Lycoming Watershed Digital Atlas

Water at Risk


A Digital Atlas Exploring the Impacts of Natural Gas Development in

the Lycoming Creek Watershed of Pennsylvania

Introduction


Coursing through lush valleys of the Allegheny Plateau, Lycoming Creek flows over 37 miles to its confluence with the West Branch Susquehanna River in Williamsport, Pennsylvania. The 272-square-mile watershed includes idyllic tributaries like Pleasant Stream and Trout Run, names reflecting the intrinsic beauty and bounty of the area. Rock Run in Loyalsock State Forest by some accounts is, “one of the most beautiful streams in all of Pennsylvania.” 

The mightier Pine Creek to the west perhaps carries greater notoriety, as does the enchanting Loyalsock to the east. But make no judgement about Lycoming Creek’s smaller stature. Forest covers 81% of the basin and only one percent is developed, with the rest of the land used for agriculture. Through the heart of this rugged terrain, a picturesque waterway beckons anglers and other revelers of the wilds.   

The Lenape people called the watershed home before European occupation. They knew the creek as Legani-hanne, meaning “sandy or gravelly stream.” The native residents and those who displaced them used it as a means of transportation, whether traveling by canoe or walking the Sheshequin Path that runs north and east along the shores.  

Lumber fueled the regional economy of the 19th century, and Lycoming’s forests fell. By rail and by water, saw logs were sent to Williamsport for milling. Wood-powered wealth gave rise to the city’s “Millionaire’s Row,” but prosperity apexed in the early 20th century. Today, the Williamsport area is home to nearly 30,000 people, down from a peak of around 45,000 in 1950. Comparatively, about 20,000 persons live within the Lycoming Creek watershed. 

These days, Williamsport buzzes with breweries, bookstores, and the vitality of an urban hub. The Little League World Series still comes to town every summer, ushering memories of simpler, quieter times. 

Nearby, the serene creek surges with life, including the Eastern hellbenderNorth America’s largest amphibian. But the same water can turn tempestuous and destructive. Notable floods in 1972, 1996, 2011, and 2016 caused loss of life and property damage. As climate change intensifies, heavy downpours and rapid snowmelt exacerbate flood risks. 

Unconventional drilling brought new threats to the area: congested truck traffic, exorbitant consumptive water use, myriad air pollution sources, extensive land clearing, and ecological disturbance; and, the dangers of spills, leaks, and water contamination. 

This report explores these impacts, underscoring the heavy footprint of extractionand related activitieson public and private lands throughout the Lycoming Creek watershed.

A wealth of public lands & recreational opportunities

The Lycoming Creek watershed provides ample opportunities for nature-based recreation. While there are no state parks in the watershed, a 507-acre (0.8 square miles) portion of the Tioga State Forest occupies the northern boundary of the watershed in Tioga County. Further south lies 45,022 acres (71.1 square miles) of the Loyalsock State Forest. This includes 332 acres (0.52 square miles) of the Devil’s Elbow Natural Area, a site known for its many wetlands—home to carnivorous sundew and pitcher plants—waters that feed the stunning Rock Run. 

The McIntyre Wild Area covers a 7,226 acre (11.3 square mile) expanse of the Loyalsock State Forest, situated entirely in the Lycoming Creek watershed. It includes spectacular waterfalls on streams that feed the aforementioned Rock Run, a tributary known for its vibrant trout population.



Recreational Opportunities in the Lycoming Creek Watershed

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To the west of Lycoming Creek and State Route 14 is Bodine Mountain, another sweeping feature of the Loyalsock State Forest. Bodine Mountain is a north-to-south ridge rising over 1,300 feet above the Lycoming Creek valley.

In addition to state forests, the watershed contains 238 acres of State Game Land 335 at the northern boundary, and 2,430 acres (3.8 square miles) of State Game Land 133, situated southeast of Bodine Mountain. These conserved lands are designated to protect wildlifea goal that seems at odds with current oil and gas leasing practices.



Fishing and enjoying mountain streams


Pennsylvania has two separate designations for streams with excellent water quality: exceptional value (EV) and high quality (HQ). The Department of Environmental Protection (DEP) explains that the quality of HQ streams can be lowered, “if a discharge is the result of necessary social or economic development, the water quality criteria are met, and all existing uses of the stream are protected.” The water quality of EV streams cannot be lowered.  

Sadly, there are no streams in the beautiful Lycoming Creek watershed with an EV designation, however deserving. On the other hand, 412 miles of streams in its drainage are designated as HQ, representing 76% of the watershed’s 542 total stream miles, according to the state’s official designated use inventory. Statewide, 3,838 out of 86,473 miles (4.4%) of inventoried streams are categorized as EV, while 58,748 miles (67.9%) are HQ, making the Lycoming Creek watershed below average for the former, and above average for the latter.

Prior to industrialization, native brook trout populations were widespread in small, forested streams across Pennsylvania. While many streams are now stocked with several species of trout, the combination of pollution and deforestation has decimated the areas where trout—especially native brook trout—thrive in sustainable wild populations. Suitable streams are designated as Class A trout streams, and they are rare, accounting for just 3,037 miles, or 3.5% of streams across the Commonwealth. The Lycoming Creek watershed contains slightly fewer Class A streams than is typical, with 17.5 miles, representing just 3.2% of all streams in the drainage. Nevertheless, it remains an important respite for trout species and the anglers who seek them.

Split estates and the Clarence Moore lands


Hundreds of thousands of acres of Pennsylvania state forest are under lease agreements for fracked gas extraction, diminishing outdoor experiences and posing ongoing environmental threats. In those situations, the state Department of Conservation and Natural Resources (DCNR) clearly controls the surface and the gas that lies beneath. However, in some areas of the state forest, private interests claim mineral ownership, even in gaseous form—a situation called “split estate.” Loyalsock State Forest contains about 25,000 split estate acres, known as the Clarence Moore Lands.

In the Lycoming Creek watershed, most of the Clarence Moore lands lie east of US Highway 15, occupying areas that drain into Rock Run and Pleasant Stream, including some of the area’s few remaining Class A wild trout waters. Another section of the Clarence Moore lands extends west of Highway 15, on Bodine Mountain’s eastern flank. In their current state, the lands provide invaluable ecological services and—coupled with the Loyalsock Creek to the east—comprise critical source waters for two major watersheds.

Gas drilling requires a significant amount of infrastructure, including multiacre well pads, miles of gathering pipelines, retention ponds, waste processing facilities, and compressor and metering stations. Allowing surface disturbance in the Clarence Moore lands could have lasting, devastating consequences.

Nearly a decade ago, the Anadarko Petroleum Corporation approached DCNR with extensive plans for dozens of fracked gas wells and all the disruptive destruction that accompanies them in a large swatch of the Loyalsock State Forest and the Clarence Moore lands. Over the years, the Clarence Moore players have changed significantly. Southwestern Energy scored a stake, while Anadarko sold their interest to Alta Resources, a privately-held company scheduled for purchase by EQT, the nation’s largest fracked gas company. While the operators play their game of musical chairs, the situation remains a serious threat to some of the few remaining portions of the region that haven’t been spoiled with industrial gas drilling.

Ironically, modern horizontal drilling enables access to Clarence Moore’s reserves from miles away—from well pads on private land. There is no need—nor social license—to expunge the forest for future generations for short-lived, selfish gain. Organizations near and far, led by the Responsible Drilling Alliance and Save PA Forests Coalition, have rallied tirelessly to save this land from development, a truly special place deserving permanent protection.




Figure 2. The Clarence Moore Lands are a complicated split estate situation in the Loyalsock State Forest, including parts of the Lycoming, Loyalsock, and Schrader Creek watersheds.


Unique wetland biomes


Countless wetlands feed Lycoming Creek’s headwaters, providing a unique opportunity to observe aquatic flora and fauna beneath the forested canopy of Penn’s Woods. The US Fish and Wildlife Service (USFWS) explains their importance, as well as their precarious state:



“Wetlands provide a multitude of ecological, economic and social benefits. They provide habitat for fish, wildlife and plantsmany of which have a commercial or recreational valuerecharge groundwater, reduce flooding, provide clean drinking water, offer food and fiber, and support cultural and recreational activities. Unfortunately, over half of America’s wetlands have been lost since 1780, and wetland losses continue today. This highlights the urgent need for geospatial information on wetland extent, type, and change.”



