The Captina Creek Watershed straddles the counties of Belmont and Monroe in Southeastern Ohio and feeds into the Ohio River. It is the highest quality watershed in all of Ohio and a great examples of what the Ohio River Valley’s tributaries once looked, smelled, and sounded like. Sadly, today it is caught in the cross-hairs of the oil and gas industry by way of drilling, massive amounts of water demands, pipeline construction, and fracking waste production, transport, and disposal. The images and footage presented in the story map below are testament to the risks and damage inherent to fracking in the Captina Creek watershed and to this industry at large. Data included herein includes gas gathering and interstate transmission pipelines like the Rover, NEXUS, and Utopia (Figure 1), along with Class II wastewater injection wells, compressor stations, unconventional laterals, and freshwater withdrawal sites and volumes.
The image at the top of the page captures my motivation for taking a deeper dive into this watershed. Having spent 13+ years living in Vermont and hiking throughout The Green and Adirondack Mountains, I fell in love with the two most prominent tree species in this photo: Yellow Birch (Betula alleghaniensis) and Northern Hemlock (Tsuga candadensis). This feeling of being at home was reason enough to be thankful for Captina Creek in my eyes. Seeing this region under pressure from the oil and gas industry really hit me in my botanical soul. We remain positive with regards to the area’s future, but protective action against fracking in the Captina Creek Watershed is needed immediately!
Fracking in the Captina Creek Watershed: A Story Map
Pennsylvania’s fracking industry is producing record amounts of toxic waste — where does it all go?
Drilling for methane and other fossil fuels is an energy-intensive process with many associated environmental costs. In addition to the gas that is produced through high volume hydraulic fracturing (“unconventional drilling,” or “fracking”), the process generates a great deal of waste at the drill site. These waste products may include several dozen tons of drill cutting at every well that is directionally drilled, in addition to liner materials, contaminated soil, fracking fluid, and other substances that must be removed from the site.
In 2018, Pennsylvania’s oil and gas industry (including both unconventional and conventional wells) produced over 2.9 billion gallons (nearly 69 million barrels) of liquid waste, and 1,442,465 tons of solid waste. In this article, we take a look at where this waste (and its toxic components) end up and how waste values have changed in recent years. We also explore how New York State, despite its reputation for being anti-fracking, isn’t exempt from the toxic legacy of this industry.
Waste that comes back to haunt us
According to a study by Physicians, Scientists and Engineers, over 80% of all waste from oil and gas drilling stays within the state of Pennsylvania. But once drilling wastes are sent to landfills, is that the end of them? Absolutely not!
Drilling waste also gets into the environment through secondary means. According to a recent report by investigative journalists at Public Herald, on average, 800,000 tons of fracking waste from Pennsylvania is sent to Pennsylvania landfills. When this waste is sent to landfills, radioactivity and other chemicals can percolate through the landfill, and are collected as leachate, which is then shipped to treatment plants.
Public Herald documented how fourteen sewage treatment plants in Pennsylvania have been permitted by Pennsylvania’s Department of Environmental Protection (PA DEP) to process and discharge radioactive wastes into more than a dozen Pennsylvania waterways.
Public Herald’s article includes an in-depth analysis of the issue. Their work is supported by a map of the discharge sites, created by FracTracker.
Trends over time
Pennsylvania Department of Environmental Protection maintains a rich database of oil and gas waste and production records associated with their Oil and Gas Reporting Website. The changes in waste disposal from Pennsylvania’s unconventional drilling reveal a number of interesting stories.
Let’s look first at overall unconventional drilling waste.
According to data from the federal Energy Information Administration, gas production in Pennsylvania began a steep increase around 2010, with the implementation of high volume hydraulic fracturing in the Marcellus Shale (see Figure 1). The long lateral drilling techniques allowed industry to exploit exponentially more of the tight shale via single well than was ever before possible with conventional, vertical drilling.
Figure 1. Data summary from FracTracker.org, based on EIA data.
The more recently an individual well is drilled, the more robust the production. We see an overall increase in gas production over time in Pennsylvania over the past decade. Paradoxically, the actual number of new wells drilled each year in the past 4-5 years are less than half of the number drilled in 2011 (see Figure 2).
Figure 2: Data summary from FracTracker.org, based on PA DEP data
Why is this? The longer laterals —some approaching 3 miles or more—associated with new wells allow for more gas to be extracted per site.
With this uptick in gas production values from the Marcellus and Utica Formations come more waste products, including copious amounts drilling waste, “produced water,” and other byproducts of intensive industrial operations across PA’s Northern Tier and southwestern counties.
Comparing apples and oranges?
When we look at the available gas production data compared with data on waste products from the extraction process, some trends emerge. First of all, it’s readily apparent that waste production does not track directly with gas production in a way one would expect.
Recall that dry gas production has increased annually since 2006 (see Figure 1). However, the reported waste quantities from industry have not followed that same trend.
In the following charts, we’ve split out waste from unconventional drilling by solid waste in tons (Figure 3) and liquid waste, in barrels (Figure 4).
Figure 3: Annual tonnage of solid waste from the unconventional oil and gas industry, organized by the state it is disposed in. Data source: PA DEP, processed by FracTracker Alliance
Figure 4: Annual volume of liquid waste from the unconventional oil and gas development, organized by state it is disposed in. One barrel is equivalent to 42 gallons. Data source: PA DEP, processed by FracTracker Alliance
Note the striking difference in disposal information for solid waste, compared with liquid waste, coming from Pennsylvania.
“Disposal Location Unknown”
Until just the last year, often more than 50% of the known liquid waste generated in PA was disposed of at unknown locations. The PA DEP waste report lists waste quantity and method for these unknown sites,depending on the year: “Reuse without processing at a permitted facility,” “Reuse for hydraulic fracturing,” “Reuse for diagnostic purposes,” “Reuse for drilling or recovery,” “Reuse for enhanced recovery,” and exclusively in more recent years (2014-2016), “Reuse other than road-spreading.”
In 2011, of the 20.5 million barrels of liquid waste generated from unconventional drilling, about 56% was allegedly reused on other drilling sites. However, over 9 million barrels—or 44% of all liquid waste—were not identified with a final destination or disposal method. Identified liquid waste disposal locations included “Centralized treatment plant for recycle,” which received about a third of the non-solid waste products.
In 2012, the quantity of the unaccounted-for fracking fluid waste dropped to about 40%. By 2013, the percentage of unaccounted waste coming from fracking fluid dropped to just over 21%, with nearly 75% coming from produced fluid, which is briny, but containing fewer “proprietary”—typically undisclosed—chemicals.
By 2017, accounting had tightened up further. PA DEP data show that 99% of all waste delivered to undisclosed locations was produced fluid shipped to locations outside of Pennsylvania. By 2018, all waste disposal was fully accounted for, according to DEP’s records.
In looking more closely at the data, we see that:
Prior to 2018, well drillers did not consistently report the locations at which produced water was disposed of or reused. Between 2012 and 2016, a greater volume of unconventional liquid waste went unaccounted for than was listed for disposal in all other locations, combined.
In Ohio, injection wells, where liquid waste is injected into underground porous rock formations, accounted for the majority of the increase in waste accepted there: 2.9 million barrels in 2017, and 5.7 million barrels in 2018 (a jump of 97%).
West Virginia’s acceptance of liquid waste increased significantly in 2018 over 2017 levels, a jump of over a million barrels, up from only 55,000. This was almost entirely due to unreported reuse at well pads.
In 2018, reporting, in general, appears to be more thorough than it was in previous years. For example, in 2017, nearly 692,000 barrels of waste were reused at well pads outside PA, but those locations were not disclosed. Almost 7000 more barrels were also disposed of at unknown locations. In 2018, there were no such ambiguities.
A closer look at Pennsylvania’s fracking waste shipped to New York State
Despite a reputation for being resistant to the fracking industry, for most of this decade, the state of New York has been accepting considerable amounts of fracking waste from Pennsylvania. The greatest percentage shipped to New York State is in the form of drilling waste solids that go to a variety of landfills throughout Central and Western New York.
Looking closely at the bar charts above, it’s easy to notice that the biggest recipients of Pennsylvania’s unconventional liquid drilling waste are Pennsylvania itself, Ohio, as well as a significant quantity of unaccounted-for barrels between 2011 and 2016 (“Disposal location unknown”). The data for disposal of solid waste in New York tells a different story, however. In this case, Pennsylvania, Ohio, and New York State all play a role. We’ll take a look specifically at the story of New York, and illustrate the data in the interactive map that follows.
In this map, source locations in Pennsylvania are symbolized with the same color marker as the facility in New York that received the waste from the originating well pad. In the “Full Screen” view, use the “Layers” drop down menu to turn on and off data from separate years.
From the early days of unconventional drilling in Pennsylvania, New York State’s landfills provided convenient disposal sites due to their proximity to the unconventional drilling occurring in Pennsylvania’s Northern tier of counties. Pennsylvania and Ohio took the majority of solid wastes from unconventional drilling waste from Pennsylvania. New York State, particularly between 2011-2015, was impacted far more heavily than all other states, combined (Figure 5, below).
Figure 5: Known disposal locations (excluding PA and OH) of Pennsylvania’s solid waste. Data source: PA DEP, processed by FracTracker Alliance
Here’s the breakdown of locations in New York to where waste was sent. Solid waste disposal into New York’s landfills also dropped by half, following the state’s ban on unconventional drilling in 2014. Most of the waste after 2012 went to the Chemung County Landfill in Lowman, New York, 10 miles southeast of Elmira.
Figure 6: Solid waste from unconventional drilling, sent to facilities in NYS. Data source: PA DEP, processed by FracTracker Alliance
Is waste immobilized once it’s landfilled?
