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Piecing together the ethane cracker - Graphic by Sophie Riedel

Piecing Together an Ethane Cracker

How fragmented approvals and infrastructure favor petrochemical development

By Leann Leiter and Lisa Graves-Marcucci

Let’s think back to 2009, when oil and gas companies like Range Resources began drilling the northeast shale plays in earnest. Picture the various stages involved in drilling – such as leasing of land, clearing of trees, boring of wells, siting of compressor stations, and construction of pipelines to gather the gas. Envision the geographic scope of the gas infrastructure, with thousands of wells in Pennsylvania alone, and thousands of miles of pipelines stretching as far as Louisiana.

Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter.

Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter

Now, picture the present, where a homeowner looks out over her yard and wonders how a lease she signed with Shell several years prior made it possible for the company to run an ethane pipeline across her property and between her house and her garage.

Think forward in time, to 2022, the year when a world-scale ethane cracker is set to go online in Beaver County, Pennsylvania, to begin churning through natural gas liquids from wells in PA and others, producing a variety of disposable plastic products.

At each of these moments in gas development, which of the many stakeholders – industry leaders, local governments, state regulatory agencies, or landowners and residents – were granted a view of the full picture?

The proposed Shell ethane cracker in Beaver County is an illustration of the fragmented nature of gas development. From the extensive web of drilling infrastructure required to supply this massive facility, to several years of construction, this project is a case-study in piecemeal permitting. Such fragmentation creates a serious barrier to transparency and to the informed decision-making that relies upon it.

In the first two articles in this series on the petrochemical development in Beaver County, we focused on ethane cracker emergency scenarios and how the area might prepare. In this article, we draw the lens back to take in the larger picture of this region-altering project and highlight the effects of limited transparency.

The “Piecemeal” Nature of Gas Development

All across the Pennsylvania, proposed industrial development – even coal operations – have historically provided to the public, elected officials, and regulatory agencies the extent or footprint of their planned operations. Nonetheless, the oil and gas industry has in several instances undertaken a practice of developing its extensive infrastructure piece-by-piece. Operators of these facilities first acquire a GP-5 General Permit, which is only available to certain oil and gas operations with “minor” emissions and which allows them to avoid having the permit undergo public notice or comment. These operators then add emissions sources and increases through a series of minor amendments. While they are required to obtain a “major” source permit once their modifications result in major emissions, they avoid the scrutiny required for a major source by this fragmented process.

Unlike most other industrial permitting, the gas industry has enjoyed a much less transparent process. Instead of presenting their entire planned operation at the time of initial permit application, gas operators having been seeking – and receiving – incremental permits in a piecemeal fashion. This process puts local decision makers and the women, men, and children who live, work, and go to school near gas development at a severe disadvantage in the following ways:

  • Without full disclosure of the entirety of the planned project, neither regulatory bodies nor the public can conduct a full and factual assessment of land use impacts;
  • Incremental approvals allow for ever-expanding operations, including issuance of permits without additional public notification and participation;
  • Piecemeal approvals allow operations to continuously alter a community and its landscape;
  • The fragmented approval process prevents consideration of cumulative impacts; and
  • Without full transparency of key components of the proposed operations, emergency planning is hampered or non-existent.

From the Well to the Ethane Cracker

In the fragmented approval process of gas development, the proposed ethane cracker in Beaver County represents a pertinent example. Developers of this massive, multi-year, and many-stage project have only revealed the size and scope in a piecemeal fashion, quietly making inroads on the project (like securing land leases along the route of the pipeline required for the cracker, years in advance of permit approvals for the facility itself). By rolling out each piece over several years, the entirety of the petrochemical project only becomes clear in retrospect.

A World-Scale Petrochemical Hub

While Shell is still pursuing key approval from the PA Department of Environmental Protection, industry leaders treat the ethane cracker as a foregone conclusion, promising that this facility is but one step in turning the area into a “petrochemical hub.”

The cracker facility, alone, will push existing air pollution levels further beyond their already health-threatening state. Abundant vacant parcels around Shell’s cracker site are attractive sites for additional spin-off petrochemical facilities in the coming “new industry cluster.” These facilities would add their own risks to the equation, including yet-unknown chemical outputs emitted into the air and their resulting cumulative impacts. Likewise, disaster risks associated with the ethane cracker remain unclear, because in the piecemeal permitting process, the industry is not required to submit Preparedness, Prevention, and Contingency (PPC) Plans until after receiving approval to build.

Figure 2: Visualization shows a portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh's Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 "Annual Report of Natural Gas and Supplemental Gas Supply and Disposition," 2007.

Figure 2. A portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh’s Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.

92.3 Miles of Explosive Pipeline

More than just a major local expansion, communities downriver and downwind will be susceptible to the impacts, including major land disturbance, emissions, and the potential for “incidents,” including explosion. The pipeline required to feed the cracker with highly flammable, explosive ethane would tie the tri-state region into the equation, expanding the zone of risk into Ohio and crossing through West Virginia.

Figure 3: The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP.

Figure 3. The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP

Renewed Demand at the Wellhead

No one piece of the gas infrastructure stands alone; all work in tandem. According to the  Energy Information Administration (EIA), the new US ethane crackers will drive consumption of ethane up by a 26% by the end of 2018. Gas wells in the northeast already supply ethane; new ethane crackers in the region introduce a way to profit from this by-product of harvesting methane without piping it to the Gulf Coast. How this renewed demand for ethane will play out at fracked wells will be the result of complex variables, but it will undoubtedly continue to drive demand at Pennsylvania’s 10,000 existing unconventional oil and gas wells and those of other states, and may promote bringing new ones online.

quote-from-petchem-report

Figure 4. Excerpt from Executive Summary of IHS Markit Report, “Prospects to Enhance Pennsylvania’s Opportunities in Petrochemical Manufacturing.”

Along with drilling comes a growing network of gathering and transmission lines, which add to the existing 88,000 miles of natural gas pipeline in Pennsylvania alone, fragment wildlife habitat, and put people at risk from leaks and explosions. Facilities along the supply stream that add their own pollution and risks include pump stations along the route and the three cryogenic facilities at the starting points of the Falcon Pipeline (see Fig. 6).

Figure 4: Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter.

Figure 5. Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter

The infrastructure investment required for ethane crackers in this region could reach $3.7 billion in processing facilities, pipelines for transmitting natural gas liquids including ethane, and storage facilities. A report commissioned by Team Pennsylvania and the PA Department of Community and Economic Development asserts that “the significant feedstock and transportation infrastructure required” will “exceed what is typically required for a similar facility” in the Gulf Coast petrochemical hub, indicating a scale of petrochemical development that rivals that of the southern states. This begs the question of how the health impacts in Pennsylvania will compare to those in the Gulf Coast’s “Cancer Alley.”

Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP.

Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP

Water Impacts, from the Ohio River to the Arctic Ocean

Shell’s facility is only one of the ethane crackers proposed for the region that, once operational, would be permitted to discharge waste into the already-beleaguered Ohio River. This waterway, which traverses six separate states, supplies the drinking water for over 3 million people. Extending the potential water impact even further, the primary product of the Shell facility is plastics, whose inevitable disposal would unnecessarily add to the glut of plastic waste entering our oceans. Plastic is accumulating at the alarming rate of 3,500 pieces a day on one island in the South Pacific and as far away as the waters of the Arctic.

Figure 7: View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.

Figure 7. View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.

How does fragmentation favor industry?

The gas and petrochemical industry would likely defend the logistical flexibility the piecemeal process affords them, allowing them to tackle projects, make investments, and involve new players as needed overtime. But in what other ways do the incredibly fragmented approval processes, and the limited requirements on transparency, favor companies like Shell and their region-changing petrochemical projects? And what effect does the absence of full transparency have on local communities like those in Beaver County? We conclude that it:

  • “Divides and conquers” the region. The piecemeal approach to gas development, and major projects like the Shell ethane cracker, deny any sense of solidarity between the people along the pipeline route resisting these potentially explosive channels cutting through their yards, and residents of Beaver County who fear the cracker’s emissions that will surround their homes.
  • Makes the project seem a foregone conclusion, putting pressure on others to approve. For example, before Shell formally announced its intention to build the facility in Potter Township, it rerouted a state-owned road to facilitate construction and increased traffic flow. Likewise, though a key permit is still outstanding with the PA DEP, first responders, including local volunteer firefighters, have already begun dedicating their uncompensated time to training with Shell. While this is a positive step from a preparedness standpoint, it is one of many displays of confidence by Shell that the cracker is a done deal.
  • Puts major decisions in the hands of those with limited resources to carry them out and who do not represent the region to be affected. In the case of the Shell ethane cracker, three township supervisors in Potter Township granted approvals for the project. The impacts, however, extend well beyond Potter or even Beaver county and include major air impacts for Allegheny County and the Pittsburgh area. Effects will also be felt by landowners and residents in numerous counties and two states along the pipeline route, those near cryogenic facilities in Ohio and Pennsylvania, plus those living on the Marcellus and Utica shale plays who will see gas well production continue and potentially increase.


