Kyle Ferrar, Western Program Coordinator for FracTracker Alliance, contributed to the December 2020 memo, “Recommendations to CalGEM for Assessing the Economic Value of Social Benefits from a 2,500’ Buffer Zone Between Oil & Gas Extraction Activities and Nearby Communities.”
The purpose of this memo is to recommend guidelines to CalGEM for evaluating the economic value of the social benefits and costs to people and the environment in requiring a 2,500 foot setback for oil and gas drilling (OGD) activities. The 2,500’ setback distance should be considered a minimum required setback. The extensive technical literature, which we reference below, analyzes health benefits to populations when they live much farther away than 2,500’, such as 1km to 5km, but 2,500’ is a minimal setback in much of the literature. Economic analyses of the benefits and costs of setbacks should follow the technical literature and consider setbacks beyond 2,500’ also.
The social benefits and costs derive primarily from reducing the negative impacts of OGD pollution of soil, water, and air on the well-being of nearby communities. The impacts include a long list of health conditions that are known to result from hazardous exposures in the vulnerable populations living nearby. The benefits and costs to the OGD industry of implementing a setback are more limited under the assumption that the proposed setback will not impact total production of oil and gas.
The comment letter submitted by Voices in Solidarity against Oil in Neighborhoods (VISIÓN) on November 30, 2020 lays out an inclusive approach to assessing the health and safety consequences to the communities living near oil and gas extraction activities. This memo addresses how CalGEM might analyze the economic value of the net social benefits from reducing the pollution suffered by nearby communities. In doing so, this memo provides detailed recommendations on one part of the broader holistic evaluation that CalGEM must use in deciding the setback rule.
This memo consists of two parts. The first part documents factors that CalGEM should take into account when evaluating the economic benefits and costs of the forthcoming proposed rule. These include factors like the adverse health impacts of pollution from OGD, the hazards causing them and their sources, and the way they manifest into social and economic costs. It also describes populations that are particularly vulnerable to pollution and its effects as well as geographic factors that impact outcomes.
The second part of this memo documents the direct and indirect economic benefits of the proposed rule. Here, the memo discusses the methods and data that should be leveraged to analyze economic benefits of reducing exposure to OGD pollution through setbacks. This includes the health benefits, impacts on worker productivity, opportunity costs of OGD activity within the proposed setback, and the fact that impacted communities are paying the external costs of OGD.
FracTracker Alliance has released a new mapof drilling fluid spills along the Mariner East 2 pipeline route, showing 320 spills from its construction since 2017. Of those, a combined 147 incidents have released over 260,000 gallons of drilling fluid into Pennsylvania waterways.
The unpermitted discharge of drilling fluid, considered “industrial waste,” into waters of the Commonwealth violates The Clean Streams Law.
Construction has caused between 260,672 – 266,223 gallons of drilling fluid to spill into waterways, threatening the health of ecosystems and negatively affecting the drinking water of many residents.
There have been 36 spills since Pennsylvania entered a statewide shutdown on March 16th, 2020, in response to the COVID-19 pandemic. These spills released over 10,000 gallons of drilling fluid — most of which poured into Marsh Creek Lake in Marsh Creek State Park. See a map of this incident.
While the total reported volume of drilling fluid released into the environment from the pipeline’s construction is between 344,590 – 405,990 gallons, the actual total is larger, as there are 28 spills with unknown volumes. Spills of drilling mud are also referred to as “inadvertent returns,” or “frac-outs.”
Most of these spills occurred during implementation of horizontal directional drills (HDD). HDDs are used to install a pipeline under a waterway, road, or other sensitive area. This technique requires large quantities of drilling fluid (comprising water, bentonite clay, and chemical additives), which when spilled into the environment, can damage ecosystems and contaminate drinking water sources.
The Mariner East 2 pipeline project is part of the Mariner East pipeline system, which carries natural gas liquids (NGLs) extracted by fracked wells in the Ohio River Valley east, to the Marcus Hook Facility in Delaware County, Pennsylvania. The NGLs will then go to Europe to be turned into plastic. Explore FracTracker’s other resources on this project:
There have been 36 spills since the Commonwealth shutdown statewide on March 16th, 2020, leaks that have jeopardized drinking water sources, putting communities at even higher risk during the COVID-19 pandemic.
On August 11th, construction caused a 15-foot wide and eight-foot deep subsidence event in the wetland (Figure 1). This caused drilling fluid to flow underground and contaminate groundwater, while also “adversely impacting the functions and values of the wetland.” Thirty-three acres of the lake are now closed to boating, fishing, and other uses of the lake — an extra blow, given the solace state parks have provided to many during this pandemic.
Figure 1. This HDD crossing in Upper Uwchlan Township, Chester County, caused over 8,000 gallons of drilling mud to spill into waterways. However, installation of the parallel 16-inch pipeline also caused spills at this same location in 2017.
Last week, the PA DEP ordered Sunoco to suspend work on this HDD site and to implement a reroute using a course Sunoco had identified as an alternative in 2017:
“A 1.01 mile reroute to the north of the HDD is technically feasible. This would entail adjusting the project route prior to this HDD’s northwest entry/exit point to proceed north, cross under the Pennsylvania Turnpike, then proceed east for 0.7 miles parallel to the turnpike, cross Little Conestoga Road, then turn south, cross under the turnpike, and then reintersect the existing project route just east of this HDD’s southeast entry/exit point. There is no existing utility corridor here, however; therefore, this route would create a Greenfield utility corridor and would result in encumbering previously unaffected properties. The route would still cross two Waters of the Commonwealth and possible forested wetlands, and would pass in near proximity or immediately adjacent to five residential home sites. Both crossings of the turnpike would require “mini” HDDs or direct pipe bores to achieve the required depth of cover under the highway. Considered against the possibility of additional IRs [inadvertent returns] occurring on the proposed HDD, which are readily contained and cleaned up with minimal affect to natural resources, the permanent taking of the new 4 easement and likely need to use condemnation against previously unaffected landowners results in SPLP’s opinion that managing the proposed HDD is the preferred option.”
Based on that description, the route could follow the general direction of the dashed line in Figure 2:
Figure 2. Possible reroute of Mariner East 2 Pipeline shown with dashed line
Residents also sounded alarm bells for this drilling site. The proposal for just this location garnered over 200 public comments, all of which called on the DEP to deny Sunoco’s permit for drilling in this area. Many implored the DEP to consider the alternate route Sunoco must now use.
George Alexander, a Delaware County resident who runs a blog on this pipeline, the Dragonpipe Diary, says, “Sunoco/Energy Transfer continues to demonstrate in real time that they cannot build the Mariner Pipelines without inflicting harm upon our communities … The Marsh Creek situation is reminiscent of the damage to another favorite Pennsylvania lake, Raystown Lake in Huntingdon County.”
In 2017, Sunoco spilled over 200,000 gallons of drilling fluid into Raystown Lake, and released millions more underground. The spill caked acres of the lakebed with a coating of mud, hurting aquatic life and limiting recreational access to the lake. Sunoco failed to report the spills when they occurred, and the DEP fined the company $1.95 million for the incident. The fine is one of many Sunoco has incurred, including a $12.6 million penalty in February 2018 for permit violations, and more recently, a $355,636 penalty for drilling fluid discharges into waterways across eight counties.
The fracking boom triggered investment in projects to convert the fracked gas to plastic, leading to an oversupply in the global market. The industry made ambitious plans based on the price of plastic being $1/pound. Now, in 2020, the price is 40 – 60 cents per pound. If the Mariner East 2 pipeline is brought online, it likely will not be as profitable as its operators expected.
The poor finances of the oil and gas industry have led to the demise of several pipeline projects over the last few months. Phillips 66 announced in March it was deferring two pipelines — the Liberty Pipeline, which would transport crude oil from Wyoming to Oklahoma — and the Red Oak Pipeline system, planned to cross from Oklahoma to Texas. Kinder Morgan expressed uncertainty for its proposed Texas Permian Pass pipeline, and Enterprise Products Partners cancelled its Midland-to-ECHO crude oil pipeline project. The Atlantic Coast Pipeline also was cancelled this past July by Duke Energy and Dominion Energy, following “an unacceptable layer of uncertainty and anticipated delays,” and the Williams Constitution pipeline was also abandoned after years of challenges. In fact, the EIA recently reported that more pipeline capacity has been cancelled in 2020 than new capacity brought in service.
Will the Mariner East 2 be the next to fall?
Before you go
A note from the Safety 7: The Safety 7 are seven residents of Delaware and Chester Counties who are challenging Sunoco before the [Pennsylvania Public Utility Commission]. If you are outraged at the ongoing threat to our communities from this dangerous, destructive pipeline, please consider donating to the Safety 7 Legal fund … Our next hearing begins September 29, and funds from your support are urgently needed. This motion is representative of the kind of legal work we need, if we are to prevail in protecting our communities from this dangerous pipeline project. Please contribute today if you are able, and please share this appeal widely and let your friends and family know why this case matters to you!
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/09/ME2FeatureImage.jpg8331875Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2020-09-17 11:20:062020-09-28 15:22:31Mariner East 2 Causes Dozens of Spills Since Lockdown Began, Over 300 in Total
As unconventional oil and natural gas extraction operations have expanded throughout the United States over the past decade, the harmful health and environmental effects of fracking have become increasingly apparent and are supported by a steadily growing number of scientific studies and reports. Although some uncertainties remain around the exact exposure pathways, it is clear that issues associated with fracking negatively impact public health and the surrounding environment.
Holding oil and gas companies accountable for the environmental health effects of unconventional oil and natural gas development (UOGD), or “fracking,” has been challenging in the US because current regulations do not require drilling operators to disclose exactly what chemicals are used. However, many of the chemicals used for fracking have been identified and come with serious health consequences. The primary known compounds of concern include BTEX chemicals (benzene, toluene, ethylbenzene, and xylene) and associated pollutants such as tropospheric ozone and hydrogen sulfide. BTEX chemicals are known to cause cancer in humans, and can lead to other serious health problems including damage to the nervous, respiratory, and immune system. While some of these BTEX chemicals can occur naturally in groundwater sources, spills and transport of these chemicals used during fracking can be a major source of groundwater contamination.
Exposure to pollution caused from fracking activity can lead to many negative short-term and long-lasting health effects. Reported health effects from short-term exposures to these pollutants include headaches, coughing, nausea, nose bleeds, skin and eye irritation, dizziness, and shortness of breath. Recent studies have also found an association between pregnant women living in close proximity to fracking sites and low-birth weights and heart defects. Additionally, a recent study conducted in the rural area of Eagle Ford, Texas found that pregnant women living within five kilometers (or about three miles) of fracking operations that regularly engaged in “flaring,” or the burning of excess natural gas, were 50% more likely to have a preterm birth than those without exposure.
Figure 1. Summary of known health impacts associated with unconventional oil and natural gas development (UOGD).
Exposure to radioactive materials is also a serious concern. During the fracking process as high-pressured water and chemicals fracture the rock formations, naturally occurring radioactive elements like radium are also drawn out of the rocks in addition to oil and natural gas. As the oil and natural gas are extracted from the ground, the radioactive material primarily comes back as a component of brine, a byproduct of the extraction process. The brine is then hauled to treatment plants or injection wells, where it’s disposed of by being shot back into the ground. Exposure to radioactivity can lead to adverse health effects such as nausea, headaches, skin irritation, fatigue, and cancer.
With fracking also comes construction, excessive truck traffic, noise, and light pollution. This has led to a rise in mental health effects including stress, anxiety, and depression, as well as sleep disruptions.
A 2020 report published by Pennsylvania’s Attorney General contains numerous testimonials from those impacted by fracking, as well as grand jury findings on environmental crimes among shale gas operations.
Exposure to the hazardous materials used in fracking can occur through many pathways including breathing polluted air, drinking, bathing or cooking with contaminated water, or eating food grown in contaminated soil. Especially vulnerable populations to the harmful chemicals used in fracking include young children, pregnant women, the elderly, and those with preexisting health conditions.
Considerations Around Scientific Certainty
While it is clear that fracking adversely impacts our health, there is still some uncertainty surrounding the exact exposure pathways and the extent that fracking can be associated with certain health effects. A compendium published in 2019 reviewed over 1,500 scientific studies and reports about the risks of fracking, and revealed that 90% found evidence of harm. Although there have been various reports of suspected pediatric cancer clusters in heavily fracked regions, there are minimal longitudinal scientific studies about the correlation between fracking and cancer. The primary reason for this is because the time between the initial exposure to a cancer-causing substance and a cancer diagnosis can take decades. Because fracking in the Marcellus Shale region is a relatively new development, this is an area of research health scientists should focus on in the coming years. While we know that drilling operations use cancer-causing chemicals, more studies are needed to understand the public’s exposure to this pollution and the extent of excess morbidity connected to fracking.