The fate of New York State’s landfill leachate that originates from unconventional drilling waste is a core concern, since landfill waste is not inert. If drilling waste contains radioactivity, fracking chemicals, and heavy metals that percolate through the landfill, and the resulting leachate is sent to municipal wastewater treatment plants, will traditional water treatment methods remove those wastes? If not, what will be the impact on public and environmental health in the water body that receives the “treated” wastewater? In Pennsylvania, for example, a case is currently under investigation relating to pollution discharges into the Monongahela River near Pittsburgh. “That water was contaminated with diesel fuels, it’s alleged, carcinogens and other pollutants,” said Rich Bower, Fayette County District Attorney.
Currently, a controversial expansion of the Hakes Landfill in Painted Post, New York is in the news. Sierra Club and others were concerned about oversight of radium and radon in the landfill’s leachate and air emissions, presumably stemming from years of receiving drill cuttings. The leachate from the landfill is sent to the Bath Wastewater Treatment plant, which is not equipped to remove radioactivity. “Treated” wastewater from the plant is then discharged into the Cohocton River, a tributary of the Chesapeake Bay. In April 2019, these environmental groups filed a law suit against Hakes C&D Landfill and the Town of Campbell, New York, in an effort to block the expansion.
Similar levels of radioactivity in leachate have also been noted in leachate produced at the Chemung County Landfill, according to Gary McCaslin, President of People for a Healthy Environment, Inc.
In recent years, much of the solid unconventional waste arriving in New York State has gone to the Chemung County Landfill (see Figure 6, above). Over the course of several years, this site requested permission to expand significantly from 180,000 tons per year to 417,000 tons per year. However, by 2016, the expansion was deemed unnecessary, and according, the plans were put on hold, in part “…because of a decline in the amount of waste being generated due to a slower economy and more recycling than when the expansion was first planned years ago.” The data in Figure 5 above also parallel this story, with unconventional drilling waste disposed in New York State dropping from over 200,000 tons in 2011 to just over 20,000 tons in 2018.
Liquid waste transported to New York State
The story about liquid unconventional drilling waste exported from Pennsylvania to states other than Ohio is not completely clear (see Figure 7, below). Note that the data indicate more than a 2000% increase in waste liquids going from Pennsylvania to West Virginia after 2017. While it has not been officially documented, FracTracker has been anecdotally informed that a great deal of waste was already going to West Virginia, but that the record-keeping prior to 2018 was simply not strongly enforced.
Figure 7: Known disposal locations (excluding Pennsylvania and Ohio) of Pennsylvania’s liquid waste. Data source: PA DEP, processed by FracTracker Alliance
Beginning in the very early years of the Pennsylvania unconventional fracking boom, a variety of landfills in New York State have also accepted liquid wastes originating in Pennsylvania, including produced water and flowback fluids (see Figure 8, below).
Figure 8: Liquid waste from unconventional drilling, sent to facilities in New York State. Data source: PA DEP, processed by FracTracker Alliance
In addition, while this information doesn’t even appear in the PA DEP records (which are publicly available back to 2010), numerous wastewater treatment plants did accept some quantity, despite being fully unequipped to process the highly saline waste before it was discharged back into the environment.
One such facility was the wastewater treatment plant in Cayuga Heights, Tompkins County, which accepted more than 3 million gallons in 2008. Another was the wastewater treatment plant in Auburn, Cayuga County, where the practice of accepting drilling wastewater was initially banned in July 2011, but the decision was reversed in March 2012 to accept vertical drilling waste, despite strong public dissent. Another wastewater treatment plant in Watertown, Jefferson County, accepted 35,000 gallons in 2009.
Fortunately, most New York State wastewater treatment plant operators were wise enough to not even consider adding a brew of unknown and/or proprietary chemicals to their wastewater treatment stream. Numerous municipalities and several counties banned fracking waste, and once the ban on fracking in New York State was instituted in 2014, nearly all importation of liquid unconventional drilling waste into the state ceased.
Nevertheless, conventional, or vertical well drilling also generates briny produced water, which the New York State Department of Environmental Conservation (DEC) permits communities in New York to accept for ice and dust control on largely rural roads. These so-called “beneficial use determinations” (BUDs) of liquid drilling waste have changed significantly over the past several years. During the height of the Marcellus drilling in around 2011, all sorts of liquid waste was permitted into New York State (see FracTracker’s map of affected areas) and was spread on roads. As a result, the chemicals—many of them proprietary, of unknown constituents, or radioactive—were indirectly discharged into surface waters via roadspreading.
Overall, in the years after the ban in 2014 on high volume hydraulic fracturing was implemented, restrictions on Marcellus waste coming into New York have strengthened. Very little liquid waste entered New York’s landfills after 2013, and what did come in was sent to a holding facility owned by Environmental Services of Vermont. This facility is located outside Syracuse, New York.
New York State says “no” to this toxic legacy
Fortunately, not long after these issues of fracking fluid disposal at wastewater treatment facilities in New York State came to light, the practice was terminated on a local level. The 2014 ban on fracking in New York State officially prevented the disposal of Marcellus fluids in municipal wastewater treatment facilities and required extra permits if it were to be road-spread.
In New York State, the State Senate—after 8 years of deadlock—in early May 2019, passed key legislation that would close a loophole that had previously allowed dangerous oil and gas waste to bypass hazardous waste regulation. Read the press release from Senator Rachel May’s office here. However, despite strong support from both the Senate, and the Assembly, as well as many key environmental groups, the Legislature adjourned for the 2019 session without bringing the law to a final vote. Said Elizabeth Moran, of the New York Public Interest Research Group (NYPIRG), “I want to believe it was primarily a question of timing… Sadly, a dangerous practice is now going to continue for at least another year.”
See Earthworks’ recent three part in-depth reporting on national, New York, and Pennsylvania oil and gas waste, with mapping support by FracTracker Alliance.
All part of the big picture
As long as hydrocarbon extraction continues, the issues of waste disposal—in addition to carbon increases in the atmosphere from combustion and leakage—will result in impacts on human and environmental health. Communities downstream and downwind will bear the brunt of landfill expansions, water contamination, and air pollution. Impacts of climate chaos will be felt globally, with the greatest impacts at low latitudes and in the Arctic.
Transitioning to net-zero carbon emissions cannot be a gradual endeavor. Science has shown that in order to stay under the 1.5 °C warming targets, it must happen now, and it requires the governmental buy-in to the Paris Climate Agreement by every economic power in the world.
No exceptions. Life on our planet requires it.
We have, at most, 12 years to make a difference for generations to come.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/07/DSC_0624_LowRes-scaled.jpg9821500Shannon Smithhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngShannon Smith2019-08-07 09:36:032020-03-20 17:32:33Wildness Lost – Pine Creek
Designating a well as “idle” is a temporary solution for operators, but comes at a great economic and environmental cost to Californians
Idle wells are oil and gas wells which are not in use for production, injection, or other purposes, but also have not been permanently sealed. During a well’s productive phase, it is pumping and producing oil and/or natural gas which profit its operators, such as Exxon, Shell, or California Resources Corporation. When the formations of underground oil pools have been drained, production of oil and gas decreases. Certain techniques such as hydraulic fracturing may be used to stimulate additional production, but at some point operators decide a well is no longer economically sound to produce oil or gas. Operators are supposed to retire the wells by filling the well-bores with cement to permanently seal the well, a process called “plugging.”
A second, impermanent option is for operators to forego plugging the well to a later date and designate the well as idle. Instead of plugging a well, operators cap the well. Capping a well is much cheaper than plugging a well and wells can be capped and left “idle” for indefinite amounts of time.
Well plugging
Unplugged wells can leak explosive gases into neighborhoods and leach toxic fluids into drinking waters. Plugging a well helps protect groundwater and air quality, and prevents greenhouse gasses from escaping and expediting climate change. Therefore it’s important that idle wells are plugged.
Wells are left idle for two main reasons: either the cost of plugging is prohibitive, or there may be potential for future extraction when oil and gas prices will fetch a higher profit margin. While idle wells are touted by industry as assets, they are in fact liabilities. Idle wells are often dumped to smaller or questionable operators.
Orphaned wells
Wells that have passed their production phase can also be “orphaned.” In some cases, it is possible that the owner and operator may be dead! Or, as often happens, the smaller operators go out of business with no money left over to plug their wells or resume pumping. When idle wells are orphaned from their operators, the state becomes responsible for the proper plugging and abandonment.
The cost to plug a well can be prohibitively high for small operators. If the operators (who profited from the well) don’t plug it, the costs are externalized to states, and therefore, the public. For example, the state of California plugged two wells in the Echo Park neighborhood of Los Angeles at a cost of over $1 million. The costs are much higher in urban areas than, say, the farmland and oilfields of the Central Valley.
Since 1977, California has permanently sealed about 1,400 orphan wells at a cost of $29.5 million, according to reports by the Division of Oil, Gas, and Geothermal Resources (DOGGR). That’s an average cost of about $21,000 per well, not accounting for inflation. From 2002-2018, DOGGR plugged about 600 wells at a cost of $18.6 million; an average cost of about $31,000.
The map above shows the locations of idle wells in California. There are 29,515 wells listed as idle and 122,467 plugged or buried wells as of the most recent DOGGR data, downloaded 3/20/19. There are a total of 245,116 oil and gas wells in the state, including active, idle, new (permitted) or plugged.
Of the over 29,000 wells are listed as idle, only 3,088 (10.4%) reported production in 2018. Operators recovered 338,201 barrels of oil and 178,871 cubic feet of gas from them in 2018. Operators injected 1,550,436,085 gallons of water/steam into idle injection wells in 2018, and 137,908,884 cubic feet of gas.
The tables below (Tables 1-3) provide the rankings for idle well counts by operator, oil field, and county (respectively). Chevron, Aera, Shell, and California Resources Corporation have the most idle wells. The majority of the Chevron idle wells are located in the Midway Sunset Field. Well over half of all idle wells are located in Kern County.
