Data driven discussions about gas extraction and related topics.

Matt Kelso, BA

Drilling and Compliance in PA’s Marcellus Over Time

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The following line chart shows the number of Marcellus Shale wells drilled in Pennsylvania from January 2007 through March 2012, and the number of violations issued (1) by PADEP over the same period of time:


Drilled Wells and Violations in PA’s Marcellus Over Time

While drilling activities in Pennsylvania’s Marcellus Shale really got under way in 2005, the threshold of 10 wells drilled in a month didn’t happen until 2007, so the earlier data has been omitted in favor of charts that are a little less crowded. Here are a few milestones that have happened along the way:

  • First month with more violations than wells: April 2008 (difference=8)
  • First month with 50 violations: June 2008 (n=82)
  • First month with 50 wells: June 2009 (n=75)
  • First month with 100 violations: July 2009 (n=101)
  • First month with 100 wells: November 2009 (n=111)
  • First month with 100 more wells than violations: September 2010 (n=109)
  • First month with 200 wells: August 2011 (n=212)
  • Longest streak with more wells than violations: 15 months (January 2007 to March 2008) (2)
  • Longest streak with more violations than wells: 7 months: (February to August 2009)
  • Second longest streak with more wells than violations: 11 months (May 2011 to March 2012)
  • Second longest streak with more violations than wells: 2 months (Aug.-Sept 2008 and Dec. 2009-Jan 2010)
  1. Included in violations is the total number of records from the compliance report linked above during the given time period where the “Marcellus only” and “Inspections with violations only” fields are set to “Yes”. This inflates the number of incidents reported by PADEP, which keeps track through the number of unique violation ID’s issued, so that if two instances are issued the same violation ID, it will be counted as one violation.
  2. This streak may well be longer if months prior to 2007 were included
Matt Kelso, BA

What are the Effects of Falling Gas Prices on PA’s Marcellus Shale?

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In July 2011, the wellhead price of gas was $4.27 per thousand cubic feet (Mcf). As of this morning that price had fallen to $2.09, a decrease of more than 51 percent in well less than a year. This trend is widely projected to continue as gas reserves approach storage capacity in the US, at a time of year in which suppliers are typically busy recouping the pipelines after peak wintertime consumption. There is plenty of speculation that the price could fall to $1 per Mcf, or maybe even lower, sometime this summer.

In Pennsylvania’s Marcellus Shale, however, drilling operators are still hard at work, having applied for 742 permits and drilled 383 wells in the first quarter of 2012.

For consumers, this is of course all very good news. On the other hand, energy companies, lease holders, and counties signing up for the new impact fee are losing money with the low price of gas.

To be sure, there are still plenty of leaseholders taking home plenty of dollars:


Reported Gas production from Marcellus wells: July to December 2011. Please click the compass rose and double carat (^) to hide those menus.

The map above was designed to show wells that would make less than $1,000 (blue); $1,000 to $10,000 (orange); and $10,000 and above (purple) in leaseholder royalties over a six month period, assuming a wellhead price of $2.00 and 12.5 percent royalty (1). At these conditions, of the 2,257 Marcellus wells reporting production for the last half of 2011, 1,651 would have yielded royalty checks over $10,000, and 104 wells would have yielded less than $1,000.

Can Non-Productive Wells Be Avoided?

While there is widespread disagreement about many issues surrounding the Marcellus Shale in Pennsylvania, it is in nobody’s best interest to drill and stimulate wells that are not going to be productive. The question is, can drilling of relatively unproductive wells be avoided? These data don’t provide a difinitive answer to that, but do show how variable production returns can be, even on a local scale:


Production from Marcellus wells in southwestern Pennsylvania from July to December 2011, by municipality and well.

This map shows communities where very large amounts of gas are produced (dark red) adjacent to those where no gas is produced at all. And even within those dark red municipalities, there is considerable variability between the wells themselves. In Cumberland Township, Greene County, for example, there are two adjacent wells that each produced more than 600,000 Mcf in the reporting period, but less than a third of a mile to the north is another Marcellus well that produced only 7,383 Mcf (2).

For all the analysis that doubtlessly goes into placing the wells, the gas yields seem highly variable, even at very short distances.