Figure 2. FracTracker’s photo album of air and water quality concerns
Fracking has caused detrimental impacts on local air quality, especially for those living within 3-5 miles of UOGD operations. Diesel emissions from truck traffic and heavy machinery used in the preparation, drilling, and production of natural gas release large amounts of toxins and particulate matter (PM). These small particles can infiltrate deeply into the respiratory system, elevating the risk for asthma attacks and cardiopulmonary disease. Other toxins released during UOGD operations include hydrogen sulfide (H2S), a toxic gas that may be present in oil and gas formations. Hydrogen sulfide can cause extensive damage to the central nervous system. BTEX (benzene, toluene, ethylbenzene, and xylene) chemicals and other volatile organic compounds (VOCs) are also released during fracking operations, and have been known to cause leukemia; liver damage; eye, nose and throat irritation; and headaches. While oil and gas workers use personal protective equipment (PPE) to protect themselves from these harmful toxins, residents in surrounding communities are exposed to these hazardous conditions without protection.
Regional air quality concerns from UOGD include tropospheric ozone, or ‘smog’. VOCs and other chemicals emitted from fracking can react with sunlight to form smog. While ozone high in the atmosphere provides valuable protection from the sun’s harmful UV rays, ozone at ground level is hazardous for human health. Ozone may cause a range of respiratory effects like shortness of breath, reduced lung function, aggravated asthma and chronic respiratory disease symptoms.
Expanding beyond local and regional impacts, fracking and UOGD has global implications. With increasing emissions from truck traffic, construction, and high rates of methane leaks, fracking emissions will continue to worsen the climate change crisis. Methane is a potent greenhouse gas, with 86 times the global warming potential (GWP) of carbon dioxide (on a weight basis) over a 20 year period. Fracking wells can leak 40-60% more methane than conventional natural gas wells, and recent studies have indicated that emissions are significantly higher than previously thought.
Unhealthy air quality also presents occupational exposures to oil and gas workers through frac sand mining. Frac sand, or silica, is used to hold open the fractures in the rock formations so the oil and gas can be released during the drilling process. Silica dust is extremely small in diameter and can easily be inhaled, making its way to the lower respiratory tract. Silica is classified as a human lung carcinogen, and when inhaled may lead to shortness of breath, chest pain, respiratory failure, and lung cancer.
Many states allow this brine to be reused on roads for dust control and de-icing. Regulations vary from state to state, but many areas do not require any level of pretreatment before reuse.
Not only does fracking affect water quality, but it also depletes the quantity of available fresh water. Water use per fracking well has increased dramatically in recent years, with each well consuming over 14.3 million gallons of water on average. For more information about increasing fracking water use, clickhere.
In addition to air and water contamination, UOGD operations can also harm soil quality. Harmful chemicals including BTEX chemicals and heavy metals like mercury and lead have contaminated agricultural areas near fracking operations. Exposure can occur from eating produce grown on contaminated soil, or by consuming animals that consumed contaminated feed. These contaminants can also alter the pH and nutrient availability of the soil, resulting in decreased crop production and economic losses. Children are also at high risk of exposure to contaminated soil due to their frequent hand to mouth behavior. Lastly, the practice of frac sand mining can make land reclamation nearly impossible, leaving irreparable damage to the landscape.
Figure 3. Toledo Refining Company Refinery in Toledo, OH, July 2019. Ted Auch, FracTracker Alliance.
Report Your Environmental and Health Concerns
If you think that your health or environment have been negatively impacted by fracking operations, contact:
For an emergency requiring immediate local police, fire, or emergency medical services, always call 911 first
A Digital Atlas Exploring the Environmental Impacts of a Decade of Unconventional Natural Gas Extraction in the Loyalsock Creek Watershed
Fig. 1. Appalachia Midstream SVC LLC , Cherry Compressor Station in Cherry, Sullivan County, PA. (FLIR camera footage by Earthworks, July 2020)
An Introduction to the Loyalsock Creek Watershed
Nestled in Pennsylvania’s scenic Endless Mountains region, the Loyalsock Creek flows 64 miles from its headwaters in Wyoming County near the Sullivan County line, to a peaceful confluence with the West Branch Susquehanna River at Montoursville, east of Williamsport in Lycoming County. The lively, clear water drains 495 square miles, journeying through thick forests of the Allegheny Plateau over a landscape prized for rugged outdoor recreation, bucolic wooded respites, and quaint villages.
Local place names reflect the Munsee-Lenape, Susquehannock, and Iroquois peoples who called the area home at the time of early colonial settlement. The name Loyalsock stems from the native word Lawi-sahquick, meaning “middle creek.”
A favorite for angling, swimming, and whitewater paddling, the waterway supports a notorious resident – the aquatic eastern hellbender, the largest salamander in North America. In 2018, the Pennsylvania Department of Conservation and Natural Resources (DCNR) crowned the Loyalsock “River of the Year,” a program honoring the state’s premier rivers and streams and encouraging their stewardship.
Fig 2. Loyalsock Watershed Overview Map. (FracTracker Alliance, July 2020)
Click on the section title to jump to that section
A Wealth of Public Lands and Recreational Opportunity
Nearly one third of the Loyalsock watershed consists of state-owned public lands, including the 780-acre Worlds End State Park; 37,519 acres of state game lands; and, 65,939 acres of the Loyalsock State Forest. The State Forest encompasses two Natural Areas, Tamarack Run (201 acres) and Kettle Creek Gorge (774 acres), as well as a 1935-acre portion of Kettle Creek Wild Area.
Worlds End State Park was originally purchased by the state in 1929 in an attempt to allow the area to recover from clear-cutting. The land was significantly improved due to the work of the Civilian Conservation Corps in the 1930s. There is some uncertainty about the historical name of the region, and as a result, the park was renamed Whirl’s End in 1936, but reverted to Worlds End in 1943.
The area is a deep gorge cut by water rushing over millions of years through the Loyalsock Creek, over sedimentary formations known as the Sullivan Highlands. The gorge reaches 800 feet deep in some locations, where the fossilized remnants of 350-million-year-old lungfish burrows can be found.
Current amenities include 70 tent camping sites, 19 cabins, as well as group camping options accommodating up to 90 campers. A small swimming area on Loyalsock Creek is open in the summer months, and the Creek is also used for boating and fishing.
The Kettle Creek Gorge Natural Area follows the path of Falls Run, which as the name suggests, contains numerous majestic waterfalls, including Angel Falls, which drops around 70 feet. The Natural Area is buffered by the Kettle Creek Wild Area. Kettle Creek is a Class A Wild Trout stream, meaning that natural populations of trout are sufficient in quantity and size to support fishing activities.
Fig. 3. A view of Loyalsock Creek from the High Rock Trail in Worlds End State Park. (Brook Lenker, FracTracker Alliance, August 2019)
Fig. 4. Tubing on Loyalsock Creek. (Brook Lenker, FracTracker Alliance, August 2019)
Relaxing on the Water
The Loyalsock watershed contains 909 miles of streams, with more than 395 miles (43%) classified as high quality (358 miles) or exceptional value (37 miles). The watershed contains 10,573 acres of wetlands, including 4,844 acres of forested wetlands, 3,261 acres of riverine wetlands, 1,013 acres of freshwater ponds, 761 acres of lakes, and 694 acres of emergent wetlands.
Another popular recreation spot within the Loyalsock watershed is Rose Valley Lake, a 389-acre artificial reservoir managed by the Pennsylvania Fish and Boat Commission. The lake contains a variety of fish, including bigmouth bass, bluegill, and walleye. Boating is restricted to electric motors and unpowered craft, making the area an idyllic getaway.
There are 238 miles of trails in the watershed, accommodating a variety of uses, including hiking, biking, horseback riding, cross-country skiing, and snowmobiles. Some notable examples include:
over 90 miles of snowmobile trails in the Loyalsock State Forest and Worlds End State Park;
most of the 64-mile-long Loyalsock Trail, showcasing numerous waterfalls;
the Double Run Ski Trail, providing cross-country opportunities in the Loyalsock State Forest;
and the 19-mile Loyalsock State Forest Bridle Trail for equestrian pursuits.
The Loyalsock Watershed also contains the entirety of state Game Lands #134 and #298, as well as parts of six others, including Game Lands #12, #13, #36, #57, #66, and #133. Not only hunting locations, these tracts preserve habitat for importantbird and mammal species, provide opportunities forbirding, and offer a variety of outdooreducation resources.
There are also privately-owned recreational opportunities in the region. A portion of the historicEagles Mere Country Club has provided golf and other activities for over 100 years. Eagles Mere Lake, just south of the watershed boundary,provides recreation opportunities for members of the privately-held Eagles Mere Association. At the south of the lake is the regionally-famous Eagles MereTobaggan Slide, where riders race down a specialized track at speeds up to 45 miles per hour, when winters are cold enough for sufficient ice conditions – a fleeting situation due to climate change.
A few miles to the east of Eagles Mere lies a cluster of lakes that surround the borough of Laporte, in Sullivan County. The largest of these lakes is Lake Mokoma, administered by the Lake Mokoma Association. Participation in the Association is limited to those who own residences or vacation homes in Sullivan County.
Fig. 5. Hiking trail in the Loyalsock State Forest. (FracTracker Alliance, July, 2020)
Fig. 6. An interactive map of recreation opportunities in the Loyalsock Watershed. (FracTracker Alliance, July 2020)
Note: Wetland data presented are from the National Wetlands Inventory (NWI), which is a geographically comprehensive dataset compiled by the US Fish and Wildlife Service from aerial photographs, but not a complete or accurate depiction of regulated wetlands for site-specific purposes. A relatively newer wetland mapping dataset for Pennsylvania appears to identify more areas of potential wetlands than NWI. Nevertheless, the NWI and other available map sources generally underestimate actual wetland coverage in Pennsylvania. Accurate wetland mapping requires the application of technical criteria in the field to identify the site-specific vegetation, soil, and hydrology indicators that define regulated wetlands (25 Pa. Code 105.451).
Stream data presented are from the Pennsylvania DEP Designated Use listing (25 Pa. Code 93.9), which is based on the National Hydrography Dataset. Some streams have updated designations of their existing water uses as depicted on other DEP datasets. Available electronic datasets and topographic maps do not display all permanent or intermittent streams included as Regulated Waters of the Commonwealth (25 Pa. Code 105.1). It is possible to map additional streams with the help of existing photo-based digital elevation models, although use of that technique was beyond the scope of this informational project. Such streams would add significantly to the total mileage, but they have not yet been acknowledged by the Pennsylvania DEP, and therefore are not included in the DEP’s inventories of high quality, exceptional value, or other streams.
The datasets used in this map collection can be found by following the links in the Details section of each map, found near the top-left corner of the page.
Fracking comes to the Loyalsock
Figures 7-9. Aerial imagery of unconventional oil and gas infrastructure in the Loyalsock State Forest. (Ted Auch, FracTracker Alliance, with aerial assistance from Lighthawk. June, 2020)
On November 17, 2009, Inflection Energy began drilling the Ultimate Warrior I well in Upper Fairfield Township, Lycoming County. In quick succession came Pennsylvania General Energy, Chesapeake Appalachia, Chief Oil & Gas, Anadarko E&P, Alta Resources (ARD), and Southwestern Production (SWN), all of which drilled a well by the end of 2010. It was a veritable invasion on the watershed, one that ushered in a dramatic change from a mostly agrarian landscape, to one with heavy industrial presence.
Residents have to deal with constant construction of well pads, pipelines, compressor stations, and staging grounds. Since each drilled well requires thousands of truck trips, enormous traffic jams are common, with each idling engine spewing diesel exhaust into the once clean air. The noise of drilling and fracking continues into the night, and bright flaring of gasses at wells and other facilities disrupts sleep schedules, and may contribute to serious health issues as well.