Table 1. Idle Well Counts by Operator
Operator Name
Idle Well Count
1
Chevron U.S.A. Inc.
6,292
2
Aera Energy LLC
5,811
3
California Resources Production Corporation
3,708
4
California Resources Elk Hills, LLC
2,016
5
Berry Petroleum Company, LLC
1,129
6
E & B Natural Resources Management Corporation
991
7
Sentinel Peak Resources California LLC
842
8
HVI Cat Canyon, Inc.
534
9
Seneca Resources Company, LLC
349
10
Crimson Resource Management Corp.
333
Table 2. Idle Well Counts by Oil Field
Oil Field
Count by Field
1
Midway-Sunset
5,333
2
Unspecified
2,385
3
Kern River
2,217
4
Belridge, South
2,075
5
Coalinga
1,729
6
Elk Hills
958
7
Buena Vista
887
8
Lost Hills
731
9
Cymric
721
10
Cat Canyon
661
Table 3. Idle Well Counts by County
County
Count by County
1
Kern
17,276
2
Los Angeles
3,217
3
Fresno
2,296
4
Ventura
2,022
5
Santa Barbara
1,336
6
Orange
752
7
Monterey
399
8
Kings
212
9
San Luis Obispo
202
10
Sutter
191
Risks
According to the Western States Petroleum Association (WSPA) the count of idle wells in California has increased from just over 20,000 idle wells in 2015 to nearly 30,000 wells in 2018! That’s an increase of nearly 50% in just 3 years!
A U.S. EPA report on idle wells published in 2011 warned that existing monitoring requirements of idle wells in California was “not consistent with adequate protection” of underground sources of drinking water. Idle wells may have leaks and damage that go unnoticed for years, according to an assessment by the state Department of Conservation (DOC). The California Council on Science and Technology is actively researching this and many other issues associated with idle and orphaned wells. The published report will include policy recommendations considering the determined risks. The report will determine the following:
State liability for the plugging and abandoning of deserted and orphaned wells and decommissioning facilities attendant to such wells
Assessment of costs associated with plugging and abandoning deserted and orphaned wells and decommissioning facilities attendant to such wells
Exploration of mechanisms to ameliorate plugging, abandoning, and decommissioning burdens on the state, including examples from other regions and questions for policy makers to consider based on state policies
Current regulation
As of 2018, new CA legislation is in effect to incentivize operators to properly plug and abandon their stocks of idle wells. In California, idle wells are defined as wells that have not had a 6-month continuous period of production over a 2-year period (previously a 5-year period). The new regulations require operators to pay idle well fees. The fees also contribute towards the plugging and proper abandonment of California’s existing stock of orphaned wells. The new fees are meant to act as bonds to cover the cost of plugging wells, but the fees are far too low:
$150 for each well that has been idle for 3 years or longer, but less than 8 years
$300 for each well that has been idle for 8 years or longer, but less than 15 years
$750 for each well that has been idle for 15 years or longer, but less than 20 years
$1,500 for each well that has been idle for 20 years or longer
Operators are also allowed to forego idle well fees if they institute long-term idle well management and elimination plans. These management plans require operators to plug a certain number of idle wells each year.
In February 2019, State Assembly member Chris Holden introduced an idle oil well emissions reporting bill. Assembly bill 1328 requires operators to monitor idle and abandoned wells for leaks. Operators are also required to report hydrocarbon emission leaks discovered during the well plugging process. The collected results will then be reported publicly by the CA Department of Conservation. According to Holden, “Assembly Bill 1328 will help solve a critical knowledge gap associated with aging oil and gas infrastructure in California.”
While the majority of idle wells are located in Kern County, many are also located in California’s South Coast region. Due to the long history and high density of wells in the Los Angeles, the city has additional regulations. City rules indicate that oil wells left idle for over one year must be shut down or reactivated within a month after the city fire chief tells them to do so.
Who is responsible?
All of California’s wells, from Kern County to three miles offshore, on private and public lands, are managed by DOGGR, a division of the state’s Department of Conservation. Responsibilities include establishing and enforcing the requirements and procedures for permitting wells, managing drilling and production, and at the end of a well’s lifecycle, plugging and “abandoning” it.
To help ensure operator liability for the entire lifetime of a well, bonds or well fees are required in most states. In 2018, California updated the bonding requirements for newly permitted oil and gas wells. These fees are in addition to the aforementioned idle well fees. Operators have the option of paying a blanket bond or a bond amount per well. In 2018, these fees raised $4.3 million.
Individual well fees:
Wells less than 10,000 feet deep: $10,000
Wells more than 10,000 feet deep: $25,000
Blanket fees:
Less than 50 wells: $200,000
50 to 500 wells: $400,000
500 to 10,000 wells: $2,000,000
Over 10,000 wells: $3,000,000
With an average cost of at least $31,000 to plug a well, California’s new bonding requirements are still insufficient. Neither the updated individual nor blanket fees provide even half the cost required to plug a typical well.
Conclusions
Strategies for the managed decline of the fossil fuel industry are necessary to make the proposal a reality. Requiring the industry operators to shut down, plug and properly abandon wells is a step in the right direction, but California’s new bonding and idle well fees are far too low to cover the cost of orphan wells or to encourage the plugging of idle wells. Additionally, it must be stated that even properly abandoned wells have a legacy of causing groundwater contamination and leaking greenhouse gases such as methane and other toxic VOCs into the atmosphere.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/03/IdleWellsHathaway_resize.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2019-04-03 11:30:582021-04-15 14:56:34Idle Wells are a Major Risk
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
In California’s Central Valley and along the South Coast, there are many communities littered with abandoned oil and gas wells, buried underground.
Many have had homes, buildings, or public parks built over top of them. Some of them were never plugged, and many of those that were plugged have since failed and are leaking oil, natural gas, and toxic formation waters (water from the geologic layer being tapped for oil and gas). Yet this issue has been largely ignored. Oil and gas wells continue to be permitted without consideration for failing and failed plugged wells. When leaking wells are found, often nothing is done to fix the issue.
As a result, greenhouse gases escape into the atmosphere and present an explosion risk for homes built over top of them. Groundwater, including sources of drinking water, is known to be impacted by abandoned wells in California, yet resources are not being used to track groundwater contamination.
Abandoned wells: plugged and orphaned
The term “abandoned” typically refers to wells that have been taken out of production. At the end of their lifetime, wells may be properly abandoned by operators such as Chevron and Shell or they may be orphaned.
When operators properly abandon wells, they plug them with cement to prevent oil, natural gas, and salty, toxic formation brine from escaping the geological formation that was tapped for production. Properly plugging a well helps prevent groundwater contamination and further air quality degradation from the well. The well-site at the surface may also be regraded to an ecological environment similar to its original state.
Wells that are improperly abandoned are either plugged incorrectly or are “orphaned” by their operators. When wells are orphaned, the financial liability for plugging the well and the environmental cleanup falls on the state, and therefore, the taxpayers.
You don’t see them?
In California’s Central Valley and South Coast abandoned wells are everywhere. Below churches, schools, homes, they even under the sidewalks in downtown Los Angeles!
FracTracker Alliance and Earthworks recently spent time in Los Angeles with an infrared camera that shows methane and volatile organic compound (VOC) emissions. We visited several active neighborhood drilling sites and filmed plumes of toxic and carcinogenic VOCs floating over the walls of well-pads and into the surrounding neighborhoods. We also visited sites where abandoned, plugged wells had failed.
In the video below, we are standing on Wilshire Blvd in LA’s Miracle Mile District. An undocumented abandoned well under the sidewalk leaks toxic and carcinogenic VOCs through the cracks in the pavement as mothers push their children in walkers through the plume. This is just one case of many that the state is not able to address.
California regulatory data shows that there are 122,466 plugged wells in the state, as shown below in the map below. Determining how many of them are orphaned or improperly plugged is difficult, but we can come up with an estimate based on the wells’ ages.
While there are no available data on the dates that wells were plugged, there are data on “spud dates,” the date when operators begin drilling into the ground. Of the 18,000 wells listing spud dates, about 70% were drilled prior to 1980. Wells drilled before 1980 have a higher risk of well casing failures and are more likely to be sources of groundwater contamination.
With a total of over 245,000 wells in the state database, and considering the lack of monitoring prior to 1950, it’s reasonable to assume there are over 80,000 improperly plugged and unplugged wells in California.
The regions with the highest counts of plugged wells are the Central Valley and the South Coast. The top 10 county ranks are listed below in Table 1. Kern County has more than half of the total plugged wells in the entire state.
Table 1. Ranks of Counties by Plugged Well Counts
Rank
1
2
3
4
5
6
7
8
9
10
County
Kern
Los Angeles
Orange
Fresno
Ventura
Santa Barbara
Monterey
San Luis Obispo
Solano
Yolo
Plugged Well Count
65,733
17,139
7,259
6,970
4,302
4,192
2,266
1,463
1,456
1,383
The issue is not unique to California. Nationally, an estimated 2.56 million oil and gas wells have been drilled and 1.93 million wells had been abandoned by 1975. Using interpolated data, the EPA estimates that as of 2016 there were 3.12 million abandoned wells in the U.S. and 69% of them were left unplugged.
In 2017, FracTracker Alliance organized an exercise to track down the locations of Pennsylvania’s abandoned wells that are not included in the PA Department of Environmental Protection’s digital records. Using paper maps and the FracTracker Mobile App, volunteers explored Pennsylvania woodlands in search of these hidden greenhouse gas emitters.
What are the risks?
Emissions
Studies by Kang et al. 2014, Kang et al 2016, Boothroyd et al 2016, and Townsend-Small et al. 2016 have all measured methane emissions from abandoned wells. Both properly plugged and improperly abandoned wells have been shown to leak methane and other VOCs to the atmosphere as well as into the surrounding groundwater, soil, and surface waters. Leaks were shown to begin just 10 years after operators plugged the wells.
