New York State Department of Environmental Conservation (DEC) Oil and Gas Database includes records for nearly 45,000 wells in the state, nearly all of which are related to the oil and gas industry. Of these records, only 19,600 include drilling dates; some records simply reflect drilling permits that were applied for and expired, or were cancelled for other reasons. Of the records listed, 99% of those drilled are vertical, “conventional” wells.
Research by Bishop (2013) indicates that there could be more than 30,000 additional oil and gas wells that are not documented in the DEC’s database, and potentially not adequately plugged.
Over the past half-century, drilling activity in New York State has ebbed and flowed. In that period of time, drilling interest in oil and gas saw two main peaks: between 1975 and 1985, and — especially for gas — between 2004 and 2010. Gas drilling activity has currently tailed off to practically nothing since the ban on high-volume hydraulic fracturing was passed in late 2014.
In this blog we’ll look specifically at spatial and temporal patterns in oil and gas drilling across New York State.
Every year, FracTracker updates the full state-wide dataset of oil, gas, and other assorted (non-drinking water) wells. To see the entire “big picture,” you can explore our interactive map below, which shows all wells in the New York State database, from prior to 1900 through late February 2021.
New York State Oil and Gas Wells
This map shows that, despite New York State banning high volume hydraulic, nearly 45,000 wells have been drilled, according to the Department of Environmental Conservation (DEC). Not all the wells in the DEC’s database were actually drilled; some were sites that were permitted, but never explored. Many have been plugged and abandoned. There may be nearly as many undocumented wells as there are in the database, given that record keeping in earlier years was nowhere near as comprehensive as it is today.
In order to turn layers on and off in the map, use the Layers dropdown menu. This tool is only available in Full Screen view. Data sources can be found in the Details section of the map as well as listed the end of this article.
FracTracker has also taken a more fine-grained approach to consider the patterns in drilling in New York State both spatially and temporally. Using the DEC wells database, we first filtered out well data for records that had actual spud (drilling) dates between 1970 and the present. Then, using pivot tables in Microsoft Excel, we graphed the data, and also looked for patterns around where the drilling was taking place.
Emergent from this process, we see the following.
Oil and gas hotspots are directly related to the underlying geology of a region. In New York State, the majority of oil wells have been drilled in the Chipmunk and Bradford Formations, followed by the Fulmer Valley, Glade, and Richburg Formations.
Oil Wells in NYS and Their Associated Geological Formations
Updated February 2021
Figure 1. Oil Wells in NYS and Their Associated Geological Formations. Gas wells have historically been most productive in the Medina Formation, followed by the Queenston, and also Trenton-Black River Formations. Data source: New York State DEC Oil and Gas Database.
Gas Wells in NYS and Their Associated Geological Formations
In 1982 and 1983, gas drilling in New York State surged, with 774 and 667 new wells drilled over those two years, respectively. The hot spot was in the Medina Group, which over the years, continued to be a primary focus. Well depths in this section of bedrock average around 3,400 feet at that time, although wells were exploited at a more shallow depth in subsequent years. Starting in 1995, gas was discovered in the Black River shale formation, with reservoirs more than 10,000 feet deep in some places. All of these wells were vertically oriented, but still were exploited using hydraulic fracturing technologies.
The early to mid-1980s marked a relatively high level in oil well drilling in New York State, with a peak occurring in 1984, with 153 wells drilled. After a lull of about 20 years, activity picked up again in 2005, hitting a high point in 2006 when 188 oil wells were drilled. In 2010, there was another peak with 188 wells, followed by a waning period of 4 years. Then, in 2019, interest exploded in a small area of the Bradford oil fields in Cattaraugus County, with 156 wells drilled, and an average production of 319 barrels per well over the course of that year.
According to EIA estimate from 2014, the cost of drilling an onshore oil well is between $4.9 – 8.3 million, however smaller vertical wells like those common in New York State are likely to cost more in the range of $150,000. With the price of oil at $64 a barrel in 2019, in its first year in production, the gross profit of any of these wells in New York, based on reported production, would have been between $0 and $120,000, with an average year around $20,400 per well. It’s hard to imagine how drilling for oil in recent years in New York State could have possibly been profitable, in particular with the steep drop-off in production typically seen after the first year or two.
These simple examples of a localized “oil boom” in New York State provide a stark example of exactly how unsustainable these endeavors are, particularly for small drilling operators. So, despite the enthusiastic rush to oil drilling in 2019, activity after that has been followed by a quick decline, with only 41 oil wells drilled in New York State in 2020, and only 4, so far, in 2021.
Patterns in other types of wells
The increase in dry wells seems to track with the general patterns of oil and gas exploration. Hence, in periods when a lot of oil and gas wells are being drilled, there will be a higher number of wells that are dry, or nonproductive. During the 1970s, there was also a strong peak in disposal wells drilled. We are not certain whether this is, or is not, related to the high number of gas wells drilled during this period.
New York State moving towards better stewardship of legacy wells
Some of the oil and gas wells drilled in the 19th and early 20th century were particularly poorly documented (or not documented at all), and improperly plugged. This creates a public and environmental safety hazard, with more than 30,000 of these undocumented oil and gas wells spread across the state potentially leaking methane into the air and water. Finding the abandoned and orphan wells has been a long term problem because they are often located in rough terrain across central and western New York. Fortunately, the New York State Department of Environmental Conservation has taken new measures to locate and plug these legacy wells, using drone technology. FracTracker reported on a pilot initiative a few years ago that was testing this technique, but the new program is backed by $400,000 in funding from NYSERDA, the New York State Energy Research and Development Authority, in support of New York States ambitious goals to reduce greenhouse gas emissions through the Climate Leadership and Community Protection Act.
One hundred years ago, few people expressed concerns about the environmental hazards associated with oil and gas drilling. Record-keeping was spotty, which has left us with a legacy of wells whose locations are lost to memory, or simply improperly plugged. After several periods of vigorous mineral extraction activity in the 1980s and early 2000s, oil and gas drilling has declined in its profitability, and formerly easily-accessed reserves have been depleted. Today, with unprecedented interest in clean energy sources like wind, geothermal, and solar, society can become less dependent on fossil fuels, and focus on responsibly stewarding the remnants of these “dinosaurs,” using new technologies to help clean up the damages left by them.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/New-York-State-wells-feature.jpg8331875Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKaren Edelstein2021-04-01 11:10:062021-04-13 10:39:49New York State Oil & Gas Well Drilling: Patterns Over Time
Access to reliable data is crucial to our understanding of risky fracking waste disposal, and in turn, our ability to protect public health. But when it comes to oil and gas liquid waste disposal wells in Pennsylvania, despite monitoring by two separate agencies, we are left with an incomplete and inaccurate account.
If we were to emulate the Charles Dickens classic, this article might begin, “It was the best of datasets, it was the worst of datasets.” Unfortunately, even that would be too generous when it comes to describing available data around oil and gas liquid waste disposal wells in Pennsylvania. To fully understand the legacy and current state of these wells, it is necessary to query the two agencies that have a role in overseeing them, the United States Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (DEP).
Given the relatively small inventory of these wells compared to other oil and gas producing states, the problems with the two datasets are enormous. Before jumping into these issues, however, it would be useful to review the nature of these wells, why there are two regulatory agencies involved, and why there are so few of them in Pennsylvania in the first place, relatively speaking.
Disposal Wells Categories
To further our industrial exploits of the planet, humans have found it useful to inject all kinds of things into the earth. In the United States, this ultimately falls under the jurisdiction of EPA’s Underground Injection Control (UIC) program, and the point of injection is known as an injection well. Altogether, there are six classes of injection wells, with those related to oil and gas operations falling into Class II.
There are three categories of Class II injection wells, including waste disposal, enhanced recovery, and hydrocarbon storage. There is also an infamous exemption known as the “Haliburton Loophole,” which has allowed oil and gas companies to inject millions of gallons of hydraulic fracturing fluid into oil and gas wells in order to stimulate production without any federal oversight at all.
When most people speak of “injection wells” in an oil and gas context, they are usually referring to waste disposal wells, and this is our focus here. This well type is also referred to as Class II-D (disposal) and salt water disposal wells (SWD). This latter term is used by a majority of state regulators, so we will use that abbreviation here, even though considering this type of toxic and radioactive fluid “salt water” is surely one of the industry’s most egregious euphemisms.
Dealing with Dangerous Fluids
There are two main types of liquid waste that are disposed of at SWD injection wells. As always, these waste types have a number of different names to keep everyone on their toes but for the sake of simplicity will call them “flowback” and “brine,” and both are problematic materials to handle. Additionally, the very act of industrial-scale fluid injection presents problems in its own right.
As mentioned above, when operators pump a toxic stew of water, sand, and chemicals into a well to stimulate oil and gas production, that mixture is known as hydraulic fracturing fluid, or fracking fluid. Some of these chemicals are so secretive that even the operators of the well don’t know what is included in the mix, let alone nearby residents or first responders in the event of an incident.
Between 10% and 100% of this fluid will return to the surface, and is then known as flowback fluid, becoming a waste stream. In Pennsylvania, the average amount of fracking fluid injected into production wells exceeds 10 million gallons in recent years according to data from the industry’s self-reporting registry known as FracFocus. With more than 12,000 of these wells drilled statewide, disposing of this waste stream becomes an enormous concern.
In addition to flowback fluid, there are pockets of ancient fluids encountered by the drilling and fracking processes that return to surface as well. These solutions are commonly referred to as brine due to their extremely high salt content, although this is not the type of fluid that you’d want to baste a Thanksgiving turkey with. Total salt concentrations can reach up to 343 grams per liter, roughly ten times the salt concentration of sea water. These brines include but are not limited to the familiar sodium chloride that we use to season our food, but include other components as well, including significant bromide and radium concentrations.