Fig. 10. An interactive map of the impacts of the unconventional oil and gas industry to the Loyalsock Creek Watershed. Note: Pipelines may be only partially depicted due to data limitations. (FracTracker Alliance, 2020)
Fracking is a nuisance and a risk in the best of times, but the Marcellus boom in the Loyalsock watershed has been notably problematic. The most frequent violations in the watershed are casing and cementing infractions, for which the “operator conducted casing and cementing activities that failed to prevent migration of gas or other fluids into sources of fresh groundwater.” This particular violation has been reported 47 times in the watershed, although there are dozens of additional casing and cementing issues that are similarly worded (see appendix). Erosion and sediment violations have also been commonplace, and these can have significant impacts on stream system health.
Improperly contained waste pits have leached toxic waste into the ground. A truck with drilling mud containing 103,000 milligrams per liter of chlorides – about five times more than ocean water – was driving down the road with an open valve, spewing fluids over a wide area. Some spills sent plumes of pollution directly into streams.
Fig. 11. Diesel truck traffic carrying fracking equipment in the Loyalsock watershed. (FracTracker Alliance, June, 2020)
Fig. 12. Diesel exhaust spewing from fracking equipment. (Barb Jarmoska)
Fig. 13. Fracking is a heavily industrial activity. Many of these sites in the Loyalsock Creek watershed are immediately adjacent to homes. (Barb Jarmoska)
Fig. 14. Open pits used to be permitted for temporary storage of oil and gas waste. Here, the liner is not properly covering the bottom-right corner, sludge is piled up past the liner in the top-right corner, and temporary fencing is failing in numerous locations. (Barb Jarmoska)
In short, it has been a mess. Altogether, there have been 631 violations issued for 317 unconventional wells drilled in the Loyalsock, an average of two violations per well.
The Pennsylvania Department of Environmental Protection (DEP) issues violations on pipelines as well, but we are unable to match pipeline violations to a specific location, so there is no way to know which ones occurred in the Loyalsock watershed.
We also know that pipeline construction is a process filled with mishaps. Specifically, there is a technique for drilling a pipeline segment underneath existing obstacles – such as streams and roads – known as horizontal directional drilling (HDD). These HDD sites frequently bleed large quantities of drilling mud into the ground or surface water. When these leaks surface, these spills are known euphemistically as “inadvertent returns.” Sometimes, the same phenomenon occurs but the fluid drains instead to an underground cavity, referred to as “loss of circulation.” We do not have data on either category for pipelines in the Loyalsock watershed. However, the DEP has published inadvertent returns for the Mariner East II route to the south, and when combining spills impacting the water and ground, these occur at a rate of about two spills for every three miles of installed pipe. Many of these releases are measured in thousands of gallons.
Unfortunately, drilling and all related activity continue in the Loyalsock Creek watershed. As the industry has proven incapable of conducting these activities in an unsullied manner that is protective of the environment and the health of nearby residents, we can expect the litany of errors to continue to grow.
A Brief Timeline of Infractions
In 2016, a major incident was reported to the Pipeline and Hazardous Materials Safety Administration (PHMSA), a federal agency under the Department of Transportation (DOT). On October 21, a Sunoco pipeline ruptured, spilling 55,000 gallons of gasoline into Wallis Run, a tributary of Loyalsock Creek. The eight-inch pipeline burst when high winds and heavy floods triggered mudslides, sweeping away at least two homes and leaving flooded roads impassable. Water suppliers and national and state agencies advised locals to conserve water, and the DEP and water supplier American Water shut down intake valves until they had measured contamination levels in three water supplies serving thousands of people downstream, including populations in Lewisburg, Milton, and Gamble Township.
Limited access to the area delayed identifying the source of the rupture, though Sunoco shut off the pipeline that runs from Reading to Buffalo, NY. When waters receded, Sunoco officials replaced the broken pipe, which they said was broken by debris from a washed out bridge ten feet upstream. The pipeline was buried five feet below the creek, but heavy rains exposed it.
Agency authorities later found that heavy rains had flushed out much of the pollution, though they recorded the highest levels in the Loyalsock Creek. While this is obviously a weather-related event, local residents questioned the placement of a hazardous liquids pipeline crossing at such a volatile location, noting that the same pipeline had been exposed, (although not breached), just five years earlier.
Sunoco tops the list of U.S. crude oil spills. Sunoco and their subsidiaries reported 527 hazardous liquids pipeline incidents between 2002 and 2017, incidents that released over 87,000 barrels of hazardous liquids, according to Greenpeace USA and Waterkeeper Alliances’ 2018 report on Energy Transfer Partners (ETP) & Sunoco’s History of Pipeline Spills. Sunoco and its subsidiary ETP are developing the Dakota Access Pipeline, the Mariner East pipeline, and the Permian Express pipeline, sites that have already seen construction errors causing leaks and spills.
The area suffered another heavy spill in 2017, when a well operated by Colorado-based Inflection Energy leaked over 63,000 gallons of natural gas drilling waste into a Loyalsock Creek tributary. The spill occurred when waste was being transferred from one container to another, a neglect of the contracted worker who had fallen asleep. DEP spokesman Neil Shader said the waste – called “flowback” – was filtered and treated, but this brine can contain chemicals, metals, salts, and other inorganic materials that can pollute soil and groundwater. Carol Parenzan, at the time serving as Middle Susquehanna’s Riverkeeper, said many residents are supplied by well water, and were not alerted of the spill until a local began investigating and calling local and state authorities.
Fig. 16. At the Chesapeake Appalachia LLC Manning Well Site and Lambert Farms Well Site, the emissions sources appear to be engines or combustion devices. (FLIR camera footage by Earthworks, July 2020)
One of Earthworks’ trained and certified thermographers visited the Loyalsock watershed and surrounding area in mid-July with a FLIR optical gas imaging (OGI) camera. This industry standard tool can make visible pollutants that are typically invisible to the human eye, but that still pose significant risks to health and the environment–including 20 volatile organic compounds, such as the carcinogens benzene and toluene, and methane, a greenhouse gas 86 times more potent than carbon dioxide.
Water is the lifeblood of the Loyalsock watershed, as it is in any basin. However, in the Loyalsock, water is of particular importance. As we have seen, recreation opportunities in the area are defined by water, including fantastic fishing streams and lakes, meandering trails passing many waterfalls, various boating sites, and inviting swimming holes. For one reason or others, most visitors come to the Loyalsock to enjoy these natural aquatic locations.
Perhaps the most important water assets are underground aquifers. The majority of the watershed is rural, and private wells for potable household water are typical. Even the municipal water supply for the Borough of Montoursville is fed by groundwater, including five wells and an artesian spring.
For a region so dependent on surface water for tourism, commercial activities, and groundwater for drinking supplies, the arrival of fracking is a significant concern. Unfortunately, spills and other violations are common at well pads and related infrastructure, with over 631 violations in the watershed since 2010.
Even pipelines that are not yet operational can have impacts on the waterways in the Loyalsock Creek watershed. In September 2012, for example, a “significant amount” of sediment and mud spilled into the Loyalsock Creek during the construction of Central New York Oil and Gas’ Marc I pipeline project. Such incidents introduce silt and clay into waterways, fine sediments that have the potential to deplete aquatic fauna. These types of episodes have received considerably more attention since this event, and it turns out that they are quite common during pipeline construction. For example, the Mariner East pipeline has had hundreds of these so-called inadvertent returns, many of which directly affected the waters of the Commonwealth.
Fig. 17.Trucks withdrawing water for drilling-related activities at the Forksville Heritage Freshwater Station, operated by Chief Oil & Gas. Photo from FracTracker mobile app report.
Fig. 18.The average amount of water used per well in the Loyalsock Watershed has increased over time. In recent years, several wells exceeded 30 million gallons (FracTracker Alliance, 2020).
In addition to contamination concerns, unconventional oil and gas wells are extremely thirsty operations. FracTracker has analyzed wells in the watershed using the industry’s chemical registry site FracFocus. Of the 274 wells in the watershed reporting to FracFocus between January 2011 and April 2020, 38 did not include a value for total water usage. These wells were all fracked on or before September 13, 2012, when the registry was still in its early phase and its use was not well standardized. Two wells fracked in 2018 by Pennsylvania General Energy had very low water consumption figures, with one reporting 2,100 gallons, and the other reporting 6,636 gallons. These two reports appear to be erroneous, and so these wells were removed from our analysis.
Of the remaining 234 wells in the data repository, one reported using less than one million gallons, although it came close, with 925,606 gallons. Another 63 wells used between one and five million gallons, 137 wells used between five and ten million gallons, 25 wells used between ten and 20 million gallons, and eight used more than 20 million gallons. The average consumption was 7,739,542 gallons, while the maximum value was for Alta Resources’ Alden Evans A 2H well, which used 34,024,513 gallons of water.
The well’s operator has a tremendous impact on the total amount of water usage reported on FracFocus in the Loyalsock watershed.
However, it is worth noting that time factors into this analysis. None of the three companies averaging less than five million gallons of water per well – including Anadarko, Atlas, and Southwestern – have records after 2014, and water consumption has increased dramatically since then. Still, Alta’s average of nearly 24.7 million gallons per well stands out, with more than twice the amount of water consumed per well, compared to the next highest user.
Altogether, the wells on the FracFocus registry in the Loyalsock watershed consumed over 1.8 billion gallons of water, enough water to supply nearly 36,000 households for a year, assuming an average of 138 gallons per household, per day. This is a real need in the United States, as a 2019 report by DigDeep and US Water Alliance estimated that there were two million people in the U.S. without running water in their homes.
Average Gallons per Well
Anadarko Petroleum Corporation
Atlas Energy, L.P.
Chesapeake Operating, Inc.
Chief Oil & Gas
Inflection Energy (PA) LLC
Pennsylvania General Energy
Seneca Resources Corporation
Fig. 19.Total amount of water usage reported by oil and gas operators in the Loyalsock watershed. (FracFocus, 2020)
Fig. 20. An interactive map of oil and gas related water sites in the Loyalsock Creek Watershed. (FracTracker Alliance, 2020)
Between January 2011 and April 2020, two conventional wells and 297 unconventional wells combined to produce 7,017,102 barrels (294.7 million gallons) of liquid waste, and 340,856 tons (681.7 million pounds) of solid waste.
Fig. 21. Liquid oil and gas waste produced in the Loyalsock Creek watershed, in barrels. Note that 2020 includes data from January to April only. (FracTracker Alliance, July 2020)
Fig. 22. Solid oil and gas waste produced in the Loyalsock Creek watershed, in tons. Note that 2020 includes data from January to April only. (FracTracker Alliance, July, 2020)
This averages out to 23,469 barrels (985,680 gallons) and 1,140 tons (2,279,973 pounds) per well drilled in the basin, and most of these wells are active and continue to produce waste. Many of these wells have generated waste quantities in great excess of these averages.
Unlike gas production, which tends to drop off precipitously after the first year, liquid waste production remains at an elevated level for years. For example, the Brooks Family A-201H well, the well reporting the largest quantity of liquid waste in the basin, produced 1,499 barrels in 2017, 28,847 barrels in 2018, 35,143 barrels in 2019, and 23,829 barrels in the first four months of 2020. The volumes from this well increase substantially each year.
For all wells in the watershed reporting liquid waste between 2018 and 2019, waste totals decreased by almost 42%. While a significant decrease, these 237 wells still generated 829,267 barrels (34.8 million gallons) of waste in 2019, and some have been generating waste since at least 2011. Wells will continue to produce waste until they are permanently plugged, but unfortunately, there are plans for more drilling in the watershed. There are 17 active status wells that have been permitted and not yet drilled. Important to remember is that fracking waste is often radioactive, and laden with salt, chemicals, and other contaminants, making it a hazardous product to transport, treat, or dispose.
Fig. 23. Cumulative liquid waste totals produced by oil and gas wells in Loyalsock Creek watershed between January 2011 and April 2020. (FracTracker Alliance, July, 2020)
Fig. 24. An interactive map of oil and gas waste generated in the Loyalsock Creek Watershed between January 2011 and May 2020. (FracTracker Alliance, July, 2020)
On a sunny Friday in June 2020, a group of 18 FracTracker staff members and volunteers gathered in the Loyalsock watershed to document activities and infrastructure related to unconventional oil and gas activities. FracTracker’s Matt Kelso used a variety of data from the DEP to prepare maps depicting an array of infrastructure, including 317 drilled wells on 110 different pads, five compressor stations, a compressed natural gas truck terminal, and 24 water facilities related to oil and gas extraction – including five surface water withdrawal sites and 19 storage reservoirs. He then divided an area of about 496 square miles into five sections, and at least two participants were assigned to explore each section.