The geospatial data referred to above is the National Wetland Inventory (NWI), which seeks to document all the wetlands in the United States, based primarily in aerial imagery. According to NWI data, there are 3,136 acres (4.9 square miles) of wetlands in the Lycoming Creek watershed. However, further field research is necessary to properly identify wetland boundaries, particularly in the case of ephemeral wetlands, for example, where the presence of aquatic plants help determine boundaries. All of this suggests that while there is every reason to believe the USFWS’ claim that over half of the nation’s wetlands have been lost since around the time of the Revolutionary War, it is believed the NWI discounts the total acreage.

A University of Vermont team developed another model for calculating wetlands, based primarily on, “2006-2008 leaf-off LiDAR data, 2005-2008 leaf-off orthoimagery, 2013 high-resolution land-cover data, and moderate-resolution predictive wetlands maps, incorporating topography, hydrological flow potential, and climate data.” This model calculates 6,943 wetlands acres (10.8 square miles) in the Lycoming Creek drainage, more than double the NWI’s estimated acreage.



Trails


Five trails traverse the Lycoming Creek watershed, crossing 152 miles total. This includes nearly 44 miles of the Loyalsock State Forest Cross-Country Ski Trail system south and east of the McIntyre Wild Area, suitable for hiking, biking, equestrian pursuits, and of course, cross-country skiing. The watershed also contains 33 miles of Bicycle PA Route J, which runs along Lycoming Creek from the confluence with the West Branch Susquehanna River on the southern end, all the way to the wetland border that feeds Lycoming Creek and neighboring Towanda Creek to the northeast. The watershed’s most popular trail may be the famous Old Loggers Path, a coveted backpacking route that meanders nearly 23 miles. The Hawkeye Cross-Country Ski Trail—frequented by hikers, bikers, and skiers—loops over seven miles in the northeastern corner of the watershed. Yet another watershed trail is the Lycoming Creek Bikeway, a mostly straight five-mile stretch from Hepburnville to the West Branch Susquehanna River.



Figure 3. Rock Run in Loyalsock State Forest’s McIntyre Wild Area. Photo by Ann Pinca.



Figure 4. A flyfisher casts in Lycoming Creek right beside Sheshequin Campground in Trout Run. Photo by Rebecca Johnson.



Figure 5. This wetland lies just beyond the northeastern boundary of the Lycoming Creek watershed and is similar to those feeding the headwaters of Rock Run near Devil’s Elbow Natural Area in Loyalsock State Forest. Photo by Shannon Smith.

Fracking comes to the Lycoming

The commercial oil and gas industry got its start in Pennsylvania in 1859 with the famous Drake Well, followed by a frenzy of drilling in the central and western portions of the state. The DEP has records of over 185,000 conventional oil and gas wells throughout the Commonwealth, and—because the industry preceded permitting requirements by almost a century—yearly estimates range between 480,000 and 760,000 conventional wells have punctured Pennsylvania’s surface. 

The Lycoming Creek watershed was further east than most of the conventional oil and gas pools, so it has seen very little conventional drilling. Of the 185,000 known well locations, only 25 (0.01%) are within the watershed. Of those, 11 (44%) have a status of “proposed but never materialized,” or “operator reported not drilled.” Eight wells (32%) are plugged, four (16%) have active status, one (four percent) is considered being in a regulatory inactive period, and one (four percent) is on the DEP’s orphan list—awaiting funding to be plugged properly.



Fracking boom


While drillers had long known about the Marcellus Shale, it wasn’t until 2004 that drilling in the formation became a profitable enterprise, through the combination of industrial-scale hydraulic fracturing and horizontal drilling. Soon thereafter, the Lycoming Creek watershed was no longer on the periphery of oil and gas exploration, but part of a densely drilled cluster of new unconventional wells in northeastern Pennsylvania.  



Fracking in the Lycoming Creek Watershed

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The first unconventional well in the Lycoming Creek watershed was permitted by Range Resources at the Bobst Mountain Hunting Club on May 31, 2007, and drilling started less than two months later.

In the years that followed, 592 unconventional wells have been proposed for the watershed, 586 (99%) of which received permits, with 384 (65%) drilled as of June 28, 2021. Some wells had a short life, with 41 (10.6%) already plugged—a figure slightly higher than the statewide average of 8.7%. Fifteen operators have been active in the watershed.

As with the rest of Pennsylvania, the total number of drilled wells peaked in 2012, with 100 wells drilled that year. In the past seven years, the highest annual total was only one-fourth of that, with 25 wells drilled in 2019. However, these trends do not foretell an end to drilling in the region. The reduced number of wells drilled is offset by drilling each well more intensively, using five times as much water per well for hydraulic fracturing. 

Gas production has flooded markets, reducing gas prices and profit margins. At the very start of the Marcellus boom in October 2005, gas prices were $13.42 per million British Thermal Units (BTUs), but have fluctuated between $1.75 and $4.00 per million BTUs in recent years. Many of the 202 wells permitted but not drilled in the watershed are located on existing well pads and can easily be drilled and brought into production as market forces dictate. For these reasons, the area is unlikely to see an end to drilling, pipeline construction, truck convoys—and all the other ancillary activities—any time soon.




Figure 6. Active fracking operation in May 2021 on ARD Operating’s COP Tract 551 A well pad, originally planned by Anadarko E&P in 2014. Photo by Ted Auch.



Figure 7. This video was taken at the same site as Figure 6, capturing ARD Operating’s well pad and the incessant noise it makes during hydraulic fracturing activities. Video footage captured by Brook Lenker.



Figure 8. Permitting, drilling, and plugging summary of unconventional wells in the Lycoming Creek watershed by year. Data through June 28, 2021.


Figure 9. Proposed unconventional wells by current operators in the Lycoming Creek watershed. Data through June 28, 2021.  Note that wells that were proposed but not drilled are still associated with the original operator, which are not always still active in the watershed. 



Figure 10. FracTracker’s partners at LightHawk provided aerial assistance to fly our photographer over the Lycoming Creek watershed. This video offers a glimpse at the oil and gas industry’s expansion in the watershed, juxtaposed with houses, farms, forests, wetlands, and numerous waterways. FracTracker’s Ted Auch captured still images while LightHawk pilot David Hartnichek gathered video footage, captured May 2021.

TimeSlider of Bodine Mountain

On the right, we see imagery from June 2021, with a substantial number of well pads, impoundments, compressors, pipelines, and access roads. Imagery on the left is from June 2014, with significantly less infrastructure. Users can zoom, pan, and choose different dates to explore the impacts of the industry over time.


Violations


In the Lycoming Creek watershed, unconventional wells and the well pads they operate on have been issued 634 violations between 2008 and June 28, 2021. This works out to 1.65 violations per drilled well, considerably above the statewide average of 1.3 violations per well.  

 Most of the violations (545, or 86%) are considered to negatively impact environmental health and safety, with the remaining 89 (14%) assessed for administrative infractions. However, the distinction between the two categories is murky at best. For example, the most common administrative violation is, “pits and tanks not constructed with sufficient capacity to contain pollutional substances,” an infraction documented 18 times in the watershed—presenting obvious hazards to health, safety, and the environment. 

Altogether, there are 66 different violation codes cited within the watershed. The ten most frequent are seen in Figure 11.

For these 634 violations, the DEP has collected fines totaling $2,460,700 from four operators. Range Resources leads the way with $1,461,000 in fines, followed by Seneca Resources with $600,000, East Resources with $380,700, and Chief Oil & Gas with $19,000. For comparison, the average cost of drilling a single well in the Marcellus Shale is $8.3 million, according to 2017 financial data from a major operator in the region. At this rate, while assuming no inflation, the watershed will have to suffer 2,138 violations before the DEP’s penalties equal the cost of drilling and fracking one well.

Clearly, operators are not cowed by receiving violations, nor do they look at the occasional fine as anything more than the cost of doing business. It seems that in practice, the DEP’s regulatory role is chronicling the industry’s misdeeds, instead of protecting the environment and the people who live among the hundreds of wells in the area.



Figure 11. The ten most frequent violations for unconventional wells and well pads in the Lycoming Creek watershed through June 28, 2021.