When Pennsylvania experimented with our public health by authorizing disposal of these fracking brines in municipal plants designed to treat sewer sludge, the bromides in that drilling waste stream became problematic as they interacted with disinfectants to cause a cancerous class of chemicals known as trihalomethanes. This ended the practice of surface “treatment” from these sites into streams in 2011, and along the way caused many water authorities to switch from chlorine to chloramine disinfectant processes. This, in turn, may have exacerbated lead exposure issues in the region, as the water disinfected with chloramine often eats away at the calcium scale deposits covering lead pipes and solder in the region’s older homes.
Marcellus and Utica wastewater are also very high in a radioactive isotope of radium known as Ra-226, which has a half-life of 1600 years. After that amount of time, half of the present radium will have emitted an alpha particle, which can cause mutations in strands of DNA when introduced inside the body, through contaminated drinking water, for example. After the hazardous expulsion of the alpha particle, the result become radon gas, which is estimated to cause 20,000 lung cancer deaths per year in the United States. Further down the decay chain is Polonium 210, which was infamously used in the assassination of Russian spy Alexander Litvinenko in London in 2006.
None of this should be injected into formations beneath people’s homes, near drinking water supplies, streams, or really anywhere that we aren’t comfortable sacrificing for the next few thousand years.
On top of all the problems with the water chemistry of both produced water and brine, the very act of injecting these fluids into the ground has triggered a large number of earthquakes in areas with frequent or large volumes of waste injection. This human-caused phenomenon is known as induced seismicity. The most well-known example of this is the previously stable state of Oklahoma which surged to have more magnitude 3.0+ earthquakes than California for a number of years during a drilling boom in that region. The largest of these was the magnitude 5.8 Pawnee earthquake in 2016.
Figure 3. PA Earthquakes and Potential Causes: 1/2000 – 2/2021, Magnitude 2.0 or Greater. Most earthquakes in the eastern portion of the state are associated with Quaternary faults. In the western portion, the causes are less straightforward, and include zipper fracking, mine blasting or collapse, and faults that are more ancient and deeper than the Quaternary faults, many of which remain unmapped. As the use of SWD wells increases, seismic activity may increase as well.
Manmade earthquakes are not limited to Oklahoma. For example, there were approximately 130 seismic events in one year period in the Youngstown, Ohio area due to SWD activity, including one measuring 4.0 on the last day of 2011. Over the years, the regulatory reaction to induced earthquakes seems to walking along the slippery slope from “that can’t happen” to “that can’t happen here” to “they’re all small earthquakes” to “we can mitigate the impact,” despite all evidence to the contrary.
So who gets to be in charge of this dumpster fire? As mentioned above, this is ultimately under the umbrella of EPA’s Underground Injection Control program. However, they have a complicated arrangement with the various states defining who has primary enforcement authority for this type of well.
In Pennsylvania, such wells must obtain a permit from EPA before obtaining a second permit from DEP. In a 2017 hearing in Plum Borough, Allegheny County, furious residents concerned with a variety of issues with a proposed SWD well were told that in Pennsylvania, EPA could only consider whether or not the well would violate the 1972 Clean Water Act when considering the permit, and that the correct audience for everything else would be DEP. Both permits for this well that is near and undear to me were ultimately issued, and operations are expected to begin in the next month if Governor Wolf does not instruct the DEP to reconsider their permit.
There is some precedent for overturning such a permit. In March of 2020, DEP yanked a permit for a SWD well in Grant Township, Indiana County, suddenly respecting a home-rule charter law that the agency had previously sued the Township over.
Without the prospect of royalties or impact fees, no community wants these wells and regulators know that they are nothing but problems. However, the reality is that the regulators oversee an industry that produces a tsunami of this toxic waste – more than 61.8 million barrels of it from unconventional wells in Pennsylvania in 2020 according to self-reported data, which is almost 2.6 billion gallons of the stuff, or slightly more than the capacity of Beaverdam Run Reservoir in Cambria County, a 382 acre lake with an average depth of 20 feet.
Nationally, injection wells are quite common, with over 740,000 such wells in the EPA inventory for 2018 and Class II (O&G) wells represent about a quarter of this figure. Of these Class II injection wells, roughly 20% are for fluid disposal, giving us an estimated 37,000 SWD wells nationwide. This number is expected to go up, as more than three-quarters of the 8,600 permits issued in 2018 were for oil and gas purposes.
However, in Pennsylvania, there have been quite few of these, compared to other states. The primary reason for this is its geology, which has largely been considered unsuitable for this type of activity. For example, a 2009 industry analysis states:
“The disposal of flowback and produced water is an evolving process in the Appalachians. The volumes of water that are being produced as flowback water are likely to require a number of options for disposal that may include municipal or industrial water treatment facilities (primarily in Pennsylvania), Class II injection wells [SWDs], and on-site recycling for use in subsequent fracturing jobs. In most shale gas plays, underground injection has historically been preferred. In the Marcellus play, this option is expected to be limited, as there are few areas where suitable injection zones are available.”
I discussed this topic in a phone call with an official from EPA, who largely confirmed this point of view, but preferred the phrase, “the geology is complicated” instead of the word “unsuitable.” When the UIC program was established from the 1974 Safe Drinking Water Act, there were only seven such wells in operation, and according to EPA’s data, there were still just 11 active SWD wells in the Commonwealth but with more on the way. I was cautioned that the geology wasn’t the only reason, however. Neighboring Ohio had hundreds of these wells, many of which are clustered close to the border with Pennsylvania. The two states have different primacy and permitting arrangements, which is a factor as well.
I have not come across sources mentioning why Pennsylvania’s geology was so unsuitable – or complicated, if we are being generous. However, there are numerous widespread issues that could be a factor, including voids created by karst and legacy coal mines, and formations that might have otherwise trapped gasses and fluids being punctured with up to 760,000 mostly unplugged oil and gas wells and more than one million drinking water wells.
Even when these fluids have been pumped deep underground, they are not necessarily out of sight and out of mind. For example, an abandoned well in Noble County Ohio suddenly began spewing gas field brine just a few weeks ago, resulting in a fish kill in a nearby stream. The incident is believed to be related to SWD wells in the general vicinity even though the closest of these is miles away from the toxic geyser. The waste fluids injected beneath the surface will exploit any pathway available through crumbling or porous rocks to alleviate the pressure built up from the injection process. These fluids don’t care whether the target is an old gas well, mine void, or drinking water aquifer.
Of course, we could ask the question in reverse, and ask what makes the injection of oil and gas fluids suitable in other locations, and the aggregated evidence would lead us to “nothing” as our answer. Nothing, other than the fact that drilling and fracking produces billions of gallons of liquid waste, and that it has to go somewhere.
Although EPA play a major role in permitting and regulating SWD wells in Pennsylvania, they do not publish data related to these wells on their website. FracTracker started hearing rumors about a spate of new SWD permits all over the state that were not accounted for in DEP data. As it turns out, many of these turned out to be other oil and gas wastewater processing facilities, and the public’s confusion about these is completely understandable because these facilities lacked the proper public notice process. These facilities are concerning in their own right – and residents of Pennsylvania should look here to see if one of these 49 facilities are in their neighborhoods – but these are not disposal wells.
To clear up the confusion, I submitted a Freedom of Information Act request to EPA for a spreadsheet of their Class II injection wells in Pennsylvania. This was apparently an onerous task that would require more than ten hours of labor on their behalf. When I mentioned that I was mostly interested in disposal wells, that sped the process up considerably.
Ultimately, I received a portion of the data fields that I had asked for.
Well API Number
Class II Category (disposal, recovery, storage)
Date application received
Application status (e.g., pending, complete)
Application result (e.g., approved, rejected)
Application result date (date of EPA’s decision)
Well status (e.g., active, plugged)
Well county name
Well municipality name
Table 1 – Summary of fields requested and received in FracTracker’s FOIA submission with EPA.
I started to compare the EPA dataset to DEP’s SWD well dataset, which is a part of its conventional well inventory. Each source had 23 records. We were off to a good start, but this data victory turned out to be limited in scope as the discrepancies between the two datasets continued to grow. Inconsistencies between the two datasets are as follows:
DEP Well Name
EPA API Match
EPA Name Match
HARRY L DANDO 1
COLUMBIA GAS OF PENNA INC CGPA5
KENNETH A DIEHL D1
Not on EPA List
THE PEOPLES NATURAL GAS CO 4627X
Not on EPA list
FRANK & SUSAN ZELMAN 1
DEP / EPA API Number mismatch
No EPA API No.
IRVIN A-19 FMLY FEE A 19
SPENCER LAND CO 2
FEE SENECA RESOURCES WARRANT 3771 38268
FEE SENECA RESOURCES WARRANT 3771 38282
DEP / EPA API Number mismatch
NORBERT CROSS 2
HAMMERMILL PLT 1
Not on EPA List
Not on EPA List
Not on EPA List
Not on DEP list. EPA Permit PAS2D210BGRE – no API to match
MARJORIE C YANITY 1025
T H YUCKENBERG 1
W SHANKSVILLE SALT WATER DISP 1
MORRIS H CRITCHFIELD 1
H A HEINRICK RW-55
Category Anomaly – Not on DEP SWD list – does appear as Plugged OG Well (consistent w/ EPA status notes)
API Mismatch (But does match Bittinger #1) Lat/Long match site name
JOSEPH BITTINGER 1
API Mismatch (But does match Bittinger #4) Lat matches site name, Long slightly off
JOSEPH BITTINGER 2
JOSEPH BITTINGER 3
Category Anomaly – Not on DEP SWD list – does appear as “Injection”
SMITH/RAS UNIT 1
Category Anomaly – Not on DEP SWD list – does appear as “Observation”
LEROY STODDARD & FRANK COFFA 1 WELL
Not on DEP list of all wells. Does appear on eFACTS. No location data
Table 2 – Discrepancies between EPA and DEP data for SWD wells in PA.