Figures 8a and 8b. Potter Township Supervisors give the go-ahead to draft approval of Shell’s proposed ethane cracker at a January meeting, while confronted with public concern about deficiencies in Shell’s permit applications. Photos courtesy of the Air Quality Collaborative.

Fragmented Transparency, Compromised Decision-making

The piecemeal, incremental, and fragmented approval processes for the ethane cracker – and other gas-related facilities in the making – create one major problem. They make it nearly impossible for locals, elected officials, and regulatory agencies to see the whole picture as they make decisions. The bit-by-bit approach to gas development amounts to far-reaching development with irreversible impacts to environmental and human health.

We ask readers, as they contemplate the impacts closest to them – be it a fracked well, a hazardous cryogenic facility, the heavily polluted Ohio River, a swath of land taken up for the pipeline’s right-of-way, or Shell’s ethane cracker itself – to insist that they, their elected officials, and regulators have access to the whole picture before approvals are granted. It’s hard to do with a project so enormous and far-reaching, but essential because the picture includes so many of us.

Sincere Appreciation

To The International League of Conservation Photographers, The Ohio Environmental Council, and The Air Quality Collaborative for sharing photographs.

To Sophie Riedel for sharing her visualizations of natural gas interstate pipelines.

To Lisa Hallowell at the Environmental Integrity Project, and Samantha Rubright and Kirk Jalbert at FracTracker, for their review of and and invaluable contributions to this series.

Wayne National Forest map and drilling

Wayne National Forest Could Be Deforested – Again

Guest article by Becca Pollard

Eighty years ago, Southeastern Ohio was a wasteland of barren, eroding hills. During the 18th and 19th centuries this once heavily forested area in the Appalachian foothills had been clear cut and mined beyond recognition. When the Great Depression struck, lowering crop prices made farming unprofitable in the area, and 40% of the population moved away.

In 1933, President Franklin Delano Roosevelt established the Civilian Conservation Corps (CCC), a public work relief program that employed men aged 18-25 to do manual labor related to conservation and development of natural resources such as planting trees, constructing trails, roads, and lodges, fighting wildfires, and controlling erosion. The following year, Ohio’s legislature agreed to allow the federal government to purchase land in the state for the purpose of establishing a national forest. The Forest Service was tasked with restoring the land for what is now called Wayne National Forest (WNF). A tree nursery was established near Chillicothe, and with the help of the CCC and volunteers, including members of the Daughters of the American Revolution, garden clubs, and school children, reforestation began.

Photos Credit: US Forest Service

An Area on the Mend

Today, WNF comprises three units that span 12 Ohio counties in the Unglaciated Allegheny Plateau. The hills are covered in biologically diverse mixed mesophytic forest, which includes approximately 120 species of trees and provides habitat for at least 45 species of mammals, 158 species of birds, 28 species of reptiles, 29 species of amphibians, and 87 species of fish. The US Forest Service estimates that 240,000 people visit this ecological wonder annually, according to Forest Recreation Program Manager, Chad Wilberger, in Nelsonville, Ohio. The restoration of barren public land to its current state is a great achievement. If it continues to be protected, Wayne could one day resemble the old growth forest that thrived here before the arrival of European settlers.

The Bureau of Land Management (BLM), however, has recently decided to lease up to 40,000 acres of Wayne to gas and oil companies for horizontal hydraulic fracturing, or fracking. The first auction took place last December resulting in the lease of 700 acres. A second auction this March leased another 1,200 acres. Nearly all of this land lies within the 60,000 acre Marietta Unit of the forest. This brings Oil & Gas Expressions of Interest (EOI) acreage to roughly 7.5% of all WNF owned parcels in this unit.

Wayne National Forest and Adjacent Existing Oil and Gas Infrastructure
Below is a map of the Wayne National Forest, along with parcels owned by WNF (shown in gray) and those that might be subject to unconventional oil and gas development (gray parcels outlined with dashes). We also include existing unconventional oil and gas infrastructure near the park. Explore the map below, or click here to view the map fullscreen.


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Not new, not old

Gas and oil development is not new to the Wayne. Since the passage of The Federal Land Policy and Management Act of 1976, the US Forest Service’s land management plan for WNF has included conventional drilling, and derricks are a common sight on both public and private land in southeastern Ohio.

Fracking (unconventional drilling), however, has a far greater impact, requiring clear cutting of large areas of land for the construction of concrete well pads, and the use of millions of gallons of water that will become contaminated during the process and then transported by truck to injection wells. Accidents can be catastrophic for workers and nearby residents, and fracking and waste water disposal have been linked to earthquakes in Ohio.

In 2012, BLM updated its WNF Land and Resource Management Plan to allow fracking in the forest without conducting new impact studies.

What is at risk?

The Marietta Unit of the WNF is located in Monroe, Perry, and Washington counties in Southeastern Ohio along the Ohio River. Within its boundary are a wealth of trails used for hiking, backpacking, horseback riding, and mountain biking, campgrounds, and waterways ideal for kayaking and fishing. Both the highest and lowest points in the Wayne lie in this unit, as does the Irish Run Natural Bridge. The area is also known for its exceptional wildflowers, as shown in the photos below.

One popular recreation area, Lamping Homestead, lies directly within an oil and gas Expression Of Interest (EOI) parcel #3040602400 (See Map Above), one of the areas under consideration for lease. In the 1800s, it was the site of the Lamping family’s farm, but today all that remains of the settlers is a small cemetery with an iron gate atop a hill overlooking a small lake. Six campsites are situated around the western side of the lake, and two intersecting hiking loops rise into the wooded hills to the east. On the western side of the parking lot is a covered picnic area. A creek flows out of the lake and into Clear Fork, a tributary of the Little Muskingum River, across the road from the parking lot.

Both the lake and stream are popular boating and fishing areas. Lamping is an excellent spot for wildlife viewing. The lake, the creeks that flow in and out of it, and the surrounding wooded hills support an impressive variety of plant and animal species. During the day, visitors might spot ducks, geese, great blue herons, red-winged blackbirds, summer tanagers, red spotted newts, box turtles, northern water snakes, garter snakes, deer, rabbits, and muskrats. At night, they could be greeted by a cacophony of voices from frogs, owls, and coyotes.

Species of trees, plants, and fungus are also numerous. In winter, stands of white pine pop out against the bare branches of oak, hickory, maple, buckeye, and other deciduous trees. In spring, eye-catching splotches of blooming dogwood and redbud contrast against the many shades of green. But hikers who pull their gaze away from the brightly colored canopy and look down are rewarded with an abundance of wildflowers and the butterflies they attract, as well as many varieties of mushrooms and fungus, including such edible varieties as morels, wood ear, and dryad’s saddle.

Estimating Disturbances

It is unclear how much surface disturbance would occur on public land if this parcel were to be fracked, but even if the well pad and pipelines were constructed on private land adjacent to the forest, in order to drill under the forest, the public land and its inhabitants and visitors would certainly be impacted.

There is no question that noise and air pollution from traffic and construction would be disruptive both to wildlife and to human visitors. Explore various photos of the oil and gas industry in the gallery below:

The extraction process requires 2 million to 6 million gallons of fresh water each time a well is fracked. The rate at which hydraulic fracturing’s water demand is increasing on a per-well basis here in Ohio reached an exponential state around Q4-2013 and Q1-2014 and continues to rise at a rate of 3.1 million gallons per well per year (Figure 1).

Ohio Hydraulic Fracturing Total and Per Well Freshwater Demand between Q3-2010 and Q3-2016.

Ohio Hydraulic Fracturing Total and Per Well Freshwater Demand between Q3-2010 and Q3-2016.

In Ohio, oil and gas companies are allowed to pull this water directly from streams and rivers at no cost. All this is possible, despite the fact that after its use it is so contaminated that it must be disposed of via injection wells and is permanently removed from the water cycle. The industry is already pulling water from streams in the Marietta Unit of the WNF for use in fracking on private land. Fracking public land simply means water withdrawals will occur on a much larger scale.

Ohio and West Virginia Shale Water Demand and Injection Waste Disposal
This map shows Utica wells weighted by water demand and disposal (and/or production). It also depicts water, sand, and chemical usage as well as injection waste and oil production. Explore the map below, or click here to view map fullscreen.


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Inevitable methane leaks, in addition to contributing to climate change, affect humans and wildlife in their immediate vicinity, causing headaches and nausea and even killing trees and plants.

In addition to the anticipated harm that fracking inflicts upon a natural area, there is also a risk of accidents with potentially devastating consequences. Residents of Monroe County have already seen a few in recent years from fracking on private land. In 2014, a well pad fire in the village of Clarington resulted in a chemical spill that contaminated nearby Opossum Creek, killing 70,000 fish. The same year a large gas leak 15 miles south in the village of Sardis resulted in the evacuation of all homes within half mile radius.

