Kyle Ferrar, Western Program Coordinator for FracTracker Alliance, contributed to the December 2020 memo, “Recommendations to CalGEM for Assessing the Economic Value of Social Benefits from a 2,500’ Buffer Zone Between Oil & Gas Extraction Activities and Nearby Communities.”
The purpose of this memo is to recommend guidelines to CalGEM for evaluating the economic value of the social benefits and costs to people and the environment in requiring a 2,500 foot setback for oil and gas drilling (OGD) activities. The 2,500’ setback distance should be considered a minimum required setback. The extensive technical literature, which we reference below, analyzes health benefits to populations when they live much farther away than 2,500’, such as 1km to 5km, but 2,500’ is a minimal setback in much of the literature. Economic analyses of the benefits and costs of setbacks should follow the technical literature and consider setbacks beyond 2,500’ also.
The social benefits and costs derive primarily from reducing the negative impacts of OGD pollution of soil, water, and air on the well-being of nearby communities. The impacts include a long list of health conditions that are known to result from hazardous exposures in the vulnerable populations living nearby. The benefits and costs to the OGD industry of implementing a setback are more limited under the assumption that the proposed setback will not impact total production of oil and gas.
The comment letter submitted by Voices in Solidarity against Oil in Neighborhoods (VISIÓN) on November 30, 2020 lays out an inclusive approach to assessing the health and safety consequences to the communities living near oil and gas extraction activities. This memo addresses how CalGEM might analyze the economic value of the net social benefits from reducing the pollution suffered by nearby communities. In doing so, this memo provides detailed recommendations on one part of the broader holistic evaluation that CalGEM must use in deciding the setback rule.
This memo consists of two parts. The first part documents factors that CalGEM should take into account when evaluating the economic benefits and costs of the forthcoming proposed rule. These include factors like the adverse health impacts of pollution from OGD, the hazards causing them and their sources, and the way they manifest into social and economic costs. It also describes populations that are particularly vulnerable to pollution and its effects as well as geographic factors that impact outcomes.
The second part of this memo documents the direct and indirect economic benefits of the proposed rule. Here, the memo discusses the methods and data that should be leveraged to analyze economic benefits of reducing exposure to OGD pollution through setbacks. This includes the health benefits, impacts on worker productivity, opportunity costs of OGD activity within the proposed setback, and the fact that impacted communities are paying the external costs of OGD.
FracTracker Alliance has released a new mapof drilling fluid spills along the Mariner East 2 pipeline route, showing 320 spills from its construction since 2017. Of those, a combined 147 incidents have released over 260,000 gallons of drilling fluid into Pennsylvania waterways.
The unpermitted discharge of drilling fluid, considered “industrial waste,” into waters of the Commonwealth violates The Clean Streams Law.
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.
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:
There have been 36 spills since the Commonwealth shutdown statewide on March 16th, 2020, leaks that have jeopardized drinking water sources, putting communities at even higher risk during the COVID-19 pandemic.
On August 11th, construction caused a 15-foot wide and eight-foot deep subsidence event in the wetland (Figure 1). This caused drilling fluid to flow underground and contaminate groundwater, while also “adversely impacting the functions and values of the wetland.” Thirty-three acres of the lake are now closed to boating, fishing, and other uses of the lake — an extra blow, given the solace state parks have provided to many during this pandemic.
Figure 1. This HDD crossing in Upper Uwchlan Township, Chester County, caused over 8,000 gallons of drilling mud to spill into waterways. However, installation of the parallel 16-inch pipeline also caused spills at this same location in 2017.
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:
Figure 2. Possible reroute of Mariner East 2 Pipeline shown with dashed line
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.
The fracking boom triggered investment in projects to convert the fracked gas to plastic, leading to an oversupply in the global market. The industry made ambitious plans based on the price of plastic being $1/pound. Now, in 2020, the price is 40 – 60 cents per pound. If the Mariner East 2 pipeline is brought online, it likely will not be as profitable as its operators expected.
The poor finances of the oil and gas industry have led to the demise of several pipeline projects over the last few months. Phillips 66 announced in March it was deferring two pipelines — the Liberty Pipeline, which would transport crude oil from Wyoming to Oklahoma — and the Red Oak Pipeline system, planned to cross from Oklahoma to Texas. Kinder Morgan expressed uncertainty for its proposed Texas Permian Pass pipeline, and Enterprise Products Partners cancelled its Midland-to-ECHO crude oil pipeline project. The Atlantic Coast Pipeline also was cancelled this past July by Duke Energy and Dominion Energy, following “an unacceptable layer of uncertainty and anticipated delays,” and the Williams Constitution pipeline was also abandoned after years of challenges. In fact, the EIA recently reported that more pipeline capacity has been cancelled in 2020 than new capacity brought in service.
Will the Mariner East 2 be the next to fall?
Before you go
A note from the Safety 7: The Safety 7 are seven residents of Delaware and Chester Counties who are challenging Sunoco before the [Pennsylvania Public Utility Commission]. If you are outraged at the ongoing threat to our communities from this dangerous, destructive pipeline, please consider donating to the Safety 7 Legal fund … Our next hearing begins September 29, and funds from your support are urgently needed. This motion is representative of the kind of legal work we need, if we are to prevail in protecting our communities from this dangerous pipeline project. Please contribute today if you are able, and please share this appeal widely and let your friends and family know why this case matters to you!
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/09/ME2FeatureImage.jpg6661500Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngErica Jackson2020-09-17 11:20:062021-04-15 14:16:08Mariner East 2 Causes Dozens of Spills Since Lockdown Began, Over 300 in Total
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.
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.
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
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/07/Mapping-gathering-lines-in-OH-and-WV-feature.jpg8331875Intern FracTrackerhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngIntern FracTracker2020-07-02 12:09:192021-04-15 14:16:43Mapping Gathering Lines in Ohio and West Virginia
We updated the FracTracker North Dakota Shale Viewer with current data and additional details on the astronomical levels of water used and waste produced throughout the process of fracking for oil and gas in North Dakota.
As folks who visit the FracTracker website may know, the fracking industry is predicated on cheap sources of water and waste disposal. The water they use to bust open shale seams becomes part of the waste stream that they refer to by the benign term “brine,” equating it to nothing more than the salt water we swim in when we hit the beaches.
Some oil and gas operators like SWEPI and Enervest in Michigan, however, have taken to calling their waste “SLOP” (Figure 1), which from my standpoint is actually refreshingly honest.
Fracking Energy Return on Investment 2012 – 2020
Since we created our North Dakota Shale Viewer on October 5th, 2012, much has changed across the fracking landscape, while other songs have remained the same. Both of these truths exist with respect to fracking’s impact on water and the industry’s inability to get its collective head around the billions of barrels of oftentimes radioactive waste it produces by its very nature. From the outset, fracking was on dubious footing when it came to the water and waste associated with its operations, and we have seen a nearly universal and exponential increase in water demand and waste production on a per well basis since fracking became the highly divisive topic it remains to this day.
Figure 1. Oil & Gas waste tank operated by SWEPI and Enervest at the Hayes pad, Otsego County, Michigan May 21st, 2016 (44.892933, -84.786530). Photo by Ted Auch, FracTracker Alliance.
Environmental economists like to look at energy sources from a more holistic standpoint vis a vis engineers, traditional economists, and the divide-and-conquer rhetoric from Bismarck to the White House. They do this by placing all manner of energy sources along a spectrum of Energy Return On Energy Invested (EROEI).