Using the FracTracker mobile app, cameras, and other documentation tools, the group was able to verify the location of 91 infrastructure sites, including well pads, compressor stations, pipelines, water withdrawal sites and reservoirs, as well as significant truck traffic. As they made their way over the rural back roads, many participants were struck by the juxtaposition of a breathtaking landscape and peaceful farmlands with imposing, polluting fracking sites.
The day was also documented by Rachel McDevitt from StateImpact Pennsylvania, a reporting project of NPR member stations, as well as the filmmakers Justin Grubb, Alex Goatz, and Michael Clark from Running Wild Media.
With the geolocated photos and site descriptions documented on this day, FracTracker was able to compile this story atlas to serve as an educational tool for concerned residents of the Loyalsock.
You can find these reports and many more by downloading the FracTracker app on your iOS or Android device, or by going to the web app at https://app.fractracker.org/.
Fig. 25. FracTracker’s Executive Director Brook Lenker addresses the gathering of volunteers, media members, and FracTracker staff at Canfield Island Heritage Trail Park on documentation day. (FracTracker Alliance, June, 2020)
Fig. 26 FracTracker’s Matt Kelso explains the maps he made of different sections in the Loyalsock Watershed. (FracTracker Alliance, June, 2020)
Fig. 27 Running Wild Media’s filmmaker captures the introduction to the documentation day by FracTracker staff. These filmmakers tagged along for additions to a film about the eastern hellbender, to be released in spring 2021. (FracTracker Alliance, June, 2020)
Fig. 28. A compressor station is seen across a field of wildflowers, somewhere in the Loyalsock Watershed. (FracTracker Alliance, June, 2020)
Fig. 29. Volunteers stand outside gated infrastructure in the watershed on the documentation field day. (FracTracker Alliance, June, 2020)
Fig. 30. A pipeline path cutting through forest in the Loyalsock watershed. (FracTracker Alliance, June, 2020)
Fig. 31. Grass has grown to cover a pipeline path traversing a hillside in the Loyalsock. (FracTracker Alliance, June, 2020)
Barb Jarmoska is a lifelong environmental and social justice activist with property adjacent to the Loyalsock State Forest that has been in her family for five generations. She has witnessed a dramatic and devastating transformation of the pristine area surrounding her home as the fracking industry moved into what they consider the Marcellus Sacrifice Zone.
This is Barb’s account, in her own words:
“For me, the door to the woods is the door to the temple,” wrote poet Mary Oliver. I understand those words, they are part of my lifetime of lived experience in the Loyalsock watershed.
I am a retired special-ed teacher and a business owner – a mother and a grandmother – and someone who treasures and reveres the rapidly dwindling wild places in Penns Woods.
Where my front yard ends, the Loyalsock State Forest (LSF) begins. Access to my property is via a no-outlet gravel road that dead-ends in the Forest.
In 1933, my grandfather bought 20 acres with an old cabin and barn bordering what is now the LSF.
As a child, I didn’t miss indoor plumbing or air conditioning in that cabin beside the Loyalsock Creek where we spent our summers. I now live on the land year-round, in a home I built in 2007, before I had ever heard the words Marcellus Shale. I have indoor plumbing now, but still no desire for air conditioning, preferring to rely on open windows and big shade trees.
The memories my family has made on this land are priceless, and my grandchildren are the fifth generation to run in the meadow, swim and fish in the creek, climb the trees, and play in the nearby woods of the PA Wilds. In our increasingly transient society, roots this deep are precious and rare.
My appalled, angry, and admittedly frightened response to the gas industry invasion of the Loyalsock watershed began in 2010, when a parade of trucks spewing diesel fumes rumbled up the no-outlet road I live on, enroute to leased COP tracts in the LSF.
That dirt trail that we loved to hike was the first thing to go. Dump trucks carrying fist-sized gravel and heavy equipment transformed the forest trail into a road – gated off and posted with trespass warnings carrying severe penalties. In my neighborhood, as in so many places in the watershed, land that legally belongs to the citizens now carries grim warnings of the consequences of trespassing.
When the drilling and fracking equipment passed my driveway, the ground shook. Oftentimes, I had to wait 15 or 20 minutes just to leave – or come home. There was a flag car pretty much permanently blocking my driveway for a while. I also walked out for the mail one day and found a porta-potty had been set up on my land. No one thought to ask permission. They just put it on my property – a few yards from my mailbox.
Life in my Loyalsock watershed neighborhood has forever changed at the hands of industry permitted to remove millions of gallons of water for fracking from the Loyalsock – the beautiful Creek that carries the designation “Exceptional Value”. Named PA’s River of the Year in 2018, the Loyalsock Creek begins in the endless mountain region of the PA Wilds, and travels 64 miles on its way to the West Branch of the Susquehanna River.
The beloved Loyalsock Creek provides recreation for hundreds of fishermen, kayakers, inner-tubers, swimmers, and summer cabin dwellers – offering clear water that to this day supports abundant fish, amphibians, birds, and wildlife – clear water the gas industry now pumps out by the millions of gallons, to be mixed with toxic chemicals and forced at great pressure through boreholes a mile deep and miles long, to release methane trapped in the Marcellus Shale.
In 2018, about two miles from my home, an estimated 55,000 gallons of “produced water” spilled from a well pad ironically named TLC. This toxic fluid ran downhill into a tributary and directly into the Loyalsock Creek. On its approximately two-mile path, the chemicals flooded a little tributary that runs through a rural neighborhood where children play in the water. Frightened residents gathered to question DEP about the safety of their private drinking water wells, and they expressed concern over the tadpoles and frogs, and in the deeper, shady pools – native trout they were used to seeing.
Pennsylvania lawmakers could obey the Constitution, protect the watershed, and choose a way forward that leads to a future of renewable energy and well-paying green jobs for Pennsylvania citizens, as well as the promise of a brighter future for our children and grandchildren.
Time is running out.
I look at my grandchildren and believe that such a shift of consciousness and political will is truly their last, great hope.
Keep It Wild
-By Barb Jarmoska
What Does the Future Hold?
On its own, climate change brings with it a wave of new and/or intensified challenges to PA’s state forests, parks, and natural areas. Flooding and erosion, insect-borne illnesses, invasive species, and changes to plant and animal life are ongoing issues the state’s natural resource managers have to consider as the climate changes. These interactive stressors will continue to disrupt ecosystem function, processes, and services; result in the loss of biodiversity and shifts in forest compositions; and negatively impact industries and communities reliant on Penns Woods.
Over the past 110 years, PA’s average temperature has increased nearly two degrees Fahrenheit, and the Commonwealth has also seen a gradual uptick in annual precipitation, but a decline in and shorter span of snow cover. As ranges shift, the state will see the distribution and abundance of native plants and animals change, a pattern that will continue to accelerate.
Penns Woods are home to over 100 species of trees. Oak/hickory forests contain primarily oaks, maples, and hickories, with an understory of rhododendrons and blueberry bushes. Northern hardwood forests are composed of black cherry, maples, American beech, and birch, with understories of ferns, striped maple and beech brush. But the composition of PA’s forests are changing. Smithsonian’s Conservation Biology Institute compared colonial-era data to recent U.S. Forest Service data, and found that maples have increased by as much as 20%, but beeches, oaks and chestnuts – important foliage for wildlife – have declined. The presence of pine trees has been more volatile, seeing increases in some areas, and decreases in others.
Overall, PA’s forests are becoming more unsustainable, conditions compounded by misaligned harvesting, suburban sprawl, insect infestations, and disease. These impacts trickle down to the wildlife that call Penns Woods home. PA’s Natural Heritage Program has begun to compile this Environmental Review List, to identify threatened and endangered species, species of special concern, and rare and significant ecological features.
One of the most notable among these is North America’s largest salamander, the eastern hellbender, designated PA’s official amphibian in April 2019. This salamander is a great indicator of clean and well-oxygenated water, as it requires fast-flowing, freshwater habitat with large rock deposits to thrive. Originally dispersed across the Appalachians from Georgia to New York, the eastern hellbender’s population has suffered greatly from the impacts of pollution, erosion and sedimentation, dams, and amphibious fungal disease.
These salamanders can reach lengths up to two feet, and live for as long as 50 years, so their presence is a key indicator of long-term stream and riparian health. Western Pennsylvania Conservancy has monitored their habitats throughout PA since 2007. Though named the state’s official amphibian, this title does not incorporate its special protection.
Fig. 33. An aerial view of the Loyalsock Creek. (Ted Auch, FracTracker Alliance, June 2020)
In its recent Loyalsock State Forest Resource Management Plan (SFRMP), PA DCNR states that “Natural gas development…especially at the scale seen in the modern shale-gas era, can affect a variety of forest resources, uses, and values, such as:
• recreational opportunities,
• the forest’s wild character and scenic beauty, and
• plant and wildlife habitat.”
Despite extensive areas marred by well pads and other fracking infrastructure, the Loyalsock watershed retains resplendent beauty and pastoral character. Natural resources have endured spills, leaks, habitat fragmentation, deforestation, and increases in impervious buildout related to the gas industry. While a global pandemic and cascading company debts have diminished extraction activities, the region remains vulnerable to future attempts to drill more — on both private and public lands.
Indicative of the omnipresent threats, Pennsylvania General Energy Company, LLC (PGE) intends to develop a substantial pipeline corridor across the Loyalsock Valley. According to PA DEP public records, the project includes the construction of the Shawnee Pipeline, with over 15,000 linear feetof an existing eight-inch diametergas pipeline to be replaced with a 16-inch pipeline. It will be supplemented by the Shawnee Pipeline Phase 2, encompassing an additional 189 linear feet of gas pipeline.
Arranged to accompany the pipelines is a temporary waterline to extend from planned pump stations on both sides of the Loyalsock Creek, to a proposed impoundment site within Loyalsock State Forest.
The company envisions cofferdams and trenches to cross the Loyalsock Creek. Other streams and wetlands will also be traversed, further degrading and endangering these vulnerable resources. Visible scarring from the pipeline cut is a major concern adding to the diminishment of the valley’s lush, green slopes. Methods exist to minimize the visibility of such development, but no one knows if PGE will follow those practices, or if regulators will require this of them. Some believe the project portends more fracking — with ceaseless demands for more water, and endless production of noxious waste and climate-killing emissions.
Only a few miles northeast of the watershed, New Fortress Energy is constructing a 260-acre complex near Wyalusing, Pennsylvania, to convert fracked gas into liquified natural gas, or LNG. The LNG will be dangerously transported by truck and rail to a planned export facility in Gibbstown, New Jersey, to send these private exploits overseas. A local group, Protect Northern PA, has formed to encourage a more sustainable path forward for the area, one that values people and the planet. The New Fortress Energy plant, if completed, would create inertia for extended extraction across the Marcellus Shale.
But hope abides in the Loyalsock. Hikers flock to enchanted trails, revelers rejoice on graveled shores. The place exudes an invisible elixir called stewardship, rippling through the air, nourishing receptive hearts and minds. Brandished for free, it shares this necessary ethos, seeking more followers.
Thank you to all of the inspiring and steadfast environmental stewards who have contributed to the creation of this digital atlas:
Dick Martin from PAForestCoalition.org;
Barb Jarmoska, Harvey M. Katz, and Ralph Kisberg from Responsible Drilling Alliance;
Ann Pinca from Lebanon Pipeline Awareness;
Paul V. Otruba and Victor Otruba from Environeers;
Justin Grubb, Alex Goatz, and Michael Clark from Running Wild Media;
and Rachel McDevitt from StateImpact
Leann Leiter from Earthworks
Staff at FracTracker Alliance
Project funding provided by The Foundation for Pennsylvania Watersheds
As a spring 2020 intern with FracTracker, my work mostly involved mapping gathering lines in West Virginia and Ohio. Gathering lines are pipelines that transport oil and gas from the wellhead to either compressor stations or storage/processing facilities. The transmission pipelines (which are often larger in diameter than gathering lines) take the oil and gas from the processing facilities to other storage facilities/compressor stations, or to distribution pipelines which go to end users and consumers. As you can see from Figure 2 in the map of Doddridge County, WV, many gathering lines eventually converge at a compressor station. You can think of gathering lines like small brooks and streams that feed transmission pipelines. The transmission lines are the main arteries, like a river, moving larger quantities of gas and oil over longer distances.