Recent studies have shown that extraction wells, in addition to injection wells, can cause earthquakes. Unsurprisingly, Monroe County has seen a spike in seismic activity with the increase in fracking activity in the area. The most recent incident was a 3.0 magnitude earthquake in the forest less than five miles from Lamping Homestead in April of this year.

Supporters of Wayne National Forest

Many people have repeatedly spoken out against BLM’s plan, submitting a petition with more than 100,000 signatures, and protesting outside Wayne National Forest Headquarters and Athens Ranger Station in Nelsonville. They have even organized voters to call and write letters to Regional Forester Kathleen Atkinson and legislators, including Senators Sherrod Brown and Rob Portman, and Governor John Kasich. BLM has not budged on its decision, unfortunately, insisting that leasing this land for fracking, and associated infrastructure buildout, will have “no significant impact.”

This May, the Center for Biological Diversity, Ohio Environmental Council, Ohio Sierra Club, and Heartwood, a regional organization focused on protecting forests, filed a lawsuit against BLM, aiming to void BLM leases and halt all fracking operations within the national forest.

Concerned citizens continue to organize raise awareness as they await the outcome of the suit.

Becca Pollard is Freelance Journalist and Co-founder of Keep Wayne Wild


Data Downloads

Click on the links below to download the data used to create this article’s maps:

Underground Gas Storage map by Drew Michanowicz

Underground Gas Storage Wells – An Invisible Risk in the Natural Gas Supply Chain

The largest accidental release of methane in U.S. history began October 23, 2015 with the blowout of an underground natural gas storage well in Aliso Canyon about 20 miles west of Los Angeles. By the time the well was plugged 112 days later, more than 5.0 billion cubic feet of methane and other pollutants had been released to the atmosphere. It was a disaster for the climate, the environment, California’s energy supply, and the more than 11,000 people that were forced to evacuate.

A new study from the Harvard T. H. Chan School of Public Health – Center for Health and the Global Environment shows that more than one in five of the almost 15,000 active underground gas storage (UGS) wells in the US could be vulnerable to serious leaks due to obsolete well designs – similar in design to the well that failed at the Aliso Canyon storage facility.

Published today in the journal Environmental Research Letters, the study presents a national baseline assessment of underground storage wells in the U.S. and indicates the need for a better understanding of the risks associated with the obsolescence of aging storage wells. The study also highlights the widespread nature of certain age-related risk factors, but indicates that some of the highest priority wells may be located in PA, OH, NY, and WV.

The study shows that the average construction year of largely unregulated active UGS wells in the US is 1963, with potentially obsolete wells that were not originally designed for storage operating in 160 facilities across 19 states. Some of the wells were constructed over 100 years ago – a time period that precedes many modern well containment systems such cement isolation and the use of multiple casings. Some of the oldest active UGS wells were not designed for two-way flow of gas, and therefore may not exhibit sufficient material-grade or redundant precautionary systems to prevent containment loss, as was evident at Aliso Canyon.

An Interview with the Author

Sam, Matt, and Kyle of FracTracker caught up with lead author and former FracTracker colleague, Dr. Drew Michanowicz, now with the Center for Health and Global Environment within the Harvard T. H. Chan School of Public Health to find out more about their study.

When we spoke with Drew, he began the interview by posing the first question to us:

Did you know that about 15% of the natural gas produced in the US is injected back into the ground each year?

While we had all heard of underground gas storage before, we had to admit that we never thought of the process like that before. In other words, some of the natural gas in the US is being produced twice from two different reservoirs before being consumed. And because many of these storage systems utilized depleted oil and gas reservoirs, many of the same pre- and post-conditioning processes, such as dehydrating and compressing, are necessary to bring the gas to market.

The following questions and answers from Drew expand upon the study’s findings:

Q: What prompted you and your colleagues to investigate this topic?

A: After the Aliso Canyon incident, we became interested in the question: ‘Is Aliso Canyon Unique?’ Interestingly, there were plenty of early warning signs at that facility that corrosion issues on very old repurposed wells were becoming a significant issue. Almost a year before the well blowout, Southern California gas went on record in front of California’s Public Utility Commission stating that they needed a rate increase to implement a necessary integrity management plan for their wells, and to be able to move beyond operating in a reactive mode. That unfortunately prophetic document really got us interested in better understanding why their infrastructure was in the state it was in. And like any major accident like this, a logical next step is to assess the prevalence of hazardous conditions elsewhere in the system, in the hope to prevent the next one.

From our research, it appears that a very large portion of the UGS sector may be facing similar obsolescence issues compared to Aliso, such as decades-old wells not originally designed for two-way flow. Our work here, however, is a simplified assessment that focused only on passive barriers or the fixed structures such as the steel pipes likely present in a well. Much more work is needed to fully understand the active-type safety measures in place such as safety valves, tubing/packers, and overall integrity management plans – all important factors for manage risks.

Q: We see that your team developed a well-level database of over 14,000 active UGS wells across 29 states. Because data-collation is a big part of our work here, can you describe that data collection process?

A: Very early on we also realized that underground gas storage was exempt from the Safe Drinking Water Act’s Underground Injection Control (UIC) program – similar to exemption with hydraulic fracturing and the Energy Policy Act of 2015, AKA the Halliburton Loophole. This meant in part that very little aggregate well data was available from the Federal Government or by third-party aggregators like FracTracker and DrillingInfo. Reminiscent of my former extreme data-paucity days at FracTracker, we knew we needed to build a database basically from scratch to effectively perform a hazard assessment that incorporated a spatial component.

We began by gathering what data we could from the U.S. Energy Information Administration (EIA), which gave us good detail at the field or facility level, but the fields were generalized to a county centroid. So to fully evaluate these infrastructure, we needed to figure out how to join the facility-level data to the well data for each state. We relied on NETL’s Energy Data eXchange to identify state-level wellbore data providers where applicable. Once we collected all of the state data, we created a decision-tree framework to join the individual wells to the EIA field names in order to produce a functional geodatabase. Because we had to manage data from so many sources, we had to devote quite a bit of effort to data QA/QC, and that is reflected in the methods and results of the paper. For example, some of our fields and wells had to be joined via visual inspection of company system maps, because of missing identifier information.

Q: We see that some of the oldest repurposed wells you mapped are located in PA, OH, NY, and WV. Was that a surprise to you?

A: That was a surprise considering this story started for us in California, and even more surprising was that some are more than 100 years old. Now, a bit of caution here is warranted when thinking about the age of any engineered system. On the one hand, something that functions for a very long time is an indication that the system was very well suited for its task, and likely has been very well taken care of – think of an antique automobile like a fully functional 1916 Model T Ford, for example. On the other hand, age and construction year relates to the integrity of an engineered system through two processes by:

  1. providing information to how long a system has been exposed to natural degradation processes such as corrosion, and stresses from thermal and abrasive cycles; and by
  2. proxying for knowledge and regulatory safety standards at the time of construction which informs the design, materials, technologies likely used.

To go back to the car example, while an old classic car may still be operational, it may not have certain safety features like antilock brakes, airbags, or safety belts, and generally will not be able to go as fast as a modern car. Therefore, a gas storage well’s integrity is at least indirectly related to its construction year when considering the multitude of technological and safety improvements have occurred over the years. This is how we have been thinking about well integrity from a 5,000 foot perspective. Needless to say, more research is needed to understand the causal effect of age on well integrity.

Q: So if we understand you correctly, these older wells can be maintained with sufficient management practices, but there may be inherent safety features missing on these older wells that don’t adhere to todays’ standards?

A: That’s right. So what we can say about some of these aging wells is that some will not reflect certain modern fail-safe engineering such as sufficient casing design strength and multiple casings or barriers along the full length. And these are permanent structural elements vestigial to the well’s original design, and therefore cannot be undone or redesigned away. In other words, it makes much more sense to drill a new well with new materials than attempt to significantly alter an old well. And the gas storage wells built today are designed with redundant fail-safe systems including multiple barriers and real-time pressure sensors.

But back to my earlier point about lack of federal regulations to set a minimum safety standard – because of that, there is also much uncertainty surrounding how many of these facilities have been dealing with safety and risk management. That is a future direction of this work – to really try to fill in some of regulatory gaps between states and the impending Federal guidelines and identify some best practices to help inform policy makers specifically at the state level.

Drew put together a map to highlight where some of these active storage wells are in PA, OH, NY, and WV:

Underground Gas Storage map

This area map of PA, WV, OH, and NY displays where active underground natural gas storage operations are located. The small white points represent active storage wells that have a completion, SPUD, or permit date that occurs after the field was designated for storage indicating that these wells are more likely to have been designed for storage operations. The green points are active storage wells that predate storage operations, indicating that these wells may not have been designed for storage.