Altogether, there was at least one data discrepancy on 17 out of 28 wells (61%) on the combined inventories, and this is allowing for significantly different formatting of the well’s name. The DEP list contained five records that were not on the EPA dataset at all, four records where the well’s API number did not match, three instances where the DEP well type was different from EPA’s listing, two wells with matching API numbers but different well names, two wells that were missing the API number on the EPA list, and one well that was on the EPA list that I have not been able to find in any of DEP’s inventories. These last two wells could not be mapped due to the lack of location data.
It isn’t always possible to know which dataset is erroneous, but the EPA list has several obvious omissions and one instance where the API number and well name are in the wrong columns. The quality of DEP data has improved over the years and appear to have some data controls in place to avoid some of these basic errors. For that reason, I suspect that most of the problems stem from the EPA dataset, and I have used DEP coordinates to map these wells.
Waste Disposal Wells in Pennsylvania
This map contains numerous layers that explore the current state of Class II-D Salt Water Disposal (SWD) injection wells for oil and gas waste in Pennsylvania. View the map “Details” tab below in the top left corner to learn more and access the data, or click on the map to explore the dynamic version of this data.
In the early 1970s, it was recognized that industrial injection of oil and gas waste underground could lead to risks to human health and the environment, so several major protective laws were put in place, including the Clean Water Act of 1972, the Safe Drinking Water Act of 1974, and the Pennsylvania’s 1971 Environmental Rights Amendment. Decades later, it feels like the Pennsylvania Department of Environmental Protection and the United States Environmental Protection Agency don’t take their regulatory responsibilities very seriously when it comes to oil and gas liquid waste disposal wells. While the state does have fewer of this type of well than other states, there are five that are currently under construction, according to the EPA dataset. Many of these, like the Sedat 3A well in Allegheny County, have come after significant community opposition, and many of the residents’ concerns have not been addressed by either agency.
There will undoubtedly be more of these disposal wells proposed in the near future. Residents would do well to hassle their municipalities to update their ordinances for this type of well if they happen to live in a place where such ordinances are possible. Solicitors should be instructed to regularly scour the Pennsylvania Bulletin and be in contact with EPA for the earliest possible notification of a proposed site, so that there is time to respond within the comment periods.
Additionally, the sloppiness of the datasets calls all sorts of questions into play regarding the co-regulation of these wells. In the case of an incident, it’s not even clear that both agencies have the information on hand to even locate the site in the field. Meanwhile, a 61% error rate between the sites name, API number, and status does not inspire confidence that agencies are keeping a close eye on these facilities, to say the least.
Above all, we must all realize that it isn’t safe to assume that someone will let us know when these types of facilities are proposed. Regulators have shown us through their actions that they are thinking far more about the billions of gallons of waste that needs to be disposed of than of the well-being of dozens or even hundreds of neighbors near each toxic dump site.
References & Where to Learn More
Data supporting this article, as well as the static map in Figure 3, can be found here.
FracTracker Pennsylvania articles, maps, and imagery: https://www.fractracker.org/map/us/pennsylvania/
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/02/Waste-Disposal-Wells-in-Pennsylvania-feature.jpg16673750Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2021-02-26 12:23:392021-03-12 14:58:33Pennsylvania’s Waste Disposal Wells – A Tale of Two Datasets
Since the advent of unconventional shale gas drilling, some effects have been immediate, some have emerged over time, and some are just becoming apparent. Two reports recently published by the Delaware Riverkeeper Network advance our understanding of the breadth of the impacts of fracking in Pennsylvania. The first report, written by FracTracker, reviews research on the ways fracking impacts the health of Pennsylvanians. The second report by ECONorthwest calculates the economic costs of the industry.
“Fracking is heavily impacting Pennsylvania in multiple ways but the burden is not being fairly and openly calculated. These reports reveal the health effects and economic costs of fracking and the astounding burdens people and communities are carrying,” said Maya van Rossum, the Delaware Riverkeeper.
Learn what the latest science and analysis tells us about the costs of fracking, who is paying now, and what the future price is forecasted to be.
Access the full reports here:
Health Impact Report
“Categorical Review of Health Reports on Unconventional Oil and Gas Development; Impacts in Pennsylvania,” FracTracker Alliance, 2019 Issue Paper
“The FracTracker Alliance conducted a review of the literature studying the impact of unconventional oil and gas on health. Findings of this review show a dramatic increase in the breadth and volume of literature published since 2016, with 89% of the literature reporting that drilling proximity has human health effects. Pennsylvanian communities were the most studied sample populations with 49% of reviewed journal articles focused on Marcellus Shale development. These studies showed health impacts including cancer, infant mortality, depression, pneumonia, asthma, skin-related hospitalizations, and other general health symptoms were correlated with living near unconventional oil and gas development for Pennsylvania and other frontline communities.”
–Kyle Ferrar, FracTracker Alliance Western Program Coordinator
Rig and house. Westwood Lake Park. Photo by J Williams, 2013.
“Fracking wells have an extensive presence across Pennsylvania’s landscape – 20 percent of residents live within 2 miles of a well. This is close enough to cause adverse health outcomes. Collectively we found annual costs of current fracking activity over $1 billion, with cumulative costs given continued fracking activity over the next 20 years of over $50 billion in net present value for the effects that we can monetize. The regional economic benefits also seem to be less than stated, as the long-term benefits for local economies are quite low, and can disrupt more sustainable and beneficial economic trajectories that might not be available after a community has embraced fracking.”
–Mark Buckley, Senior Economist at the natural resource practice at ECONorthwest
These reports on the health effects and economic impacts of unconventional oil and natural gas development yield disheartening results. There are risks of extremely serious health issues for families in impacted areas, and the long term economic returns for communities are negative.
Arming ourselves with knowledge is an important first step towards the renewable energy transformation that is so clearly needed. The stakes are too high to allow the oil and natural gas industries to dictate the physical, social, and economic health of Pennsylvanians.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/05/DrillingNearSchoolCA-1.jpg445959FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2019-05-28 13:54:472020-04-27 11:26:49Who Pays? Health and Economic Impacts of Fracking in Pennsylvania
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.
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.
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
Idle Well Count
Chevron U.S.A. Inc.
Aera Energy LLC
California Resources Production Corporation
California Resources Elk Hills, LLC
Berry Petroleum Company, LLC
E & B Natural Resources Management Corporation
Sentinel Peak Resources California LLC
HVI Cat Canyon, Inc.
Seneca Resources Company, LLC
Crimson Resource Management Corp.
Table 2. Idle Well Counts by Oil Field
Count by Field
Table 3. Idle Well Counts by County
Count by County
San Luis Obispo
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
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
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.
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 11:30:582020-05-14 16:39:24Idle Wells are a Major Risk
With the new year underway, it’s an opportune moment to reflect on the state of unconventional oil and gas extraction in Pennsylvania and examine a few of the drilling trends. A logical place to start is looking at the new wells drilled in 2018.
As always, but perhaps even more so than in previous years, unconventional drilling in Pennsylvania is a tale of two shale plays, with hotspots in the southwestern and northeastern corners of the state. The northeastern hotspot seems to be extending westward, including 25 new wells in Jones Township in Elk County (an area shown in dark red near the “St Marys” label on the map). In the southwestern hotspot, the industry continues to encircle Allegheny County, closing in on the City of Pittsburgh like a constrictor.
Screen shot showing spud report for Indiana Township, Allegheny County from 1/1/2017 through 1/4/2019. We suspect these spud dates of 11/29/17 and 11/30/17 are incorrect.
Data error? As Pittsburgh-area residents reflect on the past year, some of them must be wondering why a new well pad in Indiana Township, just northeast of the city isn’t shown on the map above. The answer is that the data the Department of Environmental Protection (DEP) has for these wells indicate they were drilled November 29-3o, 2017, although we believe this to be incorrect. FracTracker obtained the data from the Spud Report on January 2, 2019, which indicates seven wells spudded in that two day span on the “Miller Jr. 10602” well pad. This activity drew considerable opposition from families in the Fox Chapel School district in May of 2018, and was therefore widely reported on by the media. An article published on WESA indicates an expected drill date of July 2018, for example.
It turns out the new year is also a good time to remember that our understanding of the oil and gas industry around us is shaped, molded, and limited by the availability and quality of the data. We brought the Indiana Township data error to the attention of DEP, which only confirmed that the operator (Range Resources) entered the spud dates into the DEP’s online system. Perhaps these well were drilled in November of 2018 not 2017? There is even a possibility these wells have yet to be drilled.
Here are a few more dissections of the data, such as it is:
Figure 1: Unconventional wells drilled in PA by year: 2005 to 2018
Wells Drilled Over Time
Barring more widespread data issues, the status of a handful of wells in Indiana Township does not have much of an impact on the overall trend of drilling in the state. There were 779 wells on the report, representing just under 40% of the total from the peak year of 2011, when industry drilled 1,958 wells. The year 2019 was the fourth year in a row where the industry failed to drill 1,000 wells, averaging 719 per year over that span. In contrast, the five years between 2010 and 2014 saw an average of 1,497 wells per year, more than twice the more recent average. As mentioned in our Hazy Future report, projections based on very aggressive drilling patterns are already proving to be out of phase with reality, although petrochemical commodity markets might change drastically in the coming decades.