Fracking’s aquatic impacts


The DEP maintains a statewide list of water resource sites. In the Lycoming Creek watershed, 76 out of 128 (59%) listed water resource facilities are associated with oil and gas activity, including 13 surface water withdrawal sites and 63 interconnections—large impoundments where water is collected and stored for future use. As excessive as these figures are, the state’s water resources data is incomplete. By examining aerial imagery, FracTracker found six impoundments adjacent to oil and gas operations that were not listed in the inventory. The DEP was aware of these facilities and provided data upon request. Multiacre lined impoundments can be identified from such imagery, but the inventory might be missing smaller withdrawal sites occluded from view by the tree canopy.



Lycoming Creek Watershed Water Usage

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Overall, 259 wells reported using between 891,900 and 33,193,599 gallons of water as a base for their fracking chemical cocktail. 


These numbers only represent the water consumed for hydraulic fracturing and don’t include any water used for pipeline hydrostatic testing, dust suppression on dirt and gravel roads, or any other purpose. For example, the voluminous 33,193,599 gallons used to frack Alta Resources’ Mac North B-3H well pad represents only a fraction of its permitted capacity for fracking operations.


Figure 12. A lined impoundment that does not appear on DEP’s Water Resources inventory. Photo by Karen Edelstein.

FracFocus

The unconventional oil and gas industry dominates water extraction, distribution, and use throughout the watershed. The amount of water used per fracked well has increased dramatically over the years, according to data from the industry’s frack fluid registry, FracFocus.  

However, the registry is riddled with some obvious data inaccuracies—perhaps stemming from the fact that the registry is self-reported by the various operators.

For example, there are 272 well reports with latitude and longitude coordinates placing them inside the Lycoming Creek watershed, excluding wells where operators left the water usage field blank. There are some problematic data points with those remaining. 

Five wells reported a negative number of gallons used to stimulate wells, including four from Seneca Resources’ Gamble K well pad—with quantities ranging from -214.7 million to -1.18 billion gallons of water—and one well from EXCO Resources’ Emig Unit well pad that registered -859.0 million gallons. At the other end of the spectrum, eight wells reported water consumption over 100 million gallons, including four from Rockdale Marcellus’ Cochran well pad, two from Seneca Resources’ Gamble K well pad, and two from EXCO Resources’ Emig Unit well pad.  

As water consumption data of these 13 wells is obviously erroneous, they were excluded from the following analysis. 

These withdrawal allowances are truly staggering. 

Based on observations of consumptive use permit signs across the watershed, these water withdrawal limits are typical. Taking the 7.62 billion gallons per well pad average from Figure 15, this equates to about 716 billion gallons of permitted water consumption for the 94 well pads in the watershed that have at least one well with an active, regulatory inactive, or plugged well status. Given the average household consumes about 300 gallons of water per day—and that Pennsylvania has just over 5 million householdsthis volume is nearly equal to the entire residential consumption of the state for 628 days. If this is applied to each of the 125 proposed well pads, that figure rises to about 953 billion gallons, or a little less than the full capacity of Florida’s vast Lake Okeechobee.



Groundwater contamination


Contamination from spills and leaks can affect more than just surface water. In 2014, 75 water wells in Lycoming County—which includes most of the Lycoming Creek watershed—were tested for various contaminants by the United States Geologic Survey (USGS). Six wells with the highest methane concentrations were further analyzed for their ratio of chloride to bromide, with half of that smaller subset showing water chemistry indicative of mixing with oilfield brine. Although the study posited that it could be mixing deep in the aquifer, it did not mention the frenzied drilling in the region at the time of sampling.

Stemming from thousands of complaints across the Marcellus Shale region, there are 378 private water supplies where DEP determined the loss of water quality or quantity was because of oil and gas activities. The public isn’t provided with the exact location of these fouled wells due to privacy concerns of impacted residents, but it is known that 18 incidents occurred in municipalities wholly or partially within the Lycoming Creek watershed. 

According to Pennsylvania’s Act 13—an instrumental law governing various aspects of unconventional drilling in the state—oil and gas operators are presumed responsible for water wells negatively affected within 12 months and 2,500 feet of operations. Of course, the actual spread of a pollution plume depends on the characteristics of the aquifer itself, rather than definitions from Act 13, so it is possible that wells further than 2,500 feet from an incident could be negatively impacted—potentially years after the leak or spill occurred. 

Of the 18 determination letters issued by DEP, one occurred in Fox Township in Sullivan County, six in Liberty Township in Tioga County, and two in Union Township. In Lycoming County, Eldred Township received three, Hepburn Township got one, Jackson Township received two, and McNett Township got two.  

As previously mentioned, DEP also tracks violations of various state oil and gas regulations. The vast majority of incidents in the Lycoming Creek watershed resulted in an impact to surface or groundwater. Of the 634 total citations associated with unconventional wells and well pads: 41 (six percent) related to erosion and sedimentation concerns, which could harm aquatic life; 379 (60%) citations were for spills, leaks, or pollution discharges that degraded surface or groundwater; and 41 (six percent) were for other water issues. The remaining 173 (27%) violations were for various other shortcomings—most issued for improper handling of waste materials. Depending on what happened in the field to merit these violations, many of these incidents may also have had an impact on Pennsylvania’s waters.

Water is a defining characteristic for any watershed. From the expansive wetlands uphill to the brisk trout streams around Rock Run and the McIntyre Wild Area, down to the steep ravines of the Lycoming Creek, water makes this area special. In the rush to accommodate the thirsty and pollutive oil and gas industry, the state has allowed vast portions of the region to be spoiled. 


Figure 13. Water consumption per well in the Lycoming Creek watershed has increased nearly five-fold in less than a decade, from 3,679,467 gallons in 2011 to 17,512,356 gallons in 2020, according to FracFocus data downloaded April 28, 2021.



Figure 14. Water consumption postings for six ARD (Alta Resources Development) well pads. Of the five visible signs, water consumption was permitted at 3 to 4 million gallons per pad, per day, for over five years. Photo by Erica Jackson.



Figure 15. The five visible signs in Figure 14 show that well pads are permitted to withdraw over 38.1 billion gallons of water, or an average of 7.62 billion gallons per well pad.

Waste

When fossil fuel companies portray fracked gas as “clean,” they better hope the public doesn’t notice the enormous stream of liquid and solid waste. In the Lycoming Creek watershed, operators reported 9,064,377 barrels (380.7 million gallons) of liquid waste and 416,248 tons of solid waste were generated in the drainage between January 2011 and April 2021.

As a point of comparison, this volume of liquid waste—from 362 wells in the watershed—is equal to about 577 Olympic-sized swimming pools, or an acre of land covered in toxic waste 1,168 feet deep. In terms of solid waste, disposal of drill cuttings and other substances equals the garbage left behind after 8,672 Kenny Chesney concertslike having about 2.3 concerts every day. This estimation is based on 330 wells reporting solid waste generation in the watershed.



Lycoming Creek Waste

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Problems with oil & gas waste


To compare chemical-laden flowback fluid and radioactive brines to pool water based on volume alone does little to communicate the dangers of liquid waste—just as comparing drill cuttings and filter socks to beer cans and food wrappers is insufficient.

Oil and gas waste is much more harmful to human health and the environment than normal household refuse. 

Flowback fluid includes a portion of the liquid injected into a wellbore during hydraulic fracturing. As presented in the Water section, the volume of water injected into each well averaged over 17.5 million gallons in 2020. The industry’s chemical registry site FracFocus estimates that between one-half percent and two percent of the injected volumes are composed of various chemical additives. To get an accurate estimate of the volumes of these chemicals, it is necessary to add the water volume and the non-water volume together, then calculate the above range. Unfortunately, only 18 out of the 259 wells in the watershed that provide believable water volumes also provide non-water volumes.

Approximately 25% of these chemical additives could cause cancer, according to recent studies—while others may inflict skin or respiratory damage.

What is now the Marcellus Shale formation was an ancient, shallow seabed around 384 million years ago in the Middle Devonian epoch. As this sea dried out, organic content concentrated, which would eventually be the source of hydrocarbon gasses. Other components saturated with this organic matter—including barium, benzene, chloride, radium, thallium, and more. These contaminants resurface with the oil and gas, either dissolved or suspended in fluid waste called brine. Brine will continue to rise to the surface in significant quantities during a well’s operating lifespan.

Drill cuttings comprise most of the solid waste from oil and gas sites in Pennsylvania. As with brine, these cuttings contain concentrations of the same toxic and radioactive chemicals. Whether used onsite or sent to landfills, these cuttings are problematic when precipitation causes contaminants to leach, posing risks to aquifers and surface waters. Traditionally, landfill leachate is taken to water treatment facilities. However, these facilities are ill-equipped to handle oil and gas waste and cannot effectively remove the contaminant load.


