bar chart in Figure 1) generated between 2012 and 2015.
Figure 1. Pennsylvania’s liquid unconventional drilling waste disposal by state, 2010-2019
In more recent years, waste products were accounted for more accurately, as well as shipped to injection wells in Ohio.
On a relatively smaller scale, one can also see how West Virginia’s acceptance of Pennsylvania’s fracking waste has skyrocketed in 2018 and 2019, particularly in comparison to states other than Pennsylvania and Ohio (Figure 2).
Figure 2. Pennsylvania’s liquid unconventional drilling waste disposal by state (excluding Pennsylvania and Ohio), 2010-2019
In general, records indicate more solid waste disposal occurring within Pennsylvania over time, with Ohio accepting varying quantities from year to year, and New York State steadily receiving less over time (Figure 3).
Figure 3. Pennsylvania’s solid unconventional drilling waste disposal by state, 2010-2019
Now that the regulatory loophole has been closed, these numbers should drop to near zero. Data about waste coming from Pennsylvania to New York in the first half of 2020 support that assertion (Figures 4 and 5).
Figure 4. Pennsylvania’s liquid unconventional drilling waste disposal by state, January-May 2020
Figure 5. Pennsylvania’s solid unconventional drilling waste disposal by state, January-May 2020
FracTracker applauds New York State for closing the fracking waste loophole and in doing so, continuing to set high standards to protect its residents from the human and environmental impacts created by oil and gas extraction. We hope that other states will follow suit, and develop their own stringent standards to protect human and environmental health, in particular where federal legislation like RCRA has fallen woefully short.
By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance
Feature photo by Ted Auch, FracTracker Alliance, with aerial support by Lighthawk
We updated the FracTracker North Dakota Shale Viewer with current data and additional details on the astronomical levels of water used and waste produced throughout the process of fracking for oil and gas in North Dakota.
As folks who visit the FracTracker website may know, the fracking industry is predicated on cheap sources of water and waste disposal. The water they use to bust open shale seams becomes part of the waste stream that they refer to by the benign term “brine,” equating it to nothing more than the salt water we swim in when we hit the beaches.
Some oil and gas operators like SWEPI and Enervest in Michigan, however, have taken to calling their waste “SLOP” (Figure 1), which from my standpoint is actually refreshingly honest.
Since we created our North Dakota Shale Viewer on October 5th, 2012, much has changed across the fracking landscape, while other songs have remained the same. Both of these truths exist with respect to fracking’s impact on water and the industry’s inability to get its collective head around the billions of barrels of oftentimes radioactive waste it produces by its very nature. From the outset, fracking was on dubious footing when it came to the water and waste associated with its operations, and we have seen a nearly universal and exponential increase in water demand and waste production on a per well basis since fracking became the highly divisive topic it remains to this day.
Figure 1. Oil & Gas waste tank operated by SWEPI and Enervest at the Hayes pad, Otsego County, Michigan May 21st, 2016 (44.892933, -84.786530). Photo by Ted Auch, FracTracker Alliance.
Environmental economists like to look at energy sources from a more holistic standpoint vis a vis engineers, traditional economists, and the divide-and-conquer rhetoric from Bismarck to the White House. They do this by placing all manner of energy sources along a spectrum of Energy Return On Energy Invested (EROEI).
Since the dawn of the fracking revolution, shale gas from horizontal wells has been near the bottom of the league tables with respect to EROEI which means it “…has decreased from more than 1000:1 in 1919 to 5:1 in the 2010s, and for production from about 25:1 in the 1970s to approximately 10:1 in 2007” for US oil and gas according to Hall et al. (2014). This is what John Erik Meyer has come the “EROI Mountain” whereby we’ve already “burned through the richest resources.”
It stands to reason that if natural gas from fracking were a real “bridge fuel” in the transition away from coal, it would at least approach or exceed the EROEI of the latter, but at 46:1 coal is still four times more efficient than natural gas. However, it must be said that coal’s days are numbered as well. Witness the recent bankruptcy of coal giant Murray Energy, and the only reason its EROEI has increased or remained steady is because the mining industry has transitioned to almost exclusively mountaintop removal and/or strip mining and the associated efficiencies resulting from mechanization/automation.
We enhanced our North Dakota Shale Viewer nearly eight years since it debuted. This exercise included the addition of several data layers that speak to the above issues and how they have changed since we first launched the North Dakota Shale Viewer.
It is worth noting that oil production in total across North Dakota has not even doubled since 2012, and gas production has only managed to increase 3.5-fold. However, the numbers look even worse when you look at these totals on a per well basis, which as I have mentioned seems to me to be the only way reasonable people should be looking at production. Using this lens, we see that production of oil in North Dakota on a per well basis oil is 1% less than it was in 2012 and gas production has not even doubled per well. This is a stunning contrast to the upticks in water and waste we have documented and are now including in our North Dakota Shale Viewer.