It stands to reason that if natural gas from fracking were a real “bridge fuel” in the transition away from coal, it would at least approach or exceed the EROEI of the latter, but at 46:1 coal is still four times more efficient than natural gas. However, it must be said that coal’s days are numbered as well. Witness the recent bankruptcy of coal giant Murray Energy, and the only reason its EROEI has increased or remained steady is because the mining industry has transitioned to almost exclusively mountaintop removal and/or strip mining and the associated efficiencies resulting from mechanization/automation.
The North Dakota Shale Viewer
We enhanced our North Dakota Shale Viewer nearly eight years since it debuted. This exercise included the addition of several data layers that speak to the above issues and how they have changed since we first launched the North Dakota Shale Viewer.
It is worth noting that oil production in total across North Dakota has not even doubled since 2012, and gas production has only managed to increase 3.5-fold. However, the numbers look even worse when you look at these totals on a per well basis, which as I have mentioned seems to me to be the only way reasonable people should be looking at production. Using this lens, we see that production of oil in North Dakota on a per well basis oil is 1% less than it was in 2012 and gas production has not even doubled per well. This is a stunning contrast to the upticks in water and waste we have documented and are now including in our North Dakota Shale Viewer.
Water Demand Rises for Fracking
We’ve incorporated individual horizontal well freshwater demand for nearly 12,000 wells up to and including Q1-2020. The numbers are jaw dropping when you consider that at the time we debuted this map North Dakota, unconventional wells were using roughly 2.1 million gallons per well compared to an average of 8.3 million gallons per well so far this year. This per well increase is something we have been documenting for years now in states like Pennsylvania, Ohio, and West Virginia.
This is concerning for multiple reasons, the first being that if fracking ever were to rebound to its halcyon days of the early teens, it would mean some of our country’s most prized and fragile watersheds would be pushed to an irreversible hydrological tipping point. Hoekstra et al. (2012) have come to call this the “blue water” precautionary principle whereby “depletion beyond 20% of a river’s natural flow increases risks to ecological health and ecosystem services.”
Another concern is that while permitting in North Dakota has slowed like it has nationwide, the aforementioned quarterly water usage totals per well are now 5.25 times what they were in October 2012 and the total water used by the industry in North Dakota now amounts to 60.43 billion gallons– that we know of — which is nearly 50 times what the industry had used when we created our North Dakota Shale Viewer (Figure 2).[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.
Increasing Fracking Waste Production
On the fracking waste front, the monthly trend is quite volatile relative to what we’ve documented in states like Oklahoma, Kansas, and Ohio. Nonetheless, the amount of waste produced is increasing per well and in total. How you quantify this increase is quite sensitive to the models you fit to the data. The exponential and polynomial (Plotted in Figure 3) fits yield 4.76 to 9.81 million barrel per month increases, while linear and power functions yield the opposite resulting in 1.82 to 10.91 million-barrel declines per month. If we assume the real answer is somewhere in between we see that fracking waste is increasingly slightly at a rate of 1.51% per year or 460,194 barrels per month.
Figure 3. Average Per Well and Monthly Total Fracking Waste Disposal across 675 North Dakota Class II Salt Water Disposal (SWD) wells from 2010 to Q1-2020.
North Dakota has concerning legislation related to oil and gas waste disposal. Senate Bill 2344 claims that landowners do not actually own the “subsurface pore space” beneath their property. The bill was passed into law by Legislature last Spring but there are numerous lawsuits working against it. We will have further analysis of this bill published on FracTracker.org soon.
FracTracker collaborated with Earthworks to create an interactive map that allows North Dakota residents to determine if oil and gas waste is disposed of or has spilled near them in addition to a list of recommendations for state and local policymakers, including the closing of the state’s harmful oil and gas hazardous waste loophole. Read the report for detailed information about oil and gas waste in North Dakota.
This data is critical to understanding the environmental and/or hydrological impact(s) of fracking, whether it is Central Appalachia’s Ohio River Valley, or in this case North Dakota’s Missouri River Basin. We will continue to periodically update this data.
Without supply-side price signaling or adequate regulation, it appears that the industry is uninterested and insufficiently incentivized to develop efficiencies in water use. It is my opinion that the only way the industry will be incentivized to do so is if states put a more prohibitive and environmentally responsible price on water and waste. In the absence of outright bans on fracking, we must demand the industry is held accountable for pushing watersheds to the brink of their capacity, and in the process, compromising the water needs of so many communities, flora, and fauna.
[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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/Oil-Gas-waste-tank-in-Michigan-feature-scaled.jpg4301500Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngTed Auch, PhD2020-06-18 10:24:572021-04-15 14:16:44The North Dakota Shale Viewer Reimagined: Mapping the Water and Waste Impact
Challenges have plagued Shell’s construction of the Falcon Pipeline System through Pennsylvania, Ohio, and West Virginia, according to documents from the Pennsylvania Department of Environmental Protection (DEP) and the Ohio Environmental Protection Agency (EPA).
Records show that at least 70 spills have occurred since construction began in early 2019, releasing over a quarter million gallons of drilling fluid. Yet the true number and volume of spills is uncertain due to inaccuracies in reporting by Shell and discrepancies in regulation by state agencies.
A drilling fluid spill from Falcon Pipeline construction near Moffett Mill Road in Beaver County, PA. Source: Pennsylvania DEP
Releases of drilling fluid during Falcon’s construction include inadvertent returns and losses of circulation – two technical words used to describe spills of drilling fluid that occur during pipeline construction.
Drilling fluid, which consists of water, bentonite clay, and chemical additives, is used when workers drill a borehole horizontally underground to pull a pipeline underneath a water body, road, or other sensitive location. This type of installation is called a HDD (horizontal directional drill), and is pictured in Figure 1.
Figure 1. An HDD operation – Thousands of gallons of drilling fluid are used in this process, creating the potential for spills. Click to expand. Source: Enbridge Pipeline
Here’s a breakdown of what these types of spills are and how often they’ve occurred during Falcon pipeline construction, as of March, 2020:
Loss of circulation
Definition: A loss of circulation occurs when there is a decrease in the volume of drilling fluid returning to the entry or exit point of a borehole. A loss can occur when drilling fluid is blocked and therefore prevented from leaving a borehole, or when fluid is lost underground.
Cause: Losses of circulation occur frequently during HDD construction and can be caused by misdirected drilling, underground voids, equipment blockages or failures, overburdened soils, and weathered bedrock.
Construction of the Falcon has caused at least 49 losses of circulation releasing at least 245,530 gallons of drilling fluid. Incidents include:
15 losses in Ohio – totaling 73,414 gallons
34 losses in Pennsylvania – totaling 172,116 gallons
Inadvertent return
Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
Cause: Inadvertent returns are also frequent during HDD construction and are caused by many of the same factors as losses of circulation.
Construction of the Falcon has caused at least 20 inadvertent returns, releasing at least 5,581 gallons of drilling fluid. These incidents include:
18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
2,639 gallons into water resources (streams and wetlands)
2 inadvertent returns Ohio – totaling 35 gallons
35 gallons into water resources (streams and wetlands)
However, according to the Ohio EPA, Shell is not required to submit reports for losses of circulation that are less than the definition of an inadvertent return, so many losses may not be captured in the list above. Additionally, documents reveal inconsistent volumes of drilling mud reported and discrepancies in the way releases are regulated by the Pennsylvania DEP and the Ohio EPA.