What happens to the waste?


In 2019, FracTracker analyzed and mapped the destination of Pennsylvania’s oil and gas waste from 2011 through 2018 in a project with Earthworks. Most waste stays in Pennsylvania and neighboring states, but this still requires thousands of heavy tankers travelling tens or even hundreds of miles to reach their destinations. The industry ships some waste as far as Texas, Utah, and Idaho, despite enormous transportation costs. The project underscored Pennsylvania’s incapacity to deal with this noxious and problematic waste stream.

This waste is handled in various ways, with about 54% reused at other fracking sites, 30% sent to residual waste processing facilities, and ten percent disposed in injection wells. Most of the remaining six percent is sent to surface impoundments—but it is not clear what happens to the waste from there.

For solid waste, 56% goes to landfills, 34% is reused at well pads, and eight percent goes to residual waste processing facilities—with the rest handled by other methods.

There is record of 124 waste facilities in the Lycoming Creek watershed, including 121 well pads, one landfill, one residual waste processing facility, and one temporary storage site, pending future reuse or disposal.

The Clean Earth facility—a landfill and drilling mud processing facility—has taken 157,457 tons of solid oil and gas waste and 315 barrels of liquid waste from 2013 to 2016. Between 2012 and 2013, the facility operated as Clean Streams, LLC, and accepted 10,610 additional tons of solid waste and 513,894 barrels of liquid waste. At the watershed’s northern border in Tioga County is Rockdale Marcellus’ Harer Beneficial Reuse facility. Beech Resources proposed an additional facility in currently forested land across US Highway 15 from the Clean Earth facilities.


Figure 16. Estimated chemical components of fracking fluid for the 18 wells in the Lycoming Creek watershed that provide non-water volumes. The minimum estimate is 965,434 gallons, based on 0.5% chemical concentrations, while the maximum estimate is 3,861,737 gallons, based on two percent concentrations.



Figure 17. Disposition method of liquid waste from unconventional wells in Pennsylvania in 2020, based on DEP waste reports. The total liquid waste volume was 61,832,431 barrels, or about 2.6 billion gallons.



Figure 18. Disposition of solid waste from unconventional wells in Pennsylvania in 2020. Total statewide mass was 1,397,678 tons.


Mountains of waste

As drilling continues in the Lycoming Creek watershed and nearby, enormous waste streams will continue to be a conundrum. Even reused material might contaminate the land, streams, and groundwater, and harm human health. As wells are fracked with ever-increasing volumes of fluid, they will return ever-increasing volumes of waste, requiring more and more resources to process.



To see more footage & photos from this project:





Field Day Description

On a sunny and brisk Thursday in May 2021, a group of 11 FracTracker staff members and volunteers gathered in the Lycoming watershed outside Williamsport to find and document unconventional oil and gas activities and infrastructure.

This field day was in part informed by insights from members of the Responsible Drilling Alliance, a regional organization, and the knowledge and experiences of Peter Petokas, a biology and environmental science professor at Lycoming College who has explored and kept tabs on the area’s hellbender habitats for years.

FracTracker’s Matt Kelso used DEP data to develop maps illustrating various infrastructure, including 384 drilled wells on 96 different pads, nine compressor and metering stations, and 67 water facilities related to oil and gas extractionincluding 12 surface water withdrawal sites and 55 storage reservoirs. He then divided an area of about 272 square miles into five sections, and at least two participants explored each section. 

Using Matt’s maps, FracTracker’s mobile app, cameras, decibel and distance measuring apps, and other tools, the group visited and documented various infrastructure—while observing significant truck traffic and other evidence of the industry’s pervasiveness. As the groups navigated rural back roads and small state highways, many were struck by the juxtaposition of a bucolic landscape of rolling hills, green forests, and peaceful farmland with imposing, pollutive, and sometimes noisy and smelly fracking sites.

Additional fieldwork was conducted with assistance from Earthworks’ staff and their FLIR technology, as well as aerial photography and videography captured by FracTracker’s Ted Auch—with flying assistance from partners at LightHawk.

FracTracker then used the geolocated photos, video, and site-specific descriptionscoupled with variable datasets, research, and other literatureto compile this Story Atlas, an educational tool for concerned residents of the Lycoming Creek watershed, and an insightful resource for others living near fracking activity. 

The mobile app reports from this reconnaissanceand from locations across the U.S.are visible on the FracTracker mobile app, available for download on your iOS or Android device, or by visiting the web app at https://app.fractracker.org/.



Figure 19. The field day volunteers gathered before exploring the Lycoming Creek watershed. Photo by Shannon Smith, FracTracker Alliance.



Figure 20. This FLIR footage was recorded by Earthworks at NFG Midstream Trout Run LLC’s Hagerman gas processing and metering facility in Trout Run, Pennsylvania in June 2021. This recording captures visible air pollution from combustion and fugitive emissions at the facility.

Lycoming Creek Photo Map

View Full Size Map | Updated 3/1/2021 | Data Tutorial


Local insights

Much has changed in the Lycoming watershed since unconventional oil and gas exploration ramped up over the last 15 years—in terms of ecological deterioration, as well as the deterioration of locals’ attitudes toward the industry.

At first welcomed by many as a chance for financial gain through mineral rights leasing, some community members—especially those whose families have lived in the area for generations—watched their land drastically degenerated and their sovereign land rights eclipsed by industrial encroachment they did not foresee.

Between 2011 and 2018, unconventional oil and gas drilling—notably, hydraulic fracturing—transformed sections of forest and farmland into comparatively gritty industrial zones. 

“They were assured that, after the drilling phase was completed, they would hardly know the wells were there. They were also told that they had to decide quickly, and that everyone around them had already leased. A local anti-drilling advocacy group tried to warn them, but many locals distrusted environmentalists.”

As author and professor Colin Jerolmack references in his recent article for The New Republic, some landowners who willingly leased their mineral rights to oil and gas companies now view the industry’s activities with consternation. Incessant noise, traffic congestion, and foul odors have tarnished the once peaceful countryside. Even more disconcerting for property owners, the industry often operates however they please, with little consultation or consent—making some feel that they have lost their decision-making power and agency.

This disaffection potentially makes room for environmentalists to find common ground with those who embraced the industry, couched not in anti-fracking sentiments—and not necessarily in the essential need to mitigate the climate crisis—but in their shared love for the land.

Another big ecological concern in the punctured watershed centers on the fragile Eastern hellbender populations. Five conservation groups filed a lawsuit on July 1, 2021, challenging a 2019 decision to deny the amphibian protection under the Endangered Species Act. 

“The hellbender is an ancient species that deserves better protections,” said Betsy Nicholas, Executive Director of Waterkeepers Chesapeake, one of the groups involved in the lawsuit. “The hellbender reminds us that we all live downstream. As the upstream tributaries are disturbed and polluted, the hellbender disappears. And the same pollution flows downstream to our populated areas, threatening the use and enjoyment of our rivers. We need to pay attention to what happens to the hellbender.”

Once widespread across 15 states, Eastern hellbenders have been eliminated from most of their historic range and continue to face many threats, including low water flow and poor water quality, increasing water pollution, deforestation, residential development, mining—and of course—oil and gas development. 

Peter Petokas has been studying Eastern hellbender populations in the Lycoming watershed for 16 years. He is very concerned for the future of the species in the watershed, which holds one of the richest populations in Pennsylvania, concentrated in one of the few remaining streams with optimal water quality. Even so, a drought in 2020 left the area’s waterways with very low flows, which constrains the hellbender’s habitat and stresses the population. Because they lack protection under endangered species status, agencies may be remiss to implement enhanced regulations on discharges and withdrawals in the basin. Petokas remains hopeful that the pending lawsuit against the US Fish & Wildlife Service will restart an assessment for federal endangered/threatened species protection.

“If there’s ever a spill of anything, it’s the end, it would wipe out one of the best hellbender populations in Pennsylvania,” Petokas said.

Besides concerns about low water levels, the watershed is losing tree cover along streams to invasive insects and erosion. Riparian species like ash, sycamore, and river birches provide shade and keep the water cool enough for hellbenders to thrive. 


Figure 21. A pipeline path cuts through forest in McNett Township, Lycoming County. Photo by Shannon Smith.

What does the future hold?