Well density
The high density of aging and improperly plugged wells is a major risk factor for the current and future development of California’s oil and gas fields. When fields with old wells are reworked using new technology, such as hydraulic fracturing, CO2 flooding, or solvent flooding (including acidizing, water flooding, or steam flooding), the injection of additional fluid and gas increases pressure in a reservoir. Poorly plugged or aging wells often lack the integrity to avoid a blowout (the uncontrolled release of oil and/or gas from a well). There is a consistent risk that formation fluids will be forced to migrate up the plugged wellbores and bypass the existing plugs.
Groundwater
In a 2014 report, the U.S. Geological Service warned the California State Water Resources Control Board that the integrity of abandoned wells is a serious threat to groundwater sources, stating, “Even a small percentage of compromised well bores could correspond to a large number of transport pathways.”
The California Council on Science and Technology (CCST) has also suggested the need for additional research on existing aquifer contamination. In 2014, they called for widespread testing of groundwater near oil and gas fields, which has still not occurred.
Leaks
In addition to the contamination of underground sources of drinking water, abandoned well failures can even create a pathway for methane and fluids to escape to Earth’s surface. In many cases, such as in Pennsylvania, Texas, and California, where drilling began prior to the turn of the 20th century, many wells have been left unplugged. Of the abandoned wells that were plugged, the plugging process was much less adequate than it is today.
If plugged wells are allowed to leak, surface expressions can form. These leaks can travel to the Earth’s crust where oil, gas, and formation waters saturate the topsoil. A construction supervisor for Chevron named David Taylor was killed by such an event in the Midway-Sunset oil field near Bakersfield, CA. According to the LA Times, Chevron had been trying to control the pressure at the well-site. The company had stopped injections near the well, but neighboring operators continued high-pressure injections into the pool. As a result, migration pathways along old wells allowed formation fluids to saturate the Earth just under the well-site. Tragically, Taylor fell into a 10-foot diameter crater of 190° fluid and hydrogen sulfide.
California regulations
Following David Taylor’s death in 2011, California regulators vowed to make urgent reforms to the management of underground injection, and new rules finally went into effect on April 1, 2018. These regulations require more consistent monitoring of pressure and set maximum pressure standards. While this will help with the management of enhanced oil recovery operations, such as steam and water flooding and wastewater disposal, the issue of abandoned wells is not being addressed.
Why would the state of California allow new oil and gas drilling when the industry refuses to address the existing messes? Why are these messes the responsibility of private landholders and the state when operators declare bankruptcy?
New bonding rules in some states have incentivized larger operators to plug their own wells, but old low-producing or idle wells are often sold off to smaller operators or shell (not Shell) companies prior to plugging. This practice has been the main source of orphaned wells. And regardless of whether wells are plugged or not, research shows that even plugged wells release fugitive emissions that increase with the age of the plug.
If the fossil fuel industry were to plug the existing 1.666 million currently active wells, there would be nearly 5 million plugged wells that require regular inspections, maintenance, and for the majority, re-plugging, to prevent the flow of greenhouse gases. This is already unattainable, and drilling more wells adds to this climate disaster.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/03/chevron-surface-expression_resize.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2019-03-29 09:08:262021-04-15 14:56:53Literally Millions of Failing, Abandoned Wells
Oil and gas development generates a lot of liquid waste.
Some of the waste comes that comes out of a well is from the geologic layer where the oil and gas resources are located. These extremely saline brines may be described as “natural,” but that does not make them safe, as they contain dangerous levels of radiation, heavy metals, and other contaminants.
Additionally, a portion of the industrial fluid that was injected into the well to stimulate production, known as hydraulic fracturing fluid, returns to the surface. Some of these substances are known carcinogens, while others remain entirely secret, even to the personnel in the field who are employed to use the additives.
The industry likes to remind residents that they have used this technique for more than six decades, which is true. What separates “conventional” fracking from developing unconventional formations such as the Marcellus Shale is really a matter of scale. Conventional formations are often stimulated with around 10,000 gallons of fluid, while unconventional wells now average more than 10 million gallons per well.
Conventional Well: 10,000 gallons
Olympic Swimming Pool: 660,253 gal
Unconventional Well: >10 Million gal
In 2017 alone, Pennsylvania oil and gas wells generated 57,653,023 barrels (2.42 billion gallons) of liquid waste.
Managing the waste stream
Liquid waste can be reused to stimulate other oil and gas wells, but reuse concentrates the contaminant load in the fluid. There is a limit to this concentration that operators can use, even for this industrial purpose.
Another strategy is to decrease the volume of the waste through evaporation and other treatment methods. This also increases the contaminant concentration. Pennsylvania used to permit “treatment” of wastewater at sewage treatment facilities, before being forced to concede that the process was completely ineffective, and resulted in contaminating streams and rivers throughout the Commonwealth.
In many states, much of this waste is disposed of in facilities known as salt water disposal (SWD) wells, a specific type of injection well. These waste facilities fall under the auspices of the US Environmental Protection Agency’s Underground Injection Control (UIC) program. Such wells are co-managed with states’ oil and gas regulatory agencies, although the specifics vary by state.
These photos show SWD wells in other states, but what about in Pennsylvania?
The oil and gas industry in Pennsylvania has not used SWD wells as a primary disposal method, as the state’s geology has been considered unsuitable for this process. For example, on page 67 of this 2009 industry report, the authors saw treatment of flowback fluid at municipal facilities as a viable option (before the process was banned in 2011), but underground injection as less likely (emphasis added):
The disposal of flowback and produced water is an evolving process in the Appalachians. The volumes of water that are being produced as flowback water are likely to require a number of options for disposal that may include municipal or industrial water treatment facilities (primarily in Pennsylvania), Class II injection wells [SWDs], and on-site recycling for use in subsequent fracturing jobs. In most shale gas plays, underground injection has historically been preferred. In the Marcellus play, this option is expected to be limited, as there are few areas where suitable injection zones are available.
The ban on surface “treatment” being discharged into Pennsylvania waters has increased the pressure for finding new solutions for brine disposal. This is compounded by the fact that the per-well volume of fluid injected into shale gas wells in the region has nearly tripled in that time period. Much of what is injected comes back up to the surface and is added to the liquid waste stream.
Chemically-similar brine from conventional wells has been spread on roadways for dust suppression. This practice was originally considered a “beneficial use” of the waste product, but the Pennsylvania Department of Environmental Protection (DEP) halted that practice in May 2018.
None of these waste management decisions make the geology in Pennsylvania suddenly suitable for underground injection, however, they do increase the pressure on the state to find a disposal solution.
Concerns with SWD wells
There are numerous concerns with salt water disposal wells. In October 2018, the DEP held a hearing in Plum Borough, on the eastern edge of Allegheny County, where there is a proposal to convert the Sedat 3A conventional well to an injection well. Some of the concerns raised by residents include:
Fluid and/or gas migration- There are numerous routes for fluids and gas to migrate from the injection formation to drinking water aquifers or even surface water. Potential conduits include coal mines, abandoned gas wells, water wells, and naturally occurring fissures in crumbling sedimentary formations.
Induced seismicity- SWD wells have been linked to increased earthquake activity, either by lubricating or putting pressure on old faults that had been dormant. Earthquakes can occur miles away from the injection location, and in sedimentary formations, not just igneous basement rock.
Noise, diesel pollution, loss of privacy, and road degradation caused by a constant stream of industrial waste haulers to the well location.
Complicating existing issues- Plum Borough and surrounding communities are heavily undermined, and in fact the well bore goes right through the Renton Coal Mine (another part of which has been on fire for decades). Mine subsidence is already a widespread issue in the region, and many fear that even small seismic events could exacerbate this.
Possibility of surface spill- Oil and gas is, sadly, a sloppy industry, with unconventional operations having accumulated more than 13,000 violations in Pennsylvania since 2008. If a major spill were to happen at this location, there is the possibility of release into Pucketa Creek, which drains into the Allegheny River, the source of drinking water for multiple communities.
Radioactivity and other contaminants- Flowback fluids are often highly radioactive, contain heavy metals, and other contaminants that are challenging to effectively clean. The migration of radon gas into homes above the injection formation is also a possibility.
Pennsylvania has numerous data sources for oil and gas, but they are not always in agreement. To account for this, we have mapped SWDs (and a five mile buffer around them) from two different data sources in the map below. The first source is a subset of SWD wells from a larger dataset of oil and gas locations from the DEP’s mapping website. The second source is from a Waste Facility Report, represented in pink triangles that are offset at an angle to allow users to see both datasets simultaneously in instances where they overlap.
Map of existing, proposed, and plugged salt water disposal (SWD) injection wells in Pennsylvania.
According to the first data set of DEP’s oil and gas locations, Pennsylvania contains 13 SWDs with an active status, one SWD with a regulatory inactive status, and eight that are plugged. The Waste Facility Report shows 10 SWD wells total, including one well that was left out of the other data set in Annin Township, McKean County.
It is worth noting that Pennsylvania’s definition for an “active” well status is confusing, to put it charitably. It does not mean that a well is currently in operation, nor does it even mean that it is currently permitted for the activity, whether that is waste disposal or gas production, or some other function. An active status means that the well has been proposed for a given use, and the well hasn’t been plugged, or assigned some other status.
The Sedat 3A well in Plum, for example, has an active status, although the DEP has not yet granted it a permit to operate as a SWD well. Another status type is “regulatory inactive,” which is given to a well that hasn’t been used for its stated purpose in 12 months, but may potentially have some future utility.
Karst, coal mines, and streams
While there are numerous factors worthy of consideration when siting SWD wells, this map focuses on three: the proximity of karst formations, coal mines and nearby streams that the state designates as either high quality or exceptional value.