Very few of these incidents were published online for the public to see; FracTracker obtained information on them through a public records request. The map below shows the location of all known drilling fluid releases from that request, along with features relevant to the pipeline’s construction. Click here to view full screen, and add features to the map by checking the box next to them in the legend. For definitions and additional details, click on the information icon.
Our investigation into these incidents began early this year when we received an anonymous tip about a release of drilling fluids in the range of millions of gallons at the SCIO-06 HDD over Wolf Run Road in Jefferson County, Ohio. The source stated that the release could be contaminating drinking water for residents and livestock.
Working with Clean Air Council, Fair Shake Environmental Legal Services, and DeSmog Blog, we quickly discovered that this spill was just the beginning of the Falcon’s construction issues.
Documents from the Ohio EPA confirm that there were at least eight losses of circulation at this location between August 2019 and January 2020, including losses of unknown volume. The SCIO-06 HDD location is of particular concern because it crosses beneath two streams (Wolf Run and a stream connected to Wolf Run) and a wetland, is near groundwater wells, and runs over an inactive coal mine (Figure 2).
Figure 2. Losses of circulation that occurred at the SCIO-06 horizontal directional drill (HDD) site along the Falcon Pipeline in Jefferson County Ohio. Data Sources: OH EPA, AECOM
According to Shell’s survey, the coal mine (shown in Figure 2 in blue) is 290 feet below the HDD crossing. A hazardous scenario could arise if an HDD site interacts with mine voids, releasing drilling fluid into the void and creating a new mine void discharge.
A similar situation occurred in 2018, when EQT Corp. was fined $294,000 after the pipeline it was installing under a road in Forward Township, Pennsylvania hit an old mine, releasing four million gallons of mine drainage into the Monongahela River.
The Ohio EPA’s Division of Drinking and Ground Waters looked into the issues around this site and reported, “GIS analysis of the pipeline location in Jefferson Co. does not appear to risk any vulnerable ground water resources in the area, except local private water supply wells. However, the incident location is above a known abandoned (pre-1977) coal mine complex, mapped by ODNR.”
While we cannot confirm if there was a spill in the range of millions of gallons as the source claimed, the reported losses of circulation at the SCIO-06 site total over 60,000 gallons of drilling fluid. Additionally, on December 10th, 2019, the Ohio EPA asked AECOM (the engineering company contracted by Shell for this project) to estimate what the total fluid loss would be if workers were to continue drilling to complete the SCIO-06 crossing. AECOM reported that, in a “very conservative scenario based on the current level of fluid loss…Overall mud loss to the formation could exceed 3,000,000 gallons.”
Despite this possibility of a 3 million+ gallon spill, Shell resumed construction in January, 2020. The company experienced another loss of circulation of 4,583 gallons, reportedly caused by a change in formation. However, in correspondence with a resident, Shell stated that the volume lost was 3,200 gallons.
Whatever the amount, this January loss of circulation appears to have convinced Shell that an HDD crossing at this location was too difficult to complete, and in February 2020, Shell decided to change the type of crossing at the SCIO-06 site to a guided bore underneath Wolf Run Rd and open cut trench through the stream crossings (Figure 3).
Figure 3. The SCIO-06 HDD site, which may be changed from an HDD crossing to an open cut trench and conventional bore to cross Wolf Run Rd, Wolf Run stream (darker blue), an intermittent stream (light blue) and a wetland (teal). Click to expand.
An investigation by DeSmog Blog revealed that Shell applied for the route change under Nationwide Permit 12, a permit required for water crossings. While the Army Corps of Engineers authorized the route change on March 17th, one month later, a Montana federal court overseeing a case on the Keystone XL pipeline determined that the Nationwide Permit 12 did not meet standards set by federal environmental laws – a decision which may nullify the Falcon’s permit status. At this time, the ramifications of this decision on the Falcon remain unclear.
Inconsistencies in Reporting
In looking through Shell’s loss of circulation reports, we noted several discrepancies about the volume of drilling fluid released for different spills, including those that occurred at the SCIO-06 site. As one example, the Ohio EPA stated an email about the SCIO-06 HDD, “The reported loss of fluid from August 1, 2019 to August 14, 2019 in the memo does not appear to agree with the 21,950 gallons of fluid loss reported to me during my site visit on August 14, 2019 or the fluid loss reported in the conference call on August 13, 2019.”
In addition to errors on Shell’s end, our review of documents revealed significant confusion around the regulation of drilling fluid spills. In an email from September 26, 2019, months after construction began, Shell raised the following questions with the Ohio EPA:
when a loss of circulation becomes an inadvertent return – the Ohio EPA clarifies: “For purposes of HDD activities in Ohio, an inadvertent return is defined as the unintended return of any fluid to the surface, as well as losses of fluids to underground formations which exceed 50-percent over a 24-hour period and/or 25-percent loss of fluids or annular pressure sustained over a 48-hour period;”
when the clock starts for the aforementioned time periods – the Ohio EPA says the time starts when “the drill commences drilling;”
whether Shell needs to submit loss of circulation reports for losses that are less than the aforementioned definition of an inadvertent return – the Ohio EPA responds, “No. This is not required in the permit.”
How are these spills measured?
A possible explanation for why Shell reported inconsistent volumes of spills is because they were not using the proper technology to measure them.
Shell’s “Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan” states that drilling rigs must be equipped with “instruments which can measure and record in real time, the following information: borehole annular pressure during the pilot hole operation; drilling fluid discharge rate; the spatial position of the drilling bit or reamer bit; and the drill string axial and torsional loads.”
In other words, Shell should be using monitoring equipment to measure and report volumes of drilling fluid released.
Despite that requirement, Shell was initially monitoring releases manually by measuring the remaining fluid levels in tanks. After inspectors with the Pennsylvania DEP realized this in October, 2019, the Department issued a Notice of Violation to Shell, asking the company to immediately cease all Pennsylvania HDD operations and implement recording instruments. The violation also cited Shell for not filing weekly inadvertent return reports and not reporting where recovered drilling fluids were disposed.
In Ohio, there is no record of a similar request from the Ohio EPA. The anonymous source that originally informed us of issues at the SCIO-6 HDD stated that local officials and regulatory agencies in Ohio were likely not informed of the full volumes of the industrial waste releases based on actual meter readings, but rather estimates that minimize the perceived impact.
While we cannot confirm this claim, we know a few things for sure: 1) there are conflicting reports about the volume of drilling fluids spilled in Ohio, 2) according to Shell’s engineers, there is the potential for a 3 million+ gallon spill at the SCIO-06 site, and 3) there are instances of Shell not following its permits with regard to measuring and reporting fluid losses.
The inconsistent ways that fluid losses (particularly those that occur underground) are defined, reported, and measured leave too many opportunities for Shell to impact sensitive ecosystems and drinking water sources without being held accountable.
What are the impacts of drilling fluid spills?
Drilling fluid is primarily composed of water and bentonite clay (sodium montmorillonite), which is nontoxic. If a fluid loss occurs, workers often use additives to try and create a seal to prevent drilling fluid from escaping into underground voids. According to Shell’s “Inadvertent Returns From HDD” plan, it only uses additives that meet food standards, are not petroleum based, and are consistent with materials used in drinking water operations.
However, large inadvertent returns into waterways cause heavy sedimentation and can have harmful effects on aquatic life. They can also ruin drinking water sources. Inadvertent returns caused by HDD construction along the Mariner East 2 pipeline have contaminated many water wells.