“An ecological threshold is the tipping point at which incremental changes or disturbances cause drastic or disproportionate results … When you remove land past the ecological threshold, a species no longer has the options to tolerate the disturbance. Beyond this point, the losses become disproportionately large.” [i]

In addition to creating new stressors on aquatic life, natural gas development in the Lycoming Creek watershed—particularly land use changes—affect bird communities. The area contains nesting habitat for many species or is an important stopover during seasonal migrations. Forest interior birds, like the cerulean warbler, are most vulnerable. They need pristine habitat.

A watch list of birds threatened by gas development in northeastern Pennsylvania features several warblers, thrushes, vireos, and woodpeckers. Nearly half of the birds are on a conservation priority list, underscoring that fracking jeopardizes species already at risk. All bird species on the watch list are known to nest in or visit the Lycoming Creek watershed.

The noise, noxious fumes, and land clearing correspondent with fracked gas takes a toll on human communities, too. 

A loud and obtrusive competitor has complicated access to unfettered public forests. This troublesome tenant strains local resourcesand relationships. Rural qualities erode like the overburdened roads.

According to Colin Jerolmack—when writing about this very place in Up to Heaven and Down to Hellone’s decision to lease, “… alienates others’ rights to liberty and property.” [ii] This paradigm, “prevents many community stakeholders from having a say in decisions even though they absorb the externalities.” [iii]

The externalities here and in other gas and oilfields are consequential for the entire global community. “It seems increasingly apparent that to prevent catastrophic global warming, society must decarbonize rapidly,” [iv] says Jerolmack. 

Burning more methane will not get us to that goal. Words of wisdom flow from native sources: 

“At the height of battles over strip mining for coal, back in the 70s, it seemed unimaginable that we would knowingly make the same mistakes again with potential for doing such harm,” says Tim Palmer, former Lycoming County resident and author of Twilight of the Hemlocks and Beeches, “but here we are with another fossil-fuel industry leaving its mark that may last for generations on our land, waters, and communities.”  

“Fight like hell to mitigate the harm … while trying to stop the industry’s spread,” [v] says Ralph Kisberg, an activist from Williamsport. People are making a difference, from afar and closer to home, and Kisberg is optimistic. “I doubt I’ll live to see a clean energy world, but maybe a clean energy U.S. economy…” [vi]

Clean and restorative, like the promise of a cool mountain stream.


Figure 22. Miner’s Run, a stream in the Lycoming Creek watershed. Photo by Tim Palmer.

THANKS TO…



Thank you to all the inspiring and persistent environmental stewards who have contributed to the creation of this digital atlas:


Project funding provided by:


SOURCES

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Risky Byhalia Connection Pipeline Threatens Tennessee & Mississippi Health, Water Supply

 

VIEW MAP & DATA

Overview

In December 2019, Plains All-American and Valero pipeline companies announced plans to build the 49-mile Byhalia Pipeline through southwestern Tennessee and northwestern Mississippi. The proposed Byhalia Connection Pipeline is a 24-inch, high pressure (1500 psi) conduit, conveying crude oil coming Oklahoma, bound for the Gulf coast. The pipeline, which is designed to carry up to 420,000 barrels of oil a day, provides a link between the Diamond Pipeline to the west and the Capline Pipeline to the east. Construction is planned to begin in early 2021, and be completed by year’s end. Plains All-American insists that all safety precautions are being considered, but the outcry among residents and environmental advocates has been considerable.

Many factors—environmental, geological, social, and economic—have emerged as reasons that this pipeline should not move ahead. And industry most certainly didn’t count on pushback from the local community. Residents, allies, and the media have risen up to challenge the project. In this article, we’ll take a look at the story from various perspectives, augmented by FracTracker’s mapping insights.

UPDATE: On Friday, July 2, 2021, Plains All American announced that it would be abandoning its plans to build the controversial Byhalia Connection Pipeline. As one activist involved in the fight proudly stated, “We’ve shown them that we aren’t the path of least resistance. We are the path of resilience.” Read more about this momentous victory for the people of South Memphis here

Contents

Environmental and hydrological

Human health

Geological

Demographics and disaster preparedness

Economics and land ownership

Pipeline Incidents

Where From Here?


Byhalia Connection Pipeline

This interactive map looks at the various risks associated with the proposed Byhalia Connection Pipeline. The map contains all of the data layers related to the topics in this article. Scroll down in this article to find interactive maps separated out by topic. All data sources are listed in the “Details” section of the maps, as well as at the end of this article. Items will activate in this map dependent on the level of zoom in or out.

View Full Screen | Updated March, 2021

Environmental and hydrological

The 49-mile route of the proposed Byhalia Connection Pipeline passes through a patchwork of rural, suburban, and urban landscapes. Along the route, the pipeline would cross seven named waterways — Johnson Creek, Hurricane Creek, Bean Patch Creek, Camp Creek, Short Brook, Camp Creek Canal, and Coldwater Creek — and also pass immediately adjacently to a nearly 5-mile-long wetlands complex that surrounds the Coldwater River. But the natural environment is home to many more waterways than those that have official names on topographic maps. According to FracTracker’s inspection of National Wetlands Inventory data collected by the United States Fish and Wildlife Service, the proposed pipeline crosses or touches 62 streams in 102 separate locations, 25 forested wetlands, an emergent wetland, 17 ponds, and one lake.

Close to the City of Memphis, 0.8 miles of the pipeline would run directly through the Davis Wellfield Wellhead Protection Zone. The proposed pipeline is located over the extraordinary Memphis Sands Aquifer, which provides potable water for more than 400,000 people. Memphis Light, Gas and Water (MLGW) Company pumps water from over 175 artesian wells in Shelby County, Tennessee, alone—right in the path of the pipeline route. The aquifer itself is a sensitive resource, already under demand by the human population of the area, as well as many industries such as breweries and as a supply of cooling water for a nearby power plant.

Memphis Sands Aquifer is part of the larger Middle Claiborne Aquifer, a groundwater and geological unit in the lower Mississippi drainage. Technically speaking, the Memphis Sands portion of the aquifer is located in Tennessee, but is continuous with the Sparta Sands Aquifer, located in Mississippi. In the eastern portion of the Byhalia Connection’s proposed route, wetlands along Coldwater River are directly part of the recharge zone of this aquifer.

Byhalia hydrologic components

To learn more about the hydrologic features that may be impacted by the proposed Byhalia Connection Pipeline, explore our interactive map. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu.

View Full Screen | Last updated March 2021

 

The Memphis Sands Aquifer lies 350 to 1000 feet under Memphis (see Figure 1), and spans an area of 7500 square miles, roughly the size of Lake Ontario. “It’s one of the best (aquifers) in the world in terms of thickness, aerial content, quality of water”, according to Roy Van Arsdale, Professor of Geology at University of Memphis. Under Shelby County alone — where Memphis is located — the aquifer contains approximately 58 trillion gallons of clean water. Over time, the aquifer has seen threats from overpumping, as the population of Memphis grew. In addition, industrial pollution has turned up in some samples, including cancer-causing benzene. Policy protections on the aquifer have been lacking, although there is increasingly vocal public awareness about the need for more comprehensive groundwater resource protection in the area.

 

Figure 1. Cross-section of aquifers under Memphis, TN. Graphic modified from here.

 

Although water withdrawals from the aquifer have declined significantly since 2000 due, in part, to more water-efficient household appliances that reduce demand in comparison with older models, the MLGW pumped 126 million gallons a day from the aquifer in 2015. Consequently, the level of the aquifer has been rising in recent years, as the rate of recharge has exceeded use.

The courts have suggested that the water in the aquifer is an intrastate resource, and that therefore, Mississippi cannot have sole governance over the extraction of the water within its state boundaries. Instead, usage should be through “equitable apportionment.” Further arguments are still pending, as of late 2020. In short, as Figure 1 shows, withdrawal and recharge of the aquifer do not respect state boundaries.

The details of water law, and who can tap into these, and other deep, ancient aquifers, are complex questions in which agriculture, ecology, geology, and technology bump up against each other. All of these interests, not to mention human health, could be heavily impacted by a crude oil pipeline rupture or other accident that resulted in contamination of this groundwater resource.

Human health

Crude oil spills release a panoply of volatile organic compounds into the air and water that are extremely harmful to human and environmental health. These include benzene, ethylbenzene, toluene, and xylene. Polycyclic aromatic hydrocarbons (PAHs), such as carcinogenic benzo[a]pyrene, are also released. In addition, if the oil combusts, hydrogen sulfide gas, as well as heavy metals, including nickel, mercury, and cadmium, will become airborne.