  1. Just to be clear, the production numbers from these wells were from late 2011, when the wellhead price of gas was well above $2.00. The purpose of this map is to give a general idea of what royalties on $2.00 gas would look like in Pennsylvania’s Marcellus.
  2. I’m not going to claim that this result is typical without doing any spatial analysis, but it can be considered as anecdotal evidence of variability, in conjunction with the distributions visible on the map above.
Matt Kelso, BA

Interest in West Virginia’s Marcellus Now Focused on North

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If you look at the overall map of Marcellus Shale permits in West Virginia, it seems to be a topic of concern for most of the state. Looking at the map below of data obtained by the West Virginia Department of Environmental Protection (WVDEP) Oil and Gas Dataviewer, it isn’t surprising to note that such permits have been issued in 46 out of 55 counties in the Mountain State (1):

WV Marcellus Permits Issued: 2005 to 3-2012 (large)
Marcellus Shale permits issued in West Virginia from 2005 to 3-20-2012

I was curious to see how the distribution looked over time, and was surprised to notice a pronounced contraction of the area of interest:


Marcellus Shale permits issued in WV by year

West Virginia Marcellus Shale permits issued by year, showing data by county and average latitude and longitude of each permitted location. Click image to view full size PDF.

While the majority of the state has been explored over the past seven years, the entire southwestern portion has been abandoned in terms of the Marcellus Shale (2), and the average latitude and longitude of all permits issued in 2011 is less than 20 miles from the Pennsylvania border.

To illustrate the trend, let’s take a closer look at Kanawha County, which is the most southwestern county with any shade of blue in the 2011 map.  In 2007 and 2008, it led the way among all West Virginia counties with 29 and 48 permits issued, respectively, and the average permitted location was just one county to the northeast.  Three years later, the number of new permits in Kanawha had dwindled to just one.

In contrast, Marshall County (the southernmost county in the panhandle) and Wetzel County (just to the south of Marshall) generated very little interest in the early exploration of West Virginia’s Marcellus Shale hydrocarbons, but by 2011, they were the top two counties in terms of permits issued.

This all begs the question of why the southwestern portion of the state is abandoned.  While I don’t have access to production data, I assume that wells that were drilled in that area yielded disappointing returns on industry investments, or else efforts to extract resources would have continued.  A colleague noted that the abandoned territory also happens to be the heart of West Virginia’s coal country, so perhaps there was some interference between the two extractive industries.  This could be a contributing factor, but it is difficult to imagine a situation in which drillers would totally cede an eight county area to miners without massive compensation.

Lacking further data, it may not be possible to know the full story of what happened between 2008 and 2011 in southwestern West Virginia.  But there is one thing that we know for sure:  for all intents and purposes, the recoverable portion of the Marcellus Shale is smaller than we used to think.

  1. The WVDEP data is fairly sloppy, as some of the permitted locations are actually in adjacent states, and 373 of the 2472 records downloaded (15 percent) on 3-20-2012 lacked permit issue dates. It is possible that these dates could be obtained from the alternative data source of https://apps.dep.wv.gov/oog/permitsearch_new.cfm. The Oil and Gas Dataviewer was preferred because it was possible to select for permits issued, and because the location data were in longitude and latitude rather than universal transverse Mercator.
  2. County data is not included in the original data, but it is encoded in the well API number.  Of necessity, the entries without permit issue dates were omitted from this analysis.
Matt Kelso, BA

Where Does the Waste From PA’s Marcellus Wells Go?

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A new dataset has been added to FracTracker’s DataTool which aggregates the waste produced by Marcellus Shale wells in Pennsylvania in the last half of 2011 by the facilities that receive them. And while all of this waste was produced within the Commonwealth, the waste products are disposed of over a wide geographical area, spanning six states:


Note: Due to a change in FracTracker’s mapping utility, data from the last half of 2011 has been replaced by data from the first half of 2013 in the map above.  Please press the expanding arrows icon in the top-right corner of the map to access full controls.

One can only guess at the business decisions involved with the shipping of large quantities of waste from Pennsylvania to eastern New Jersey or southern West Virginia. In other shale plays, the majority of waste is disposed of through deep well injections nearby, but it has long been known that Pennsylvania’s geology is unsuitable for these wells (see page 67 of this 2009 report, for example). And the 4.0 New Year’s Eve temblor near caused by waste fluid injection near Youngstown, Ohio has residents and officials in the Buckeye State thinking much the same.