Losses of circulation can impact drinking water too. This past April in Texas, construction of the Permian Highway Pipeline caused a loss that left residents with muddy well water. A 3 million gallon loss of circulation along the Mariner East route led to 208,000 gallons of drilling mud entering a lake, and a $2 million fine for Sunoco, the pipeline’s operator.
Our Falcon Public EIA Project found 240 groundwater wells within 1/4 mile of the pipeline and 24 within 1,000 ft of an HDD site. The pipeline also crosses near surface water reservoirs. Drilling mud spills could put these drinking water sources at risk.
But when it comes to understanding the true impact of the more than 245,000+ gallons of drilling fluid lost beneath Pennsylvania and Ohio, there are a lot of remaining questions. The Falcon route crosses over roughly 20 miles of under-mined land (including 5.6 miles of active coal mines) and 25 miles of porous karst limestone formations (learn more about karst). Add in to the mix the thousands of abandoned, conventional, and fracked wells in the region – and you start to get a picture of how holey the land is. Where or how drilling fluid interacts with these voids underground is largely unknown.
Other Drilling Fluid Losses
In addition to the SCIO-04 HDD, there are other drilling fluid losses that occurred in sensitive locations.
In Robinson Township, Pennsylvania, over a dozen losses of circulation (many of which occurred over the span of several days) released a reported 90,067 gallons of drilling fluid into the ground at the HOU-04 HDD. This HDD is above inactive surface and underground mines.
The Falcon passes through and near surface drinking water sources. In Beaver County, Pennsylvania, the pipeline crosses the headwaters of the Ambridge Reservoir and the water line that carries out its water for residents in Beaver County townships (Ambridge, Baden, Economy, Harmony, and New Sewickley) and Allegheny County townships (Leet, Leetsdale, Bell Acres, and Edgeworth). The group Citizens to Protect the Ambridge Reservoir, which formed in 2012 to protect the reservoir from unconventional oil and gas infrastructure, led efforts to stop Falcon Construction, and the Ambridge Water Authority itself called the path of the pipeline “not acceptable.”In response to public pressure, Shell did agree to build a back up line to the West View Water Authority in case issues arose from the Falcon’s construction.
Unfortunately, a 50-gallon inadvertent return was reported at the HDD that crosses the waterline (Figure 4), and a 160 gallon inadvertent return occurred in Raccoon Municipal Park within the watershed and near its protected headwaters (Figure 5). Both of these releases are reported to have occurred within the pipeline’s construction area and not into waterways.
Figure 4) HOU-10 HDD location on the Falcon Pipeline, where 50 gallons were released on the drill pad on 7/9/2019
Figure 5) SCIO-05 HDD location on the Falcon Pipeline, where 160 gallons were released on 6/10/19, within the pipeline’s LOD (limit of disturbance)
Farther west, the pipeline crosses through the watershed of the Tappan Reservoir, which provides water for residents in Scio, Ohio and the Ohio River, which serves over 5 million people.
A 35- gallon inadvertent return occurred at a conventional bore within the Tappan Lake Protection Area, impacting a wetland and stream. We are not aware of any spills impacting the Ohio River.
Pipelines in a Pandemic
This investigation makes it clear that weak laws and enforcement around drilling fluid spills allows pipeline construction to harm sensitive ecosystems and put drinking water sources at risk. Furthermore, regulations don’t require state agencies or Shell to notify communities when many of these drilling mud spills occur.
The problem continues where the 97-mile pipeline ends – at the Shell ethane cracker. In March, workers raised concerns about the unsanitary conditions of the site, and stated that crowded workspaces made social distancing impossible. While Shell did halt construction temporarily, state officials gave the company the OK to continue work – even without the waiver many businesses had to obtain.
The state’s decision was based on the fact it considered the ethane cracker to “support electrical power generation, transmission and distribution.” The ethane cracker – which is still months and likely years away from operation – does not currently produce electrical power and will only provide power generation to support plastic manufacturing.
This claim continues a long pattern of the industry attempting to trick the public into believing that we must continue expanding oil and gas operations to meet our country’s energy needs. In reality, Shell and other oil and gas companies are attempting to line their own pockets by turning the country’s massive oversupply of fracked gas into plastic. And just as Shell and state governments have put the health of residents and workers on the line by continuing construction during a global pandemic, they are sacrificing the health of communities on the frontlines of the plastic industry and climate change by pushing forward the build-out of the petrochemical industry during a global climate crisis.
This election year, while public officials are pushing forward major action to respond to the economic collapse, let’s push for policies and candidates that align with the people’s needs, not Big Oil’s.
By Erica Jackson, Community Outreach & Communications Specialist, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/FalconPipelineFrontPage-scaled.jpg4301500Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngErica Jackson2020-06-16 11:47:062021-04-15 14:16:44Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
Unconventional wells in Pennsylvania were always resource-intensive, but the maps below show how the amount of water used per well has grown significantly in recent years. In 2013, these wells used an average of 5.8 million gallons per well. By 2019, that figure had increased 145%, consuming more than 14.3 million gallons per well. This is a glimpse into the unsustainable resource demands of this industry and the decreasing energy returned on investment.
As fracking proponents will eagerly remind you, hydraulic fracturing was invented decades ago – back in 1947 – so the practice has been in use for quite a while. What really separates modern unconventional shale gas wells from the supposedly traditional, conventional wells is more a matter of scale than anything else. While conventional wells are typically fracked with tens of thousands of gallons of fluid, their unconventional counterparts are far thirstier, consuming millions of gallons per well.
And of course, more inputs translate into more outputs — not necessarily in the form of gas, but in the form of toxic, radioactive waste. This creates a slew of problems ranging from health impacts, to increased transportation, to disposal.
However, this increase in consumption has continued to grow on a per-well basis, so that wells drilled in recent years aren’t really in the same category as wells drilled a decade ago at the beginning of Pennsylvania’s unconventional boom.
In Pennsylvania, unconventional wells are primarily drilled into two deep shale layers, the Devonian-aged Marcellus Shale, which is about 390 million years old, and the Utica Shale from the Late Ordovician period, which was deposited about 60 million years before the Marcellus. These formations have been known about for decades, but did not yield enough gas justify the expense of drilling until the 21st century, when horizontal drilling allowed for a much greater surface area of exposure to the shale formations. However, stimulating this increased distance also requires significantly more fracking fluid – a mixture of water, sand, and chemicals – which increased the consumptive use of water by several orders of magnitude. And in the end, all of this extra work that is required to extract the gas from the ground has made the industry unprofitable, as high production numbers have outpaced demand.
FracFocus Data
As residents in shale fields around the country started to see impacts to their drinking water, they began to demand to know more about what was injected into the ground around them. The industry’s response was FracFocus, a national registry to address the water component of this question, if not the issue of fracking chemicals. In the early days, visitors to the site could only access data one well at a time, so systematic analyses by third parties were precluded. Additionally, record keeping was sloppy, with widespread data entry issues, incorrect locations, duplicate entries, and so forth.
Many of these issues were addressed with the rollout of FracFocus 2.0 in May of 2013. This fixed many of the data entry issues, such as the six different spellings of “Susquehanna” that were used, and enabled downloads of the entire data set. For that reason, when we wanted to look at changes over time, our analysis started in 2013, where only minimal obvious corrections were required at the county level.