The main project and goal of my internship was to record as many gathering pipelines as I could find in Ohio and West Virginia, since gathering lines are not generally mapped and therefore not easily available for the public to view. For example, the National Pipeline Mapping System’s public map viewer (created by the Department of Transportation Pipeline and Hazardous Materials Safety Administration) has a note stating, “It does not contain gas gathering or distribution pipelines.” Mapping gathering lines makes this data accessible to the public and will allow us to see the bigger picture when it comes to assessing the environmental impact of pipelines.
After collecting gathering line location data, I performed GIS analysis to determine the amount of acreage of land that has been clearcut due to gathering pipeline installations.
Another analysis we could perform using this data is to count the total number of waterways that the gathering lines cross/interact with and assess the quality of water and wildlife in areas with higher concentrations of gathering pipelines.
Figure 1. This map shows an overview of gathering line pipelines in the Powhatan Point, Ohio and Moundsville, West Virginia of the Ohio River Valley.
PIPELINE GATHERING LINE MAPPING PROCESS
I worked with an aerial imagery BaseMap layer (a BaseMap is the bottommost layer when viewing a map), a county boundaries layer, production well location points, and compressor station location points. I then traced lines on the earth that appeared to be gathering lines by creating polygon shapefiles in the GIS application ArcMap.
My methodology and process of finding the actual routes of the gathering lines included examining locations at various map scale ranges to find emerging line patterns of barren land that connect different production well points on the map. I would either concentrate on looking for patterns along well pad location points and look for paths that may connect those points, or I would begin at the nearest gathering line I had recorded to try to find off-shoot paths off of those pipelines that may connect to a well pad, compressor station or previously recorded gathering line.
I did run into a few problems during my search for gathering lines. Sometimes, I would begin to trace a gathering line path, only to either loose the path entirely, or on further inspection, find that it was a power line path. Other times when using the aerial imagery basemap, the gathering line would flow into an aerial photo from a year prior to the pipeline installation and I would again lose the path. To work around these issues, I would first follow the gathering line trail to its end point before I started tracing the path. I would also view the path very closely in various scale ranges to ensure I wasn’t tracing a road, waterway, or powerline pathway.
In the three months that I was working on recording gathering pipeline paths in Ohio and West Virginia, I found approximately 29,103 acres (3,494 miles) of barren land clearcut by gathering pipelines. These total amounts are not exact since not all gathering lines can be confirmed. There are still more gathering lines to be recorded in both Ohio and West Virginia, but these figures give the reader an idea of the land disturbance caused by gathering lines, as shown in Figures 1 and 2.
In Ohio, I recorded approximately 10,083 acres (641 miles) with the average individual gathering pipeline taking up about 45 acres of land. With my gathering line data and data previously recorded by FracTracker, I found that there are 28,490 acres (1,690 miles) of land spanning 9 counties in southeastern Ohio that have been cleared and used by gathering lines.
For West Virginia, I was able to record approximately 19,020 acres (1,547 miles) of gathering lines, with the average gathering line taking up about 48 acres of space each. With previous data recorded in West Virginia by FracTracker, the total we have so far for the state is 22,897 acres (1,804 miles), although that is only accounting for the 9 counties in northern West Virginia that are recorded.
Figure 2. This aerial view map shows connecting gathering line pipelines that cover a small portion of Doddridge County, WV.
I was shocked to see how many gathering lines there are in these rural areas. Not only are they very prevalent in these less populated communities, but it was surprising to see how concentrated and close together they tend to be. When most people think of pipelines, they think of the big transmission pipeline paths that cross multiple states and are unaware of how much land that the infrastructure of these gathering pipelines also take up.
It was also very eye-opening to find that there are at least 29,000 acres of land in Ohio and West Virginia that were clearcut for the installation of gathering lines. It is even more shocking that these gathering pipelines are not being recorded or mapped and that this data is not publicly available from the National Pipeline Mapping System. While driving through these areas you may only see one or two pipelines briefly from your car, but by viewing the land from a bird’s eye perspective, you get a sense of the scale of this massive network. While the transmission pipeline arteries tend to be bigger, the veins of gathering lines displace a large amount of land as well.
I was also surprised by the sheer number of gathering lines I found that crossed waterways, rivers, and streams. During this project, it wasn’t unusual at all to follow a gathering line path that would cross water multiple times. In the future, I would be interested to look at the number of times these gathering pipelines cross paths with a stream or river, and the impact that this has on water quality and surrounding environment. I hope to continue to record gathering lines in Ohio and West Virginia, as well as Pennsylvania, so that we may learn more about this infrastructure and the impact it may have on the environment.
I first heard of FracTracker three years ago when I was volunteering with an environmental group called Keep Wayne Wild in Ohio. Since learning about FracTracker, I have been impressed with their eye-opening projects and their ability to make the gas and oil industry more transparent. A few years after first hearing about FracTracker, and as my interest in the GIS field continued to grow, I began taking GIS classes and reached out to them for this internship opportunity.
By Trevor Oatts, FracTracker Spring 2020 Data & GIS Intern
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/07/Mapping-gathering-lines-in-OH-and-WV-feature.jpg8331875Intern FracTrackerhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgIntern FracTracker2020-07-02 12:09:192020-08-24 14:49:34Mapping Gathering Lines in Ohio and West Virginia
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.
Fracking Energy Return on Investment 2012 – 2020
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).
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.
The North Dakota Shale Viewer
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.
Water Demand Rises for Fracking
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.
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).
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!
Figure 2. Average Freshwater Demand Per Well and Cumulative Freshwater Demand by North Dakota fracking industry from 2011 to Q1-2020.
Increasing Fracking Waste Production
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.
 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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/Oil-Gas-waste-tank-in-Michigan-feature.jpg8963125Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgTed Auch, PhD2020-06-18 10:24:572020-08-24 14:49:53The North Dakota Shale Viewer Reimagined: Mapping the Water and Waste Impact
Challenges have plagued Shell’s construction of the Falcon Pipeline System through Pennsylvania, Ohio, and West Virginia, according to documents from the Pennsylvania Department of Environmental Protection (DEP) and the Ohio Environmental Protection Agency (EPA).
Records show that at least 70 spills have occurred since construction began in early 2019, releasing over a quarter million gallons of drilling fluid. Yet the true number and volume of spills is uncertain due to inaccuracies in reporting by Shell and discrepancies in regulation by state agencies.
A drilling fluid spill from Falcon Pipeline construction near Moffett Mill Road in Beaver County, PA. Source: Pennsylvania DEP
Releases of drilling fluid during Falcon’s construction include inadvertent returns and losses of circulation – two technical words used to describe spills of drilling fluid that occur during pipeline construction.
Drilling fluid, which consists of water, bentonite clay, and chemical additives, is used when workers drill a borehole horizontally underground to pull a pipeline underneath a water body, road, or other sensitive location. This type of installation is called a HDD (horizontal directional drill), and is pictured in Figure 1.
Figure 1. An HDD operation – Thousands of gallons of drilling fluid are used in this process, creating the potential for spills. Click to expand. Source: Enbridge Pipeline
Here’s a breakdown of what these types of spills are and how often they’ve occurred during Falcon pipeline construction, as of March, 2020:
Loss of circulation
Definition: A loss of circulation occurs when there is a decrease in the volume of drilling fluid returning to the entry or exit point of a borehole. A loss can occur when drilling fluid is blocked and therefore prevented from leaving a borehole, or when fluid is lost underground.
Cause: Losses of circulation occur frequently during HDD construction and can be caused by misdirected drilling, underground voids, equipment blockages or failures, overburdened soils, and weathered bedrock.
Construction of the Falcon has caused at least 49 losses of circulation releasing at least 245,530 gallons of drilling fluid. Incidents include:
15 losses in Ohio – totaling 73,414 gallons
34 losses in Pennsylvania – totaling 172,116 gallons
Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
Cause: Inadvertent returns are also frequent during HDD construction and are caused by many of the same factors as losses of circulation.
Construction of the Falcon has caused at least 20 inadvertent returns, releasing at least 5,581 gallons of drilling fluid. These incidents include:
18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
2,639 gallons into water resources (streams and wetlands)
2 inadvertent returns Ohio – totaling 35 gallons
35 gallons into water resources (streams and wetlands)
However, according to the Ohio EPA, Shell is not required to submit reports for losses of circulation that are less than the definition of an inadvertent return, so many losses may not be captured in the list above. Additionally, documents reveal inconsistent volumes of drilling mud reported and discrepancies in the way releases are regulated by the Pennsylvania DEP and the Ohio EPA.
Very few of these incidents were published online for the public to see; FracTracker obtained information on them through a public records request. The map below shows the location of all known drilling fluid releases from that request, along with features relevant to the pipeline’s construction. Click here to view full screen, and add features to the map by checking the box next to them in the legend. For definitions and additional details, click on the information icon.
Our investigation into these incidents began early this year when we received an anonymous tip about a release of drilling fluids in the range of millions of gallons at the SCIO-06 HDD over Wolf Run Road in Jefferson County, Ohio. The source stated that the release could be contaminating drinking water for residents and livestock.
Working with Clean Air Council, Fair Shake Environmental Legal Services, and DeSmog Blog, we quickly discovered that this spill was just the beginning of the Falcon’s construction issues.
Documents from the Ohio EPA confirm that there were at least eight losses of circulation at this location between August 2019 and January 2020, including losses of unknown volume. The SCIO-06 HDD location is of particular concern because it crosses beneath two streams (Wolf Run and a stream connected to Wolf Run) and a wetland, is near groundwater wells, and runs over an inactive coal mine (Figure 2).
Figure 2. Losses of circulation that occurred at the SCIO-06 horizontal directional drill (HDD) site along the Falcon Pipeline in Jefferson County Ohio. Data Sources: OH EPA, AECOM
According to Shell’s survey, the coal mine (shown in Figure 2 in blue) is 290 feet below the HDD crossing. A hazardous scenario could arise if an HDD site interacts with mine voids, releasing drilling fluid into the void and creating a new mine void discharge.
A similar situation occurred in 2018, when EQT Corp. was fined $294,000 after the pipeline it was installing under a road in Forward Township, Pennsylvania hit an old mine, releasing four million gallons of mine drainage into the Monongahela River.
The Ohio EPA’s Division of Drinking and Ground Waters looked into the issues around this site and reported, “GIS analysis of the pipeline location in Jefferson Co. does not appear to risk any vulnerable ground water resources in the area, except local private water supply wells. However, the incident location is above a known abandoned (pre-1977) coal mine complex, mapped by ODNR.”
While we cannot confirm if there was a spill in the range of millions of gallons as the source claimed, the reported losses of circulation at the SCIO-06 site total over 60,000 gallons of drilling fluid. Additionally, on December 10th, 2019, the Ohio EPA asked AECOM (the engineering company contracted by Shell for this project) to estimate what the total fluid loss would be if workers were to continue drilling to complete the SCIO-06 crossing. AECOM reported that, in a “very conservative scenario based on the current level of fluid loss…Overall mud loss to the formation could exceed 3,000,000 gallons.”
Despite this possibility of a 3 million+ gallon spill, Shell resumed construction in January, 2020. The company experienced another loss of circulation of 4,583 gallons, reportedly caused by a change in formation. However, in correspondence with a resident, Shell stated that the volume lost was 3,200 gallons.
Whatever the amount, this January loss of circulation appears to have convinced Shell that an HDD crossing at this location was too difficult to complete, and in February 2020, Shell decided to change the type of crossing at the SCIO-06 site to a guided bore underneath Wolf Run Rd and open cut trench through the stream crossings (Figure 3).
Figure 3. The SCIO-06 HDD site, which may be changed from an HDD crossing to an open cut trench and conventional bore to cross Wolf Run Rd, Wolf Run stream (darker blue), an intermittent stream (light blue) and a wetland (teal). Click to expand.
An investigation by DeSmog Blog revealed that Shell applied for the route change under Nationwide Permit 12, a permit required for water crossings. While the Army Corps of Engineers authorized the route change on March 17th, one month later, a Montana federal court overseeing a case on the Keystone XL pipeline determined that the Nationwide Permit 12 did not meet standards set by federal environmental laws – a decision which may nullify the Falcon’s permit status. At this time, the ramifications of this decision on the Falcon remain unclear.
Inconsistencies in Reporting
In looking through Shell’s loss of circulation reports, we noted several discrepancies about the volume of drilling fluid released for different spills, including those that occurred at the SCIO-06 site. As one example, the Ohio EPA stated an email about the SCIO-06 HDD, “The reported loss of fluid from August 1, 2019 to August 14, 2019 in the memo does not appear to agree with the 21,950 gallons of fluid loss reported to me during my site visit on August 14, 2019 or the fluid loss reported in the conference call on August 13, 2019.”