State receiving Pennsylvania Marcellus Shale waste produced from July to December 2011

In the chart above, solid waste is measured in tons while liquid waste is measured in barrels. In terms of solid waste, the majority–218,000 tons–is actually shipped out of state.  On the other hand, most of the liquid waste is dealt with in Pennsylvania (15.1 million barrels), but the 1.7 million barrels sent to Ohio is certainly significant. The 3.5 million barrels sent to an “unspecified location” is actually good news: the vast majority of that is recycled for use in subsequent wells. Not only does this give operators something constructive to do with the waste they produce, it also helps preserve fresh water resources in the region by offsetting water withdrawals.   Here is the same data arranged to show the various methods of disposal:


PA Marcellus Shale waste disposal by method, July-December 2011

While the recycling efforts are starting to make a dent in the overall picture of how Pennsylvania handles its Marcellus Shale waste fluids, it still far from being the primary means of disposal. In fact, two thirds of the liquid waste produced is still being treated at brine and industrial waste facilities, which have a questionable ability to remove total dissolved solids, heavy metals, and other contaminants from waste water, which ultimately works its way back into Pennsylvania’s rivers and streams.

Karen Edelstein

NY Local Land Use Laws Upheld in Challenges to Municipal Drilling Prohibitions

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Karen Edelstein, NYS FracTracker Liaison

Click to enlarge map

New York State has had a long history of natural gas drilling. The earliest gas wells were drilled in Fredonia, NY in 1825, and by 1857, engineers had discovered that if they fractured rock layers at the base of a gas well, the process stimulated greater flow of gas from the rock strata. Natural gas has been a common source of fuel for both heat and lighting for many years, and many rural properties in central and western New York have been leased and drilled. The New York State Department of Environmental Conservation lists nearly 40,000 wells in their database. While slightly fewer than half of those wells are now plugged and abandoned, many are still in production. Virtually all of these wells are vertical, conventionally drilled gas wells.

In around 2005, a new wave of gas leasing began in New York State. Companies conducted seismic testing throughout the rural countryside, with “thumper trucks” moving in slow formations along town roads, and helicopters canvassing the region dropping their cargoes of cables that were unrolled across fields and forests to aid in further assessment. Simultaneously, “landsmen”—hired by the gas industries—were going door-to-door, offering leasing deals to homeowners. Promoting a rationale of “energy independence” and appealing signing bonuses, the landsmen were successful in convincing tens of thousands of rural New Yorkers to lease their land for natural gas. With a history of conventional, vertical gas drilling in the area, many landowners did not consider asking an attorney to review the new leases. Furthermore, no mention was made of the recently-developed process of gas extraction: high volume, slickwater, horizontal hydraulic fracturing (HVHF), a technique that industry would want to use for natural gas extraction in the Marcellus Shale.

As awareness about the new extraction process, combining high volume, chemically-enhanced, hydraulic fracturing with horizontal drilling, began to spread among New York State communities, local decision-makers and citizen groups became concerned about risks inherent to the method. Troubling stories of polluted air and drinking water, impacts to human- and livestock health, and economic and social woes connected with rapid industrialization of rural communities spread from Pennsylvania, Colorado, Texas, and Wyoming, where HVHF was well underway.

Yet in New York State, the Department of Environmental Conservation (DEC) houses divisions that potentially work at cross-purposes with each other — one making laws that encourage mineral extraction, and the other that is supposed to oversee protection of land and water resources. Concerned citizens also became aware that changes to the Clean Air and Clean Water Acts, promulgated during the recent Bush administration, now exempted oil and gas drilling. Would there be any legal means of standing up against potentially disastrous industrialization of our rural landscape?

Investigative journalists including Ian Urbina (New York Times) and Abram Lustgarten (ProPublica) published hard-hitting articles that time and again confirmed that New York had a lot to be concerned about if wide-spread HVHF were to come to our state. Scientists stepped forward with additional information that the DEC had not supplied in their draft environmental impact statements. Citizen committees formed to discuss both the science and the social implications of allowing wide-spread gas drilling in our communities.

New York State’s Department of Environmental Conservation laws prevent local governments from regulating oil and gas development. However, home rule rights are also accorded to local governments. While, by law, municipalities cannot regulate industry, many attorneys are now arguing that towns can, on behalf of the health and well-being of their constituents, determine land use laws through zoning and other ordinances. Some of these land use laws may result in effectively banning activities such as HVHF in those towns.

The towns of Dryden (in Tompkins County, NY), and Middlefield (in Otsego County, NY) were two of more than twenty towns that put laws in place in the past year that banned HVHF. In the fall of 2011, Denver-based Anschutz Exploration Corporation sued the Town of Dryden, saying that state laws allowing for drilling pre-empted municipal laws. On February 21, 2012, State Supreme Court Judge Rumsey upheld Dryden’s right to set their own zoning regulations against HVHF stating, “Nowhere in legislative history provided to the court is there any suggestion that the Legislature intended — as argued by Anschutz — to encourage the maximum ultimate recovery of oil and gas regardless of other considerations, or to preempt local zoning authority.”