How long before wells are plugged?
We also like to periodically check to see how long these wells stay in service. In Pennsylvania, there are two relevant well statuses worth following: plugged and regulatory inactive. While there are a number of conditions that characterize regulatory inactive wells, they are essentially drilled wells that are not currently in production, but may have “future utility.” Therefore, the wells are not required to be permanently plugged at this time.
Figure 2: This chart shows the percentage of unconventional wells drilled since 2005 with a plugged or regulatory inactive status as of December 31, 2018.
In order to understand some of the finer points, it’s best to use Figure 1 (above) in conjunction with Figure 2. We can see that most of the wells drilled in the initial years of the Marcellus boom have already been plugged, although Figure 1 shows us that the sample size is fairly low for these years. In 2005, for example, 7 of the 9 (78%) unconventional wells drilled in the state that year are already plugged. The following year, 24 of the 37 (65%) wells drilled are now plugged, and an additional 4 (11%) wells have a regulatory inactive status as of the end of 2018. The following year, the combined plugged and inactive wells account for just over 50% of the 113 wells drilled that year, and this trend continues along a fairly predictable curve. An exception is the noticeable bump around the most active drilling years of 2010 and 2011, where there are slightly more wells with a plugged or inactive status than might be expected. It is interesting to note that even the most recent wells are not immune to being plugged, including 8 plugged wells and 4 inactive wells drilled in 2018 that were not able to get past their very first year in production.
Overall, of the 11,675 drilled wells accounted for on this graphic, 851 (7%) are plugged already, with an additional 572 (5%) of wells with an inactive status. Unconventional wells that are 11 years old have a roughly 50% chance of being plugged or inactive, and we would therefore expect to see the number of these wells skyrocket in the coming years before leveling off, roughly mirroring the drilling boom and subsequent slowdown of Marcellus Shale extraction in Pennsylvania.
Many factors contribute to fluctuations in drilling trends for the Marcellus Shale and other unconventional wells in Pennsylvania. Very cold winters result in high consumption by residential and commercial users. New gas-fired power plants can increase the demand for additional drilling. Recessions and economic conditions are known to reduce the demand for energy as well, and drillers’ heavy debt burdens can slow down operations appreciably. Additionally, other fossil fuel and renewable energy sources compete with one another, altering the market conditions even further. And finally, every oil and gas play eventually reaches a point where the expected results from new wells are not worth the money required to get the hydrocarbons to the surface, and unconventional wells are much more expensive to develop than more traditional operations.
Because of all of these variables, month to month or even year to year fluctuations are not necessarily that telling. On the other hand, a four-year period where drilling is roughly half of previous extraction is significant, and can’t be easily dismissed as a blip in the data.
By Matt Kelso, Manager of Data and Technology, FracTracker Alliance
In recent years, Pennsylvanians have had to endure numerous massive pipeline projects in the Commonwealth. Some of these, such as the Mariner East 2, the Revolution, and the Atlantic Sunrise, have been beset with continuous problems. In fact, both the Mariner East 2 and the Revolution projects had their operations suspended in 2018. The operators have struggled to grapple with a variety of issues – ranging from sinkholes near houses, erosion and sediment issues, hundreds ofbentonite spillsinto the waters and upland areas of Pennsylvania, and more.
Part of the reason for the recent spate of incidents is the fact that so many pipelines are being built right now. These lines are traversing through undermined areas and land known to have underground karst formations, which are prone to subsidence and sinkholes. With more than 90,000 miles of pipelines and 84,000 miles of streams in Pennsylvania, substantial erosion and runoff issues are unfortunately quite common.
Map of pipeline routes in southwestern PA, various pipeline incidents, and karst formations:
Click here to learn more about recent pipeline incidents in Pennsylvania, along with how users of the FracTracker App have helped to chronicle problems associated with them.
Residents keeping track
Many residents have been trying to document issues in their region of Pennsylvania for a long time. Any pipeline incident should be reported to the Department of Environmental Protection (DEP), but in some instances, people want other residents to know and see what is going on, and submission to DEP does not allow for that. FracTracker’s Mobile App allow users to submit a detailed report, including photographs, which are shared with the public. App users have submitted more than 50 photographs of pipelines in Pennsylvania, including these images below.
The FracTracker Mobile App uses crowd-sourced data to document and map a notoriously nontransparent industry. App users can also report violations, spills, or whatever they find striking. For example, the first image shows construction of the Mariner East 2 in extreme proximity to high density housing. While regulators did approve this construction, and it is therefore not a violation, the app user wanted others to see the impact to nearby residents. Other photos do show incidents, such as the second photo on the second row, showing the sinkhole that appeared along the Mariner East 1 during the construction of the nearby Mariner East 2 pipeline.
Please note that app submissions are not currently shared with DEP, so if you happen to submit an incident on our app that you think they should know about, please contact their office, as well. The FracTracker Mobile App provides latitude and longitude coordinates to make it easier for regulators to find the issue in question.
Why have there been so many problems with pipelines in recent years?
Drillers in Pennsylvania’s Marcellus Shale and other unconventional formations predicted that they would find a lot of natural gas, and they have been right about that. However, the large resulting supply of natural gas from this industrial-scaled drilling is more than the region can use. As a result, gas prices remain low, making drilling unprofitable in many cases, or keep profit margins very low in others.
The industry’s solution to this has been two-pronged. First, there is a massive effort underway to export the gas to other markets. Although there are already more than 2.5 million miles of natural gas pipelines in the United States, or more than 10 times the distance from the Earth to the Moon, it was apparently an insufficient network to achieve the desired outcome in commodity prices. The long list of recent and proposed pipeline projects, complete with information about their status, can be downloaded from the Energy Information Administration (Excel format).
The industry’s other grand effort is to create demand for natural gas liquids (NGLs, mostly ethane, propane, and butane) that accompanies the methane produced in the southwestern portion of the state. The centerpiece of this plan is the construction of multiple ethane crackers, such as the one currently being built in Beaver County by Royal Dutch Shell, for the creation of a new plastics industry in northern Appalachia. These sites will be massive consumers of NGLs which will have to be piped in through pressurized hazardous liquid routes, and would presumably serve to lock in production of unconventional gas in the region for decades to come.
Are regulators doing enough to help prevent these pipeline development problems?
In 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) led the formation of an advisory group called Pipelines and Informed Planning Alliance (PIPA), comprised mostly of industry and various state and local officials. Appendix D of their report includes a long list of activities that should not occur in pipeline rights-of-way, from all-terrain vehicle use to orchards to water wells. These activities could impact the structural integrity of the pipeline or impede the operator’s ability to promptly respond to an incident and excavate the pipe.
However, we find this list to be decidedly one-directional. While the document states that these activities should be restricted in the vicinity of pipelines, it does not infer that pipelines shouldn’t be constructed where the activities already occur:
This table should not be interpreted as guidance for the construction of new pipelines amongst existing land uses as they may require different considerations or limitations. Managing land use activities is a challenge for all stakeholders. Land use activities can contribute to the occurrence of a transmission pipeline incident and expose those working or living near a transmission pipeline to harm should an incident occur.
Pipeline being constructed near a home
While we understand the need to be flexible, and we certainly agree that every measure should be taken by those engaging in the dozens of use types listed in the PIPA report, it equally makes sense for the midstream industry to take its own advice, and refrain from building pipelines where these other land uses are already in place, as well. If a carport is disallowed because, “Access for transmission pipeline maintenance, inspection, and repair activities preclude this use,” then what possible excuse can there be to building pipelines adjacent to homes?
What distance is far enough away to escape catastrophic failure in the event of a pipeline fire or blast?
This chart shows varying hazard distances from natural gas pipelines, based on the pipe’s diameter and pressure. Source: Mark J. Stephens, A Model for Sizing High Consequence Areas Associated with Natural Gas Pipelines
It turns out that it depends pretty dramatically on the diameter and pressure of the pipe, as well as the nature of the hydrocarbon being transported. A 2000 report estimates that it could be as little as a 150-foot radius for low-pressure 6-inch pipes carrying methane, whereas a 42-inch pipe at 1,400 pounds per square inch (psi) could be a threat to structures more than 1,000 feet away on either side of the pipeline. There is no way that the general public, or even local officials, could know the hazard zone for something so variable.
While contacting Pennsylvania One Call before any excavation is required, many people may not consider a large portion of the other use cases outlined in the PIPA document to be a risk, and therefore may not know to contact One Call. To that end, we think that hazard placards would be useful, not just at the placement of the pipeline itself, but along its calculated hazard zone, so that residents are aware of the underlying risks.
If there is an incident, it is obviously critical for operators to be able to respond as quickly as possible. In most cases, a part of this process will be shutting off the flow at the nearest upstream valve, thereby stopping the flow of the hydrocarbons to the atmosphere in the case of a leak, and cutting the source of fuel in the event of a fire. Speed is only one factor in ameliorating the problem, however, with the spacing between shutoff valves being another important component.
Comprehensive datasets on pipeline valves are difficult to come by, but in FracTracker’s deep dive into the Falcon ethane pipeline project, which is proposed to supply the Shell ethane cracker facility under construction Beaver County, we see that there are 18 shutoff valves planned for the 97.5 mile route, or one per every 5.4 miles of pipe. We also know that the Falcon will operate at a maximum pressure of 1,440 psi, and has pipe diameters ranging from 10 to 16 inches. The amount of ethane that could escape is considerable, even if Shell were able to shut the flow off at the valve instantly. It stands to reason that more shutoff valves would serve to lessen the impact of releases or the severity of fires and explosions, by reducing the flow of fuel to impacted area.