There are 121 storage fields connected to at least 6,624 active gas storage wells across these four states. A portion of wells in this region were not included in this final count because they did not contain sufficient status or date information. Pennsylvania has the most individual storage fields of any state with 47, while Ohio boasts the most active storage wells of any state in the country with 3,318 across its 22 active fields. Of the 6,624 active UGS wells across these four states, 1,753 predate storage designation indicating that these wells were likely not originally designed for storage. These ‘repurposed’ wells have a median age of 84 years, with 210 wells constructed over 100 years ago (red points). The 100 year cutoff is not arbitrary, as the year 1917 marks the advent of cement zonal isolation techniques, indicating that these wells may be of the highest priority in terms of design deficiencies related to well integrity, and they are primarily located across the four states pictured above.

Top Counties with Obsolete1/Repurposed2 Wells

  1. Westmoreland, PA (86/93)
  2. Ashland, OH (50/217)
  3. Richland, OH (31/99)
  4. Greene, PA (25/76)
  5. Hocking, OH (18/99)

1Obsolete wells are repurposed wells constructed before 1916
2Repurposed wells predate the storage facility

Additional Notes

The well that failed at Aliso Canyon was originally drilled in 1954 for oil production. In 1972, it was repurposed for underground gas storage, which entails both production and injection cycles in a single well. The problem seems to be that because it was not originally constructed to store natural gas, only a single steel pipe separated the flow of gas and the outside rock formation. That meant the well’s passive structural integrity was vulnerable to a single point-of-failure along a portion of its casing. When part of the subsurface well casing failed, there were no redundancies or safety valves in place to prevent or minimize the blow out.

  • More information related to the Aliso Canyon incident and this study is available here.
  • More info on the Center for Health and the Global Environment can be found here.
Photo by Garth Lenz, iLCP - for Ethane Cracker article about risk and disclosure

Understanding in Order to Prepare: Ethane Cracker Risk and Disclosure

By Leann Leiter and Lisa Graves Marcucci
Maps and data analysis by Kirk Jalbert

Highly industrialized operations like petrochemical plants inherently carry risks, including the possibility of large-scale disasters. In an effort to prepare, it is incumbent upon all stakeholders to fully understand the risk potential. Yet, the planned Shell ethane cracker and additional petrochemical operations being proposed for Western Pennsylvania are the first of their kind in our region. This means that residents and elected officials are without a frame of reference as they consider approving these operations. Officials find themselves tasked with reviewing and approving highly complicated permit applications, and the public remains uncertain of what questions to ask and scenarios to consider. Often overlooked in the decision-making process is valuable expertise from local first responders like police, fire and emergency crew members, HAZMAT teams, and those who protect vulnerable populations, like emergency room personnel, nursing home staff, and school officials.

Steam cracker at BASF's Ludwigshafen site. Photo credit: BASF - for risk and disclosure article

Example of cracker producing ethylene, located at BASF’s Ludwigshafen site. Photo credit: BASF

In the first article in this series , we tried to identify the known hazards associated with ethane crackers. In this article, we look more closely at how that risk could play out in Beaver County, PA and strive to initiate an important dialogue that invites valuable, local expertise.

In keeping with the first article in this series, we use the terms vulnerability and capacity. Vulnerability refers to the conditions and factors that increase the disaster impact that a community might experience, and capacity consists of the strengths that mitigate those impacts. Importantly, vulnerability and capacity frequently intertwine and overlap. We might, for example, consider a fire station to be a site of “capacity,” but if it lies within an Emergency Planning Zone (discussed more below), an explosion at the plant could render it a vulnerability. Likewise, “vulnerable” populations such as the elderly may have special skills and local knowledge, making them a source of capacity.

Emergency Planning: Learning from Louisiana

FracTracker got in touch with the Emergency Operations Center (EOC) in St. Charles Parish, Louisiana, to learn how a community already living with Shell-owned and other petrochemical facilities manages risk and disclosure. The Emergency Manager we spoke with explained that they designate a two- and a five-mile area around each new facility in their jurisdiction, like ethane crackers, during their emergency planning process. They call these areas “ emergency planning zones ” or EPZs, and they maintain records of the vulnerabilities and sites of capacity within each zone. In case of a fire, explosion, or other unplanned event at any facility, having the EPZs designated in advance allows them to mobilize first responders, and notify and evacuate everyone living, working, and attending school within the zone. Whether they activate a two- or a five-mile EPZ depends on the type of incident, and factors like wind speed and direction.

Based on those procedures, the map below shows similar likely zones for the proposed plant in Beaver County, along with sites of vulnerability and capacity.

Ethane Cracker Hazard Map

View Map Fullscreen | How FracTracker Maps Work

The map helps us visualize the vulnerability and capacity of this area, relative to the proposed ethane cracker. It includes three main elements: the Shell site and parcels likely to be targeted for buildout of related facilities, two Emergency Planning Zones (EPZs) around the Shell facility, and infrastructure and facilities of the area that represent vulnerability and capacity.

vacant-parcels

Vacant parcels near the site

It is important to note that the proposed ethane cracker in Beaver County is merely the first of an influx of petrochemical spin-off facilities promised for the area, potentially occupying the various empty parcels indicated on the map above as “vacant properties” and presented in light gray in the screenshot left.

Each new facility would add its own risks and cumulative impacts to the equation. It would be impossible to project these additional risks without knowing what facilities will be built here, so in this article, we stick to what we do know – the risks already articulated by Shell, lessons learned from other communities hosting petrochemical industry in other parts of the country, and past disasters at similar facilities.

Vulnerability and Capacity in Beaver County

Red, blue, and green points on the map above and in the screenshot below stand in for hospitals like Heritage Valley Beaver; fire and emergency medical services like Vanport Volunteer Fire Company; police stations like the Beaver County Sheriff’s office; and daycares and schools like Center Grange Primary School.

Transportation routes, if impacted, could challenge evacuation. Potter Township Fire Chief Vicki Carlton pointed out that evacuations due to an event at this facility could also be complicated by the need to stay upwind, when evacuations would likely move in a downwind direction. This map lacks drinking water intakes and other essential features upon which lives depend, but which nonetheless also sit within this zone of vulnerability.

points-within-epzs

Points within EPZS

Vulnerability/capacity within 2-mile zone:

  • 1 hospital
  • 5 police stations
  • 10 fire/EMS stations
  • 23 schools/daycare facilities
  • 47,717 residents*

When expanded to 5-mile zone:

  • 2 hospitals
  • 9 police stations
  • 23 fire/EMS stations
  • 40 schools/daycare facilities
  • 120,849 residents*

*Note: For census tracts that are partly within a zone, a ratio is determined based on the percentage of land area in the tract within the zone. This ratio is then used to estimate the fraction of the population likely within the zone.

Stakeholders’ Right to Know

No person or community should be subjected to risk without the opportunity to be fully informed and to give meaningful input. Likewise, no group of people should have to bear a disproportionate share of environmental risks, particularly stakeholders who are already frequently disenfranchised in environmental decision-making. “Environmental justice” (EJ) refers to those simple principles, and DEP designates environmental justice areas based on communities of color and poverty indicators.

Presented as blue fields on the map and shown in the screenshot below, several state-designated EJ areas fall partially or entirely within the 2- and 5-mile EPZs (a portion of two EJ areas home to 2,851 people, and when expanded to five miles, two entire EJ areas and a portion of seven more, home to 18,679 people, respectively).

EJ Areas and Emergency Planning Zones around the Site

EJ Areas and Emergency Planning Zones around the Site

The basic ideas behind environmental justice have major bearing in emergency scenarios. For example, those living below the poverty line tend to have less access to information and news sources, meaning they might not learn of dangerous unexpected emissions plumes coming their way. They also may not have access to a personal vehicle, rendering them dependent upon a functioning public transportation system to evacuate in an emergency. Living below poverty level may also mean fewer resources at home for sheltering-in-place during a disaster, and having less financial resources, like personal savings, may lead to more difficult post-disaster recovery.

Local expertise

FracTracker recently consulted with the Emergency Management Director for Beaver County, Eric Brewer, and with Potter Township Fire Chief Vicki Carlton. Both indicated that their staff have already begun training exercises with Shell -including a live drill on site that simulated a fire in a work trailer. But when asked, neither reported that they had been consulted in the permit approval process. Neither had been informed of the chemicals to be held on site, and both referred to emergency planning considerations as something to come in the future, after the plant was built.

Unfortunately, the lack of input from public safety professionals during the permit approval stage isn’t unique to Beaver County. Our emergency management contact in Louisiana pointed to the same disturbing reality: Those who best understand the disaster implications of these dangerous developments and who would be mobilized to respond in the case of a disaster are not given a say in their approval or denial. This valuable local expertise – in Louisiana and in Beaver County – is being overlooked.