Karst formations are unstable soluble rock formations like limestone deposits which are likely to contain numerous subsurface voids. These voids are concerning in this context. For one reason, there’s the possibility of contaminated fluids and gasses migrating into underground freshwater aquifers. Also, the voids are inherently structurally unstable, which could compound the impacts of artificially-induced seismic activity caused by fluid injections in the well.
Our analysis found over 78,000 acres (123 square miles) of karst geology within five miles of current, proposed, or plugged SWD wells in Pennsylvania.
Coal mines, while a very different sedimentary formation, have similar concerns because of subsurface voids. Mine subsidence is already a widespread problem in many of the communities surrounding SWD well sites. Pennsylvania has several available data sets, including active underground mine permits and digitized mined areas, which are used in this map. Active mine permits show current permitted operations, while digitized mine areas offer a highly detailed look at existing mines, including abandoned mines, although the layer is not complete for all regions of the state.
In Pennsylvania, there are 56,542 acres (88 square miles) of active mines within five miles of SWD wells. Our analysis found 97,902 acres (153 square miles) of digitized mined areas within five miles of SWD wells. Combined, there are 139,840 acres (219 square miles) of existing and permitted mines within the 5 mile buffer zone around SWDs in Pennsylvania.
Streams with the designation “high quality” and “exceptional value” are the best streams Pennsylvania has to offer, in terms of recreation, fishing, and biological diversity. In this analysis, we have identified such streams within a five mile radius of SWD wells, irrespective of the given watershed of the well location.
While the rolling topography of Western Pennsylvania sheds rainwater in a complicated network of drainages, groundwater is not subject to that particular geography. Furthermore, groundwater regularly interacts with surface water through water wells, abandoned O&G wells, and natural seeps and springs. Therefore, it is possible for SWDs to contaminate these treasured streams, even if they are not located within the same watershed.
Altogether, there are 716 miles of high quality streams and 110 miles of exceptional value streams within 5 miles of the SWDs in this analysis.
Conclusion
For decades, geologists have concluded that the subsurface strata in Pennsylvania were not suitable for oil and gas liquid waste disposal in underground injection wells. The fact that vast quantities of this waste are now being produced in Pennsylvania has not suddenly made it a suitable location for the practice. If anything, additional shallow and deep wells have further fractured the sedimentary strata, thereby increasing the risk of contamination.
The only factor that has changed is the volume of waste being produced in the region. SWD wells in nearby Ohio and West Virginia have capacity issues from their own production wells, and it is not clear that the geologic formations across the border are that much better than in Pennsylvania. But as new wells are drilled and volumes of hydraulic fracturing fluid continue to spiral into the tens of millions of gallons per well, the pressure to open new SWD wells in the state will only increase.
Perhaps because of these pressures, DEP has become quite bullish on the technology:
Several successful disposal wells are operating in Pennsylvania and options for more sites are always being considered. The history of underground disposal shows that it is a practical, safe and effective method for disposing of fluids from oil and gas production.
Up against this attitude, residents are facing an uphill battle trying to prevent harm to their health and property from these industrial facilities in their communities. Municipalities that have attempted to stand up for their residents have been sued by DEP to allow for these injection wells. The Department’s actions, which put the interests of industry above the health of residents and the environment, is directly at odds with the agency’s mission statement:
The Department of Environmental Protection’s mission is to protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment. We will work as partners with individuals, organizations, governments and businesses to prevent pollution and restore our natural resources.
It’s time for DEP to live up to its promises.
By Matt Kelso, Manager of Data and Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/01/SWD_PA2.png6671500Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2019-01-31 10:54:552021-04-15 14:56:56Getting Rid of All of that Waste – Increasing Use of Oil and Gas Injection Wells in Pennsylvania
Utica oil and gas production, Class II injection well volumes, and lateral length trends from 2010-2018
The US Energy Information Administration (EIA) recently announced that Ohio’s recoverable shale gas reserves have magically increased by 11,076 billion cubic feet (BCF). This increase ranks the Buckeye State in the top 5 for changes in recoverable shale natural gas reserves between 2016 and 2017 (pages 31- 32 here). After reading the predictable and superficial media coverage, we thought it was time to revisit the data to ask a pertinent question: What is the fracking industry costing Ohio?
Recent Shale Gas Trends in Ohio
According to the EIA’s report, Ohio currently sits at #7 on their list of proven reserves. It is estimated there are 27,021 BCF of shale gas beneath the state (Figure 1).
There are a few variations in the way the oil and gas industry defines proven reserves:
…an estimated quantity of all hydrocarbons statistically defined as crude oil or natural gas, which geological and engineering data demonstrate with reasonable certainty to be recoverable in future years from known reservoirs under existing economic and operating conditions. Reservoirs are considered proven if economic producibility is supported by either actual production or conclusive formation testing. – The Organization of Petroleum Exporting Countries
… the quantity of natural resources that a company reasonably expects to extract from a given formation… Proven reserves are classified as having a 90% or greater likelihood of being present and economically viable for extraction in current conditions… Proven reserves also take into account the current technology being used for extraction, regional regulations and market conditions as part of the estimation process. For this reason, proven reserves can seemingly take unexpected leaps and drops. Depending on the regional disclosure regulations, extraction companies might only disclose proven reserves even though they will have estimates for probable and possible reserves. – Investopedia
What’s missing from this picture?
Neither of the definitions above address the large volume of water or wastewater infrastructure required to tap into “proven reserves.” While compiling data for unconventional wells and injection wells, we noticed that the high-volume hydraulic fracturing (HVHF) industry is at a concerning crossroads. In terms of “energy return on energy invested,” HVHF is requiring more and more resources to stay afloat.
OH quarterly Utica oil & gas production along with quarterly Class II injection well volumes:
The map below shows oil and gas production from Utica wells (the primary form of shale gas drilling in Ohio). It also shows the volume of wastewater disposed in Class II salt water disposal injection wells.
Publications like the aforementioned EIA article and language out of Columbus highlight the nominal increases in fracking productivity. They greatly diminish, or more often than not ignore, how resource demand and waste production are also increasing. The data speak to a story of diminishing returns – an industry requiring more resources to keep up gross production while simultaneously driving net production off a cliff (Figure 2).
Figure 2. Number of Utica permits in Ohio on a cumulative and monthly basis along with the average price of West Texas Intermediate (WTI) and Brent Crude oil per barrel from September 2010 to December 2018
The Great Decoupling of New Year’s 2013
In the following analysis, we look at the declining efficiency of the HVHF industry throughout Ohio. The data spans the end of 2010 to middle of 2018. We worked with Columbus-area volunteer Gary Allison to conduct this analysis; without Gary’s help this work and resulting map, would not have been possible.
A little more than five years ago today, a significant shift took place in Ohio, as the number of producing gas wells increased while oil well numbers leveled off. The industry’s permitting high-water mark came in June of 2014 with 101 Utica permits that month (a level the industry hasn’t come close to since). The current six-month permitting average is 25 per month.
As the ball dropped in Times Square ringing in 2014, in Ohio, a decoupling between oil and gas wells was underway and continues to this day. The number of wells coming online annually increased by 229 oil wells and 414 gas wells.
Figure 3. Number of producing oil and gas wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018
Figure 4. Producing oil and gas wells as a percentage of permitted wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018
Permits
The ringing in of 2014 also saw an increase in the number of producing wells as a percentage of those permitted. In 2014, the general philosophy was that the HVHF industry needed to permit roughly 5.5 oil wells or 7 gas wells to generate one producing well. Since 2014, however, this ratio has dropped to 2.2 for oil and 1.4 for gas well permits.
Put another way, the industry’s ability to avoid dry wells has increased by 13% for oil and 18% for gas per year. As of Q2-2018, viable oil wells stood at 44% of permitted wells while viable gas wells amounted to 71% of the permitted inventory (Figure 4).
Production declines
from the top-left to the bottom-right
To understand how quickly production is declining in Ohio, we compiled annual (2011-2012) and quarterly (Q1-2013 to Q2-2018) production data from 2,064 unconventional laterals.
First, we present average data for the nine oldest wells with respect to oil and gas production on a per day basis (Note: Two of the nine wells we examined, the Geatches MAH 3H and Hosey POR 6H-X laterals, only produced in 2011-2012 when data was collected on an annual basis preventing their incorporation into Figures 6 and 7 belwo). From an oil perspective, these nine wells exhibited 44% declines from year 1 to years 2-3 and 91% declines by 2018 (Figure 5). With respect to natural gas, these nine wells exhibited 34% declines from year 1 to years 2-3 and 79% declines by 2018 (Figure 5).
Figure 5. Average daily oil and gas production decline curves for the above seven hydraulically fractured laterals in Ohio’s Utica Shale Basin, 2011 to Q2-2018
Four of the nine wells demonstrated 71% declines by the second and third years and nearly 98% declines by by Q2-2018 (Figure 6). These declines lend credence to recent headlines like Fracking’s Secret Problem—Oil Wells Aren’t Producing as Much as Forecast in the January 2nd issue of The Wall Street Journal. Four of the nine wells demonstrated 49% declines by the second and third years and nearly 81% declines by Q2-2018 (Figure 7).
Figure 6. Oil production decline curves for seven hydraulically fractured laterals in Ohio’s Utica Shale Basin from 2011 to Q2-2018
Figure 7. Natural gas production decline curves for seven hydraulically fractured laterals in Ohio’s Utica Shale Basin from 2011 to Q2-2018
Fracking waste, lateral length, and water demand
from bottom-left to the top-right
An analysis of fracking’s environmental and economic impact is incomplete if it ignores waste production and disposal. In Ohio, there are 226 active Class II Salt Water Disposal (SWD) wells. Why so many?