Groups promoting the oil and gas industry like to speak of natural gas development as clean and safe, but unless we are comparing the industry to something else that is dirtier or more dangerous, these words are really just used to provoke an emotional response. Even governmental agencies like PHMSA are using the rhetoric.
PHMSA’s mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives.
If the safe transportation of hazardous materials sounds oxymoronic, it should. Oil and gas, and related processed hydrocarbons, are inherently dangerous and polluting.
Gas Transmission / Gathering
Impacts of pipeline incidents in Pennsylvania from January 1, 2010 through July 13, 2018. National totals for the same time include 5,308 incidents resulting 125 fatalities, 550 injuries, 283 explosions, and nearly $4 billion in property damage.
Current investments in large-scale transmission pipelines and those facilitating massive petrochemical facilities like ethane crackers are designed to lock Pennsylvania into decades of exposure to this hazardous industry, which will not only adversely the environment and the people who live here, but keep us stuck on old technology. Innovations in renewable energy such as solar and wind will continue, and Pennsylvania’s impressive research and manufacturing capacity could make us well positioned to be a leader of that energy transformation. But Pennsylvania needs to make that decision, and cease being champions of an industry that is hurting us.
Industry, not deterred by resistance from regulators and environmentalists, has developed a new work-around method to get their product to market. Rather than build pipelines across rugged, remote, or highly-populated terrain, a new “solution” called “virtual pipelines” has come on the scene, with roots in New England in 2011.
The term “virtual pipeline,” itself, is so new that it is trademarked by Xpress Natural Gas (XNG), Boston, MA. XNG and other virtual pipeline companies use specially-designed tanker trucks to move compressed natural gas (CNG) or liquefied natural gas (LNG) via our public roads and highways. CNG in this system is under very high pressure — up to 3,600 psi when tank trailers are full. Rail and barge shipments are also considered part of the system, and trailers are designed to be easily loaded onto train cars or boats.
For the gas industry, virtual pipelines can be used in locales where gas is only needed for a limited time period, the pipeline network is not developed, or opposition by landowners is too contentious to make eminent domain an option, among other issues.
Restricted only by permissible weight limits on roads (up to 80,000 pounds or more), 5-axle trucks may make in excess of 100 round trips a day from the fueling location to their destination — sometimes hundreds of miles away. These trucks, which may travel alone or in caravans, are identifiable by the hazard class 2.1 placard they carry: 1971, indicative of flammable, compressed natural gas or methane. Manufacturers of these virtual pipeline rigs tout the safety considerations that go into their engineered design. These considerations include special pressure monitoring for the dozens of tanks and super-strength materials to protect against ruptures.
Specialized equipment has been created to load compressed gas tanks into the trailers that will carry them to their destinations. Here’s a promotional video from Quantum:
Loading CNG into specialized trailers for transport
Impacts on Communities
Following New York State’s rejection of the Constitution Pipeline in 2016 based on water quality concerns, industry has been looking for ways to move natural gas from Pennsylvania’s Marcellus gas fields to the Iroquois Pipeline. The current strategy is to load the gas in canisters from a special compressor facility, and re-inject the gas to a pipeline at the journey’s endpoint. The extent to which virtual pipelines may be utilized in New York State and New England is not well known, but the natural gas industry does speak in sanguine terms about this strategy as a solution to many of its transportation issues.
Citizen blogger/activist Bill Huston has compiled a list accidents that have occurred with CNG transport trucks along the virtual pipeline that runs from a “mother station” at Forest Lake, PA to Manheim, NY, near the Iroquois pipeline. While there have been no explosions or loss of life as a result of these accidents, there are a number of reported incidents of trucks tipping or rolling over, sliding off the road, or spontaneously venting.
To move CNG from “Point A” to “Point B,” truck traffic through populated areas is unavoidable. In central New York, public outcry about virtual pipelines is rising, due in large part to the safety issues associated with increased truck traffic on state highways. In rural New York, state highways run through towns, villages, and cities. They are not separated from population centers in the way that interstate highways typically are. Traffic from CNG transport trucks clogs roadways, in some cases burdening the pass-through communities with 100 or more tractor trailers a day. Routes pass directly in front of schools and health care facilities.
In short, virtual pipelines present a public safety hazard that has yet to be addressed.
Virtual Pipelines and the Cayuga Power Plant
In Lansing, NY, there is an inefficient and economically-beleaguered power plant, currently run on coal, that the power utility would prefer to see shut down. The Cayuga Power Plant was cited in 2016 for exceeding mercury emissions by nearly 2000%. Its inherently inefficient design makes it a significant greenhouse gas contributor. Years ago, it provided considerable tax benefits to its host community of Lansing, and as such has some lingering support. After both a devastating fire in one stack and mechanical failure in another, the plant has been barely running for the past 3 or 4 years. It is currently used as a “peaker plant“, operating only during periods of excessive demand on the electric grid, during summer months.
New York State’s Governor, Andrew Cuomo, has stated that all coal-power plants will be shut down by 2020.
Cayuga Power Plant in Lansing, NY.
Nonetheless, the plant owners are pushing to re-power the Cayuga Power Plant with natural gas. Currently, however, there is no pipeline to deliver the gas to the plant. Without support by the public nor the Public Service Commission for the construction of a supply pipeline, Cayuga Power Plant has revealed they plan to receive gas deliveries via truck.
FracTracker has modeled the five most likely scenarios that would take compressed natural gas from a loading station in northern Pennsylvania to the Cayuga Power Plant in Lansing. All of the scenarios bring the trucks through populated communities, in dangerous proximity to high-risk facilities where both human safety and evacuations are problematic. The routes also pass through intersections and road stretches that have some of the highest accident rates in the area.
Route 1: This route passes within a half mile of homes of 36,669 people in the Villages of Lansing, Candor, Spencer, Owego; Towns of Ithaca, Lansing, Newfield, Danby, Candor, Spencer, Tioga, Owego, Vestal; and the City of Ithaca. Within the half-mile evacuation zone of this route, should there be an accident, are:
17 health care facilities
20 day care centers
4 private school
21 public schools
Route 2: This route passes within a half mile of homes of 54,182 people in the Villages of Groton, Marathon, Whitney Point, Johnson City; Towns of Lansing, Dryden, Cortlandville, Groton, Virgil, Lapeer, Marathon, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and Cities of Cortland and Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
31 health care facilities
37 day care centers
3 private school
19 public schools
Route 3: This route passes within a half mile of homes of 39,638 people in the Villages of Dryden, Lisle, Whitney Point, Johnson City; Towns of Lansing, Dryden, Groton, Harford, Richford, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and the City of Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
17 health care facilities
23 day care centers
1 private school
14 public schools
Route 4: This route passes within a half mile of homes of 44,804 people in the Villages of Homer, Marathon, Whitney Point, Johnson City; Towns of Lansing, Summerhill, Locke, Genoa, Homer, Cortlandville, Virgil, Lapeer, Marathon, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and Cities of Cortland and Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
24 health care facilities
31 day care centers
2 private school
15 public schools
Route 5: This route passes within a half mile of homes of 59,731 people in the Villages of Lansing, Lisle, Whitney Point, Johnson City; Towns of Lansing, Dryden, Ithaca, Caroline, Richford, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and Cities of Ithaca and Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
26 health care facilities
37 day care centers
3 private school
21 public schools
Click on the tabs in the box above to explore the five potential truck routes with maps.
For a full interactive map of the potential routes for CNG delivery to the Cayuga Power Plant, and the schools, health care facilities, etc. within a half-mile evacuation zone of the routes, view the interactive map below.
Despite the apparent convenience that virtual pipelines present for the fossil fuel industry, they are not the solution the future energy supply needs. Yes, they present an alternative to pipeline transportation — but they also play a disastrous role in continuing our descent into climate chaos caused by increasing greenhouse gas concentrations in the atmosphere.
Methane leakage is an unavoidable component of the entire life cycle of natural gas usage — from “cradle to grave” — or more precisely, from the moment a well is drilled to when the gas is combusted by its end-user. And methane, as a greenhouse gas, is up to 100 times more potent than carbon dioxide. The Intergovernmental Panel on Climate Change’s (IPCC) recent report (see summary here) is unflinching in its clarion call for immediate, and extreme, cut-backs in greenhouse gas production. If we choose not to heed this call, much of humanity’s future survival is called into question.
More of the details about the Cayuga Power Plant will be explained in the upcoming weeks in a related guest blog by environmental activist and organizer, Irene Weiser, of Tompkins County, NY.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/10/VirtualPipelines-Feature-Map.png400900Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKaren Edelstein2018-10-30 15:49:512020-03-12 14:57:13Virtual pipelines: Convenient for Industry, a Burden on Communities
We are always learning new things at FracTracker. While we have been analyzing and mapping oil and gas (O&G) violations issued by the Department of Environmental Protection (DEP) in Pennsylvania since 2010, we have apparently been under-representing the total amount of issues associated with unconventional drilling in the state.
The reason for the missing violations is that there are inconsistencies with how well pads are classified in the compliance report. Many of these well pads – full of unconventional permits and drilled wells – are indeed categorized as “unconventional” in the DEP compliance data. Others, equally full of unconventional permits and wells, simply leave that field blank.
Therefore, any analysis for unconventional violations is likely to miss some of the incidents that are attributed to the well pad itself, as opposed to any of the wells that are found upon that well pad.
Midas Well Pad unearths issue
While we have heard about missing violation data in the past, I discovered the nature of the issue while researching the Midas Well Pad in Plum Borough, Allegheny County on the DEP resource site eFACTS, noting the presence of multiple violations at the nascent well site. However, when attempting to download the relevant data on the compliance report, the results were missing. I had entered search parameters that made sense to me, limiting results to violations in the proper county and municipality, and including an inspection date range that was broader than what was showing up on eFACTS. I had also limited results to unconventional wells, because while this is Plum’s first unconventional well pad, the back roads are dotted with dozens – if not hundreds – of conventional O&G sites.