In Otsego County, the situation was slightly different. A local dairy farmer, who had leased her land sued the Town of Middlefield, asserting that the Town’s ban prevented her from enjoying the full value of her property. Just a week following the Dryden decision, a different judge ruled in the Middlefield case, and decided in favor of the town. Because drilling had not yet begun, the situation could not be considered a “takings.” The judge felt that while New York State can dictate (through regulations) how any industry operates, it is up to the town to decide where those industrial activities may take place.

Until the cases are heard in the Court of Appeals, these decisions stand as the opinion of the courts, but it is possible that there will be additional suits in the lower courts before a final decision is reached that will set the standard statewide. Nonetheless, the Dryden and Middlefield decisions clearly show that the lower courts support local community rights.

Although lawsuits are costly, the towns’ legal efforts have been supplemented by organizations that support the bans, and their costs have been reduced through the generous support of ordinary people. The prospect of additional suits has not deterred New York State’s municipalities from passing bans and moratoria preventing HVHF. To date, 21 towns have established bans, and more than 50 towns have enacted moratoria. Nearly 60 additional towns are in the process of developing bans or moratoria. See below for a map-in-progress within Data.FracTracker.org of the areas where bans and moratoria are in place or in development:

Progress of New York State towns enacting home rule to control impacts of high volume hydraulic fracturing for natural gas:

Matt Kelso, BA

Oil and Gas Production and Waste Reports Available

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Oil and gas production and waste reports for 2011 are now available for download at the PADEP Office of Oil and Gas Management website, and the Marcellus shale portion of that is now available on FracTracker’s DataTool as well:


Marcellus Shale production from July to December 2011. Click the gray compass rose and double carat to hide those fields.

The third dataset contains the production and waste data aggregated by county, as in the following chart:

Keep in mind that these totals are self-reported by drilling operators to the DEP.  Marcellus Shale waste and production data are released every six months, while non-Marcellus Shale data is released annually.  The following non Marcellus shale datasets are also available:

Statewide Production Totals

The following chart includes statewide production totals for 2011:

So Pennsylvania joins the trillion cubic foot (Tcf) club with 1.2 Tcf of natural gas produced, more than doubling the 2010 dry production value, according to the US Energy Information Administration (EIA).  The EIA does not yet have state values for 2011 posted, but Pennsylvania’s 2011 total would have ranked eighth in 2010 behind  Texas (6.3 Tcf); Federal Offshore Gulf of Mexico (2.2 Tcf); Wyoming (2.2 Tcf); Louisiana (2.1 Tcf); Oklahoma (1.7 Tcf); Colorado (1.5 Tcf) and New Mexico (1.2 Tcf) for dry gas production.

Here is the reported waste for 2011:

Stay tuned to FracTracker for more analyses of these reports in the coming days and weeks.

Matt Kelso, BA

“Administrative” Violations Should not be Dismissed

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Last night, I queried the Oil and Gas Compliance Report wizard the PADEP website for Marcellus Shale violations from 2005 through February 15, 2012. The resulting document contained 4,072 rows of data, which as tallied by the DEP includes 3,497 violations, and 976 enforcement actions.

For an industry that would like to convince us that it is producing safe and clean energy, these numbers are pretty big. When presented with numbers like this, I hear the following refutation with surprising frequency:  “Most of those are administrative violations.  It’s just paperwork.”


Administrative and Environmental Health and Safety Violations for MS Wells in PA by Year(1)

So about 58 percent of the total number of violations are indeed categorized as administrative, which is a significant majority of all the Marcellus Shale violations in Pennsylvania (1).  And yet, this is merely an observation, not an effective counterpoint to the  argument that there sure are a lot of violations associated with this industry.  This is doubly true when trying to address the fact that some operators have a better culture of compliance than others.  If we were to take the leap that many have that administrative violations amount to paperwork, shouldn’t they be easy to avoid?  If a drilling operator in this multi-billion dollar industry wanted to convey respect for Pennsylvania’s laws, wouldn’t adequate paperwork be a good place to start?