Unconventional wells in Pennsylvania were always resource-intensive, but this GIF shows that the amount of water used per well has grown significantly in recent years. In 2013, these wells used an average of 5.8 million gallons per well. By 2019, that figure had increased 145%, consuming more than 14.3 million gallons per well. This is a glimpse into the unsustainable resource demands of this industry and the decreasing energy returned on investment.
However, statewide data is available since 2008, and as long as we keep in mind the data quality issues from the earlier years, the results are even more stark.
Year
FracFocus Reports
Total Water (gal)
Average Water per Well (gal)
Maximum Water (gal)
2008
2
4,117,827
4,117,827
4,117,827
2009
19
37,415,216
4,157,246
6,176,104
2010
57
123,747,550
4,267,157
7,595,793
2011
1,174
786,513,944
4,345,381
12,146,478
2012
1,375
2,721,696,367
4,676,454
14,247,085
2013
1,272
7,431,752,338
5,842,573
19,422,270
2014
1,277
10,359,150,398
8,112,099
26,927,838
2015
904
8,216,787,382
9,089,367
32,049,750
2016
589
5,933,622,817
10,074,063
32,701,940
2017
710
8,547,034,675
12,038,077
38,681,496
2018
805
10,901,333,749
13,542,030
36,812,580
2019
686
9,811,475,207
14,302,442
39,329,556
2020
76
986,425,600
12,979,284
29,177,980
Grand Total
8,946
65,861,073,069
9,248,852
39,329,556
Figure 1: While the total number of frack jobs reported to FracFocus has declined over the years, the amount of water per well has increased substantially.
In terms of the total number of unconventional wells drilled, the boom years in Pennsylvania were around 2010 to 2014, with more than 1,000 wells drilled each of those years, a total that has not been achieved again since. It is important to note that in this FracFocus data, we are not counting the wells, per se, but the reported instances of well stimulation through hydraulic fracturing, commonly called frack jobs. In the earliest portion of the date range, submitting data to FracFocus was voluntary, and therefore the total activity from 2008 through 2010 is vastly undercounted, but we have included what data was available.
It should be noted that the average consumption for frack jobs started in 2020 are down from the 2019 totals, however, the sample size is considerably smaller. This smaller sample due, in part, to reduced drilling activity due to oversupply of gas in the Northeast, but also due to the fact that the year is still in progress. This analysis is based on data downloaded from FracFocus in April 2020.
Changes Over Time
As we examine changes in the average water consumption over time from Figure 1, we can see that operators in Pennsylvania averaged between 4-5 million gallons of water per well from 2008 to 2012. The numbers take off from there, tripling to more than 14 million gallons for 2019, the last full year available. At the same time, drilling operators began experimenting with truly monstrous quantities of water. In 2008, the only well with water data available used just over 4.1 million gallons. By 2019, there was a well that used 39.3 million gallons of water, almost a tenfold increase.
From late 2008 through early 2020, the industry recorded the use of 65.8 billion gallons of water in unconventional wells. Since we know that many wells during the early boom years did not report to FracFocus, the actual usage must be substantially higher. For the years with the most reliable and complete data – 2013 to 2019 – total water consumption ranged from 5.9 to 10.9 billion gallons per year. For context, the average Pennsylvanian uses about 100 gallons per day, or 36,500 gallons per year.
That means that the 10.9 billion gallons that were pumped into fracked wells in 2018 equals the total usage of 298,667 residents for an entire year. Alternatively, that water could have filled 16,517 Olympic-sized swimming pools. It is equivalent to 33,455 acre-feet, meaning it could fill an acre-sized column of water that stretches more than six miles high.
Surely, there must be a better way to make use of our precious resources than to turn millions upon millions of gallons of water into toxic waste.
By Matt Kelso, Manager of Data & Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/05/waterfall-1806956_1920.jpg7241500Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2020-05-29 16:22:102021-04-15 14:16:48Fracking Water Use in Pennsylvania Increases Dramatically
Map: Ohio Quarterly Utica Oil and Gas Production along with Quarterly Wastewater Disposal
Well Volumes
A little under a year ago, FracTracker released a map and associated analysis, “A Disturbing Tale of Diminishing Returns in Ohio,” with respect to Utica oil and gas production, highlighting the increasing volume of waste injected in wastewater disposal wells, and trends in lateral length in fracked wells from 2010 to 2018. In this article, I’ll provide an update on Ohio’s Utica oil and gas production in 2018 and 2019, the demands on freshwater, and waste disposal. After looking at the data, I recommend that we holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste in order to minimize negative externalities.
Recently, I’ve been inspired by the works of Colin Woodward[1] and Marvin Harris, who outline the struggle between liberty and the common good. They relate this to the role that commodities and increasing resource intensity play in maintaining or enhancing living standards. This quote from Harris’s “Cannibals and Kings” struck me as the 122 words that most effectively illustrate the impacts of the fracking boom that started more than a decade ago in Central Appalachia:
“Regardless of its immediate cause, intensification is always counterproductive. In the absence of technological change, it leads inevitably to the depletion of the environment and the lowering of the efficiency of production since the increased effort sooner or later must be applied to more remote, less reliable, and less bountiful animals, plants, soils, minerals, and sources of energy. Declining efficiency in turn leads to low living standards – precisely the opposite of the desired result. But this process does not simply end with everybody getting less food, shelter, and other necessities in return for more work. As living standards decline, successful cultures invent new and more efficient means of production which sooner or later again lead to the depletion of the natural environment.” From Chapter 1, page 5 of Marvin Harris’ “Cannibals and Kings: The Origins of Cultures, 1977
In reflecting on Harris’s quote as it pertains to fracking, I thought it was high time I updated several of our most critical data sets. The maps and data I present here speak to intensification and the fact that the industry is increasingly leaning on cheap water withdrawals, landscape impacts, and waste disposal methods to avoid addressing their increasingly gluttonous ways. To this point, the relationship between intensification and resource utilization is not just the purview of activists, academics, and journalists anymore; industry collaborators like IHS Markit admitting as much in their latest analysis pointing to the fact that oil and gas operators “will have to drill substantially more wells just to maintain current production levels and even more to grow production”. Insert Red Queen Hypothesis analogy here!
Oil and Gas Production in Ohio
The four updated data sets presented here are: 1) oil, gas, and wastewater production, 2) surface and groundwater withdrawal rates for the fracking industry, 3) freshwater usage by individual Ohio fracked wells, and 3) wastewater disposal well (also referred to as Class II injection wells) rates.
Below are the most important developments from these data updates as it pertains to intensification and what we can expect to see in the future, with or without the ethane cracker plants being trumpeted throughout Appalachia.
From a production standpoint, total oil production has increased by 30%, while natural gas production has increased by 50% year over year between the last time we updated this data and Q2-2019 (Table 1).
According to the data we’ve compiled, the rate of growth for wastewater production has exceeded oil and is nearly equal to natural gas at 48% from 2017 to 2018. On average the 2,398 fracked wells we have compiled data for are producing 27% more wastewater per well now than they did at the end of 2017.
————–2017————–
————–2019————–
Oil (million barrels)
Gas (million Mcf)
Brine (million barrels)
Oil (million barrels)
Gas (million Mcf)
Brine (million barrels)
Max
0.51
12.92
0.23
0.62
17.57
0.32
Total
83.14
5,768.47
76.01
108.15
8,679.12
112.28
Mean
0.40
2.79
0.37
0.45
3.62
0.47
Table 1. Summary statistics for 2,398 fracked wells in Ohio from a production perspective from 2017 to Q2 2019.