We’ve incorporated individual horizontal well freshwater demand for nearly 12,000 wells up to and including Q1-2020. The numbers are jaw dropping when you consider that at the time we debuted this map North Dakota, unconventional wells were using roughly 2.1 million gallons per well compared to an average of 8.3 million gallons per well so far this year. This per well increase is something we have been documenting for years now in states like Pennsylvania, Ohio, and West Virginia.
For more analysis around water used for fracking, see “The Human Right to Water and Unconventional Energy,” a paper co-authored by Dr. Ted Auch with partners in the UK.
This is concerning for multiple reasons, the first being that if fracking ever were to rebound to its halcyon days of the early teens, it would mean some of our country’s most prized and fragile watersheds would be pushed to an irreversible hydrological tipping point. Hoekstra et al. (2012) have come to call this the “blue water” precautionary principle whereby “depletion beyond 20% of a river’s natural flow increases risks to ecological health and ecosystem services.”
Another concern is that while permitting in North Dakota has slowed like it has nationwide, the aforementioned quarterly water usage totals per well are now 5.25 times what they were in October 2012 and the total water used by the industry in North Dakota now amounts to 60.43 billion gallons– that we know of — which is nearly 50 times what the industry had used when we created our North Dakota Shale Viewer (Figure 2).[1]
With respect to the points made earlier about the value of EROEI, this increase in water demand has not been reflected in the productivity of North Dakota’s oil and gas wells, which means the EROEI continues to fall at rate that should make the industry blush. Furthermore, this trend should prompt regulators and elected officials in Bismarck and elsewhere to begin to ask if the long-term and permanent environmental and/or hydrological risk is worth the short-term rewards vis à vis the “blue water” precautionary principle, in this case of the Missouri River, outlined by Hoekstra et al. (2012). It is my opinion that it most assuredly is not and never was worth the risk!
The most stunning aspect of the above divergence in production and water demand is that on a per well basis, water only costs the industry roughly 0.46-0.76% of total well pad costs. This narrow range is a function of the water pricing schemes shared with me by the North Dakota Western Area Water Supply Authority (WAWSA). This speaks to an average price of water between $3.68 and $4.07 per 1,000 gallons for “industrial” use (aka, fracking industry) by way of eight depots and “several hundred miles of transmission and distribution lines” spread across the state’s four northwest counties of Mountrail, Divide, Williams, and McKenzie.
Figure 2. Average Freshwater Demand Per Well and Cumulative Freshwater Demand by North Dakota fracking industry from 2011 to Q1-2020.
On the fracking waste front, the monthly trend is quite volatile relative to what we’ve documented in states like Oklahoma, Kansas, and Ohio. Nonetheless, the amount of waste produced is increasing per well and in total. How you quantify this increase is quite sensitive to the models you fit to the data. The exponential and polynomial (Plotted in Figure 3) fits yield 4.76 to 9.81 million barrel per month increases, while linear and power functions yield the opposite resulting in 1.82 to 10.91 million-barrel declines per month. If we assume the real answer is somewhere in between we see that fracking waste is increasingly slightly at a rate of 1.51% per year or 460,194 barrels per month.
Figure 3. Average Per Well and Monthly Total Fracking Waste Disposal across 675 North Dakota Class II Salt Water Disposal (SWD) wells from 2010 to Q1-2020.
North Dakota has concerning legislation related to oil and gas waste disposal. Senate Bill 2344 claims that landowners do not actually own the “subsurface pore space” beneath their property. The bill was passed into law by Legislature last Spring but there are numerous lawsuits working against it. We will have further analysis of this bill published on FracTracker.org soon.
FracTracker collaborated with Earthworks to create an interactive map that allows North Dakota residents to determine if oil and gas waste is disposed of or has spilled near them in addition to a list of recommendations for state and local policymakers, including the closing of the state’s harmful oil and gas hazardous waste loophole. Read the report for detailed information about oil and gas waste in North Dakota.
This data is critical to understanding the environmental and/or hydrological impact(s) of fracking, whether it is Central Appalachia’s Ohio River Valley, or in this case North Dakota’s Missouri River Basin. We will continue to periodically update this data.
Without supply-side price signaling or adequate regulation, it appears that the industry is uninterested and insufficiently incentivized to develop efficiencies in water use. It is my opinion that the only way the industry will be incentivized to do so is if states put a more prohibitive and environmentally responsible price on water and waste. In the absence of outright bans on fracking, we must demand the industry is held accountable for pushing watersheds to the brink of their capacity, and in the process, compromising the water needs of so many communities, flora, and fauna.
[1] Here in Ohio where I have been looking most closely at water supply and demand across the fracking landscape it is clear that we aren’t accounting for some 10-12% of water demand when we compare documented water withdrawals in the numerator with water usage in the denominator.
By Ted Auch, PhD, Great Lakes Program Coordinator
216 Franklin St, Suite 400, Johnstown, PA 15901
Phone: +1 (717) 303-0403 | info@fractracker.org
FracTracker Alliance is a 501(c)3 non-profit: Tax identification number: 80-0844297
FracTracker Alliance, 2021