But if you take a closer look at the administrative data, the paperwork argument itself begins to fall into disarray. To date, there have been 59 violation codes used under the administrative category.  Let’s take a closer look at the 15 of those which have been cited most frequently:


15 most frequent administrative violations for Marcellus Shale wells in PA

And here is the color key for the chart above:

The two most frequent administrative violations cited are so vague that they are practically meaningless for our purposes.  With many of the rest of the categories, it is possible to argue that they are fundamentally administrative or fundamentally environmental, health and safety in nature.  Obviously, these are my interpretations, but I think that in general, categories in green seem to be matters of procedure while categories in red reflect actual problems in the field.

Not only are there more administrative violations in the red category than the green, but the truly administrative violations are also important.  If something goes wrong at the well site and the operator cannot be contacted because they didn’t post the required signage, that is a problem.  If there are insufficient plans for dealing with erosion and sedimentation, that’s a problem.  If such plans exist, but they aren’t on site where the workers can access them, that’s a problem too.

Before laying the “it’s just paperwork” argument to rest, let’s take a look at the exchange of paper with pictures of presidents’ faces on them:


PADEP fines for Marcellus Shale wells, sorted by violation type

Yikes! Once we recover from the fact that the aggregate fine totals are trending sharply downward (3), the question that we were trying to address is pretty obvious: more fines are assessed for violations categorized as administrative than for environmental health and safety ones.  All together, almost 63 percent of the $22 million in DEP fines for Marcellus Shale wells have been for “administrative” violations.

So can we please dispense with the notion that “it’s just paperwork”?

  1. Astute readers will note:
    A) There is a value for 2001, when data was queried from 2005 onward. Clearly, this reflects an input error in the violation issue date.
    B) There are 4,080 records being accounted for, which doesn’t equal any of the three numbers above. Here then is the story of this data….There are indeed 3,497 unique violation ID numbers, but some of these are used to address more than one concern, which explains the 4,072 rows. The original data did not contain location information, so I merged that data with permit data, using the API number for a match. This resulted in 4,732 records, as there are often more than one entry for a single API in the permit data. Therefore, I took the results and removed duplicate lines, the result of which was 4,080 records.
  2. However, if we look at data from 2011 on, we see that there are more Environmental Health and Safety violations than Administrative ones.
  3. There is often a considerable latency period between the incident and when the fine is issued, especially for high profile cases. But still, given the media attention given to oil and gas fines recently, this downward trend is surprising, to say the least.
Approaching 10K Unconventional Wells in PA
Matt Kelso, BA

How Many MS Permits Are There in PA?

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People interested in Pennsylvania’s Marcellus Shale data frequently ask me what they think is a relatively straightforward question: how many drilling permits are there for Marcellus Shale wells in Pennsylvania? As it happens, this is actually a somewhat complicated question, as there are numerous paths to finding the answer, all of which will lead to a different result. Consider, for example:

  • If you go to the Well Permit Workload Report for the week ending 1/20/12, the answer is provided for you: 9,883. But…
  • …if you search the Permits Issued Detail Report using the same end date, you will be given the result since the year 2000 as 9,868.
  • The above item is particularly confusing when you realize that it consists of 11,209 rows of data. No problem, you say, I’ll just use my Excel skills to pivot the data by it’s unique API number, and as of today’s data we’re down to a mere 9,880 (plus two items with the wrong numerical formatting altogether).

So which number is right? In my opinion, none of them. If you follow the API link above, you will see that there are serveral components to the API number, which generally is in the format AB-CDE-FGHIJ-KL-MN, where each letter is represented by a digit ranging from 0 to 9. Here’s what they mean:

  • “AB” represents the state code. In Pennsylvania, the code is “37”, but it is not included on the DEP dataset.
  • “CDE” is the county code, which is alphabetical, and starts at 001. So for example, Allegheny County has a code of 003, since it is near the start of the alphabet, while Washington County is 125, which is near the end.
  • “FGHIJ” is the unique well indicator. In theory, this allows for 100,000 wells per county to each have their own number. If you count the distinct combination of county codes and unique well indicators, there were 8,942 well permits as of 1-20.
  • “KL” indicates the directional sidetrack code. This could represent multiple horizontal components of a well, so there is some wiggle room for argument if you want to consider each horizontal segment to be its own well. I argue against it, as the language talks about there being numerous horizontal components to a well, but for the record if you include it, then the number is 9,638.
  • “MN” represents the event sequence code, which includes modifications to existing wells that also require permit actions. The number of distinct Marcellus Shale permits if you were to include the directional sidetrack and event sequence code would be 9,878 as of the 20th of January.