Ohio’s Class II well inventory serves as the primary receptacle for HVHF liquid waste for Pennsylvania, West Virginia, and Ohio.
The Class II network is situated in a crescent shape around the state’s unconventional wells. This expands the geographic impact of HVHF to counties like Ashtabula, Trumbull, and Portage to the northeast and Washington, Athens, and Muskingum to the south (Figure 8).
Figure 8. Ohio’s unconventional gas laterals and Class II salt water disposal injection wells. Weighted by cumulative production and waste disposal volumes to Q3-2018.
Disposal Rates
We graphed average per well (barrels) and cumulative (million barrels) disposal rates from Q3-2010 to Q3-2018 for these wells. The data shows an average increase of 24,822 barrels (+1.05 million gallons) per well, each year.
That’s a 51% per year increase (Figure 9).
A deeper dive into the data reveals that the top 20 most active Class II wells are accepting more waste than ever before: an astounding annual per well increase of 728,811 barrels (+30.61 million gallons) or a 230% per year increase (Figure 10). This divergence resulted in the top 20 wells disposing of 4.95 times the statewide average between Q3-2010 and Q2-2013. They disposed 13.82 times the statewide average as recently as Q3-2018 (Figure 11).
Figure 9
Cumulative and average well volumes for all 226 of Ohio’s Class II Salt Water Disposal wells from Q3-2010 to Q3-2018
Figure 10
Cumulative and average per well volumes for Ohio’s Top 20 Class II salt water disposal wells from Q3-2010 to Q3-2018
Figure 11
The ratio of average per well volumes for Ohio’s top 20 Class II salt water disposal (SWD) wells to all 226 Class II SWD wells from Q3-2010 to Q3-2018
All of this means that we are putting an increasing amount of pressure on fewer and fewer wells. The trickle out, down, and up of this dynamic will foist a myriad of environmental and economic costs to areas surrounding wells. As an example, the images below are injection wells currently under construction in Brookfield, Ohio, outside Warren and minutes from the Pennsylvania border.
More concerning is the fact that areas of Ohio that are injection well hotspots, like Warren, are proposing new fracking-friendly legislation. These disturbing bills would lubricate the wheels for continued expansion of fracking waste disposal and permitting. House bills 578 and 393 and Senate Bill 165 monetize and/or commodify fracking waste by giving townships a share of the revenue. Such bills “…would only incentivize communities to encourage more waste to come into their existing inventory of Class II… wells, creating yet another race to the bottom.” Co-sponsors of the bills include Democratic Reps. Michael O’Brien, Glenn Holms, John Patterson, and Craig Riefel.
Lateral Lengths
The above trends reflect an equally disturbing trend in lateral length. Ohio’s unconventional laterals are growing at a rate of 9.1 to 15.6%, depending on whether you buy that this trend is linear or exponential (Figure 12). This author believes the trend is exponential for the foreseeable future. Furthermore, it’s likely that “super laterals” in excess of 3-3.5 miles will have a profound impact on the trend. (See The Freshwater and Liquid Waste Impact of Unconventional Oil and Gas in Ohio and West Virginia.)
This lateral length increase substantially increases water demand per lateral. It also impacts Class II well disposal rates. The increase accounts for 76% of the former and 88% of the latter when graphed against each other (Figure 13).
Figure 12. Ohio Utica unconventional lateral length from Q3-2010 to Q4-2018
Figure 13. Ohio Utica unconventional water demand and Class II SWD injection well disposal volumes vs lateral length from Q3-2010 to Q4-2018.
Conclusion
This relationship between production, resource demand, and waste disposal rates should disturb policymakers, citizens, and the industry. One way to this problem is to more holistically price resource utilization (or stop oil and gas development entirely).
Unfortunately, states like Ohio are practically giving water away to the industry.
Politicians are constructing legislation that would unleash injection well expansion. This would allow disposal to proceed at rates that don’t address supply-side concerns. It’s startling that an industry and political landscape that puts such a premium on “market forces” is unwilling to address these trends with market mechanisms.
We will continue to monitor these trends and hope to spread these insights to states like Oklahoma and Texas in the future.
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance – with invaluable data compilation assistance from Gary Allison
Data Downloads
FracTracker is a proponent of data transparency, and so we often share the data we use to construct our maps analyses. Click on the links below to download the data associated with the present analysis:
Inventory of volumes disposed on a quarterly basis from 2010 to Q3-2018 for all 223 active Class II Salt Water Disposal (SWD) Injection wells in Ohio (zip file)
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/01/InjectionWell-Sky-Feature.jpg400900Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngTed Auch, PhD2019-01-09 14:37:272021-04-15 14:56:57A Disturbing Tale of Diminishing Returns in Ohio
Offshore drilling in the United States federal waters has caused the most environmentally destructive disasters in North America. Yet, new policy is pushing for the expansion of offshore drilling, particularly off the coast of California.
Offshore Drilling History
In 1969, Union Oil’s offshore rig Platform A had a blowout that leaked 100,000 barrels into the Santa Barbara Channel, one of the most biologically diverse marine environments in the world. The spill lasted ten days and killed an estimated 3,500 sea birds, as well as an untold number of marine mammals. Unbelievably, the Santa Barbara spill is only the third largest spill in U.S. waters. It follows the 1989 Exxon Valdez and the 2010 Deepwater Horizon spills. These incidents keep getting bigger.
More offshore drilling means a higher risk of catastrophe, additional contamination of air and water locally, and more greenhouse gas emissions globally.
Federal Moratorium on California Offshore Leases
Up until the beginning of 2018, further oil and gas development using offshore oil rig platforms seemed quite unlikely. After the 1969 oil spill from Platform A and the subsequent ban on further leasing in state waters, the risk of another devastating oil spill was too large for even the federal government to consider new leases. The fact that the moratorium lasted through 16 years of Bush presidencies is truly a victory. Across the aisle, expanding offshore operations has been opposed. In Florida, even Republican Governor Rick Scott teamed up with environmental groups to fight the Department of Interior’s recent sales of offshore leases.
Trump’s New Gas Leasing Program
Now, the U.S. Bureau of Ocean Energy Management (BOEM) is preparing a new 2019-2024 national Outer Continental Shelf (OCS) oil and gas leasing program to replace the existing 2017-2022 program. This is an unusual practice, and part of Trump’s America-First Offshore Energy Strategy. The Trump administration opened up most of the US coastal waters for new oil and gas drilling with a recent draft proposal offering 47 new offshore block lease sales to take place between 2019 and 2024.
Where might these new leases occur?
The offshore federal waters that are open for oil and gas leases are shown in dark blue in the map below (Figure 1). Zoom out to see the extent.
Southern California has a legacy of oil extraction, particularly Los Angeles. It’s not just the federal government that is keen on continuing this legacy. While the state has not permitted the leasing of new blocks in offshore waters, Governor Brown’s policies have been very friendly to the oil and gas industry. According to Oil Change International’s Sky’s the Limit report: “Under the Brown administration, the state has permitted the drilling of more than 20,000 new wells,” including 5,000 offshore wells in state waters. About 2,000 of these offshore wells have been drilled since 2012.
Southern California is the main target for future offshore leasing. The Monterey Shale formation, which underlies the city of Los Angeles and expands north offshore to the Ventura Coast, is thought to contain the largest conventional oil plays left IN THE WORLD! The map above shows the locations of state and federal offshore oil and gas wells and the rigs that service them. It also shows historical wells off the coast of Northern California.
Northern California, both onshore and offshore, sits on top of major reserves of natural gas, which may also be developed given the political climate. With an increase in the price of natural gas, operators will be developing these gas fields. Some operators, such as Chevron, have already drilled natural gas wells in northern California, but have left the wells “shut in” (capped) until production becomes more profitable.
FracTracker, in collaboration with Earthworks, recently teamed up with the Center for Biological Diversity and Greenpeace International to get up close to offshore oil rigs. As a certified Optical Gas Imaging Thermographer, Kyle Ferrar (Western Program Coordinator for FracTracker Alliance and California Community Empowerment Project Organizer for Earthworks), took footage of the offshore oil rigs.
Using infrared technology, we were able to visualize and record emissions and leaks of volatile hydrocarbons and other greenhouse gases coming from these offshore sites. We documented many cases of intense flaring from the rigs, including several cases where the poorly burning flare allowed hydrocarbons to be leaked to the atmosphere prior to complete combustion of CO2.
Below you can view a compilation of the footage we were able to capture from small pontoon boats.
Conclusion
FracTracker has looked at offshore oil and gas drilling from many different angles. We have looked to the past, and found the most egregious environmental damages in U.S. history. We have analyzed the data and shown where, when, and how much offshore drilling is happening in California. We have demonstrated that much of the drilling and many of the proposed leases are in protected and sensitive habitats. We have looked at policy and found that both Governor Brown and President Trump are aligned to promote more oil and gas development. We have even looked at the rigs in person in multiple spectrums of light and found that these operations continuously leak and emit greenhouse gases and other air toxins.
No matter which way you look at offshore oil and gas drilling, it is clearly one of the most threatening methods of oil and gas extraction in use today.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/10/CA-Offshore-Feature.png400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2018-11-05 14:32:422021-04-15 14:57:10The Feds Trump California’s State Ban on Offshore Oil Drilling
In August 2016, Shell announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. In response to available data, FracTracker launched the Falcon Public EIA Project in January of 2018 to unearth the environmental and public health impacts of the proposed pipeline. As part of that project, today we explore Shell’s Chapter 105 application and the deficiencies the Pennsylvania Department of Environmental Protection (DEP) cited after reviewing Shell’s application.
Just a heads up… there are a lot.
Shell originally submitted a Chapter 105 application to the DEP to receive a permit for water obstruction and encroachment. The DEP began reviewing the application in January of 2018. On June 1st, they sent Shell technical deficiency letters listing several issues with the application. Shell responded to these deficiencies on August 1st.