The Midas Well Pad, as seem from Coxcomb Hill Rd. in Plum, PA
After that attempt failed, I downloaded the entire state’s worth of data, whether conventional or not, and I was able to find the 31 violations associated with the well pad.
I contacted DEP about this, wondering whether there was some data irregularity that prevented my search in Plum from finding all of the incidents that occurred there. The reply was somewhat helpful, noting that there was no county, municipality, or unconventional value associated with that well pad in the compliance report, explaining why the search result came up negative.
It is worth noting that the separate well pad report does indeed have values for all of these fields for the Midas Well Pad, so there is a lack of consistency on this issue. Even more importantly, it is worth remembering that any compliance report search that limits results using county, municipality, or unconventional variables are likely to result in incomplete results.
The violations at the Midas Well Pad are focused around erosion and sedimentation issues, wetland impacts, failure to follow approved methodology, and failure to fix some of the problems on subsequent site inspections. The compliance report includes a narrative inspection comment, giving the public a glimpse through the inspector’s eyes. Here is one of several such comments at the site:
Follow up inspection related to wetland impact reported on 2/23/18 and 2/24/18. At the time of inspection, the Operator was actively conducting earth disturbance activity associated with the construction of well pad channel 6. The Department gave verbal permission on 2/27/2018 to deviate from the construction sequence and continue with the construction of PCSM wet pond 1. At the time of inspection wet pond 1 was partially constructed. The outlet structure and emergency spillway associated with wet pond 1. At the time of inspection wet pond 1 was holding water, however the slopes were not temporary stabilized. The Operator indicated that additional work was planned for the wet pond and would be temporary stabilized. The Operator indicated a previously unidentified seep located upgradient and outside of the LOD is contributing additional water to wet pond 1. The Department recommended the Operator identify wet weather springs upgradient from wet pond 1. Additionally, the Department recommends the Operator monitor all additional flow and submit a permit modification outlines changes made to the construction sequence and identifies the location of all toe drains to be constructed on site. The Department and Operator agreed to reschedule an onsite meeting to discuss the remediation of the wetland. Th Department recommends the Operator monitor the vegetative growth in the wetland. The Department recommends that the Operator add additional temporary mulch to the disturbed area and continue to perform routine maintenance to the temporary BMPs.
How pervasive is this problem?
The DEP well pad report contains data on 12,600 wells, situated on 3,715 wells pads. On the compliance side, there are 2,689 violations at 390 different sites that contain the words “Well Pad.” 739 of these violations do not have associated Well API Numbers, and are therefore not shown in our Pennsylvania Shale Viewer map. The number of sites with violations per operator is shown below in Figure 1 (click to expand).
Figure 1: Number of well pads appearing on compliance report by operator, through 5/15/2018. Click on the image to see the full-sized version.
There are four things to note about about Figure 1.
First, this table is not the number of violations on well pads, but merely the count of well pads with violations appearing on the compliance report.
Second, this does not contain any data on wells on those pads that were issued violations – only instances where the well pads themselves were cited are shown.
This map shows oil and gas (O&G) violations in Pennsylvania that are assessed to well pads, as opposed to individual wells. To access the map’s legend and other details, click the double-arrow icon at the top-left corner of the map.
The third thing to note about Figure 1 is that there are instances where the same pad falls into more than one category. Hilcorp Energy, for example, has 10 wells in the unconventional category, 11 wells that are not defined, but only 13 total wells, indicating significant overlap between the categories.
And fourth, there are 31 instances where the phrase “well pad” occurs in the compliance report where the unique Site ID# does not appear on the well pad report. In some cases, the name of the facility indicates that it might be for another facility that is related to the well pad, such as “Southwest System – Well Pad 36 to Bluestone Pipeline.” For other entries, such as “Yarasavage Well Pad”, it remains unclear why the Site ID# does not yield a matching entry from the well pad report.
By Matt Kelso, Manager of Data and Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/05/PA-Well-Pad-Violations-Feature.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2018-05-23 09:39:172020-03-12 15:31:41Well Pad Violations in Pennsylvania
In August 2016, Shell Pipeline announced plans to develop the Falcon Ethane Pipeline System, a 97-mile pipeline network that will carry more than 107,000 barrels of ethane per day through Pennsylvania, West Virginia, and Ohio, to feed Shell Appalachia’s petrochemical facility currently under construction in Beaver County, PA.
FracTracker has covered the proposed Falcon pipeline extensively in recent months. Our Falcon Public EIA Project explored the project in great detail, revealing the many steps involved in risk assessments and a range of potential impacts to public and environmental health.
Shell’s response to these events has invariably focused on their intent to build and operate a pipeline that exceeds safety standards, as well as their commitments to being a good neighbor. In this article, we investigate these claims by looking at federal data on safety incidents related to Shell Pipeline.
Contrary to claims, records show that Shell’s safety record is one of the worst in the nation.
The “Good Neighbor” Narrative
Maintaining a reputation as a “good neighbor” is paramount to pipeline companies. Negotiating with landowners, working with regulators, and getting support from implicated communities can hinge on the perception that the pipeline will be built and operated in a responsible manner. This is evident in cases where Shell Pipeline has sold the Falcon in press releases as an example of the company’s commitment to safety in public comments.
Figure 1. Shell flyer
A recent flyer distributed to communities in the path of the Falcon, seen in Figure 1, also emphasizes safety, such as in claims that “Shell Pipeline has a proven track record of operating safely and responsibility and remains committed to engaging with local communities regarding impacts that may arise from its operations.”
Shell reinforced their “good neighbor” policy on several occasions at a recent Shell-sponsored information meeting held in Beaver County, stating that, everywhere they do business, Shell was committed to the reliable delivery of their product. According to project managers speaking at the event, this is achieved through “planning and training with first responders, preventative maintenance for the right-of-way and valves, and through inspections—all in the name of maintaining pipeline integrity.”
Shell Pipeline also recently created an informational website dedicated to the Falcon pipeline to provide details on the project and emphasize its minimal impact. Although, curiously, Shell’s answer to the question “Is the pipeline safe?” is blank.
U.S. Pipeline Incident Data
Every few years FracTracker revisits data on pipeline safety incidents that is maintained by the Pipeline and Hazardous Materials Safety Administration (PHMSA). In our last national analysis we found that there have been 4,215 pipeline incidents resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion.
These numbers were based on U.S. data from 2010-2016 for natural gas transmission and gathering pipelines, natural gas distribution pipelines, and hazardous liquids pipelines. It is also worth noting that incident data are heavily dependent on voluntary reporting. They also do not account for incidents that were only investigated at the state level.
Shell Pipeline has only a few assets related to transmission, gathering, and distribution lines. Almost all of their pipeline miles transport highly-volatile liquids such as crude oil, refined petroleum products, and hazardous liquids such as ethane. Therefore, to get a more accurate picture of how Shell Pipeline’s safety record stacks up to comparable operators, our analysis focuses exclusively on PHMSA’s hazardous liquids pipeline data. We also expanded our analysis to look at incidents dating back to 2002.
Shell’s Incident Record
In total, PHMSA data show that Shell was responsible for 194 pipeline incidents since 2002. These incidents spilled 59,290 barrels of petrochemical products totaling some $183-million in damages. The below map locates where most of these incidents occurred. Unfortunately, 34 incidents have no location data and so are not visible on the map. The map also shows the location of Shell’s many refineries, transport terminals, and off-shore drilling platforms.
Open the map fullscreen to see more details and tools for exploring the data.
PHMSA’s hazardous liquid pipeline data account for more than 350 known pipeline operators. Some operators are fairly small, only maintaining a few miles of pipeline. Others are hard to track subsidiaries of larger companies. However, the big players stand out from the pack — some 20 operators account for more than 60% of all pipeline miles in the U.S., and Shell Pipeline is one of these 20.
Comparing Shell Pipeline to other major operators carrying HVLs, we found that Shell ranks 2nd in the nation in the most incidents-per-mile of maintained pipeline, seen in table 1 below. These numbers are based on the total incidents since 2002 divided by the number of miles maintained by each operator as of 2016 miles. Table 2 breaks Shell’s incidents down by year and number of miles maintained for each of those years.
Table 1: U.S. Pipeline operators ranked by incidents-per-mile
HVL Pipeline Miles
Incidents Per Mile (2016)
Table 2: Shell incidents and maintained pipeline miles by year
no PHMSA data
no PHMSA data
Hurricane Katrina & Rita
no PHMSA data
no PHMSA data
As of 3/1/18
Cause & Location of Failure
What were the causes of Shell’s pipeline incidents? At Shell’s public informational session, it was said that “in the industry, we know that the biggest issue with pipeline accidents is third party problems – when someone, not us, hits the pipeline.” However, PHMSA data reveal that most of Shell’s incidents issues should have been under the company’s control. For instance, 66% (128) of incidents were due to equipment failure, corrosion, welding failure, structural issues, or incorrect operations (Table 3).
Table 3. Shell Pipeline incidents by cause of failure
Material and/or Weld Failure
However, not all of these incidents occurred at one of Shell’s petrochemical facilities. As Table 4 below illustrates, at least 57 incidents occurred somewhere along the pipeline’s right-of-way through public areas or migrated off Shell’s property to impact public spaces. These numbers may be higher as 47 incidents have no mention of the property where incidents occurred.