Figure 2. Observed/documented oil spill-induced acute and chronic human health effects. Source: Guidance for the Environmental Public Health Management of Crude Oil Incidents, Health Canada (2018).

 

The take-away is that crude oil spills from pipelines are not uncommon, result in environmental damage, impacts on the health and safety of workers and nearby residents. Most importantly, despite monitoring and inspections, pipelines fail. A partial list of pipeline failures is shown in the sidebar.

Within the 2-mile buffer of the pipeline, there are 20 facilities that the United States Environmental Protection Agency (US EPA) lists in its Toxic Release Inventory (TRI), including several chemical plants associated with hydrocarbon extraction. Carcinogens such as polycyclic aromatic compounds, benzene, styrene, dioxins, and naphthalene are just a few of the compounds produced by facilities owned by Valero Energy Corporation, Drexel Chemical Company, and other companies within the 2-mile buffer zone of the pipeline, which compound the risks to the populations there. In addition, while the TRI lists exposure to toluene and xylene from these facilities, neither are categorized by EPA’s TRI database as a carcinogen due to a lack of data; however, their deleterious impacts on the central nervous system are undeniable, and well- documented (see examples here and here).

Byhalia civic and industrial facilities

View Full Screen | Updated March, 2021

In this interactive map, you can see sites in the proposed Byhalia Connection route that are listed in the TRI, as well as civic facilities like schools, daycare centers, and health care facilities. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu.

Geological

The most active seismic fault line in the eastern United States — the New Madrid Fault — is located about 40 miles from one end of the proposed pipeline (see Figure 2). The last major earthquakes along this fault line occurred in 1811 and 1812. Although the current Richter scale was not in use at that time, first quake in mid-December 1811 was estimated to have had a magnitude of between 7.2 and 8.2, and was followed by an aftershock of about 7.4. In January and February of 1812, there were additional earthquakes of this magnitude. Obviously, at this time in history, there was relatively sparse population in the area, and little infrastructure. Were such a quake to occur today, the outcomes would be catastrophic.

Figure 3: New Madrid Seismic Zone. Source: United States Geological Survey

 

According to a Wikipedia entry, “[i]n October 2009, a team composed of University of Illinois and Virginia Tech researchers headed by Amr S. Elnashai, funded by the Federal Emergency Management Agency, considered a scenario where all three segments of the New Madrid fault ruptured simultaneously with a total earthquake magnitude of 7.7. The report found that there would be significant damage in the eight states studied – Alabama, Arkansas, Illinois, Indiana, Kentucky, Mississippi, Missouri, and Tennessee – with the probability of additional damage in states farther from the New Madrid Seismic Zone. Tennessee, Arkansas, and Missouri would be most severely impacted, and the cities of Memphis, Tennessee, and St. Louis, Missouri, would be severely damaged. The report estimated 86,000 casualties, including 3,500 fatalities, 715,000 damaged buildings, and 7.2 million people displaced, with two million of those seeking shelter, primarily due to the lack of utility services. Direct economic losses, according to the report, would be at least $300 billion.” Source: University of Illinois report]

Another article on the New Madrid fault added that “….the US Geological Survey and the University of Memphis Center for Earthquake Research estimate there’s a 7 to 10 percent chance of a major quake — one with a magnitude between 7.5 and 8.0 — occurring in the region in the next 50 years….’ The scope is about as big as you could possibly have,’ said Jonathon Monken, director of the Illinois Emergency Management Agency and chairman of the Central U.S. Earthquake Consortium… ‘Putting it in a purely financial context, Hurricane Katrina was a $106 billion disaster. We estimate this would be a $300 billion disaster, the worst in the history of the United States.’”

Earthquake damage to pipelines can occur from movement on the fault itself, soil liquefaction, uplift, and landslides, resulting in potentially catastrophic situations. Engineering solutions to minimize or prevent seismic damage to pipelines do exist. These solutions must be part of the overall pipeline design, however. For example, the Trans-Alaska oil pipeline was constructed with considerations for earthquake impacts in mind. For more information, read about the solution that was implemented there.

Byhalia geological context

This map shows the New Madrid seismic zone in the context of the proposed Byhalia Connection Pipeline. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu.

View Full Screen | Updated March 2021

Demographics and disaster preparedness

As eloquently reported in a series of articles in mlk50.com, the siting of the Byhalia Connection Pipeline is not only an issue environmental tied with the natural environment. This is very much an issue of environmental justice, as well. Many of the census blocks along the proposed, preferred route of the pipeline, are 99% Black. Boxtown, a community in southwest Memphis is one of places, and already has a long history of impacts by environmental contamination from the dozens of industries that operate there. Toxic waste from coal power plants includes heavy metals and radioactive materials.

The pipeline route from Memphis to its terminus in Mississippi takes a circuitous route, avoiding wealthier parts of the city and its suburbs, but goes directly through low-income areas, some of which are inhabited by a nearly 100% Black population.

FracTracker looked at US Census data along the pipeline route, and calculated a half-mile (minimum recommended) and two-mile buffer zone from the pipeline right-of-way to consider populations that might be impacted in the case of an accident.

Byhalia route demographics

Explore the the demographics along the proposed Byhalia Connection Pipeline route. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu, such as the non-white population ration along the proposed pipeline route.

View Full Screen | Updated March 2021

There are 15,000 people living in the immediate evacuation zone of a half mile from the pipeline. In some parts of South Memphis, within this half-mile evacuation zone, population density is above 4,000 people per square mile, and the Black population approaches 100%. Within a two mile distance, the number climbs to over 76,000. Depending on the direction of the wind, a crude oil-induced fire could spew dangerous levels of volatile organic compounds through the air towards these populations. The disproportional risks to minority and low-income populations make the location of this pipeline — undeniably — an issue of environmental justice.

 

Demographic Within ½ mile of Byhalia Connection Pipeline Within 2 miles of Byhalia Connection Pipeline
Total population 15,041 76,016
Non-white population 7204 (48%, although some parts of South Memphis are 99+%) 27,548 (36%, although some parts of South Memphis are 99+%)
Low income population 4272 (28%, although some parts of South Memphis are 90+%) 43,486(57%, although some parts of South Memphis are 90+%)

Table 1: Population demographics along the proposed Byhalia Connection pipeline corridor.

 

Key civic facilities are also located within the half-mile evacuation zone of the pipeline. Were a disaster to occur, would the schools, childcare centers and medical facilities be able to successfully usher their residents and students to safety? Would they have had regular safety trainings to prepare them for this possibility?

 

Facility Within ½ mile of pipeline Within 2 miles of pipeline
Child care 4 (one within 800 feet) 30
Public school 2 (one within 800 feet) 26
EMS 2 11
Hospital 0 1
Private school 0 1

Table 2: Facilities along the proposed Byhalia Connection pipeline corridor (also shown in the interactive map here).

 

Al Gore calls proposed Byhalia Connection pipeline ‘reckless, racist rip-off’ at rally

Former Vice President Al Gore voiced his opposition to the Byhalia Connection and put Memphis elected officials on notice during a rally against the pipeline on March 14, 2021.

Source: Article in commercialappeal.com

“Why is it that 64% of the polluting facilities of these pipeline communities are located in or adjacent to Black communities? Why is it that the cancer rate in SW Memphis four times higher than the national average? Why is it that Black children suffer from asthma three times more than white children? Why is it that the death rate from asthma for Black children is ten times higher than for white children?” – Former Vice President Al Gore

And two days later, on March 16th, the Memphis City Council unanimously approved a resolution that opposes the Byhalia Connection Pipeline project.

Economics and land ownership

Approximately 300 property owners adjacent to the pipeline have already accepted monetary compensation to abandon their homes or sell property easements to make way for the pipeline. If a landowner refuses payment offered by the pipeline company for a property easement — often far under market value — the company can take the landowner to court, and seize the property (or portion of it) with no requirement of compensation. Although a majority of property owners accepted the terms of the easements drawn up by Byhalia’s developers, at least 14 did not. When numerous owners refused, nine properties were targeted for taking by eminent domain, and sued by the pipeline company. The Southern Environmental Law Center (SELC) is defending many of these property owners, claiming that the seizures — regardless of whether they are temporary or permanent — do not comply with the criteria of meeting a public good. The oil being transported in the proposed pipeline is entirely bound for export.