All Beaver County first responders who spoke with FracTracker clearly showed their willingness to perform their duties in any way that Shell’s new facility might demand, hopefulness about its safety, and a generally positive relationship with the company so far. Chief Carlton believes that the ethane cracker will be an improvement over the previous facility on the same site, the Horsehead zinc smelter, though a regional air pollution report characterizes this as a trade off of one type of dangerous pollution for another. Director Brewer pointed to the existing emergency plans for the county’s nuclear facility as giving Beaver County an important leg-up on preparedness.

But the conversations also raised concern about what the future relationship between the community and the industry will look like. Will funds be allocated to these first responders for the additional burdens brought on by new, unprecedented facilities, in what amount, and for how long into the future? Chief Carlton pointed out that until Shell’s on-site fire brigade is in place two or three years from now, her all-volunteer department would be the first line of defense in case of a fire or other incident. In the meantime, her fire company has ordered a much-needed equipment upgrade to replace a 30-year old, outdated tanker at a cost of $400,000. They are formally requesting all corporate businesses in the township, including Shell, to share the cost. Hopefully, the fire company will see this cost covered by their corporate neighbors who use their services. But further down the road? Once all is said and done, and Shell has what they need to operate unfettered, Chief Carlton wonders, “where do we stand with them?”

Waiting for disclosure of the risks

Emergency preparedness and planning should be a process characterized by transparency and inclusion of all stakeholders. However, when it comes to the Shell ethane cracker, those who will share a fence line with such operations have not yet been granted access to the full picture. Currently, the DEP allows industrial operations like the proposed ethane cracker to wait until immediately before operations begin to disclose emergency planning information, in the form of Preparedness, Prevention, and Contingency (PPC) plans. In other words, when permits are up for approval or denial prior to construction, permit applicants are not currently required to provide PPC plans, and the public and emergency managers cannot weigh the risks or provide crucial input.

Shell’s Acknowledged Risks
According to public information provided by Shell

Sampling of Shell’s Disastrous
Petrochemical Precedents

Fire and Explosions

Shell’s Deer Park, Texas, 1997:
Blast at chemical plant

Leaks

Shell’s Deer Park, Texas refinery and chemical plant, 2013:
Harmful air pollution and benzene leak

Equipment Failures

Shell’s Martinez Refinery in California, 2016:
Equipment failure event; Shell’s refusal to reveal gases emitted

According to Shell, possible risks of the proposed Beaver County petrochemical facility include fire, explosion, leaks, and equipment failures. More than mere potentialities, examples of each are already on the books. The above table presents a sampling. Shell also points out the increased risk of traffic accidents, not explored in this chart. It is worth noting, however, that the proposed facility, and likely spin-off facilities, would greatly increase vehicular and rail traffic.

The ethane cracker in Beaver County plant has not yet been constructed. However, Shell operates similar operations with documented risks and their own histories of emergency events. Going forward, the various governmental agencies tasked with reviewing permit applications should require industrial operations like Shell, to make this information public as part of the review and planning process. Currently they can relegate safety information to a few vague references and get a free pass to mark it as “confidential” in permit applications. Strengthening risk disclosure requirements would be a logical and basic step toward ensuring that all stakeholders – including those with special emergency planning expertise – can have input on whether those risks are acceptable before permits are approved and site prep begins.

Until regulations are tightened, we invite Shell to fulfill its own stated objective of being a “good neighbor” by being forthcoming about what risks will be moving in next door. Shell can and should take the initiative to share information about its existing facilities, as well as lessons learned from past emergencies at those sites. Instead of waiting for the post-construction, or the “implementation” stage, all stakeholders deserve disclosure of Shell’s plans to prevent and respond to emergencies now.

In our next article, we will explore the infrastructure for the proposed Shell facility, which spans multiple states, and sort out the piecemeal approval processes of building an ethane cracker in Pennsylvania.


Sincere Appreciation

Emergency Managers and First Responders in St. Charles Parish, Louisiana and Potter Township and Center Township, PA.

Lisa Hallowell, Senior Attorney at the Environmental Integrity Project, for her review of this article series and contributions to our understanding of relevant regulations.

Kirk Jalbert, in addition to maps and analysis, for contributing key points of consideration for and expertise on environmental justice.

The International League of Conservation Photographers for sharing the feature image used in this article.

The image used on our homepage of the steam cracker at BASF’s Ludwigshafen site was taken by BASF.


By Leann Leiter, Environmental Health Fellow for FracTracker Alliance and the Southwest PA Environmental Health Project and Lisa Graves Marcucci, PA Coordinator, Community Outreach of Environmental Integrity Project

With maps and analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance

Gas-Fired Power Plant Buildout in PA

Wanted: More Places to Burn Natural Gas

By Alison Grass, Senior Researcher at Food & Water Watch

Over the past decade, the natural gas industry has experienced a renaissance that has been a boon to energy company profits. But it has altered the quality of life for the rural communities where most new gas wells have been drilled. Now, fracking is fueling a gas-fired power plant boom in Pennsylvania, with 47 new facilities. Most have already been approved, with a handful in commercial operation (see map below).

New research by Pennsylvanians Against Fracking shows, in vivid detail, the scale of this buildout, and the impacts it will have on Pennsylvania communities.

Current & Potential PA Gas-Fired Power Plants & their Emissions

View Map Fullscreen

Approximately half of the new gas power plants are located in northeastern region of Pennsylvania, a part of the state already overburdened by the lingering environmental maladies of coal mining and the more recent dangers associated with fracking. These rural communities may see increased drilling, fracking and pipeline construction to support the power plants — and the siting could be strategic. In a StateImpact Pennsylvania article about the first Marcellus shale gas power plant, for example, a company representative admitted that the location was chosen specifically due to its convenient access to shale gas. “This plant was sited precisely where it is because of its access to the abundant, high-quality natural gas that’s found a mile to two miles beneath our feet.”

Drilling Trends

The first modern Marcellus well was drilled in Pennsylvania by Range Resources in 2003, and commercial production began in 2005. Although fracking expanded rapidly in several areas across the country, Pennsylvania has been ground zero of the fracking boom, with just over 10,000 shale gas wells drilled between 2005 and 2016. Since then, however, there has been a rapid downturn in new wells drilled. After the early and dramatic increase in drilling – from 9 shale wells in 2005 to 1,957 shale wells in 2011 – the number dropped to 504 in 2016.

According to Natural Gas Intelligence, natural gas from the Appalachian Basin “…hit a roadblock in 2016, as pipeline projects struggled to move forward and a storage glut slowed the region’s previously rapid production growth.” Thus, it appears that in order to maintain fracking’s profitability, the gas industry is relying on new gas-fired power plants to alleviate the storage glut, while potentially increasing demand for shale gas (which could propagate more drilling and fracking).

Gas-Fired Power Plant Siting

The siting of these power plants also enables companies to use Pennsylvanian fracked gas to generate power for larger regional markets. This is because northeastern Pennsylvania is close to dense populations, including New York City. In Luzerne County, for instance, the new Caithness Moxie Freedom Generating Station gas-fired power plant will supply electricity to not just Pennsylvania residents, but also to New Jersey and New York State. And in the more central region of the state in Snyder County, the Panda Hummel Station will send “much of its power to the New York City market.”

Siting gas-fired power plants in the northeast may also increase drilling and fracking in the region, where gas is predominantly “dry”  and less profitable than the “wet” gas found in southwest PA. This trend is largely due to a resurgence in North American petrochemical markets and increased ethane exports that rely on wet gas. (Dry natural gas contains primarily methane and smaller amounts of other hydrocarbons, while wet natural gas has higher concentrations of natural gas liquids. Natural gas liquids — predominantly ethane but also propane, butane, isobutane and pentanes — are the raw materials for manufacturing petrochemicals.)

Well Integrity and Other Risks

However, increased drilling and fracking mean more pollution for the Marcellus shale region of Pennsylvania, where shale gas wells have proven to be more prone to well construction “impairments” and well integrity problems, compared to conventional wells. This risk is especially true in the northeastern part of the state, where over nine percent of shale gas wells have indications of compromised well integrity.

Overall, fracking causes many public health and environmental problems. Methane, fracking fluids, and wastewater can pollute water supplies and imperil the livelihoods of farmers, who rely on clean water. Increased truck traffic and drilling emissions reduce air quality, and methane leaks contribute to global warming. Meanwhile, the proliferation of natural gas derricks and associated infrastructure destroys pristine landscapes (and related tourism and recreation industries).

The last thing that Pennsylvanians need is another way for the oil and gas industry to capitalize on shale at the expense of residents’ health and well-being.

Frac sand mining from the sky in Wisconsin

Fracking in Dairy Country

A dairy farmer in Wisconsin reflects upon a new industry in town: frac sand mining, how it is perceived, and where the industry is headed.

By Paul Jereczek
Jereczek Homestead Dairy, Dodge, Wisconsin

In 4th grade, every Wisconsin student learns about their state. Topics pertaining to Wisconsin’s economy, geography, and history along with ethnicity and traditions are introduced and explored. State facts and anecdotes are discussed and naturally memorized. The one that stood out to me the most was how Wisconsin became known as the “Badger State.”