So…which number is right?  My interpretation of what the code means is that to count the number of wells in any given state, you should include all of the three digit county codes and all of the five digit unique well indicators (or “CDE-FGHIJ”, as described above.)  As of January 20th, that number was 8,942 for Marcellus Shale well permits in Pennsylvania, and as of today, that number is 9,005.

Sometime this year, I expect that the number of total Marcellus Shale permits in Pennsylvania to top the 10,000 mark.  But if that claim comes within the next week or two, my opinion is that it isn’t an accurate representation of the data–even if the claim comes from the DEP itself.

The following charts contain data through the end of January 2012.  The first is based on 11,297 permit actions (or records on the permit report), while the second is classified by unique 8 digit well API numbers.

Matt Kelso, BA

Non Marcellus Shale Horizontal Wells in PA

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Archived

This page has been archived. It is provided for historical reference only.

Did you know that there have been sixty horizontal oil and gas wells drilled in Pennsylvania since 2008 that are not Marcellus Shale wells? Since they are bunched together, I have split them into two separate maps, one for Southwestern Pennsylvania, and another for the northern portions of the state.

Click on the gray compass rose and double carat (^) to hide those menus. For more information on any well, click the “i” button in the blue circle, then any map feature.

[maps removed]

Matt Kelso, BA

Ethylene Cracker Would Contribute Jobs, Air Pollution

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Last year, Shell Chemicals announced its intentions to build a multi-billion dollar ethylene cracker “in Appalachia”, effectively setting the stage for a bidding war between Ohio, West Virginia, and Pennsylvania. There have been numerous other plans for such plants in the area, including a recent partnership trying to get Aither Chemicals catalytic cracking process up in running, once again, “in Appalachia.”  The interest in the region is mostly due to the Marcellus and Utica shale gas produced in the region, which contains mostly methane (so-called natural gas used for heating, cooking, etc.), as well as other hydrocarbons that must be removed from the methane before the gas is put into pipelines.  These other hydrocarbons are mostly ethane, propane, and butane, which are converted into ethylene, propylene, and butadiene, respectively, through a process called cracking, and are then used for the creation of plastics, synthetic rubber, and other petrochemicals.

Whichever state lands these massive facilities stands to gain several thousand temporary construction jobs and several hundred permanent positions at the facility.  It seems reasonable to take a look at other similar facilities in the country, not only to get a reasonable idea of the economic contribution, but also to gain insight on the facility’s contribution to air pollution in the region.

I have chosen to look at the cracker in Norco, Loisiana, also run by Shell Chemicals. Norco is the ultimate company town, named for the now defunct New Orleans Refining Company, it contains not only the Shell plant, but also major petrochemical facilities owned by Dow, Hexion, and Valero. There is also a presence by Motiva, but all indications are that this is functionally part of the Shell plant that is simply owned by a different company.


Norco, LA as seen from Google Earth

According to the Shell page linked above, the facility employs 600 full time workers and 160 contractors for an annual payroll of $50 million. It also contributes $22 million in state, local, and property taxes to the community. That’s all very significant, albeit a far cry from the 17,000 jobs, $1 billion in wages, and $169 million in tax revenues that the good people of Ohio are being promised–perhaps those figures are over the estimated life of the facility, who knows? I’m guessing the proposed facility in Appalachia won’t be 22 times larger than the one in Norco, Louisiana though.

In terms of air emissions, it is hard to know what to expect. Emissions may wind up being quite different from Norco’s due to a different chemical composition of the feedstock, for example.  However, to get the conversation started, I have compiled the EPA’s 2008 National Emissions Inventory (NEI) estimated emissions for Norco, as well as a well known polluter that’s already in the area, Clairton Coke Works. I should mention that based on my experience, I don’t have a lot of faith of the validity of NEI data, especially for data in Pennsylvania (see this discussion about Clairton, for example), but it is what’s available.  Also, I need to mention that the data for Shell is aggregated between the Norco East, Norco West, and Motiva facilities, because from looking at the the websites for Shell and Motiva, the whole operation seems to be focused around cracking.  Let’s take a look:


2008 USEPA National Emissions Inventory for the Coke Works in Clairton, PA and the Shell ethylene cracker in Norco, LA

Now before you go to the EPA site to research these 84 pollutants, I didn’t put these up for direct comparison, since the facilities are obviously quite different. The point is that in an area that still largely in nonattainment for fine particulate matter and just recently re-entering attainment for ozone, the prospect of adding another major emitter of particulates and ozone and particulate precursors (as well as a whole host of other junk) isn’t going to help.