Figure 1. Total fracked gas produced per quarter and average fracked gas produced per well in Ohio from 2013 to Q2-2019.
The increasing amount of resources and number of wells necessary to achieve marginal increases in oil and gas production is a critical factor to considered when assessing industry viability and other long-term implications. As an example, in Ohio’s Utica Shale, we see that total production is increasing, but as IHS Markit admits, this is only possibly by increasing the total number of producing wells at a faster rate. As is evidenced in Figure 1, somewhere around the Winter of 2017-2018, the production rate per well began to flatline and since then it has begun to decrease.
Water demands for oil and gas production in Ohio
Since last we updated the industry’s water withdrawal rates, the Ohio Department of Natural Resources (ODNR) has begun to report groundwater rates in addition to surface water. The former now account for nine sites in seven counties, but amount to a fraction of reported withdrawals to date (around 00.01% per year in 2017 and 2018). The more disturbing developments with respect to intensification are:
1) Since we last updated this data, 59 new withdrawal sites have come online. There are currently 569 sites in total in ODNR’s database. This amounts to a nearly 12% increase in the total number of sites since 2017. With this additional inventory, the average withdrawal rate across all sites has increased by 13% (Table 2).
2) Since 2010, the demand for freshwater to be used in fracking has increased by 15.6% or 693 million gallons per year (Figure 2).
3) We expect to see an inflection point when water production will increase to accommodate the petrochemical buildout with cracker plants in Dilles Bottom, OH; Beaver County, PA; and elsewhere. In 2018 alone, the oil and gas industry pulled 4.69 billion gallons of water from the Ohio River Valley. Since 2010, the industry has permanently removed 22.96 billion gallons of freshwater from the Ohio River Valley. It would take the entire population of Ohio five years to use the 2018 rate in their homes.[2]
As we and others have mentioned in the past, this trend is largely due to the bargain basement price at which we sell water to the oil and gas sector throughout Appalachia.[3] To increase their nominal production returns, companies construct longer laterals with orders of magnitude more water, sand, and chemicals. At this rate, the fracking industry’s freshwater demand will have doubled to around 8.8-.9.5 billion gallons per year by around 2023. Figure 3 demonstrates that average fracked lateral length continues to increase to the tune of +15.7-21.2% (+1,564-2,107 feet) per quarter per lateral. This trend alone is more than 2.5 times the rate of growth in oil production and roughly 24% greater than the rate of growth in natural gas production (See Table 1).
4. The verdict is even more concerning than it was a couple years ago with respect to water demand increasing by 30% per quarter per well or an average of 4.73 million gallons (Figure 4). The last time we did this analysis >1.5 years ago demand was rising by 25% per quarter or 3.84 million gallons. At that point I wouldn’t have guessed that this exponential rate of water demand would have increased but that is exactly what has happened. Very immediate conversations must start taking place in Columbus and at the region’s primary distributor of freshwater, The Muskingum Watershed Conservancy District (MWCD), as to why this is happening and how to push back against the unsustainable trend.
2017
2018
Sites
510
569
Maximum (billion gallons)
1.059
1.661
Sum (billion gallons)
18.267
22.957
Mean (billion gallons)
0.358
0.404
Table 2. Summary of fracking water demands throughout Ohio in 2017 when we last updated this data as well as how those rates changed in 2018.
Figure 2. Hydraulic fracturing freshwater demand in total across 560+ sites in Ohio from 2010 to 2018 (million gallons per year).
Figure 3. Average lateral length for all of Ohio’s permitted hydraulically fractured laterals from from Q3-2010 to Q4-2019, along with average rates of growth from a linear and exponential standpoint (feet).
Figure 4. Average Freshwater Demand Per Unconventional Well in Ohio from Q3-2011 to Q3-2019 (million gallons).
Waste Disposal
When it comes to fracking wastewater disposal, the picture is equally disturbing. Average disposal rates across Ohio’s 220+ wastewater disposal wells increased by 12.1% between Q3-2018 and Q3-2019 (Table 3). Interestingly, this change nearly identically mirrors the change in water withdrawals during the same period. What goes down– freshwater – eventually comes back up.
Across all of Ohio’s wastewater disposal wells, total volumes increased by nearly 22% between 2018 and the second half of 2019. However, the more disturbing trend is the increasing focus on the top 20 most active wastewater disposal wells, which saw an annual increase of 17-18%. These wells account for nearly 50% of all waste and the concern here is that many of the pending wastewater disposal well permits are located on these sites, within close proximity, and/or are proposed by the same operators that operate the top 20.
When we plot cumulative and average disposal rates per well, we see a continued exponential increase. If we look back at the last time, we conducted this analysis, the only positive we see in the data is that at that time, average rates of disposal per well were set to double by the Fall of 2020. However, that trend has tapered off slightly — rates are now set to double by 2022.
Each wastewater disposal well is seeing demand for its services increase by 2.42 to 2.94 million gallons of wastewater per quarter (Figure 5). Put another way, Ohio’s wastewater disposal wells are rapidly approaching their capacity, if they haven’t already. Hence why the oil and gas industry has been frantically submitting proposals for additional waste disposal wells. If these wells materialize, it means that Ohio will continue to be relied on as the primary waste receptacle for the fracking industry throughout Appalachia.
Variable
——————-All Wells——————-
——————-Top 20——————-
To Q3-2018
To Q3-2019
% Change
To Q3-2018
To Q3-2019
% Change
Number of Wells
223
243
+9.0
——-
——-
——-
Max (MMbbl)
1.12
1.20
+7.1
——-
——-
——-
Sum (MMbbl)
203.19
247.05
+21.6
101.43
119.31
+17.6
Average (MMbbl)
0.91
1.02
+12.1
5.07
5.97
+17.8
Table 3. Summary Statistics for Ohio’s Wastewater Disposal Wells (millions of barrels (MMbbl)).
Figure 5. Average Fracking Waste Disposal across all of Ohio’s Wastewater Disposal Wells and the cumulative amount of fracking waste disposed of in these wells from Q3-2010 to Q2-2019 (million barrels).
Using the Pennsylvania natural gas data merged with the Ohio wastewater data, we were able to put a finer point on how much wastewater would be produced with a 100,000 barrel ethane cracker like the one PTT Global Chemical has proposed for Dilles Bottom, Ohio. The following are our best estimate calculations assuming 1 barrel of condensate is 20-40% ethane. These calculations required that we take some liberties with the merge of the ratio of gas to wastewater in Ohio with the ratio of gas to condensate in Pennsylvania:
For 2,064 producing Ohio fracked wells, the ratio of gas to wastewater is 64.76 thousand cubic feet (Mcf) of gas produced per barrel of wastewater.
Assuming 40% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 320.08 Mcf of gas per barrel of ethane condensate. For 100,000 barrels of ethane needed per cracker per day, that would result in 494,285 barrels (20.76 million gallons) of brine per day.
Assuming 20% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 640.15 Mcf per barrel of ethane condensate = For 100,000 barrels of ethane needed per cracker per day that would result in 988,571 barrels/41.52 million gallons of wastewater per day.
But wait, here is the real stunner:
The 40% assumption result is 3.81 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 5.37 times the daily rates of brine taken in by the top 20 wells (Note: the top 20 wastewater disposal wells account for 71% of all wastewater waste taken in by all of the state’s disposal wells).