In addition to errors on Shell’s end, our review of documents revealed significant confusion around the regulation of drilling fluid spills. In an email from September 26, 2019, months after construction began, Shell raised the following questions with the Ohio EPA:
when a loss of circulation becomes an inadvertent return – the Ohio EPA clarifies: “For purposes of HDD activities in Ohio, an inadvertent return is defined as the unintended return of any fluid to the surface, as well as losses of fluids to underground formations which exceed 50-percent over a 24-hour period and/or 25-percent loss of fluids or annular pressure sustained over a 48-hour period;”
when the clock starts for the aforementioned time periods – the Ohio EPA says the time starts when “the drill commences drilling;”
whether Shell needs to submit loss of circulation reports for losses that are less than the aforementioned definition of an inadvertent return – the Ohio EPA responds, “No. This is not required in the permit.”
How are these spills measured?
A possible explanation for why Shell reported inconsistent volumes of spills is because they were not using the proper technology to measure them.
Shell’s “Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan” states that drilling rigs must be equipped with “instruments which can measure and record in real time, the following information: borehole annular pressure during the pilot hole operation; drilling fluid discharge rate; the spatial position of the drilling bit or reamer bit; and the drill string axial and torsional loads.”
In other words, Shell should be using monitoring equipment to measure and report volumes of drilling fluid released.
Despite that requirement, Shell was initially monitoring releases manually by measuring the remaining fluid levels in tanks. After inspectors with the Pennsylvania DEP realized this in October, 2019, the Department issued a Notice of Violation to Shell, asking the company to immediately cease all Pennsylvania HDD operations and implement recording instruments. The violation also cited Shell for not filing weekly inadvertent return reports and not reporting where recovered drilling fluids were disposed.
In Ohio, there is no record of a similar request from the Ohio EPA. The anonymous source that originally informed us of issues at the SCIO-6 HDD stated that local officials and regulatory agencies in Ohio were likely not informed of the full volumes of the industrial waste releases based on actual meter readings, but rather estimates that minimize the perceived impact.
While we cannot confirm this claim, we know a few things for sure: 1) there are conflicting reports about the volume of drilling fluids spilled in Ohio, 2) according to Shell’s engineers, there is the potential for a 3 million+ gallon spill at the SCIO-06 site, and 3) there are instances of Shell not following its permits with regard to measuring and reporting fluid losses.
The inconsistent ways that fluid losses (particularly those that occur underground) are defined, reported, and measured leave too many opportunities for Shell to impact sensitive ecosystems and drinking water sources without being held accountable.
What are the impacts of drilling fluid spills?
Drilling fluid is primarily composed of water and bentonite clay (sodium montmorillonite), which is nontoxic. If a fluid loss occurs, workers often use additives to try and create a seal to prevent drilling fluid from escaping into underground voids. According to Shell’s “Inadvertent Returns From HDD” plan, it only uses additives that meet food standards, are not petroleum based, and are consistent with materials used in drinking water operations.
However, large inadvertent returns into waterways cause heavy sedimentation and can have harmful effects on aquatic life. They can also ruin drinking water sources. Inadvertent returns caused by HDD construction along the Mariner East 2 pipeline have contaminated many water wells.
Losses of circulation can impact drinking water too. This past April in Texas, construction of the Permian Highway Pipeline caused a loss that left residents with muddy well water. A 3 million gallon loss of circulation along the Mariner East route led to 208,000 gallons of drilling mud entering a lake, and a $2 million fine for Sunoco, the pipeline’s operator.
Our Falcon Public EIA Project found 240 groundwater wells within 1/4 mile of the pipeline and 24 within 1,000 ft of an HDD site. The pipeline also crosses near surface water reservoirs. Drilling mud spills could put these drinking water sources at risk.
But when it comes to understanding the true impact of the more than 245,000+ gallons of drilling fluid lost beneath Pennsylvania and Ohio, there are a lot of remaining questions. The Falcon route crosses over roughly 20 miles of under-mined land (including 5.6 miles of active coal mines) and 25 miles of porous karst limestone formations (learn more about karst). Add in to the mix the thousands of abandoned, conventional, and fracked wells in the region – and you start to get a picture of how holey the land is. Where or how drilling fluid interacts with these voids underground is largely unknown.
Other Drilling Fluid Losses
In addition to the SCIO-04 HDD, there are other drilling fluid losses that occurred in sensitive locations.
In Robinson Township, Pennsylvania, over a dozen losses of circulation (many of which occurred over the span of several days) released a reported 90,067 gallons of drilling fluid into the ground at the HOU-04 HDD. This HDD is above inactive surface and underground mines.
The Falcon passes through and near surface drinking water sources. In Beaver County, Pennsylvania, the pipeline crosses the headwaters of the Ambridge Reservoir and the water line that carries out its water for residents in Beaver County townships (Ambridge, Baden, Economy, Harmony, and New Sewickley) and Allegheny County townships (Leet, Leetsdale, Bell Acres, and Edgeworth). The group Citizens to Protect the Ambridge Reservoir, which formed in 2012 to protect the reservoir from unconventional oil and gas infrastructure, led efforts to stop Falcon Construction, and the Ambridge Water Authority itself called the path of the pipeline “not acceptable.”In response to public pressure, Shell did agree to build a back up line to the West View Water Authority in case issues arose from the Falcon’s construction.
Unfortunately, a 50-gallon inadvertent return was reported at the HDD that crosses the waterline (Figure 4), and a 160 gallon inadvertent return occurred in Raccoon Municipal Park within the watershed and near its protected headwaters (Figure 5). Both of these releases are reported to have occurred within the pipeline’s construction area and not into waterways.
Figure 4) HOU-10 HDD location on the Falcon Pipeline, where 50 gallons were released on the drill pad on 7/9/2019
Figure 5) SCIO-05 HDD location on the Falcon Pipeline, where 160 gallons were released on 6/10/19, within the pipeline’s LOD (limit of disturbance)
Farther west, the pipeline crosses through the watershed of the Tappan Reservoir, which provides water for residents in Scio, Ohio and the Ohio River, which serves over 5 million people.
A 35- gallon inadvertent return occurred at a conventional bore within the Tappan Lake Protection Area, impacting a wetland and stream. We are not aware of any spills impacting the Ohio River.
Pipelines in a Pandemic
This investigation makes it clear that weak laws and enforcement around drilling fluid spills allows pipeline construction to harm sensitive ecosystems and put drinking water sources at risk. Furthermore, regulations don’t require state agencies or Shell to notify communities when many of these drilling mud spills occur.
The problem continues where the 97-mile pipeline ends – at the Shell ethane cracker. In March, workers raised concerns about the unsanitary conditions of the site, and stated that crowded workspaces made social distancing impossible. While Shell did halt construction temporarily, state officials gave the company the OK to continue work – even without the waiver many businesses had to obtain.
The state’s decision was based on the fact it considered the ethane cracker to “support electrical power generation, transmission and distribution.” The ethane cracker – which is still months and likely years away from operation – does not currently produce electrical power and will only provide power generation to support plastic manufacturing.
This claim continues a long pattern of the industry attempting to trick the public into believing that we must continue expanding oil and gas operations to meet our country’s energy needs. In reality, Shell and other oil and gas companies are attempting to line their own pockets by turning the country’s massive oversupply of fracked gas into plastic. And just as Shell and state governments have put the health of residents and workers on the line by continuing construction during a global pandemic, they are sacrificing the health of communities on the frontlines of the plastic industry and climate change by pushing forward the build-out of the petrochemical industry during a global climate crisis.
This election year, while public officials are pushing forward major action to respond to the economic collapse, let’s push for policies and candidates that align with the people’s needs, not Big Oil’s.
By Erica Jackson, Community Outreach & Communications Specialist, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/FalconPipelineFrontPage.jpg8963125Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2020-06-16 11:47:062020-06-18 12:11:30Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
Unconventional wells in Pennsylvania were always resource-intensive, but the maps below show how the amount of water used per well has grown significantly in recent years. In 2013, these wells used an average of 5.8 million gallons per well. By 2019, that figure had increased 145%, consuming more than 14.3 million gallons per well. This is a glimpse into the unsustainable resource demands of this industry and the decreasing energy returned on investment.
As fracking proponents will eagerly remind you, hydraulic fracturing was invented decades ago – back in 1947 – so the practice has been in use for quite a while. What really separates modern unconventional shale gas wells from the supposedly traditional, conventional wells is more a matter of scale than anything else. While conventional wells are typically fracked with tens of thousands of gallons of fluid, their unconventional counterparts are far thirstier, consuming millions of gallons per well.
And of course, more inputs translate into more outputs — not necessarily in the form of gas, but in the form of toxic, radioactive waste. This creates a slew of problems ranging from health impacts, to increased transportation, to disposal.
However, this increase in consumption has continued to grow on a per-well basis, so that wells drilled in recent years aren’t really in the same category as wells drilled a decade ago at the beginning of Pennsylvania’s unconventional boom.
In Pennsylvania, unconventional wells are primarily drilled into two deep shale layers, the Devonian-aged Marcellus Shale, which is about 390 million years old, and the Utica Shale from the Late Ordovician period, which was deposited about 60 million years before the Marcellus. These formations have been known about for decades, but did not yield enough gas justify the expense of drilling until the 21st century, when horizontal drilling allowed for a much greater surface area of exposure to the shale formations. However, stimulating this increased distance also requires significantly more fracking fluid – a mixture of water, sand, and chemicals – which increased the consumptive use of water by several orders of magnitude. And in the end, all of this extra work that is required to extract the gas from the ground has made the industry unprofitable, as high production numbers have outpaced demand.
As residents in shale fields around the country started to see impacts to their drinking water, they began to demand to know more about what was injected into the ground around them. The industry’s response was FracFocus, a national registry to address the water component of this question, if not the issue of fracking chemicals. In the early days, visitors to the site could only access data one well at a time, so systematic analyses by third parties were precluded. Additionally, record keeping was sloppy, with widespread data entry issues, incorrect locations, duplicate entries, and so forth.
Many of these issues were addressed with the rollout of FracFocus 2.0 in May of 2013. This fixed many of the data entry issues, such as the six different spellings of “Susquehanna” that were used, and enabled downloads of the entire data set. For that reason, when we wanted to look at changes over time, our analysis started in 2013, where only minimal obvious corrections were required at the county level.
Unconventional wells in Pennsylvania were always resource-intensive, but this GIF shows that the amount of water used per well has grown significantly in recent years. In 2013, these wells used an average of 5.8 million gallons per well. By 2019, that figure had increased 145%, consuming more than 14.3 million gallons per well. This is a glimpse into the unsustainable resource demands of this industry and the decreasing energy returned on investment.
However, statewide data is available since 2008, and as long as we keep in mind the data quality issues from the earlier years, the results are even more stark.
Total Water (gal)
Average Water per Well (gal)
Maximum Water (gal)
Figure 1: While the total number of frack jobs reported to FracFocus has declined over the years, the amount of water per well has increased substantially.
In terms of the total number of unconventional wells drilled, the boom years in Pennsylvania were around 2010 to 2014, with more than 1,000 wells drilled each of those years, a total that has not been achieved again since. It is important to note that in this FracFocus data, we are not counting the wells, per se, but the reported instances of well stimulation through hydraulic fracturing, commonly called frack jobs. In the earliest portion of the date range, submitting data to FracFocus was voluntary, and therefore the total activity from 2008 through 2010 is vastly undercounted, but we have included what data was available.
It should be noted that the average consumption for frack jobs started in 2020 are down from the 2019 totals, however, the sample size is considerably smaller. This smaller sample due, in part, to reduced drilling activity due to oversupply of gas in the Northeast, but also due to the fact that the year is still in progress. This analysis is based on data downloaded from FracFocus in April 2020.
Changes Over Time
As we examine changes in the average water consumption over time from Figure 1, we can see that operators in Pennsylvania averaged between 4-5 million gallons of water per well from 2008 to 2012. The numbers take off from there, tripling to more than 14 million gallons for 2019, the last full year available. At the same time, drilling operators began experimenting with truly monstrous quantities of water. In 2008, the only well with water data available used just over 4.1 million gallons. By 2019, there was a well that used 39.3 million gallons of water, almost a tenfold increase.