Table 4. Shell Pipeline incidents by location of failure
Contained on Operator Property
Originated on Operator Property, Migrated off Property
Contained on Operator-Controlled Right-of-Way
On several occasions, Shell has claimed that the Falcon will be safely “unseen and out of mind” beneath at least 4ft of ground cover. However, even when this standard is exceeded, PHMSA data revealed that at least a third of Shell’s incidents occurred beneath 4ft or more of soil.
Many of the aboveground incidents occurred at sites like pumping stations and shut-off valves. For instance, a 2016 ethylene spill in Louisiana was caused by lightning striking a pumping station, leading to pump failure and an eventual fire. In numerous incidents, valves failed due to water seeping into systems from frozen pipes, or large rain events overflowing facility sump pumps. Table 5 below breaks these incidents down by the kind of commodity involved in each case.
Table 5. Shell Pipeline incidents by commodity spill volumes
Highly Volatile Liquids
Impacts & Costs
None of Shell’s incidents resulted in fatalities, injuries, or major explosions. However, there is evidence of significant environmental and community impacts. Of 150 incidents that included such data, 76 resulted in soil contamination and 38 resulted in water contamination issues. Furthermore, 78 incidents occurred in high consequence areas (HCAs)—locations along the pipeline that were identified during construction as having sensitive environmental habitats, drinking water resources, or densely populated areas.
Table 6 below shows the costs of the 194 incidents. These numbers are somewhat deceiving as the “Public (other)” category includes such things as inspections, environmental cleanup, and disposal of contaminated soil. Thus, the costs incurred by private citizens and public services totaled more than $80-million.
Table 6. Costs of damage from Shell Pipeline incidents
Damage to Operator
A number of significant incidents are worth mention. For instance, in 2013, a Shell pipeline rupture led to as much as 30,000 gallons of crude oil spilling into a waterway near Houston, Texas, that connects to the Gulf of Mexico. Shell’s initial position was that no rupture or spill had occurred, but this was later found not to be the case after investigations by the U.S. Coast Guard. The image at the top of this page depicts Shell’s cleanup efforts in the waterway.
Another incident found that a Shell crude oil pipeline ruptured twice in less than a year in the San Joaquin Valley, CA. Investigations found that the ruptures were due to “fatigue cracks” that led to 60,000 gallons of oil spilling into grasslands, resulting in more than $6 million in environmental damage and emergency response costs. Concerns raised by the State Fire Marshal’s Pipeline Safety Division following the second spill in 2016 forced Shell to replace a 12-mile stretch of the problematic pipeline, as seen in the image above.
These findings suggest that while Shell is obligated to stress safety to sell the Falcon pipeline to the public, people should take Shell’s “good neighbor” narrative with a degree of skepticism. The numbers presented by PHMSA’s pipeline incident data significantly undermine Shell’s claim of having a proven track record as a safe and responsible operator. In fact, Shell ranks near the top of all US operators for incidents per HVL pipeline mile maintained, as well as damage totals.
There are inherent gaps in our analysis based on data inadequacies worth noting. Incidents dealt with at the state level may not make their way into PHMSA’s data, nor would problems that are not voluntary reported by pipeline operators. Issues similar to what the state of Pennsylvania has experienced with Sunoco Pipeline’s Mariner East 2, where horizontal drilling mishaps have contaminated dozens of streams and private drinking water wells, would likely not be reflected in PHMSA’s data unless those incidents resulted in federal interventions.
Based on the available data, however, most of Shell’s pipelines support one of the company’s many refining and storage facilities, primarily located in California and the Gulf states of Texas and Louisiana. Unsurprisingly, these areas are also where we see dense clusters of pipeline incidents attributed to Shell. In addition, many of Shell’s incidents appear to be the result of inadequate maintenance and improper operations, and less so due to factors beyond their control.
As Shell’s footprint in the Appalachian region expands, their safety history suggests we could see the same proliferation of pipeline incidents in this area over time, as well.
NOTE: This article was amended on 4/9/18 to include table 2.
Oil and gas operators are polluting groundwater in Colorado, and the state and U.S. EPA are granting them permission with exemptions from the Safe Drinking Water Act.
FracTracker Alliance’s newest analysis attempts to identify groundwater risks in Colorado groundwater from the injection of oil and gas waste. Specifically, we look at groundwater monitoring data near Class II underground injection control (UIC) disposal wells and in areas that have been granted aquifer exemptions from the underground source of drinking water rules of the Safe Drinking Water Act (SDWA). Momentum to remove amend the SDWA and remove these exemption.
Aquifer exemptions are granted to allow corporations to inject hazardous wastewater into groundwater aquifers. The majority, two-thirds, of these injection wells are Class II, specifically for oil and gas wastes.
The results of this assessment provide insight into high-risk issues with aquifer exemptions and Class II UIC well permitting standards in Colorado. We identify areas where aquifer exemptions have been granted in high quality groundwater formations, and where deep underground aquifers are at risk or have become contaminated from Class II disposal wells that may have failed.
Of note: On March 23, 2016, NRDC submitted a formal petition urging the EPA to repeal or amend the aquifer exemption rules to protect drinking water sources and uphold the Safe Drinking Water Act. Learn more
Research shows injection wells do fail
Class II injection well in Colorado explodes and catches fire. Photo by Kelsey Brunner for the Greeley Tribune.
Disposal of oil and gas wastewater by underground injection has not yet been specifically researched as a source of systemic groundwater contamination nationally or on a state level. Regardless, this issue is particularly pertinent to Colorado, since there are about 3,300 aquifer exemptions in the US (view map), and the majority of these are located in Montana, Wyoming, and Colorado. There is both a physical risk of danger as well as the risk of groundwater contamination. The picture to the right shows an explosion of a Class II injection well in Greeley, CO, for example.
Applicable and existing research on injection wells shows that a risk of groundwater contamination of – not wastewater – but migrated methane due to a leak from an injection well was estimated to be between 0.12 percent of all the water wells in the Colorado region, and was measured at 4.5 percent of the water wells that were tested in the study.
…groundwater contamination problems related to the subsurface disposal of liquid wastes by deep-well injection have been reviewed in the literature since 1950 (Morganwalp, 1993) and groundwater contamination accordingly is a serious problem.
According to his textbook, a 1974 U.S. EPA report specifically warns of the risk of corrosion by oil and gas waste brines on handling equipment and within the wells. The potential effects of injection wells on groundwater can even be reviewed in the U.S. EPA publications (1976, 1996, 1997).
As early as 1969, researchers Evans and Bradford, who reported on the dangers that could occur from earthquakes on injection wells near Denver in 1966, had warned that deep well injection techniques offered temporary and not long-term safety from the permanent toxic wastes injected.
Will existing Class II wells fail?
For those that might consider data and literature on wells from the 1960’s as being unrepresentative of activities occurring today, of the 587 wells reported by the Colorado’s oil and gas regulatory body, COGCC, as “injecting,” 161 of those wells were drilled prior to 1980. And 104 were drilled prior to 1960!
Wells drilled prior to 1980 are most likely to use engineering standards that result in “single-point-of-failure” well casings. As outlined in the recent report from researchers at Harvard on underground natural gas storage wells, these single-point-of-failure wells are at a higher risk of leaking.
It is also important to note that the U.S. EPA reports only 569 injection wells for Colorado, 373 of which may be disposal wells. This is a discrepancy from the number of injection wells reported by the COGCC.
Aquifer Exemptions in Colorado
According to COGCC, prior to granting a permit for a Class II injection well, an aquifer exemption is required if the aquifer’s groundwater test shows total dissolved solids (TDS) is between 3,000 and 10,000 milligrams per liter (mg/l). For those aquifer exemptions that are simply deeper than the majority of current groundwater wells, the right conditions, such as drought, or the needs of the future may require drilling deeper or treating high TDS waters for drinking and irrigation. How the state of Colorado or the U.S. EPA accounts for economic viability is therefore ill-conceived.
Data Note: The data for the following analysis came by way of FOIA request by Clean Water Action focused on the aquifer exemption permitting process. The FOIA returned additional data not reported by the US EPA in the public dataset. That dataset contained target formation sampling data that included TDS values. The FOIA documents were attached to the EPA dataset using GIS techniques. These GIS files can be found for download in the link at the bottom of this page.
Map 1 above shows the locations of aquifer exemptions in Colorado, as well as the locations of Class II injection wells. These sites are overlaid on a spatial assessment of groundwater quality (a map of the groundwater’s quality), which was generated for the entire state. The changing colors on the map’s background show spatial trends of TDS values, a general indicator of overall groundwater quality.
In Map 1 above, we see that the majority of Class II injection wells and aquifer exemptions are located in regions with higher quality water. This is a common trend across the state, and needs to be addressed.
Our review of aquifer exemption data in Colorado shows that aquifer exemption applications were granted for areas reporting TDS values less than 3,000 mg/l, which contradicts the information reported by the COGCC as permitting guidelines. Additionally, of the 175 granted aquifer exemptions for which the FOIA returned data, 141 were formations with groundwater samples reported at less than 10,000 mg/l TDS. This is half of the total number (283) of aquifer exemptions in the state of Colorado.
When we mapped where class II injection wells are permitted, a total of 587 class II wells were identified in Colorado, outside of an aquifer exemption area. Of the UIC-approved injection wells identified specifically as disposal wells, at least 21 were permitted outside aquifer exemptions and were drilled into formations that were not hydrocarbon producing. Why these injection wells are allowed to operate outside of an aquifer exemption is unknown – a question for regulators.
You can see in the map that most of the aquifer exemptions and injection wells in Colorado are located in areas with lower TDS values. We then used GIS to conduct a spatial analysis that selected groundwater wells within five miles of the 21 that were permitted outside aquifer exemptions. Results show that groundwater wells near these sites had consistently low-TDS values, meaning good water quality. In Colorado, where groundwater is an important commodity for a booming agricultural industry and growing cities that need to prioritize municipal sources, permitting a Class II disposal well in areas with high quality groundwater is irresponsible.