The 20% assumption result is 7.62 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 10.74 times the daily rates of wastewater taken in by the top 20 wells.
Therefore, we estimate the fracked wells supplying the proposed PTTGC ethane cracker will generate between 20.76 million and 41.52 million gallons of wastewater per day. That is 3.8 to 7.6 times the amount of wastewater currently received by Ohio’s wastewater disposal wells.
What does this means in terms of truck traffic? We can assume that at least 80% of the trucks that transport wastewater are the short/baby bottle trucks which haul 110 barrels per trip. This means that our wastewater estimates would require between 4,493 and 8,987 truck trips per day, respectively. The pressures this amount of traffic will put on Appalachian roads and communities will be hard to measure and given the current state of state and federal politics and/or oversight it will be even harder to measure the impact inevitable spills and accidents will have on the region’s waterways.
Conclusion
There is no reason to believe these trends will not persist and become more intractable as the industry increasingly leans on cheap waste disposal and water as a crutch. The fracking industry will continue to present shareholders with the illusion of a robust business model, even in the face of rapid resource depletion and precipitous production declines on a per well basis.
I am going to go out on a limb and guess that unless we more holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste, there will be no other supply-side signal that we could send that would cause the oil and gas industry to change its ways. Until we reach that point, we will continue to compile data sets like the ones described above and included in the map below, because as Supreme Court Justice Louis Brandeis once said, “Sunlight is the best disinfectant!”
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison
[1] Colin Woodward’s “American Character: A history of the epic struggle between individual liberty and the common good” is a must read on the topic of resource utilization and expropriation.
[3] In Ohio the major purveyor of water for the fracking industry is the Muskingum Watershed Conservancy District (MCWD) and as we’ve pointed out in the past they sell water for roughly $4.50 to $6.50 per thousand gallons. Meanwhile across The Ohio River the average price of water for fracking industry in West Virginia in the nine primary counties where fracking occurs is roughly $8.38 per thousand gallons.
Data Downloads
Quarterly oil, gas, brine, and days in production for 2,390+ Unconventional Utica/Point Pleasant Wells in Ohio from 2010 to Q2-2019
Despite the ever-increasing heaps of violations and drilling waste, Pennsylvania’s fracked wells continue to produce an excess supply of gas, driving prices down. To cut their losses, the oil and gas industry is turning towards increased exports and petrochemical production. Continuing to expand fracking in Pennsylvania will only increase risks to the public and to the climate, all for what may amount to another boom and bust cycle that is largely unprofitable to investors.
Let’s take a look at gas production, waste, newly drilled wells, and violations in Pennsylvania in the past year to understand just how precarious the fracking industry is.
Production
Fracked hydrocarbon production continues to rise in Pennsylvania, resulting in an increase in waste production, violations, greenhouse gas emissions, and public health concerns. There are three types of hydrocarbons produced from wells in Pennsylvania: gas, condensate, and oil. Gas is composed mostly of methane, the most basic of the hydrocarbons, but in some parts of Pennsylvania, there can be significant quantities of ethane, propane, and other so-called “natural gas liquids” (NGLs) mixed in. Each of these NGLs are actually gaseous at atmospheric conditions, but operators try to separate these with a combination of pressure and low temperatures, converting them to a liquid phase. Some of these NGLs can be separated on-site, and this is typically referred to as condensate. Fracked wells in Pennsylvania also produce a relatively tiny amount of oil.
For those of you wondering why we are looking at the November, 2018 through October, 2019 time frame, this is simply a reflection of the available data. In this 12-month period, 9,858 fracked Pennsylvania wells, classified as “unconventional,” reported producing 6.68 trillion cubic feet of gas (Tcf), 4.89 million barrels of condensate, and just over 70,000 barrels of oil.
By means of comparison, Pennsylvania consumed about 1.46 Tcf of gas across all sectors in 2018, of which just 253 billion cubic feet (Bcf) was used in the homes of Pennsylvania’s 12.8 million residents. In fact, the amount of gas produced in Pennsylvania exceeds residential consumption in the entire United States by almost 1.7 Tcf. However, less than 17% of all gas consumed in Pennsylvania is for residential use, with nearly 28% being used for industrial purposes (including petrochemical development), and more than 35% used to generate electricity.
Figure 1. Fracked gas production compared to all fracked gas consumption and residential gas consumption in Pennsylvania from 2013 through 2018. Data from ref. Energy Information Administration.
While gas production has expansive hotspots in the northeastern and southwestern portions of the state, the liquid production comes from a much more limited geography. Eighty percent of all condensate production came from Washington County, while 87% of all fracked oil came from wells in Mercer County.
Because the definition of condensate has been somewhat controversial in the past (while the oil export ban was still in effect), I asked the Department of Environmental Protection (DEP) for the definition, and was told that if hydrocarbons come out of the well as a liquid, they should be reported as oil. If they are gaseous but condense to a liquid at standard temperature and pressure (60 degrees Fahrenheit and pressure 14.7 PSIA) on-site, then it is to be reported as condensate. Any NGLs that remain gaseous but are removed from the gas supply further downstream are reported as gas in this report. For this reason, it is not really possible to use the production report to find specific amounts of NGLs produced in the state, but it certainly exceeds condensate production by an appreciable margin.
The volume of gas withdrawn from fracked wells in Pennsylvania in just one year is equal to the volume of 3.2 Mount Everests!
Waste
Hydrocarbons aren’t the only thing that come out of the ground when operators drill and frack wells in Pennsylvania. Drillers also report a staggering amount of waste products, including more than 65 million barrels (2.7 billion gallons) of liquid waste and 1.2 million tons of solid waste in the 12-month period.
Waste facilities have significant issues such as inducing earthquakes, toxic leachate, and radioactive sediments in streambeds.
Waste Type
Liquid Waste (Barrels)
Solid Waste (Tons)
Basic Sediment
63
Brine Co-Product
247
Drill Cuttings
1,094,208
Drilling Fluid Waste
1,439,338
11,378
Filter Socks
143
Other Oil & Gas Wastes
2,236,750
6,387
Produced Fluid
61,376,465
41,165
Servicing Fluid
17,196
3,250
Soil Contaminated by Oil & Gas Related Spills
25,505
Spent Lubricant Waste
1,104
Synthetic Liner Materials
21,051
Unused Fracturing Fluid Waste
7,077
1,593
Waste Water Treatment Sludge
35,151
Grand Total
65,078,240
1,239,831
Figure 2. Oil and gas waste generated by fracked wells as reported by drillers from November 1, 2018 through October 31, 2019. Data from ref: PA DEP.
Some of the waste is probably best described as sludge, and several of the categories allow for reporting in barrels or tons. Almost all of the waste was in the well bore at one time or another, although there are some site-related materials that need to be disposed of, including filter socks which separate liquid and solid waste, soils contaminated by spills, spent lubricant, liners, and unused frack fluid waste.
Where does all of this waste go? We worked with Earthworks earlier this year to take a deep dive into the data, focusing on these facilities that receive waste from Pennsylvania’s oil and gas wells. While the majority of the waste is dealt with in-state, a significant quantity crosses state lines to landfills and injection wells in neighboring states, and sometimes as far away as Idaho.
Oil and gas operators have started the drilling process for 616 fracking wells in 2019, which appear on the Pennsylvania DEP spud report. This is less than one third of the 2011 peak of 1,956 fracked wells, and 2019 is the fifth consecutive year with fewer than 1,000 wells drilled. This has the effect of making industry projections relying on 1,500 or more drilled wells per year seem rather dubious.