“The pipeline company is not created by, affiliated with or owned by the government, and the general public would have no access to the proposed crude oil pipeline… So, there is no ‘public use’ justifying the use of the condemnation power as required by Tennessee law,” said one of SELC’s attorneys. In addition, SELC has cited the illegality of the pipeline route because it runs through the municipal wellfield, and therefore violates permits issued by the Army Corps of Engineers. The Army Corp was still considering this request, as of mid-January 2021.

Furthermore, the eminent domain targeting of land owned by Black Americans in the south is a pointed question of racial justice. Historically, black and brown people throughout the United States have had far lower levels of home ownership than whites. This gap is most pronounced in lower income areas.

Figure 5: Homeownership rate in the US, by household income (2017). Source: The Urban Institute.

 

“The 71.9 percent white homeownership rate in 2017 represented a 0.7 percentage point decline since 2010, and the 41.8 percent black homeownership rate represented a 2.7 percentage point decline during that same period. The 30.1 percentage point gap is wider than it was when race-based discrimination against homebuyers was legal.” The Urban Institute

Figure 6: Homeownership in the US by race or ethnicity. Source: The Urban Institute.

 

Losing land to eminent domain represents a loss of control for a landowner — white or black. But the loss is especially unjust when a property may have been so hard won, and sometimes the result of a multi-generational lineage of ownership, as is the case for many properties along the Byhalia right-of-way.

Pipeline Incidents

Crude oil spills, 2010-2021

FracTracker has created an interactive map showing the locations of crude oil spills across the United States between 2010 and 2021, using the most up-to-date information from PHMSA, the Pipeline and Hazardous Materials Safety Administration.

View Full Screen | Updated March, 2021


You can also read more about a wider diversity of hazardous liquid materials accidents analyzed by FracTracker in an article from February 2020, entitled “Pipelines Continue to Catch Fire and Explode”.

Case study of a pipeline explosion

A 2020 research paper states, “Modeling and analysis of a catastrophic oil spill and vapor cloud explosion in a confined space upon oil pipeline leaking” provides a stark example of the damage done from the leak and explosion of a crude oil pipeline operating at a third of the pressure proposed for Byhalia.

“It is obvious that the explosion caused big damages to the adjacent buildings, roads, and public structures. Moreover, the explosion, combustion, and the shock wave caused injuries and deaths of workers, pedestrians, and residents. The total affected zone spread nearly 5 km [3.1 miles].”

 

Note: The oil pipeline shown in Shengzhu, Xu, et al.’s paper in was 28 inches in diameter, and operating at a pressure of between 400 and 660 psi. A vapor cloud from the spill into a municipal drainage area caused this explosion, which killed 62 people and injured 136 in November 2013. The 24-inch, proposed Byhalia pipeline would operate at triple the pressure of the pipeline shown in these photos of its explosion.

(a) bird’s eye view of the location of the explosion point, (b) scene of the oil spill point after explosion, (c) scene of the nearby street, (d) scene of the drainage of the adjacent plant.

Figure 7: Scene of an oil pipeline explosion site in China. (a) bird’s eye view of the location of the explosion point, (b) scene of the oil spill point after explosion, (c) scene of the nearby street, (d) scene of the drainage of the adjacent plant. Image from Shengzhu, Xu, et al.

Guidance in the case of a crude oil incident

Health Canada published the information document Guidance on the Management of Crude Oil Incidents (2018), which details important information about how to deal with crude oil spills. Here are checklists on whether to evacuate or shelter in place and information on determining protective zone distances, particularly downwind of a spill from the 2016 Emergency Response Guidebook.

In case of a large spill: Consider initial downwind evacuation for at least 300 meters (1000 feet).

In case of a fire: If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions. Source: Petroleum crude oil hazards

Where from here?

The Byhalia Connection Pipeline is receiving considerable scrutiny, both from media sources like the Memphis Daily News and MLK50, as well as advocacy groups including Sierra Club’s Tennessee Chapter, the Southern Environmental Law Center, Memphis Community Against the Pipeline, and Protect Our Aquifer. In a move considered egregious by a vast swath of stakeholders, in early February 2021, the US Army Corps of Engineers approved a Nationwide 12 permit to fast-track the Byhalia project, effectively cutting out public comment from the process, and lightening the environmental review requirements. Because the project touches vulnerabilities in the intersection of environment, economics, health, safety, and social justice, this discussion is not likely to easily recede into the background, despite placating claims by the companies that are poised to profit.

Protests are ongoing, and just recently, on February 22, 2021, United States Congressional Representative Steve Cohen sent a direct appeal to President Biden to revoke a key permit for Byhalia, directly citing the burden the pipeline would impose on long-suffering Black neighborhoods in South Memphis. Simultaneously, the Public Works Department of Memphis is considering a resolution condemning the pipeline, and asking the Memphis Light, Gas, and Water Division to oppose the project.

This story will undoubtedly continue to evolve in the upcoming months.

The Takeaway

Regardless of where a pipeline is sited, there are inevitably risks to the environment, and to human communities living nearby. The proposed Byhalia Connection pipeline project is situated in a particularly problematic intersection where environmental justice, hydrology, geology, and risks to human and environmental health intersect. Without taking all of these factors into consideration, a potentially catastrophic cascade of impacts may ensue. Engagement and resistance to the project by the residents in the area, as well as support by advocacy groups, will hopefully result in comprehensive consideration of all the risks. Time will tell whether the project is modified, or simply defeated.

References & Where to Learn More

MLK50.com maintains an archive of excellent reading materials on this controversial project that can be found here.

Topics in this Article

Pipelines | Social | Water

Data Sources in this Article


Los Angeles, California skyline

California Oil & Gas Setbacks Recommendations Memo

 

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.”

 

Below is the introduction, and you can find the full memo here.

Introduction

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.

 

 

Please find the full memo here.

 

 

 

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Pipeline Map

Mariner East 2 Causes Dozens of Spills Since Lockdown Began, Over 300 in Total

FracTracker Alliance has released a new map of 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.

What you need to know:

  • Sunoco’s installation of the Mariner East 2 pipeline has triggered 320 incidences of drilling mud spills since 2017, releasing between 344,590 – 405,990 gallons of drilling fluid into the environment. View an interactive map and see a timeline of these incidents.
  • 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.

Pipeline Map

 

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. 

ME2 Background

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:

Three dozen spills during COVID-19 pandemic

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.

The most concerning occurred on August 10th, when pipeline construction released 8,163 gallons of drilling fluids into a wetland and stream system that drains into Marsh Creek Lake in Chester County, a drinking water reservoir (Figure 1). The Department of Environmental Protection (DEP), Pennsylvania Fish and Boat Commission, private contractors, and the Department of Conservation and Natural Resources are responding to the incident and conducting water tests.

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.

Map of Spills at Marsh Creek Lake

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.

A plume of drilling mud, captured here on video, entered the Marsh Creek Lake and settled on the lake bottom. 

Upper Uwchlan Reroute

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:

Map of pipeline

Figure 2. Possible reroute of Mariner East 2 Pipeline shown with dashed line

The DEP’s order also requires Sunoco to restore and remediate “impacted aquatic life, biota, and habitat, including the functions and values of the impacted wetlands resources, and all impacted recreational uses.” Sunoco must submit an Impact Assessment and Restoration Plan for this drill site by October 1, 2020, and the plan must provide for five years of monitoring after its completed restoration. In the meantime, Sunoco must secure the borehole using “grouting or equivalent method,” and continue to monitor the site. 

Sunoco’s continued negligence

The August incident likely surprised no one, as it was not the first spill at this location, and Sunoco’s own assessment acknowledged that this HDD crossing came with “a moderate to high risk of drilling fluid loss and IRs.”

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.

Bleak outlook for oil and gas pipelines

On top of the delays, fines, strong public opposition, and even House and Senate members calling for permits to be revoked,  there’s another factor working against Sunoco — the bleak financial outlook of the petrochemical industry.

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!

Learn more and donate here.

By Erica Jackson, Community Outreach and Communications Specialist, FracTracker Alliance

This map and analysis relied on data provided by the Pennsylvania Department of Environmental Protection.

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Health & Environmental Effects of Fracking

The Health & Environmental Effects of Fracking

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.

Health Effects

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. 

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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. 

How can I be exposed?

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. 

Methane and Air & Water Quality Concerns

Figure 2. FracTracker’s photo album of air and water quality concerns

Environmental Effects



Air Quality

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. 