The origin of the badger nickname is from mining. The 4th grade story I remember was that miners were too busy to build houses so they moved into abandoned mineshafts and/or dug their own burrows. These men became known as “badgers.” The 4th grade version of myself thought that was real impressive. I pictured strong, hard working men fiercely toiling away in the earth like mythical creatures, helping make Wisconsin what it is today.

It made for a great story.

Back to Reality

The reality and documentation of the times suggests something different. Most miners lived in cabins or other structures above ground. There most certainly were a few outliers on the fringe of mining society who burrowed their own holes or lived in abandoned underground mines, but the adult version of myself has a hard time imagining that the term used to describe such men – badgers – was used as a compliment.

Either way, the result is the same. Word spread and eventually Wisconsin became known as the Badger State. The state may be known worldwide for its cheese and agriculture, but there was mining in Wisconsin long before the first dairy cow. While the state was earning its nickname, mining was a prominent reason for the early success of the region.

Dairy Farming in WI

The 700 acre Jereczek Homestead Dairy in Dodge Township, Trempealeau County, Wisconsin first established in 1873 and now being operated by the the 6th generation of Jereczeks.

The 700 acre Jereczek Homestead Dairy in Dodge Township, Trempealeau County, Wisconsin first established in 1873 and now being operated by the 6th generation of Jereczeks.

Our farm is in Trempealeau County, Wisconsin – a driftless area – meaning the land was not covered by glaciers during the last ice age. The terrain is hilly and uneven, with tree-topped bluffs and hills overlooking valleys. The valleys, ranging from deep and narrow to wide and shallow, bump and flow into each other. Over the years, our farm has received its fair share of breaker rock, crushed rock, and gravel from the prevalent rock quarries. Sandstone deposits are huge and close to the surface. As a kid, there was a ledge in the cow pasture, where I hunted through chunks of sandstone for fossils.

As with everything else in the world, dairy farming continues to change. Most barns sit derelict and hold only memories of cows as they fade into the landscape. Small farms that clung to the valley walls have been sold to bigger operations, sit vacant, or have been built over. A lot of once prime farmland has been converted into houses with ridiculously large lawns. In 1990, Wisconsin had over 34,000 licensed dairy herds. Now there are just over 9,000.

We are the last dairy farm in our valley. Parallel to the trend, my childhood herd of 40 cows has turned to 200, which is about an average-sized herd. Margins are tighter than ever. Consistent help is hard to find. Milk prices are a terrible rollercoaster ride – it seems to take forever for them to go up, but when they fall, it’s fast and sickening. In the dairy business world, survival is a measure of success.

Frac Sand Mining Perceptions

Wisconsin Frac Sand Mines, Processing Facilities, and Related Operations

Wisconsin Frac Sand Mines, Processing Facilities, and Related Operations

The term frac sand is relatively new to me. I always assumed sand was sand and had given the word sand a negative connotation. Sand’s large particles don’t hold moisture or nutrients well, so sandy fields tend to perform poorly. But what if that sand has value for something else? What if there is a market for this sand much like a market for corn or soybeans?

Farmers tend to be resourceful. Every asset is scrutinized and employed to the fullest. Every acre is pushed. But what about what may lie beneath the soil? Sand mining has been going on in Wisconsin for well over a hundred years, but the recent surge in fracking has created an enormous demand for frac sand – and there are many people and companies set to take advantage of the boom.

Top U.S. Destinations for Wisconsin's Frac Sands Estimated from Superior Silica Sands' 2015 SEC 10Ks

Top U.S. Destinations for Wisconsin’s Frac Sands Estimated from Superior Silica Sands’ 2015 SEC 10Ks

Trempealeau County has zoning and planning ordinances to protect its industries and way of life. These aggressive ordinances allow more citizen input than other county’s ordinances. Public hearings are required, and orderly processes are enforced. With the economics involved with frac sand mining, citizens got educated very quickly. Much like abortion or immigration, frac sand has become a polarizing subject. Strong emotions built up by personal ideologies have pushed this topic to a boiling point. The for and against groups trade barbs without much convincing being done on either side. Frac sand mining editorials are common in local papers with those against appearing to be the most vocal and emotional.

New Player, New Approach

One such editorial detailed the approach a sand company took to obtaining a property. A local farmer had a sand mine company representative approach him with an oversized check written out to him for a sizable amount of money for his land. It was as though the sand rep was taking a page out of the Publishers Clearing House’s playbook. The farmer turned down the check. The sand rep left and returned a short time later with a significantly larger offer. The farmer was equally surprised and insulted. He found out later a few neighbors turned down similar proposals.

So what’s the deal with such a brazen approach? Intentions from this company may well have been good. Many people believed the sand mines were a win-win opportunity. Companies were selling hype – there was no way for anything but success. Extreme optimism. Sand mines were going to increase the tax base, fund schools and roads. Concerns were minimized, and residents were told what they wanted to hear. Such talk produced plenty of skeptics.

Environmental Costs of Frac Sand Mining

With both dairying and fracking, there is an environmental cost. Whether you milk 10, 100, or 1,000 cows – there are environmental pressures. With sand mining, the environmental effects are well documented. It is important, if not just practical, to measure these with the fiscal rewards. And where does this money go and who benefits the most? But, most importantly, who must deal with the consequences?

The risks of sand mines can be mitigated if proper regulations are taken seriously. With the extra scrutiny, a magnifying glass was placed over the sand mines, and what was found only proved the skeptics right. Trapping or pooling storm water seemed to be a learning process for sand mine companies; reported in 2012, every operating sand mine in Trempealeau County had storm water runoff violations. In 2014, over half of the sand mines in all of Wisconsin had violated environmental regulations imposed by the Department of Natural Resources. Add to this loss of surrounding property values, damage to roads, and a damper on quality of life – and you’ll create a substantial amount of public backlash.

Regulations Have Their Place

As was mentioned earlier, mining Is not new to the state. There are many multi-generational mining companies who have the experience, tradition, and financial network to abide by current standards and environmental regulations. Nobody likes to be told what to do. No industry is out there begging for more regulations. Often, the rules are in place to protect – not hinder – those that use environmentally safe and humane practices. Dairying has its own unique regulations – some are good, some not so much, and some downright stupid. Yet, overall it can be argued that these regulations protect the industry and the environment.

One heated topic in the dairy industry involves the sale of raw (unpasteurized) milk. It is illegal for any dairy in the state to sell raw milk. I have been drinking raw milk straight from the bulk tank since before I can remember. Our whole family did. Now, I still drink it and so do all my children from the age of a year and a half on up. None of us has ever had trouble with it. However, I am in complete agreement that the sale of raw milk should be illegal. All it takes is for one child to get terribly sick (which most certainly would happen) and for that kid lying on a hospital bed being blasted by every news network in the nation. These images create strong negative emotions that reverberate throughout society. The potential costs far outweigh the economic benefits from such a sale. Sure, some people are upset, but the greater good is maintained by taking away a risky practice.

The same principle works for mining. Rules and regulations get negative press and reaction, but who stands to lose the most from environmental catastrophes related to mining – the company in business 90-some years or the startup mining ventures trying to capture lightning in a bottle? Some companies have built years of trust and compatibility and support for their local communities. These are businesses that will remain after the sand rush has fizzled.

Booms and Busts, Ups and Downs

The frac sand industry is going through the same economic cycle as the dairy industry. The sand companies are getting better at what they do and increase their production capacity. Like milk, sand is a commodity. As the price of sand decreased, production increased to maintain profits. The dairy industry does the same thing, by expanding and improving efficiency to get more milk to catch those dollars slipping away. However, when the market is flush with milk or bombed with sand, they’re just doing more damage to themselves. This is a simplified take on the industry, as there are many global factors that come into play, but the overall pattern tends to remain. As the dairy industry can attest, this fluctuating cycle is not sustainable for all producers.

Primary and Secondary US Silica Sand Geologies and Existing Frac Sand Mines

Primary and Secondary US Silica Sand Geologies and Existing Frac Sand Mines

Worse yet for the sand industry, this cycle has occurred in hyper speed. At first, just the small mines cut production. Outcompeted by larger operations, production at smaller mines was no longer profitable. Soon, the larger mines cut production due to the weakening demand. Many mines in the permit or early production phases never got started. Unlike the dairy industry, there was no rollercoaster effect because prices have yet to return to prior levels. The bubble, it seems, had popped.

With any kind of new mine developed comes the environmental impacts. Yet, I find the fervent negative reaction to such practices directly related to the end result. Fracking. Fracking isn’t magic. They’re not just mixing water with this sand and forcing oil and gas out of the ground. Harmful chemicals are being added to the mix. Worst yet, the quantity and potency of such chemicals is kept secret, closely guarded from the public. Harmful chemicals are being legally pumped into the ground. All the short-term gains will have long-term consequences. This is where I believe a significant backlash for new mines comes from. The end result. Can you imagine what the public’s perception of dairy farms would be if milk was mixed with chemicals and pumped into the ground?