Figure 3. Unconventional (fracked) wells drilled from 2005 through December 23, 2019, showing totals by regional office. Data from ref: PA DEP.
Oil and gas wells in Pennsylvania fall under the jurisdiction of three different regional offices. By looking at Figure 2, it becomes apparent that the North Central Regional Office (blue line) was a huge driver of the 2009 to 2014 drilling boom, before falling back to a similar drilling rate of the Southwest Regional Office.
The slowdown in drilling for gas in recent years is related to the lack of demand for the product. In turn, this drives prices down, a phenomenon that industry refers to as a “price glut.” The situation it is forcing major players in the regions such as Range Resources to reduce their holdings in Appalachia, and some, such as Chevron, are pulling out entirely.
Violations
Disturbingly, 2019 was the fifth straight year that the number of violations issued by DEP will exceed the total number of wells drilled.
Figure 4. Unconventional (fracked) drilled wells and issued violations from 2005 through December 2019. Data from ref: DEP.
Violations related to unconventional drilling are a bit unwieldy to summarize. The 13,833 incidents reported in Pennsylvania fall into 359 different categories, representing the specific regulations in which the drilling operator fell short of expectations. The industry likes to dismiss many of these as being administrative matters, and indeed, the DEP does categorize the violations as either “Administrative” or “Environmental, Health & Safety”. However, 9,998 (72%) of the violations through December 3, 2019, are in the latter category, and even some of the ones that are categorized as administrative seem like they ought to be in environmental, health, and safety. For example, let’s look at the 15 most frequent infractions:
Violation Code
Incidents
Category
SWMA301 – Failure to properly store, transport, process or dispose of a residual waste.
767
Environmental Health & Safety
CSL 402(b) – POTENTIAL POLLUTION – Conducting an activity regulated by a permit issued pursuant to Section 402 of The Clean Streams Law to prevent the potential of pollution to waters of the Commonwealth without a permit or contrary to a permit issued under that authority by the Department.
613
Environmental Health & Safety
102.4 – Failure to minimize accelerated erosion, implement E&S plan, maintain E&S controls. Failure to stabilize site until total site restoration under OGA Sec 206(c)(d)
595
Environmental Health & Safety
SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.
540
Environmental Health & Safety
601.101 – O&G Act 223-General. Used only when a specific O&G Act code cannot be used
469
Administrative
402CSL – Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution.
362
Environmental Health & Safety
78.54* – Failure to properly control or dispose of industrial or residual waste to prevent pollution of the waters of the Commonwealth.
339
Environmental Health & Safety
401 CSL – Discharge of pollutional material to waters of Commonwealth.
299
Environmental Health & Safety
102.4(b)1 – EROSION AND SEDIMENT CONTROL REQUIREMENTS – Person conducting earth disturbance activity failed to implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation.
285
Environmental Health & Safety
102.5(m)4 – PERMIT REQUIREMENTS – GENERAL PERMITS – Person failed to comply with the terms and conditions of the E & S Control General Permit.
283
Environmental Health & Safety
78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances.
256
Administrative
78a53 – EROSION AND SEDIMENT CONTROL AND STORMWATER MANAGEMENT – Person proposing or conducting earth disturbance activities associated with oil and gas operations failed to comply with 25 Pa. Code § 102.
247
Environmental Health & Safety
102.11(a)1 – GENERAL REQUIREMENTS – BMP AND DESIGN STANDARDS – Person failed to design, implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation to protect, maintain, reclaim and restore water quality and existing and designated uses.
235
Environmental Health & Safety
CSL 401 – PROHIBITION AGAINST OTHER POLLUTIONS – Discharged substance of any kind or character resulting in pollution of Waters of the Commonwealth.
235
Environmental Health & Safety
OGA3216(C) – WELL SITE RESTORATIONS – PITS, DRILLING SUPPLIES AND EQUIPMENT – Failure to fill all pits used to contain produced fluids or industrial wastes and remove unnecessary drilling supplies/equipment not needed for production within 9 months from completion of drilling of well.
206
Environmental Health & Safety
Figure 5. Top 15 most frequently cited violations for unconventional drilling operations in Pennsylvania through December 3, 2019. Data from ref: DEP.
Of the 15 most common categories, only two are considered administrative violations. One of these is a general code, where we don’t know what happened to warrant the infraction without reading the written narrative that accompanies the data, and is therefore impossible to categorize. The only other administrative violation in the top 15 categories reads, “78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances,” which certainly sounds like it would have some real-world implications beyond administrative concerns.
To address the excess supply of gas, companies have tried to export the gas and liquids to other markets through pipelines. Those efforts have been fraught with trouble as well. Residents are reluctant to put up with an endless barrage of new pipelines, yielding their land and putting their safety at risk for an industry that can’t seem to move the product safely. The Revolution pipeline explosion hasn’t helped that perception, nor have all of the sinkholes and hundreds of leaky “inadvertent returns” along the path of the Mariner East pipeline system. In a sense, the industry’s best case scenario is to call these failures incompetence, because otherwise they would be forced to admit that the 2.5 million miles of hydrocarbon pipelines in the United States are inherently risky, prone to failure any time and any place.
In addition to increasing the transportation and export of natural gas to new markets, private companies and elected officials are collaborating to attract foreign investors to fund a massive petrochemical expansion in the Ohio River Valley. The planned petrochemical plants intend to capitalize on the cheap feedstock of natural gas.
Pennsylvania’s high content of NGLs is a selling point by the industry, because they have an added value when compared to gas. While all of these hydrocarbons can burn and produce energy in a similar manner, operators are required to remove most of them to get the energy content of the gas into an acceptable range for gas transmission lines. Because of this, enormous facilities have to be built to separate these NGLs, while even larger facilities are constructed to consume it all. Shell’s Pennsylvania Petrochemicals Complex ethane cracker being built in Beaver County, PA is scheduled to make 1.6 million metric tons of polyethylene per year, mostly for plastics.
This comes at a time when communities around the country and the world are enacting new regulations to rein in plastic pollution, which our descendants are going to finding on the beach for thousands of years, even if everyone on the planet were to stop using single-use plastics today. Of course, none of these bans or taxes are currently permitted in Pennsylvania, but adding 1.6 million metric tons per year to our current supply is unnecessary, and indeed, it is only the beginning for the region. A similar facility, known as the PTT Global Chemical cracker appears to be moving forward in Eastern Ohio, and ExxonMobil appears to be thinking about building one in the region as well. Industry analysts think the region produces enough NGLs to support five of these ethane crackers.
Despite all of these problems, the oil and gas industry still plans to fill the Ohio River Valley with new petrochemical plants, gas processing plants, and storage facilities in the hopes that someday, somebody may want what they’ve taken from the ground.
Here’s hoping that 2020 is a safer and healthier year than 2019 was. But there is no need to leave it up to chance. Together, we have the power to change things, if we all demand that our voices are heard. As a start, consider contacting your elected officials to let them know that renewing Pennsylvania’s blocking of municipal bans and taxes on plastic bags is unacceptable.
By Matt Kelso, Manager of Data & Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/01/PA-2019-Fracked-Gas-Production-Feature-scaled.jpg6671500Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2020-01-07 18:02:382021-04-15 14:55:32Fracking in Pennsylvania: Not Worth It
Ted Auch, FracTracker Alliance