Now, it’s up to the DEP to decide if Shell’s response is adequate, and if the department should go ahead and approve the application or require more work from Shell. Explore the technical deficiencies below for more information.
Technical Deficiencies
Below is a map that highlights several of the deficiencies the DEP found with Shell’s application and a brief explanation of each one. Expand the map full-screen to explore more layers – Some layers only become visible when you zoom in due to the level of detail they display.
Next, we’ll walk you through the technical deficiencies, which we have broken down into the following categories:
Wetlands, rivers, streams
Stormwater control
Public health and safety (drinking water & trails)
Conservation areas
Alternative routes
Geological concerns (including mining issues)
Documentation issues
Legend
A = Allegheny County, B = Beaver County, W = Washington County. The numbers reference the number listed in the deficiencies letter.
1. Wetlands, Rivers, & Streams
Water withdrawal from rivers and discharge
B2A2W2 The project will discharge waste water from an industrial activity to a dry swale, surface water, ground water, or an existing sanitary sewer system or separate storm water system. The DEP requested that Shell identify and describe this discharge, as the DEP’s Clean Water Program must authorize discharges. Shell stated that water will be discharged from hydrostatic testing, (which ensures a pipeline can withstand high pressure by pumping water through it to test for leaks), and a PAG-10 permit (needed for hydrostatic test water discharge) was submitted to the DEP July 27, 2018 with the locations of discharge. Drawings of the discharges are in Attachment O. (The locations of the discharges were not included in Shell’s public response to this deficiency.)
B33 A31 W31 Shell will be withdrawing water for hydrostatic testing. The DEP asked Shell to explain the intake and discharge methods so the DEP can decide if these should be included as impacts. The DEP also asked Shell to provide the location of intake and discharge. The DEP’s Clean Water Program must authorize discharges. In response, Shell stated that water will be withdrawn from Raccoon Creek and the Ohio River in West Virginia. The specific locations are listed in the PAG-10 permit, submitted to the DEP in July. Drawings of the discharges are included in Attachment O.
Wetlands and Streams
B5 A3 W4 The DEP asked Shell to identify the presence of wetlands within the project area that are identified by the US Fish & Wildlife Service’s National Wetlands Inventory (NWI) data system, and provide data on how they may be impacted by the proposed pipeline.Shell identified one NWI wetland in Beaver County, but did not delineate or provide information on it, due to safety concerns (it’s on a steep cliff). This wetland will be crossed via HDD (horizontal directional drill). In Allegheny County, there is an NWI wetland that Shell also did not provide data on. This wetland was not initially evident, and when staff returned to survey it, the property owner did not let them access the site becausethey did not want a pipeline on their property. According to Shell, this NWI wetland is not within the “Project’s Limit of Disturbance.” In Washington County, Shell stated that “all of the NWI-mapped wetlands that were determined not to be wetlands have been accounted for in Washington County. These NWI wetlands were all located in an area that had been previously strip-mined and due to mining activities, those wetlands are no longer there. Data were taken for these areas and included… separately as Attachment D.” Also in Washington County is an NWI wetland located above the Panhandle Trail, which Shell determined to be outside of the study area and therefore did not collect data on it. This wetland is not on the map, but Shell did provide this image of it.
B6 A4W5 The DEP requested that Shell match off-line wetland data with sampling point locations from study area maps. In response, Shell placed offline data sheets in the order that they are in Table 3 in the Wetlands Delineation Report and in Table 4 in the Watercourse Delineation Report.
B7 A5W6 Shell needed to discuss the types and conditions of riverine resources that the project impacts. Specifically, how the conditions of these resources relate to their hydrological functions, biogeochemical functions, and habitat attributes. These are discussed under question 7 for Beaver County, question 5 for Allegheny County, and question 6 for Washington County.
B8 A6 W7 Shell needed to discuss the types and conditions of wetlands that the project impacts. Specifically, how the conditions of these wetlands contribute to their hydrological functions, biogeochemical functions, and habitat attributes. Shell also needed to discuss impacts to wetlands that will be temporarily impacted, as it previously only discussed wetlands facing permanent impacts. These are discussed under question 8 for Beaver County, question 6 for Allegheny County, and question 7 for Washington County.
B9 A7 W8 The DEP asked Shell to evaluate the impact of open cut installation on wetlands with perched water tables and/or confining layers. Perched water tables have an impermeable confining layer (such as clay) between them and the main water table below. If open cut methods are used, the confining layer is destroyed and this water table will be lost. In Beaver County, Shell identified one wetland (W-PA-170222-MRK-002) will be open cut. If it is perched, Shell states it will replace the confining layer “along the same horizon during pipeline backfilling, and then [compact the layer] so that hydrology may be maintained.” Shell will also put trench plugs “on either side of the wetland on the ROW to prevent water from migrating out on the sides.” In Allegheny County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160401-MRK-006, W-PA-161220-MRK-001, and W-PA-161220-MRK-002.In Washington County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160407-JLK-002, W-PA-151203-MRK-005, and W-PA-151203-MRK-006.
A11 The DEP asked Shell to evaluate if any wetlands can be classified as “exceptional value” due to their proximity to nesting areas of the northern harrier (a threatened species in Pennsylvania). Wetlands are exceptional value if they serve as habitat for threatened or endangered species, or if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain habitat for the species in the wetland. Shell determined that there are six wetlands that could be nesting areas for northern harriers, and therefore are exceptional value (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003, W-PA-170207-MRK-001, W-PA-170113-MRK-008, W-PA-170113-MRK-001). Three of these wetlands are within the project’s LOD (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003).
B13 A10W11 The DEP asked Shell to evaluate whether the proposed Falcon Pipeline will impact wetlands that are of “exceptional value” based on their proximity to public water systems. Wetlands can be considered “exceptional value” if they are located along public or private drinking water supplies (surface or ground water), and help maintain the quality or quantity of the supply. Shell stated that the (potentially man made) ponds near public water supply A could be considered exceptional value, however, they are located outside of the project’s study area and were not delineated, therefore Shell does not have information on them or their impact to this well. There were no other wetlands Shell considered to be exceptional value based on their proximity to public water systems.
B21 There were two protected plant species- harbinger of spring (PA threatened) and purple rocket (PA endangered)- located within the Raccoon Creek floodplain. The DEP asked Shell to evaluate whether there are wetlands in the project area that should be considered “exceptional value” due to their proximity to these species. Wetlands are considered “exceptional value” if they serve as habitat for a threatened or endangered plant or animal species. They are also exceptional value if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain the habitat of the species. There are six wetlands near populations of these plant populations: W-PA-151014-MRK-001, W-PA-151013-MRK-002, -003, and -004, W-PA-170407-JLK-001, W-PA151013-MRK-001. However, Shell stated that the harbinger of spring is not dependent on wetland habitat for survival and the species is considered an upland plant species (because it is not listed on Eastern Mountains and Piedmont List or on the National Wetland Plant List). Purple rocket is listed as a “Facultative Wetland Plant” (FACW) on both lists. However, Shell stated that, “although it is a FACW, this plant is not one that occurs in wetlands,” and the population of purple rocket was found in an upland, disturbed area. Therefore, Shell determined that none of these wetlands are considered exceptional value.
B23 A21 W21 Shell needs to assess cumulative impacts to wetlands from the proposed pipeline and other existing projects and potential future projects. These are discussed in the Cumulative Impact Assessment document, Sections 4.1 and 4.2, and Tables B1 and B2.
B24 A22 W22 Shell needed to provide an explanation of how it will restore wetlands and streams disturbed during construction. The explanation needed to include information on seed mixes, shrubs, and trees that will restore stream banks and riparian areas.
B26 A24 W24 Shell needed to provide a table that lists, describes, and quantifies permanent impacts to wetlands and watercourses. Shell stated that there are no permanent fills associated with the project, but there will be permanent conversion impacts to the following wetlands. They total 10,862 ft2 or 0.25 acres in Beaver County, 5,166 ft2 (0.12 acres) in Allegheny County, and 4971 ft2 (0.11 acres) in Washington County. (W-PA-151013-JLK-005, W-PA-161202-MRK-001, W-PA-160404-MRK-001, W-PA-160412-CBA-004, W-PA-160412-CBA-001, W-PA-161205-WRA-003, W-PA-160401-MRK-005, W-PA-170213-JLK-003, W-PA-160406-MRK-001, W-PA-170413-RCL-005, W-PA-170214-CBA-005.)
B27 A25 W25 Shell needed to provide more information on the Neshannock Creek Restoration site, including a master restoration plan for the entire site. This mitigation is required to offset conversion impacts to wetlands along the pipeline route. The plan for the site is documented here.
B28 A26 W26 Shell needed to provide the location and resource crossing number for the HDDs in PA. They are listed in these tables:
Allegheny County:
Washington County:
Beaver County:
2. Stormwater control
B3 A1 W1 Shell indicated that the project was in a floodplain project by the Commonwealth, a political subdivision of the commonwealth or a public utility. The DEP asked for an identification of this floodplain project, to which Shell responded that it misunderstood the question and the pipeline will not go through a floodplain project by one of these entities, but rather a floodway. The pipeline will pass many floodways, which are listed in Table 1 in separate documents for Beaver County, Allegheny County, and Washington County.
W3 The DEP requested that Shell provide an analysis of impact to Act 167 plans. Act 167 requires counties to create stormwater management plans and municipalities to adopt ordinances to regulate development in accordance with these plans. The pipeline route occurs in areas with Act 167 plans in Chartiers Township, Mount Pleasant Township, and Robinson Township.