The Future of Dairy Farming in Wisconsin

The 2016 presidential election has breathed some life into the frac sand industry. The new president promises to cut regulations interfering with business, and thus far has kept those promises. The environment will not be a detriment to his goals. Sand companies are returning with ads in the local papers, looking for qualified applicants and offering great salaries. In contrast, the dairy industry is stuck in a rollercoaster spiral. Milk prices have been too low for far too long. The dairy dispersal continues with some very good cows being sold and very good dairymen and women calling it quits. Naturally, some land will be sold. To what end remains to be seen. But it is a safe bet, the frac sand mining ride has not ended.

The Shale Gas & Oil Health Registry: A Collective Step to Track the Impacts of Fracking

“It’s all about facts. Documented facts…”

… asserted a county commissioner to a recent gathering of concerned residents in Hannibal, Ohio. His comment came at the end of over an hour of deeply moving narratives from residents, sharing disturbing changes in their health after a disastrous well pad fire in their community and other ongoing shale development in the area. One family, whose home was blanketed by the heavy black smoke from the fire, which burned for five days in 2014, told of respiratory problems, hair loss, newly-diagnosed thyroid issues, and a premature birth. Another family reported worsening of existing cardiac conditions, sleep disturbances, and considerable stress due to continued encroachment of pipelines and compression stations.

lisa-photo-1

Figure 1: Residents of the Fort Berthold Indian Reservation in North Dakota live amid numerous oil rigs. Photo credit: Shalefield Stories, Vol. 2.

Throughout the country, personal stories like these offer a meaningful window into the experiences of people living at the frontlines of shale gas and oil development – often called ‘fracking.’ But aggregated into a formal health registry, these experiences can also form the kind of documentation needed to inform public health research and legislators who, like the county commissioner in Ohio, insist on documented evidence before issuing health-protective policies.

A health registry is “a dataset of uniform information about individuals collected in a systematic and comprehensive way, in order to serve a predetermined medical or public health purpose.”

The Southwest PA Environmental Health Project (EHP), in partnership with the Genetic Alliance, has just introduced the first such national system. In this online system, participants share – and control access to – their own data, making it unique among many other registries. This exciting new forum invites those living, working, or going to school near shale gas and oil development, like the families described above, to share their exposures and document their health symptoms. Perhaps most importantly, it ensures that personal stories are collected, respected, and treated as the important data that they are.

Figure 2: These quick and informative videos introduce EHP’s Shale Gas & Oil Health Registry and how it works. They feature the voices of those who helped create it, including public health professionals, the director of EHP, and a community member.

Why a registry?

Public health research affirms that there are significant health risks for those living, working, or attending school near shale gas and oil development. Research points to links between proximity to fracking and worsened asthma and other respiratory impacts and skin conditions; fracking’s noise pollution and stress-related conditions, like cardiovascular problems; and low birth weight babies among mothers living near numerous hydraulically fractured wells.

Physicians, Scientists, and Engineers for Healthy Energy (PSE) conducted a thorough examination of the extensive and growing body of shale gas and oil-related research and found that between 2009 and 2015, 84% of the studies focused on health have findings that “indicate public health hazards, elevated risks, or adverse health outcomes.”

US map of populations near active drilling activity

Figure 3: Populations in the U.S. near active drilling. The Shale Gas & Oil Health Registry has a national scope. Click on the image to learn more about how this map was made.

For years, some medical professionals attuned to environmental effects on health have noted correlations between fracking and health symptoms in their patients. But without a clear explanation of causation that links such symptoms to fracking, researchers need more data.

The Pennsylvania Medical Society recommended a registry as a necessary step toward getting a grasp on the public health problem. A health registry collects health data systematically, and may support further epidemiology and toxicology research by putting these patterns in higher contrast.

Laying the Groundwork

The Shale Gas & Oil Health Registry did not emerge in isolation, but rather is one of several ongoing efforts toward gathering the innumerable accounts of health symptoms from shale development regions around the country.

Important grassroots initiatives include the List of the Harmed, started by Jenny Lisak in 2011. The List catalogues over 20,000 stories of human, animal, and environmental impacts. The Natural Gas Exploration & Production Health and Community Impacts Survey, created by The Damascus Citizens for Sustainability (DCS), is an effort to collect health impact information from individuals in shale gas communities and hopefully trigger further review from the Agency for Toxic Substances and Disease Registry (ATSDR). Additionally, there are numerous peer reviewed studies on the topic, but they are often too limited in scope and size to be generalized to communities outside of where the data was originally collected.

Families in Washington Co., Pa who are facing possible issues through the creation of cybergentic gas processing plant in western Pa. A Cibus Imperial compression station sits above a suburban community, people there are fearful of their air quality because of this plant, in Bulger, PA

Figure 4: In Washington County, PA, houses sit just below a compressor station, a type of natural gas facility that can produce air emissions, noise, and light pollution. In the health registry, participants can answer questions about the types of facilities they are exposed to. Photo credit: Karen Kasmauski, iLCP.

Two states have begun their own registry-related efforts. Colorado’s Oil & Gas Health Information and Response Program includes an online self-referral form, a hotline for those with health concerns potentially related to oil and gas, and a health information “clearinghouse.” Their program aims to illuminate “possible health effects related to oil and gas operations,” which the program intends to make available to the public, researchers, and policy-makers (source).

Pennsylvania, where EHP does much of its on-the-ground work, has a history of legislative calls for its own registry, beginning with recommendations issued by Governor Tom Corbett’s Marcellus Shale Advisory Commission in 2011. The Secretary of Health at the time called a registry “the most timely and important initiative” for the Department of Health (DOH). Current Governor Tom Wolf called for a shale gas health registry in his 2014 gubernatorial campaign. He proposed budgeting $100,000 to the PA Department of Health (DOH) for the cause, although health professionals argue that more is needed to implement an effective registry. According to recent conversations with EHP, DOH is in the process of developing a system similar to Colorado’s, in coordination with that state. For the time being, Pennsylvanians seeking assistance from DOH will find a webpage with limited information, directing calls to the state’s Bureau of Epidemiology.

Making the Registry a Reality

There is a clear need for a system to collect individuals’ exposures and health symptoms, with a national scope that matches the country-wide scale of shale development. Yet, the costs of initiating and maintaining a registry, political issues related to industry reporting on the chemicals they use and discharge, and scientific issues such as scant exposure data and limited funding for research, are some of the various obstacles that faced the implementation of a health registry.

From a health perspective, symptoms potentially related to drilling activity may be similar to symptoms from unrelated causes, or may be exacerbations of existing health conditions. Added to this is the complexity of exposure sources, since an individual or family may live, work, or go to school in proximity to multiple types of shale gas and oil facilities. Moreover, those at the frontlines of shale oil and gas development – whose health data is essential to the registry – may be reluctant to participate due to social or family pressures.

The Shale Gas & Oil Health Registry directly addresses each of these challenges. Using an existing registry infrastructure created by Genetic Alliance significantly reduced the costs of launching and maintaining the registry. Including systematic questions that let users record their proximity to – and frequency of – exposure captures the complexity of this important information. And through steps like collecting zip codes instead of home addresses, and offering the choice of privacy settings that only allow researchers to see data in anonymous form, the registry ensures confidentiality and user control of data.

Figure 6. A variety of sources can trigger health issues during shale gas and oil development. These include air emissions from processing facilities and well pad accidents, as well as the heavy truck traffic required to drill and frack a well; spills and other forms of water contamination; and psychological impacts like stress and sleep disruption. 

End Result: The Shale Gas & Oil Health Registry

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Figure 7: The health registry includes a set of questions for participants whose exposures come from working in the gas and oil industry. Photo credit: Bill Hughes.

The result of these efforts is a secure, online system where participants – people within five miles of shale gas and oil development, with or without health symptoms – can create an account for themselves and/or their family members. The online registry guides them through a series of screens inviting them to share the various exposures they encounter, such as heavy truck traffic, air emissions, and water impacts. Participants can catalogue and update health symptoms that have surfaced or worsened during their exposure, while controlling who can view and share their personal information.

Industry workers and children can even be registered in this system using a set of tailored questions. The registry also allows an assistor to create a profile and answer the questions for someone not comfortable with or able to use the online system.

One Registry to Meet Many Needs

EHP created the health registry to respond to the needs of several groups: affected communities, researchers, policymakers, and the public.

shirley-eakin

Figure 8: A resident of Washington County, PA sits in front of paperwork documenting health struggles that may be connected to shale gas development near her home. Photo credit: Shalefield Stories, Vol. 2.