From late 2008 through early 2020, the industry recorded the use of 65.8 billion gallons of water in unconventional wells. Since we know that many wells during the early boom years did not report to FracFocus, the actual usage must be substantially higher. For the years with the most reliable and complete data – 2013 to 2019 – total water consumption ranged from 5.9 to 10.9 billion gallons per year. For context, the average Pennsylvanian uses about 100 gallons per day, or 36,500 gallons per year.
That means that the 10.9 billion gallons that were pumped into fracked wells in 2018 equals the total usage of 298,667 residents for an entire year. Alternatively, that water could have filled 16,517 Olympic-sized swimming pools. It is equivalent to 33,455 acre-feet, meaning it could fill an acre-sized column of water that stretches more than six miles high.
Surely, there must be a better way to make use of our precious resources than to turn millions upon millions of gallons of water into toxic waste.
By Matt Kelso, Manager of Data & Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/05/waterfall-1806956_1920.jpg9271920Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgMatt Kelso, BA2020-05-29 16:22:102020-06-01 10:54:09Fracking Water Use in Pennsylvania Increases Dramatically
Map: Ohio Quarterly Utica Oil and Gas Production along with Quarterly Wastewater Disposal
A little under a year ago, FracTracker released a map and associated analysis, “A Disturbing Tale of Diminishing Returns in Ohio,” with respect to Utica oil and gas production, highlighting the increasing volume of waste injected in wastewater disposal wells, and trends in lateral length in fracked wells from 2010 to 2018. In this article, I’ll provide an update on Ohio’s Utica oil and gas production in 2018 and 2019, the demands on freshwater, and waste disposal. After looking at the data, I recommend that we holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste in order to minimize negative externalities.
Recently, I’ve been inspired by the works of Colin Woodward and Marvin Harris, who outline the struggle between liberty and the common good. They relate this to the role that commodities and increasing resource intensity play in maintaining or enhancing living standards. This quote from Harris’s “Cannibals and Kings” struck me as the 122 words that most effectively illustrate the impacts of the fracking boom that started more than a decade ago in Central Appalachia:
“Regardless of its immediate cause, intensification is always counterproductive. In the absence of technological change, it leads inevitably to the depletion of the environment and the lowering of the efficiency of production since the increased effort sooner or later must be applied to more remote, less reliable, and less bountiful animals, plants, soils, minerals, and sources of energy. Declining efficiency in turn leads to low living standards – precisely the opposite of the desired result. But this process does not simply end with everybody getting less food, shelter, and other necessities in return for more work. As living standards decline, successful cultures invent new and more efficient means of production which sooner or later again lead to the depletion of the natural environment.” From Chapter 1, page 5 of Marvin Harris’ “Cannibals and Kings: The Origins of Cultures, 1977
In reflecting on Harris’s quote as it pertains to fracking, I thought it was high time I updated several of our most critical data sets. The maps and data I present here speak to intensification and the fact that the industry is increasingly leaning on cheap water withdrawals, landscape impacts, and waste disposal methods to avoid addressing their increasingly gluttonous ways. To this point, the relationship between intensification and resource utilization is not just the purview of activists, academics, and journalists anymore; industry collaborators like IHS Markit admitting as much in their latest analysis pointing to the fact that oil and gas operators “will have to drill substantially more wells just to maintain current production levels and even more to grow production”. Insert Red Queen Hypothesis analogy here!
Oil and Gas Production in Ohio
The four updated data sets presented here are: 1) oil, gas, and wastewater production, 2) surface and groundwater withdrawal rates for the fracking industry, 3) freshwater usage by individual Ohio fracked wells, and 3) wastewater disposal well (also referred to as Class II injection wells) rates.
Below are the most important developments from these data updates as it pertains to intensification and what we can expect to see in the future, with or without the ethane cracker plants being trumpeted throughout Appalachia.
From a production standpoint, total oil production has increased by 30%, while natural gas production has increased by 50% year over year between the last time we updated this data and Q2-2019 (Table 1).
According to the data we’ve compiled, the rate of growth for wastewater production has exceeded oil and is nearly equal to natural gas at 48% from 2017 to 2018. On average the 2,398 fracked wells we have compiled data for are producing 27% more wastewater per well now than they did at the end of 2017.
Oil (million barrels)
Gas (million Mcf)
Brine (million barrels)
Oil (million barrels)
Gas (million Mcf)
Brine (million barrels)
Table 1. Summary statistics for 2,398 fracked wells in Ohio from a production perspective from 2017 to Q2 2019.
Figure 1. Total fracked gas produced per quarter and average fracked gas produced per well in Ohio from 2013 to Q2-2019.
The increasing amount of resources and number of wells necessary to achieve marginal increases in oil and gas production is a critical factor to considered when assessing industry viability and other long-term implications. As an example, in Ohio’s Utica Shale, we see that total production is increasing, but as IHS Markit admits, this is only possibly by increasing the total number of producing wells at a faster rate. As is evidenced in Figure 1, somewhere around the Winter of 2017-2018, the production rate per well began to flatline and since then it has begun to decrease.
Water demands for oil and gas production in Ohio
Since last we updated the industry’s water withdrawal rates, the Ohio Department of Natural Resources (ODNR) has begun to report groundwater rates in addition to surface water. The former now account for nine sites in seven counties, but amount to a fraction of reported withdrawals to date (around 00.01% per year in 2017 and 2018). The more disturbing developments with respect to intensification are:
1) Since we last updated this data, 59 new withdrawal sites have come online. There are currently 569 sites in total in ODNR’s database. This amounts to a nearly 12% increase in the total number of sites since 2017. With this additional inventory, the average withdrawal rate across all sites has increased by 13% (Table 2).
2) Since 2010, the demand for freshwater to be used in fracking has increased by 15.6% or 693 million gallons per year (Figure 2).
3) We expect to see an inflection point when water production will increase to accommodate the petrochemical buildout with cracker plants in Dilles Bottom, OH; Beaver County, PA; and elsewhere. In 2018 alone, the oil and gas industry pulled 4.69 billion gallons of water from the Ohio River Valley. Since 2010, the industry has permanently removed 22.96 billion gallons of freshwater from the Ohio River Valley. It would take the entire population of Ohio five years to use the 2018 rate in their homes.
As we and others have mentioned in the past, this trend is largely due to the bargain basement price at which we sell water to the oil and gas sector throughout Appalachia. To increase their nominal production returns, companies construct longer laterals with orders of magnitude more water, sand, and chemicals. At this rate, the fracking industry’s freshwater demand will have doubled to around 8.8-.9.5 billion gallons per year by around 2023. Figure 3 demonstrates that average fracked lateral length continues to increase to the tune of +15.7-21.2% (+1,564-2,107 feet) per quarter per lateral. This trend alone is more than 2.5 times the rate of growth in oil production and roughly 24% greater than the rate of growth in natural gas production (See Table 1).
4. The verdict is even more concerning than it was a couple years ago with respect to water demand increasing by 30% per quarter per well or an average of 4.73 million gallons (Figure 4). The last time we did this analysis >1.5 years ago demand was rising by 25% per quarter or 3.84 million gallons. At that point I wouldn’t have guessed that this exponential rate of water demand would have increased but that is exactly what has happened. Very immediate conversations must start taking place in Columbus and at the region’s primary distributor of freshwater, The Muskingum Watershed Conservancy District (MWCD), as to why this is happening and how to push back against the unsustainable trend.
Maximum (billion gallons)
Sum (billion gallons)
Mean (billion gallons)
Table 2. Summary of fracking water demands throughout Ohio in 2017 when we last updated this data as well as how those rates changed in 2018.
Figure 2. Hydraulic fracturing freshwater demand in total across 560+ sites in Ohio from 2010 to 2018 (million gallons per year).
Figure 3. Average lateral length for all of Ohio’s permitted hydraulically fractured laterals from from Q3-2010 to Q4-2019, along with average rates of growth from a linear and exponential standpoint (feet).
Figure 4. Average Freshwater Demand Per Unconventional Well in Ohio from Q3-2011 to Q3-2019 (million gallons).
When it comes to fracking wastewater disposal, the picture is equally disturbing. Average disposal rates across Ohio’s 220+ wastewater disposal wells increased by 12.1% between Q3-2018 and Q3-2019 (Table 3). Interestingly, this change nearly identically mirrors the change in water withdrawals during the same period. What goes down– freshwater – eventually comes back up.
Across all of Ohio’s wastewater disposal wells, total volumes increased by nearly 22% between 2018 and the second half of 2019. However, the more disturbing trend is the increasing focus on the top 20 most active wastewater disposal wells, which saw an annual increase of 17-18%. These wells account for nearly 50% of all waste and the concern here is that many of the pending wastewater disposal well permits are located on these sites, within close proximity, and/or are proposed by the same operators that operate the top 20.
When we plot cumulative and average disposal rates per well, we see a continued exponential increase. If we look back at the last time, we conducted this analysis, the only positive we see in the data is that at that time, average rates of disposal per well were set to double by the Fall of 2020. However, that trend has tapered off slightly — rates are now set to double by 2022.
Each wastewater disposal well is seeing demand for its services increase by 2.42 to 2.94 million gallons of wastewater per quarter (Figure 5). Put another way, Ohio’s wastewater disposal wells are rapidly approaching their capacity, if they haven’t already. Hence why the oil and gas industry has been frantically submitting proposals for additional waste disposal wells. If these wells materialize, it means that Ohio will continue to be relied on as the primary waste receptacle for the fracking industry throughout Appalachia.
Number of Wells
Table 3. Summary Statistics for Ohio’s Wastewater Disposal Wells (millions of barrels (MMbbl)).
Figure 5. Average Fracking Waste Disposal across all of Ohio’s Wastewater Disposal Wells and the cumulative amount of fracking waste disposed of in these wells from Q3-2010 to Q2-2019 (million barrels).
Using the Pennsylvania natural gas data merged with the Ohio wastewater data, we were able to put a finer point on how much wastewater would be produced with a 100,000 barrel ethane cracker like the one PTT Global Chemical has proposed for Dilles Bottom, Ohio. The following are our best estimate calculations assuming 1 barrel of condensate is 20-40% ethane. These calculations required that we take some liberties with the merge of the ratio of gas to wastewater in Ohio with the ratio of gas to condensate in Pennsylvania:
For 2,064 producing Ohio fracked wells, the ratio of gas to wastewater is 64.76 thousand cubic feet (Mcf) of gas produced per barrel of wastewater.
Assuming 40% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 320.08 Mcf of gas per barrel of ethane condensate. For 100,000 barrels of ethane needed per cracker per day, that would result in 494,285 barrels (20.76 million gallons) of brine per day.
Assuming 20% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 640.15 Mcf per barrel of ethane condensate = For 100,000 barrels of ethane needed per cracker per day that would result in 988,571 barrels/41.52 million gallons of wastewater per day.
But wait, here is the real stunner:
The 40% assumption result is 3.81 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 5.37 times the daily rates of brine taken in by the top 20 wells (Note: the top 20 wastewater disposal wells account for 71% of all wastewater waste taken in by all of the state’s disposal wells).
The 20% assumption result is 7.62 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 10.74 times the daily rates of wastewater taken in by the top 20 wells.
Therefore, we estimate the fracked wells supplying the proposed PTTGC ethane cracker will generate between 20.76 million and 41.52 million gallons of wastewater per day. That is 3.8 to 7.6 times the amount of wastewater currently received by Ohio’s wastewater disposal wells.
What does this means in terms of truck traffic? We can assume that at least 80% of the trucks that transport wastewater are the short/baby bottle trucks which haul 110 barrels per trip. This means that our wastewater estimates would require between 4,493 and 8,987 truck trips per day, respectively. The pressures this amount of traffic will put on Appalachian roads and communities will be hard to measure and given the current state of state and federal politics and/or oversight it will be even harder to measure the impact inevitable spills and accidents will have on the region’s waterways.
There is no reason to believe these trends will not persist and become more intractable as the industry increasingly leans on cheap waste disposal and water as a crutch. The fracking industry will continue to present shareholders with the illusion of a robust business model, even in the face of rapid resource depletion and precipitous production declines on a per well basis.
I am going to go out on a limb and guess that unless we more holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste, there will be no other supply-side signal that we could send that would cause the oil and gas industry to change its ways. Until we reach that point, we will continue to compile data sets like the ones described above and included in the map below, because as Supreme Court Justice Louis Brandeis once said, “Sunlight is the best disinfectant!”
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison
 Colin Woodward’s “American Character: A history of the epic struggle between individual liberty and the common good” is a must read on the topic of resource utilization and expropriation.