In Map 2, above, the locations of groundwater wells in Colorado are shown. The colors of the dots represent the concentration of TDS on the right and well depth on the left side of the screen. By sliding the bar on the map, users can visualize both. This feature allows people to explore where deep wells also are characterized by high levels of TDS. Users can also see that areas with high quality low TDS groundwater are the same areas that are the most developed with oil and gas production wells and Class II injection wells, shown in gradients of purple.
Statistical analysis of this spatial data gives a clearer picture of which regions are of particular concern; see below in Map 3.
In Map 3, above, the data visualized in Map 2 were input into a hot-spots analysis, highlighting where high and low values of TDS and depth differ significantly from the rest of the data. The region of the Front Range near Denver has significantly deeper wells, as a result of population density and the need to drill municipal groundwater wells.
The Front Range is, therefore, a high-risk region for the development of oil and gas, particularly from Class II injection wells that are necessary to support development.
Methods Notes: The COGCC publishes groundwater monitoring data for the state of Colorado, and groundwater data is also compiled nationally by the Advisory Committee on Water Information (ACWI). (Data from the National Groundwater Monitoring Network is sponsored by the ACWI Subcommittee on Ground Water.) These datasets were cleaned, combined, revised, and queried to develop FracTracker’s dataset of Colorado groundwater wells. We cleaned the data by removing sites without coordinates. Duplicates in the data set were removed by selecting for the deepest well sample. Our dataset of water wells consisted of 5,620 wells. Depth data was reported for 3,925 wells. We combined this dataset with groundwater data exported from ACWI. Final count for total wells with TDS data was 11,754 wells. Depth data was reported for 7,984 wells. The GIS files can be downloaded in the compressed folder at the bottom of this page.
Site Assessments – Exploring Specific Regions
Particular regions were further investigated for impacts to groundwater, and to identify areas that may be at a high risk of contamination. There are numerous ways that groundwater wells can be contaminated from other underground activity, such as hydrocarbon exploration and production or waste injection and disposal. Contamination could be from hydraulic fracturing fluids, methane, other hydrocarbons, or from formation brines.
From the literature, brines and methane are the most common contaminants. This analysis focuses on potential contamination events from brines, which can be detected by measuring TDS, a general measure for the mixture of minerals, salts, metals and other ions dissolved in waters. Brines from hydrocarbon-producing formations may include heavy metals, radionuclides, and small amounts of organic matter.
Wells with high or increasing levels of TDS are a red flag for potential contamination events.
Groundwater wells at deep depths with high TDS readings are, therefore, the focus of this assessment. Using GIS methods we screened our dataset of groundwater wells to only identify those located within a buffer zone of five miles from Class II injection wells. This distance was chosen based on a conservative model for groundwater contamination events, as well as the number of returned sample groundwater wells and the time and resources necessary for analysis. We then filtered the groundwater wells dataset for high TDS values and deep well depths to assess for potential impacts that already exist. We, of course, explored the data as we explored the spatial relationships. We prioritized areas that suggested trends in high TDS readings, and then identified individual wells in these areas. The data initially visualized were the most recent sampling events. For the wells prioritized, prior sampling events were pulled from the data. The results were graphed to see how the groundwater quality has changed over time.
Case of Increasing TDS Readings
If you zoom to the southwest section of Colorado in Map 2, you can see that groundwater wells located near the injection well 1 Fasset SWD (EPA) (05-067-08397) by Operator Elm Ridge Exploration Company LLC were disproportionately high (common). Groundwater wells located near this injection well were selected for, and longitudinal TDS readings were plotted to look for trends in time. (Figure 1.)
The graphs in Figure 1, below, show a consistent increase of TDS values in wells near the injection activity. While the trends are apparent, the data is limited by low numbers of repeated samples at each well, and the majority of these groundwater wells have not been sampled in the last 10 years. With the increased use of well stimulation and enhanced oil recovery techniques over the course of the last 10 years, the volumes of injected wastewater has also increased. The impacts may, therefore, be greater than documented here.
This area deserves additional sampling and monitoring to assess whether contamination has occurred.
Figures 1a and 1b. The graphs above show increasing TDS values in samples from groundwater wells in close proximity to the 1 Fassett SWD wellsite, between the years 2004-2015. Each well is labeled with a different color. The data for the USGS well in the graph on the right was not included with the other groundwater wells due to the difference in magnitude of TDS values (it would have been off the chart).
Groundwater Contamination Case in 2007
We also uncovered a situation where a disposal well caused groundwater contamination. Well records for Class II injection wells in the southeast corner of Colorado were reviewed in response to significantly high readings of TDS values in groundwater wells surrounding the Mckinley #1-20-WD disposal well.
When the disposal well was first permitted, farmers and ranchers neighboring the well site petitioned to block the permit. Language in the grant application is shown below in Figure 2. The petitioners identified the target formation as their source of water for drinking, watering livestock, and irrigation. Regardless of this petition, the injection well was approved. Figure 3 shows the language used by the operator Energy Alliance Company (EAC) for the permit approval, which directly contradicts the information provided by the community surrounding the wellsite. Nevertheless, the Class II disposal well was approved, and failed and leaked in 2007, leading to the high TDS readings in the groundwater in this region.
Figure 2. Petition by local landowners opposing the use of their drinking water source formation for the site of a Class II injection disposal well.
Figure 3. The oil and gas operation EAC claims the Glorietta formation is not a viable fresh water source, directly contradicting the neighboring farmers and ranchers who rely on it.
Figure 4. The COGCC well log report shows a casing failure, and as a result a leak that contaminated groundwater in the region.
Areas where lack of data restricted analyses
In other areas of Colorado, the lack of recent sampling data and longitudinal sampling schemes made it even more difficult to track potential contamination events. For these regions, FracTracker recommends more thorough sampling by the regulatory agencies COGCC and USGS. This includes much of the state, as described below.
Our review of the groundwater data in southeastern Colorado showed a risk of contamination considering the overlap of injection well depths with the depths of drinking water wells. Oil and gas extraction and Class II injections are permitted where the aquifers include the Raton formation, Vermejo Formation, Poison Canyon Formation and Trinidad Sandstone. Groundwater samples were taken at depths up to 2,200 ft with a TDS value of 385 mg/l. At shallower depths, TDS values in these formations reached as high as 6,000 mg/l, and 15 disposal wells are permitted in aquifer exemptions in this region. Injections in this area start at around 4,200 ft.
In Southwestern Colorado, groundwater wells in the San Jose Formation are drilled to documented depths of up to 6,000 feet with TDS values near 2,000 mg/l. Injection wells in this region begin at 565 feet, and those used specifically for disposal begin at below 5,000 feet in areas with aquifer exemptions. There are also four disposal wells outside of aquifer exemptions injecting at 5,844 feet, two of which are not injecting into active production zones at depths of 7,600 and 9,100 feet.
In western Colorado well Number 1-32D VANETA (05-057-06467) by Operator Sandridge Exploration and Production LLC’s North Park Horizontal Niobara Field in the Dakota-Lokota Formation has an aquifer exemption. The sampling data from two groundwater wells to the southeast, near Coalmont, CO, were reviewed, but we can’t get a good picture due to the lack of repeat sampling.
In Northwestern Colorado near Walden, CO and the McCallum oil field, two groundwater wells with TDS above 10,000 ppm were selected for review. There are 21 injection wells in the McCallum field to the northwest. Beyond the McCallum field is the Battleship field with two wastewater disposal wells with an aquifer exemption. West of Grover, Colorado, there are several wells with high TDS values reported for shallow wells. Similar trends can be seen near Vernon. The data on these wells and wells from along the northern section of the Front Range, which includes the communities of Fort Collins, Greeley, and Longmont, suffered from the same issue. Lack of deep groundwater well data coupled with the lack of repeat samples, as well as recent sampling inhibited the ability to thoroughly investigate the threat of contamination.
Trends and Future Development
Current trends in exploration and development of unconventional resources show the industry branching southwest of Weld County towards Fort Collins, Longmont, Broomfield and Boulder, CO.
These regions are more densely populated than the Front Range county of Weld, and as can be seen in the maps, the drinking water wells that access groundwaters in these regions are some of the deepest in the state.
This analysis shows where Class II injection has already contaminated groundwater resources in Colorado. The region where the contamination has occurred is not unique; the drinking water wells are not particularly deep, and the density of Class II wells is far from the highest in the state.
Well casing failures and other injection issues are not exactly predictable due to the variety of conditions that can lead to a well casing failure or blow-out scenario, but they are systemic. The result is a hazardous scenario where it is currently difficult to mitigate risk after the injection wells are drilled.
Allowing Class II wells to expand into Front Range communities that rely on deep wells for municipal supplies is irresponsible and dangerous.
The encroachment of extraction into these regions, coupled with the support of Class II injection wells to handle the wastewater, would put these groundwater wells at particular risk of contamination. Based on this analysis, we recommend that regulators take extra care to avoid permitting Class II wells in these regions as the oil and gas industry expands into new areas of the Front Range, particularly in areas with dense populations.
Feature Image: Joshua Doubek / WIKIMEDIA COMMONS
Article by: Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
October 31, 2017 Edit: This post originally cited the Clean Water Act instead of the Safe Drinking Water Act as the source that EPA uses to grant aquifer exemptions.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/10/kansas_wellpad.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2017-10-26 14:55:032020-03-12 15:45:07Groundwater risks in Colorado due to Safe Drinking Water Act exemptions