3. Public health and safety
B1 The proposed pipeline does not meet the provisions of a zoning ordinance or have zoning approval in a particular area. Specifically, in Independence Township, the pipeline is within setback distances of places of congregation and/or of residences. One example is the Beaver County Conservation District, considered a place of congregation. Shell responded to this deficiency, saying it is working with Independence Township to obtain necessary approvals, and the township will “officially remove the pipeline ordinance from their records and no variances or permits will be required.”
B10 A8W9 The DEP requested that Shell evaluate and discuss how the pipeline may impact public water systems that are within 1 mile of the pipeline route. Shell located 12 sites within a mile, most of which are ground water wells. One site is the Ambridge Water Authority, which provides drinking water for an estimated 30,000 people. Shell stated that impacts “might include an Inadvertent Return (IR) causing a bentonite slurry mix to enter the supply, which might contaminate the supply for any wells that are located near an HDD site or construction equipment.” Shell stated that all wells are a minimum of 1000 feet outside construction zones and built in thick bedrock which will minimize threat on contamination. The sites within 1 mile include:
Youthtowne Barn
Beaver County Conservation District
Independence Elementary School
Independence Volunteer Fire Department
McConnell’s Farm and Market, Inc
Ambridge Water Authority- Independence Township
Ambridge Water Authority- Raccoon Township
Hookstown Free Methodist Church
Hookstown Fair
Hookstown Grange
South Side Memorial Post 952
Jack’s Diner
NOVA Chemical, Inc
B11 A9 W10 The DEP asked Shell to discuss efforts to avoid/minimize impacts to the above public water systems, and suggested that efforts “might include, but are not limited to, considering alternative locations, routings or design for the proposed pipeline; providing provisions for shut-off in the event of break or rupture; etc.” Shell stated that the route avoids direct impacts to groundwater wells and surface water intake. Shell will provide water buffalos if wells are contaminated, and drill new wells if necessary. There are mainline valves approximately 7 to 7.5 miles apart that can automatically shut off the flow of ethane. There will also be staff living within the project area that can quickly respond to issues.
B12 The pipeline crosses headwaters of the Ambridge Reservoir and the Reservoir’s raw water service pipeline, which supplies water to 30,000 residents. The DEP noted significant public concern regarding this crossing, and asked Shell to evaluate and discuss the pipeline’s potential to affect the Reservoir and public water supply service. The DEP also asked Shell to elaborate on efforts to avoid/minimize impacts, and what measures will be implemented to mitigate any unavoidable impacts. In response, Shell stated the pipeline will cross the raw water line via an HDD 31 feet below the line. Shell explained that the water service line is made of pre-stressed concrete, which cannot be retrofitted in the field if a break occurs. It can take six weeks for pipe joints to be made and delivered from Ohio if there is a rupture. Shell stated it will supply extra pipe joints so the Ambridge Water Authority can have pieces on deck in case of a break. Shell also outlined the protective coatings and design of the HDD portion of the pipeline that will cross the water line, and said valves that can shut off the pipeline are located 2.4 miles from one side of the water line and 3.5 on the other.
A17W17 The DEP asked Shell to consider the proposed pipeline’s effect on the Montour Trail, a multi-use, recreational trail, and to consider re-routes that would avoid impacts to the Trail. Shell determined that routing around the trail is not feasible. Shell will use conventional bore or HDD methods. If the trail needs to be temporarily closed during construction, operation, or maintenance, Shell will notify the trail owner and provide alternate temporary access for trail users. Shell will also cross the Panhandle Trail by HDD. The entrance and exit sights of the bore will not be on the trail’s property. Shell has “unlimited ingress and egress over Owners property” for inspections, repair and maintenance of the pipeline, and in case of emergency situations.
B29 A27 W27 Shell needed to revise the “Shell Pipeline HDD Procedure” to include HDD site feasibility analysis, inadvertent return risk assessment, water supply protection, agency contact information, etc. Shell’s response is included in the document, Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan.
B30 A28 W28 Shell needed to include a preboring geologic evaluation to determine if drinking water supplies will be impacted around boring locations. Shell also needed to discuss how it will verify that drinking water sources and aquifers are protected and what measures will be taken in the event that they are impacted. Shell’s response is included as Appendix C to this document.
4. Conservation
B19 A18 W18 19A 19W – There are many areas important for the region’s biodiversity and natural heritage that the proposed pipeline passes near or through. The DEP asked Shell to evaluate impacts to these areas. Information on them is available from the Pennsylvania Natural Heritage Program. They include:
Ambridge Reservoir Valleys Natural Heritage Area
Lower Raccoon Creek Natural Heritage Area
Raccoon Creek Valley and Wildflower Reserve Natural Heritage Area
Raccoon Creek Floodplain Biologically Diverse Area
Raccoon Creek Landscape Conservation Area
Clinton Wetlands Biologically Diverse Area
Raccoon Creek Landscape Conservation Area
Raccoon Creek Valley & State Park Important Bird Area – Regarding the Important Bird Area, Shell stated that 23 miles of the pipeline is located within this area. Shell has not been able to get in contact with the National Audobon SW PA office. Shell added that the only waterbody large enough in the project area to support the documented waterfowl is the open water at Beaver County Conservation District.Shell stated that “an outlet has been installed at the far end of the lake to restore it to more of a wetland and less of a lake, as it was originally designed.” Raccoon Creek Valley is also a passageway for migratory birds, which are protected under the Migratory Bird Treaty Act. Shell stated that less than 2% of this Important Bird Area will be permanently impacted by pipeline construction and installation.
5. Alternative locations
B17 A15 W15 The DEP asked Shell to revise its current alternatives and provide a more detailed “analysis of the alternative locations and routes that were considered to avoid or minimize adverse environmental impacts.” The alternatives are discussed in Section 9 of Shell’s Comprehensive Environmental Assessment.
B18 16A16W According to the DEP, “18.5 of the 45 miles (41%) of the proposed pipeline are parallel to or adjacent to existing right-of-ways (ROWs).” The DEP asked Shell to see if there are additional opportunities to build the pipeline within existing ROWs, with the hope of reducing environmental impacts. In response, Shell discussed the additional ROWs that were considered (along Mariner West) but ultimately rejected. Shell discusses these routes more in Section 9.1 of the Comprehensive Environmental Assessment.
B32 A30 W30 The DEP asked Shell to discuss the feasibility of several changes to the proposed pipeline’s route, including avoiding impacts to wetlands, relocating resource crossings, moving valve sites outside of wetlands, moving HDD locations, and evaluating the impact to a coal refuse pile (the pipeline crosses underneath at least one pile via HDD). These reroutes are discussed under question 32 for Beaver County, question 30 for Allegheny County, and question 30 for Washington County.
6. Geological concerns
B14 12A 12W The pipeline is located in previously coal mined areas. The DEP asked Shell to provide a map of the pipeline that showed these mining areas, and GIS shape files with this information. Shell’s response is included in the HDD Subsurface Investigation Reports, which includes the following table of the extent of mined areas along the pipeline route:
B15 A13 W13 The pipeline is located in coal mined areas, which could be susceptible to subsidence and/or mine water discharge. The DEP requested that Shell revise drawings to show the limits of previously mined areas, depth of cover over the mine workings in areas the proposed pipeline crosses through, and the distance between mine workings and the proposed pipeline. Furthermore, the DEP asked Shell to “evaluate and discuss the potential for a subsidence event compromising the utility line, and the potential to create a mine water discharge.” Shell discusses this in Appendix B of this this document and in the Mining Summary Report. Shell also identifies the following areas as being at risk for coal mine discharge: HOU MM 1.2, HOU MM 8.9 (proposed HDD), HOU MM 12.1, HOU MM 12.95, HOU MM 13.1, HOU MM 13.6, HOU MM 17.4, and HOU MM 17.65 (proposed HDD).
B16 A1414W The DEP requested that Shell include areas where the pipeline will cross active mining permit boundaries. There is one active mining permit boundary that intersects the proposed pipeline, the Rosebud Mine in Beaver County.
B31 A29 W29 Shell needed to evaluate the potential for the project to encounter areas underlain by carbonate bedrock and landslide prone areas. Carbonate bedrock is indicative of a karst landscape, meaning an area likely to have underground sinkholes and caves. The DEP also asked Shell to discuss precautionary methods taken during construction in these areas. Shell’s response is included in the Carbonate Rock Analysis and Slope Stability and Investigation Report. The Carbonate Rock Analysis report shows that carbonate bedrock was encountered in 20 out of 40 of the borings taken during the analysis.
7. Documentation
B4 The PA DEP asked Shell to describe the structures and activities that occur within junction sites. Shell responded that there will be a Junction Custody Transfer Meter Station at the site, and provided maps of the site.
B22 20A 20w The DEP requested that Shell revise their Comprehensive Environmental Assessment to include alternatives, impacts, and mitigation items that were previously included in other sections of their environmental assessment.
B25 A23W23 The DEP asked Shell to provide a copy of the Mitigation Bank Credit Availability Letter from First Pennsylvania Resource, LLC. In response, Shell stated the Letter is no longer needed because “the permanent stream and wetland fills have been removed from this project.”
B35 A33 W33 Shell needs to include all of the above modifications to the application in the Chapter 103 permit application.
Conclusion
As evidenced by the list above, the proposed Falcon Pipeline poses a variety of threats to Pennsylvania’s natural resources, wildlife, and public health – but this deficiencies list is likely not complete. The pipeline also passes through West Virginia and Ohio, and if completed, will likely attract more pipelines to the area. As it feeds Shell’s ethane cracker plant in Beaver County, it is a major step towards the region becoming a hub for plastic manufacturing. Therefore, the public response to the above deficiencies and the decision the DEP makes regarding them will have major implications for the Ohio River Valley’s future.
Of note: The DEP’s letters and Shell’s response to them are available to the public in separate documents for Allegheny, Beaver, and Washington Counties.
By Erica Jackson, Community Outreach and Communications Specialist
Photo by Ted Auch, FracTracker Alliance