 In Ohio the major purveyor of water for the fracking industry is the Muskingum Watershed Conservancy District (MCWD) and as we’ve pointed out in the past they sell water for roughly $4.50 to $6.50 per thousand gallons. Meanwhile across The Ohio River the average price of water for fracking industry in West Virginia in the nine primary counties where fracking occurs is roughly $8.38 per thousand gallons.
Quarterly oil, gas, brine, and days in production for 2,390+ Unconventional Utica/Point Pleasant Wells in Ohio from 2010 to Q2-2019
Despite the ever-increasing heaps of violations and drilling waste, Pennsylvania’s fracked wells continue to produce an excess supply of gas, driving prices down. To cut their losses, the oil and gas industry is turning towards increased exports and petrochemical production. Continuing to expand fracking in Pennsylvania will only increase risks to the public and to the climate, all for what may amount to another boom and bust cycle that is largely unprofitable to investors.
Let’s take a look at gas production, waste, newly drilled wells, and violations in Pennsylvania in the past year to understand just how precarious the fracking industry is.
Fracked hydrocarbon production continues to rise in Pennsylvania, resulting in an increase in waste production, violations, greenhouse gas emissions, and public health concerns. There are three types of hydrocarbons produced from wells in Pennsylvania: gas, condensate, and oil. Gas is composed mostly of methane, the most basic of the hydrocarbons, but in some parts of Pennsylvania, there can be significant quantities of ethane, propane, and other so-called “natural gas liquids” (NGLs) mixed in. Each of these NGLs are actually gaseous at atmospheric conditions, but operators try to separate these with a combination of pressure and low temperatures, converting them to a liquid phase. Some of these NGLs can be separated on-site, and this is typically referred to as condensate. Fracked wells in Pennsylvania also produce a relatively tiny amount of oil.
For those of you wondering why we are looking at the November, 2018 through October, 2019 time frame, this is simply a reflection of the available data. In this 12-month period, 9,858 fracked Pennsylvania wells, classified as “unconventional,” reported producing 6.68 trillion cubic feet of gas (Tcf), 4.89 million barrels of condensate, and just over 70,000 barrels of oil.
By means of comparison, Pennsylvania consumed about 1.46 Tcf of gas across all sectors in 2018, of which just 253 billion cubic feet (Bcf) was used in the homes of Pennsylvania’s 12.8 million residents. In fact, the amount of gas produced in Pennsylvania exceeds residential consumption in the entire United States by almost 1.7 Tcf. However, less than 17% of all gas consumed in Pennsylvania is for residential use, with nearly 28% being used for industrial purposes (including petrochemical development), and more than 35% used to generate electricity.
Figure 1. Fracked gas production compared to all fracked gas consumption and residential gas consumption in Pennsylvania from 2013 through 2018. Data from ref. Energy Information Administration.
While gas production has expansive hotspots in the northeastern and southwestern portions of the state, the liquid production comes from a much more limited geography. Eighty percent of all condensate production came from Washington County, while 87% of all fracked oil came from wells in Mercer County.
Because the definition of condensate has been somewhat controversial in the past (while the oil export ban was still in effect), I asked the Department of Environmental Protection (DEP) for the definition, and was told that if hydrocarbons come out of the well as a liquid, they should be reported as oil. If they are gaseous but condense to a liquid at standard temperature and pressure (60 degrees Fahrenheit and pressure 14.7 PSIA) on-site, then it is to be reported as condensate. Any NGLs that remain gaseous but are removed from the gas supply further downstream are reported as gas in this report. For this reason, it is not really possible to use the production report to find specific amounts of NGLs produced in the state, but it certainly exceeds condensate production by an appreciable margin.
The volume of gas withdrawn from fracked wells in Pennsylvania in just one year is equal to the volume of 3.2 Mount Everests!
Hydrocarbons aren’t the only thing that come out of the ground when operators drill and frack wells in Pennsylvania. Drillers also report a staggering amount of waste products, including more than 65 million barrels (2.7 billion gallons) of liquid waste and 1.2 million tons of solid waste in the 12-month period.
Waste facilities have significant issues such as inducing earthquakes, toxic leachate, and radioactive sediments in streambeds.
Liquid Waste (Barrels)
Solid Waste (Tons)
Drilling Fluid Waste
Other Oil & Gas Wastes
Soil Contaminated by Oil & Gas Related Spills
Spent Lubricant Waste
Synthetic Liner Materials
Unused Fracturing Fluid Waste
Waste Water Treatment Sludge
Figure 2. Oil and gas waste generated by fracked wells as reported by drillers from November 1, 2018 through October 31, 2019. Data from ref: PA DEP.
Some of the waste is probably best described as sludge, and several of the categories allow for reporting in barrels or tons. Almost all of the waste was in the well bore at one time or another, although there are some site-related materials that need to be disposed of, including filter socks which separate liquid and solid waste, soils contaminated by spills, spent lubricant, liners, and unused frack fluid waste.
Where does all of this waste go? We worked with Earthworks earlier this year to take a deep dive into the data, focusing on these facilities that receive waste from Pennsylvania’s oil and gas wells. While the majority of the waste is dealt with in-state, a significant quantity crosses state lines to landfills and injection wells in neighboring states, and sometimes as far away as Idaho.
Oil and gas operators have started the drilling process for 616 fracking wells in 2019, which appear on the Pennsylvania DEP spud report. This is less than one third of the 2011 peak of 1,956 fracked wells, and 2019 is the fifth consecutive year with fewer than 1,000 wells drilled. This has the effect of making industry projections relying on 1,500 or more drilled wells per year seem rather dubious.
Figure 3. Unconventional (fracked) wells drilled from 2005 through December 23, 2019, showing totals by regional office. Data from ref: PA DEP.
Oil and gas wells in Pennsylvania fall under the jurisdiction of three different regional offices. By looking at Figure 2, it becomes apparent that the North Central Regional Office (blue line) was a huge driver of the 2009 to 2014 drilling boom, before falling back to a similar drilling rate of the Southwest Regional Office.
The slowdown in drilling for gas in recent years is related to the lack of demand for the product. In turn, this drives prices down, a phenomenon that industry refers to as a “price glut.” The situation it is forcing major players in the regions such as Range Resources to reduce their holdings in Appalachia, and some, such as Chevron, are pulling out entirely.
Disturbingly, 2019 was the fifth straight year that the number of violations issued by DEP will exceed the total number of wells drilled.
Figure 4. Unconventional (fracked) drilled wells and issued violations from 2005 through December 2019. Data from ref: DEP.
Violations related to unconventional drilling are a bit unwieldy to summarize. The 13,833 incidents reported in Pennsylvania fall into 359 different categories, representing the specific regulations in which the drilling operator fell short of expectations. The industry likes to dismiss many of these as being administrative matters, and indeed, the DEP does categorize the violations as either “Administrative” or “Environmental, Health & Safety”. However, 9,998 (72%) of the violations through December 3, 2019, are in the latter category, and even some of the ones that are categorized as administrative seem like they ought to be in environmental, health, and safety. For example, let’s look at the 15 most frequent infractions:
SWMA301 – Failure to properly store, transport, process or dispose of a residual waste.
Environmental Health & Safety
CSL 402(b) – POTENTIAL POLLUTION – Conducting an activity regulated by a permit issued pursuant to Section 402 of The Clean Streams Law to prevent the potential of pollution to waters of the Commonwealth without a permit or contrary to a permit issued under that authority by the Department.
Environmental Health & Safety
102.4 – Failure to minimize accelerated erosion, implement E&S plan, maintain E&S controls. Failure to stabilize site until total site restoration under OGA Sec 206(c)(d)
Environmental Health & Safety
SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.
Environmental Health & Safety
601.101 – O&G Act 223-General. Used only when a specific O&G Act code cannot be used
402CSL – Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution.
Environmental Health & Safety
78.54* – Failure to properly control or dispose of industrial or residual waste to prevent pollution of the waters of the Commonwealth.
Environmental Health & Safety
401 CSL – Discharge of pollutional material to waters of Commonwealth.
Environmental Health & Safety
102.4(b)1 – EROSION AND SEDIMENT CONTROL REQUIREMENTS – Person conducting earth disturbance activity failed to implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation.
Environmental Health & Safety
102.5(m)4 – PERMIT REQUIREMENTS – GENERAL PERMITS – Person failed to comply with the terms and conditions of the E & S Control General Permit.
Environmental Health & Safety
78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances.
78a53 – EROSION AND SEDIMENT CONTROL AND STORMWATER MANAGEMENT – Person proposing or conducting earth disturbance activities associated with oil and gas operations failed to comply with 25 Pa. Code § 102.
Environmental Health & Safety
102.11(a)1 – GENERAL REQUIREMENTS – BMP AND DESIGN STANDARDS – Person failed to design, implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation to protect, maintain, reclaim and restore water quality and existing and designated uses.
Environmental Health & Safety
CSL 401 – PROHIBITION AGAINST OTHER POLLUTIONS – Discharged substance of any kind or character resulting in pollution of Waters of the Commonwealth.
Environmental Health & Safety
OGA3216(C) – WELL SITE RESTORATIONS – PITS, DRILLING SUPPLIES AND EQUIPMENT – Failure to fill all pits used to contain produced fluids or industrial wastes and remove unnecessary drilling supplies/equipment not needed for production within 9 months from completion of drilling of well.
Environmental Health & Safety
Figure 5. Top 15 most frequently cited violations for unconventional drilling operations in Pennsylvania through December 3, 2019. Data from ref: DEP.
Of the 15 most common categories, only two are considered administrative violations. One of these is a general code, where we don’t know what happened to warrant the infraction without reading the written narrative that accompanies the data, and is therefore impossible to categorize. The only other administrative violation in the top 15 categories reads, “78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances,” which certainly sounds like it would have some real-world implications beyond administrative concerns.
To address the excess supply of gas, companies have tried to export the gas and liquids to other markets through pipelines. Those efforts have been fraught with trouble as well. Residents are reluctant to put up with an endless barrage of new pipelines, yielding their land and putting their safety at risk for an industry that can’t seem to move the product safely. The Revolution pipeline explosion hasn’t helped that perception, nor have all of the sinkholes and hundreds of leaky “inadvertent returns” along the path of the Mariner East pipeline system. In a sense, the industry’s best case scenario is to call these failures incompetence, because otherwise they would be forced to admit that the 2.5 million miles of hydrocarbon pipelines in the United States are inherently risky, prone to failure any time and any place.
Pennsylvania’s high content of NGLs is a selling point by the industry, because they have an added value when compared to gas. While all of these hydrocarbons can burn and produce energy in a similar manner, operators are required to remove most of them to get the energy content of the gas into an acceptable range for gas transmission lines. Because of this, enormous facilities have to be built to separate these NGLs, while even larger facilities are constructed to consume it all. Shell’s Pennsylvania Petrochemicals Complex ethane cracker being built in Beaver County, PA is scheduled to make 1.6 million metric tons of polyethylene per year, mostly for plastics.
This comes at a time when communities around the country and the world are enacting new regulations to rein in plastic pollution, which our descendants are going to finding on the beach for thousands of years, even if everyone on the planet were to stop using single-use plastics today. Of course, none of these bans or taxes are currently permitted in Pennsylvania, but adding 1.6 million metric tons per year to our current supply is unnecessary, and indeed, it is only the beginning for the region. A similar facility, known as the PTT Global Chemical cracker appears to be moving forward in Eastern Ohio, and ExxonMobil appears to be thinking about building one in the region as well. Industry analysts think the region produces enough NGLs to support five of these ethane crackers.
Despite all of these problems, the oil and gas industry still plans to fill the Ohio River Valley with new petrochemical plants, gas processing plants, and storage facilities in the hopes that someday, somebody may want what they’ve taken from the ground.
Here’s hoping that 2020 is a safer and healthier year than 2019 was. But there is no need to leave it up to chance. Together, we have the power to change things, if we all demand that our voices are heard. As a start, consider contacting your elected officials to let them know that renewing Pennsylvania’s blocking of municipal bans and taxes on plastic bags is unacceptable.
By Matt Kelso, Manager of Data & Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/01/PA-2019-Fracked-Gas-Production-Feature.jpg16673750Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgMatt Kelso, BA2020-01-07 18:02:382020-08-24 15:12:16Fracking in Pennsylvania: Not Worth It
FracTracker Alliance studies, maps, and communicates the risks of oil and gas development to protect our planet and support the renewable energy transformation.