Water Quality

 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, click here

A summary of other water contamination pathways can be found on page 13 of Earthworks’ Pennsylvania Oil and Gas Waste Report (2019). 

Soil

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.

Toledo Refining Co Refinery in Toledo, OH, July 2019

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
  • To report a spill or other emergency in PA, contact the PA Department of Environmental Protection (PADEP): 1-800-541-2050 or report to your regional office. In Southwestern PA, call 412-442-4000.
  • PA Department of Environmental Protection (PADEP) Environmental Complaint Line (PA only): 1-888-723-3721 or online. (To find your state environmental or health agency, click here.)
  • Environmental Protection Agency (EPA) Environmental Violations form online.
  • Join the Environmental Health Project Shale Gas & Oil Health Registry & Resource Network here

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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)

A Wealth of Public Lands and Recreational Opportunity

Public Lands

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 Tamarack Run Natural Area protects one of the few enclaves of the tamarack tree, a species of larch common in Canada, but relatively rare as far south as the Loyalsock watershed. 

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.

Trails

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 important bird and mammal species, provide opportunities for birding, and offer a variety of outdoor education resources.



Commercial Opportunities

There are also privately-owned recreational opportunities in the region. A portion of the historic Eagles 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 Mere Tobaggan 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.

Loyalsock State Forest Trail

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)

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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)

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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)

    Diesel exhaust spewing from fracking equipment. Photo by 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)

    Fracking is a heavily industrial activity. Many of these sites in the Loyalsock Creek watershed are immediately adjacent to homes. Photo by 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)

    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. Photo by 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.

Chesapeake Manning July 2020 Earthworks

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.

Oil and gas air pollution isn’t isolated to the Loyalsock watershed, and Earthworks has gathered optical gas imaging evidence of leaks and other air emissions on more PA public lands–like the Allegheny National Forest and the Pine Creek watershed area.


To see more photos and videos FracTracker collected in the Loyalsock Watershed, visit our Flickr album.

Water – a precious resource

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.

Contamination

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. 

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. 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.

Average water use per well in the Loyalsock Watershed

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 twmillion people in the U.S. without running water in their homes.

Operator Average Gallons per Well
Alta Resources 24,658,871
Anadarko Petroleum Corporation 3,320,469
Atlas Energy, L.P. 4,926,427
Chesapeake Operating, Inc. 6,572,047
Chief Oil & Gas 8,537,475
Inflection Energy (PA) LLC 7,716,069
Pennsylvania General Energy 11,680,249
Seneca Resources Corporation 8,410,013
Southwestern Energy 2,355,864

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)

View map fullscreen

A Waste-Filled Proposition

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.

Liquid oil and gas waste produced in the Loyalsock Creek watershed, in barrels. Note that 2020 includes data from January to March only.

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)

Solid oil and gas waste produced in the Loyalsock Creek watershed, in tons. Note that 2020 includes data from January to March only.

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)

For sake of comparison, this amount of liquid waste could fill the Lincoln Memorial Reflecting Pool more than 43 times, while the solid waste from this modest-sized watershed exceeds the weight of three Nimitz-class aircraft carriers.

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. 

Cumulative liquid waste totals produced by oil and gas wells in Loyalsock Creek watershed between January 2011 and April 2020.

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)

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Documentation Field Day

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)

    Loyalsock watershed fractracker app expedition
  • 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)

Click on various elements in te map to see visualizations such as videos, FLIR camera footage, gifs, and photos.


Fig. 32. An interactive map of community-led documentation of oil and gas related impacts in the Loyalsock Creek Watershed. (FracTracker Alliance, 2020)

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Local Insights

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 feet of an existing eight-inch diameter gas 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. 


Thanks to…

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 
  • Lighthawk 
  • Staff at FracTracker Alliance

Project funding provided by The Foundation for Pennsylvania Watersheds

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Mapping gathering lines in OH and WV feature

Mapping Gathering Lines in Ohio and West Virginia

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.

PROJECT DESCRIPTION

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.

Oil and Gas Wells and Gathering Lines in OH and WV

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.

ACREAGE ANALYSIS

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.

Wells and Gathering Lines in Doddridge County, WV

Figure 2. This aerial view map shows connecting gathering line pipelines that cover a small portion of Doddridge County, WV.

 

CONCLUSION

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.

About Me

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

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Oil & Gas waste tank operated by SWEPI and Enervest at the Hayes pad, Otsego County, Michigan May 21st, 2016

The North Dakota Shale Viewer Reimagined: Mapping the Water and Waste Impact

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.

Oil & Gas waste tank operated by SWEPI and Enervest at the Hayes pad, Otsego County, Michigan May 21st, 2016 (44.892933, -84.786530).

Figure 1. Oil & Gas waste tank operated by SWEPI and Enervest at the Hayes pad, Otsego County, Michigan May 21st, 2016 (44.892933, -84.786530). Photo by Ted Auch, FracTracker Alliance.

Environmental economists like to look at energy sources from a more holistic standpoint vis a vis engineers, traditional economists, and the divide-and-conquer rhetoric from Bismarck to the White House. They do this by placing all manner of energy sources along a spectrum of Energy Return On Energy Invested (EROEI).

Since the dawn of the fracking revolution, shale gas from horizontal wells has been near the bottom of the league tables with respect to EROEI which means it “…has decreased from more than 1000:1 in 1919 to 5:1 in the 2010s, and for production from about 25:1 in the 1970s to approximately 10:1 in 2007” for US oil and gas according to Hall et al. (2014). This is what John Erik Meyer has come the “EROI Mountain” whereby we’ve already “burned through the richest resources.”

It stands to reason that if natural gas from fracking were a real “bridge fuel” in the transition away from coal, it would at least approach or exceed the EROEI of the latter, but at 46:1 coal is still four times more efficient than natural gas. However, it must be said that coal’s days are numbered as well. Witness the recent bankruptcy of coal giant Murray Energy, and the only reason its EROEI has increased or remained steady is because the mining industry has transitioned to almost exclusively mountaintop removal and/or strip mining and the associated efficiencies resulting from mechanization/automation.

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.

View map fullscreen 

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).[1]

With respect to the points made earlier about the value of EROEI, this increase in water demand has not been reflected in the productivity of North Dakota’s oil and gas wells, which means the EROEI continues to fall at rate that should make the industry blush.  Furthermore, this trend should prompt regulators and elected officials in Bismarck and elsewhere to begin to ask if the long-term and permanent environmental and/or hydrological risk is worth the short-term rewards vis à vis the “blue water” precautionary principle, in this case of the Missouri River, outlined by Hoekstra et al. (2012). It is my opinion that it most assuredly is not and never was worth the risk!

The most stunning aspect of the above divergence in production and water demand is that on a per well basis, water only costs the industry roughly 0.46-0.76% of total well pad costs. This narrow range is a function of the water pricing schemes shared with me by the North Dakota Western Area Water Supply Authority (WAWSA). This speaks to an average price of water between $3.68 and $4.07 per 1,000 gallons for “industrial” use (aka, fracking industry) by way of eight depots and “several hundred miles of transmission and distribution lines” spread across the state’s four northwest counties of Mountrail, Divide, Williams, and McKenzie.

 

Figure 2. Average Freshwater Demand Per Well and Cumulative Freshwater Demand by North Dakota fracking industry from 2011 to Q1-2020.

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.

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.

 

Earthworks ND Frack Waste Report

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.

 

The Value of Our Water

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.

Data Links

  1. Water Usage for nearly 12,000 fracked laterals in North Dakota up to and including April, 2020. We also include API number and operator in GIS, KML, and Spreadsheet formats. (https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/05/ND_FracFocus_April_2020_With_KML_Excel.zip)
  2. Monthly volumes (2010 to 2020) and demographics for surrounding area for the 675 Class II Salt Water Disposal (SWD) Fracking Waste Injection Wells in North Dakota. We also include API number and operator in GIS, KML, and Spreadsheet formats. (https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/05/ND_ClassII_Well_MonthlyWaste_2010_Q2_2020_Demographics_WithKML_Excel.zip)
  3. North Dakota Gas Plants (https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/GasPlants_WithExcel_KML.zip)

[1] Here in Ohio where I have been looking most closely at water supply and demand across the fracking landscape it is clear that we aren’t accounting for some 10-12% of water demand when we compare documented water withdrawals in the numerator with water usage in the denominator.

By Ted Auch, PhD, Great Lakes Program Coordinator

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