In developing the health registry, EHP recognized that those affected by shale development must not be treated as “data points,” but as collaborators in – and beneficiaries of – the process. As a venue to share health concerns, the registry helps give voice to those who may be suffering in silence. Participants can connect with researchers, receive a biannual newsletter of updates on the growing size of the registry and new knowledge around health impacts and treatment. In the long view, the registry gives individuals an opportunity to take part in a large-scale effort that may ultimately inform positive change and promote protections from ever-expanding shale development.

 The data participants provide via the registry can also help researchers identify emergent patterns and generate testable hypotheses for new studies. Through this process, a registry can enable research that is responsive to community needs.

Policymakers stand to benefit, as well. The patterns that the registry highlights, and the additional research it makes possible, can help elected leaders to understand the scope of the health problem. In time, this knowledge can inform policies and regulations that benefit those living in shale country.

A chance to be a part of something larger

EHP encourages those who live near shale gas and oil development, with or without health symptoms, to register now and fill out the registry questionnaire. The three-step process takes only about 20 minutes.

  1. Share: Answer as many questions as you would like, and control how and with whom that information is shared
  2. Connect: Find out how you compare to others, and let support and helpful resources come to you
  3. Discover: If you wish, let researchers access your information to help them understand the health impacts of shale oil and gas development and transport

Researchers and healthcare providers who want to take part in the possibilities created by the registry, such as studying data patterns from participants who have elected to share certain information, can contact Jill Kriesky (jkriesky@environmentalhealthproject.org) or Beth Weinberger (bweinberger@environmentalhealthproject.org) for more information.

Button to join the Shale Gas & Oil Health Registry

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Click here to join the Shale Gas & Oil Health Registry!

Sincere Appreciation

Many thanks to those who contributed to this article about the Shale Gas & Oil Health Registry through interviews and by sharing the images used in this story.

The International League of Conservation Photographers and the Environmental Integrity Project for sharing photographs of families coping with fracking where they live, “The Human Cost of Energy Production.”

Dana Dolney, co-founder of Friends of the Harmed. Friends of the Harmed, publishers of Shalefield Stories, dedicate 100% of donations they receive to providing much-needed direct aid to families negatively affected by fracking.

Jenny Lisak, creator of List of the Harmed. List of the Harmed is an ever-growing list of the individuals and families that have been harmed by fracking (or fracked gas and oil production) in the U.S.

Barbara Arrindell, director of Damascus Citizens’ Group. Damascus Citizens for Sustainability (DCS) is a collaborative endeavor to preserve and protect clean air, land and water as a civil and basic human right in the face of the threat posed by the shale gas extraction industry.

Jill Kriesky, Associate Director and Beth Weinberger, Research & Communications Specialist, both of The Southwest PA Environmental Health Project. The Environmental Health Project (EHP) is a nonprofit public health organization that assists and supports residents of Southwestern Pennsylvania and beyond who believe their health has been, or could be, impacted by unconventional oil and gas development (UOGD, or “fracking”).


By Leann Leiter, Environmental Health Fellow, FracTracker Alliance & EHP

Radium Watersheds a Risk

By Greg Pace – Columbus Community Bill of Rights, and Julie Weatherington-Rice – Environmental Consultant

columbus_classiimap

Figure 1. Map of Columbus, OH Watersheds and Class II Injection Wells

Most Ohio residents are unaware of the frack fluid deep underground injection occurring north of Columbus, underneath the region’s source water protection watersheds (Figure 1).

Materials injected are liquids that have as much as ten times the salt concentration of sea-water. Mixed with this “brine” solution is a combination from hundreds of chemicals that are used in different stages of horizontal hydraulic fracturing, the process used to extract natural gas, petroleum, and hydrocarbon liquids used to make industrial materials such as plastics. BTEX compounds including benzene are always present in the wastewater, along with formaldehyde, bromides, ethylene glycol (antifreeze), and arsenic, with many other carcinogenic and otherwise highly-toxic substances.

Radioactivity of Shale Gas Wastewater

One of the biggest questions in this mix of toxic disposal is how much radioactive content exists. Radium-226 is most worrisome, as it has a very long half-life (1,600 years). It is water-soluble and, once it enters the human body, seeks to find a home in our bones where it will emit its cell-formation-destabilizing effects for the remainder of our lifetime. This radionuclide is known to cause leukemia, bone cancers, blood disorders, and other diseases.

The state of Ohio does not monitor the content of materials that are injected into our Class II injection wells deep in the ground. This oil and gas waste can come from anywhere, including Pennsylvania’s Marcellus shale, which is the most highly-radioactive geology of all the shale plays in the country. Radium-226 readings as high as 15,000 pico-curies per liter have been read in Marcellus shale brines. The EPA drinking water limit for radium-226 is 5 pico-curies per liter, which puts the Marcellus reading at 3,000 times higher than the drinking water limit.

Exposure through drinking water is a pathway to human disease from radium-226. Once oil and gas waste is disposed of underground in a sandstone or limestone layer, the fluids are subject to down-gradient movement, wicking through capillary action, and seepage over time. This means that the highly radioactive wastewater could eventually end up in our underground drinking water sources, creating radium watersheds. This practice is putting our watersheds at risk from radioactive contamination for hundreds of years, at least.

Can injected fluids migrate?

Depending on whether you confer with a geologist who works with the oil and gas industry, or from an independent geologist, you will get a different opinion on the likelihood of such a pollution event occurring. Industry geologists mostly claim that deep injection leaves very low risk of water contamination because it will not migrate from the planned area of injection. On the other hand, independent geologists will tell you that it is not a matter of if the liquids will migrate, but how and when. The ability to confirm the geology of the underground area layer of injection “storage” is not exact, therefore accuracy in determining the probability for migration over time is poor.

Figure 2. Ohio Utica Brine Production and Class II Injection Well Disposal


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We do know, however, that all underground systems in Ohio leak – Research by The Ohio State University and the US Geological Survey show that the age of the water in brine formations is far younger than the age of the rock deposits they are found in. See where wastewater is being created and disposed of in Ohio using the dynamic map above (Figure 2).

Spill Risks to Columbus, OH Water

According to area geologist, Dr. Julie Weatherington-Rice, the source for Columbus’s water to the north is mostly from surface water. This water comes from the Delaware and Morrow county watersheds that feed into sources such as the Hoover and Alum Creek reservoirs. The major threat from injection wells to our watershed is from spills, either from trucks or from storage at the injection well sites themselves.

Dead fish floating in Vienna area pond contaminated by injection well system spill Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

Figure 3. Dead fish floating in Vienna area pond contaminated by injection well system spill. Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

In April 2015, as much as 8,000 gallons of liquid leaked from a malfunctioning pipe in the storage apparatus of an oil/gas waste storage and injection well site in Vienna, OH. This caused a wildlife kill in two ponds (Figure 3), and the spill was not contained until 2/3 mile downstream in a tributary. The firm who owned the facility was found negligent in that they did not install a required containment liner for spills. The incident was discovered by neighboring residents, but apparently employees knew of the leak weeks before. Of note in this incident was that Ohio Department of Natural Resources, the regulatory agency that oversees all oil/gas production activity in Ohio including injection, stated that there was “minimal impact to wildlife.”

Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

Figure 4. Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

In March, 2016, a tanker truck carrying produced waste from a hydraulically fractured well pad overturned outside of the Village of Barnesville, Ohio (Figure 4). The truck spilled 5,000 gallons of liquid waste into a field that led into a tributary, leading the fluids to enter one of the city’s three drinking water supply reservoirs. The water source was shut down for more than two months while regulators determined if water levels were safe for consumption. There was a noted spike in radium-226 levels during water testing immediately after the spill.

Of greatest concern is that, although many millions of gallons of frack waste have been injected into the wells north of Columbus over the past few years, we expect that this activity will increase. For the first time, the United States began exporting its own natural gas in 2016, to regions such as Europe and South America. As the industry consolidates from the depression of oil prices over the past two years and begins to ramp up again, we expect the extraction activity in the Marcellus and especially Utica to increase to levels beyond what we have seen since 2011. The levels of injection will inevitably follow, so that injection wells in Ohio will receive much more than in the past. The probability of spills, underground migration, and human-induced earthquakes may increase steeply, as well.

An Aging Disposal Infrastructure

On our Columbus Community Bill of Rights website, we show pictures of some of the Class II injection wells in Morrow County, most of them converted from legacy production wells. These old wells are located in played out oil/gas fields that may still be producing or have abandoned but not plugged (closed) wells, allowing other routes for injected liquids to migrate into shallow ground water and to the surface. The dilapidated condition of these converted Class II wells makes it hard to believe that they are used to inject millions of gallons of wastewater under high pressure. While many of the wells in the state are as deep as 9,000 feet, all of the injection wells we have seen in Morrow County are only 3,000-4,000 feet deep. This situation puts surface water at greater risk over time, as it is probable that, over the generations, some of the fluids will migrate and wick into the higher subterranean strata.

Figure 5. Ohio Class II Injection Wells by Type


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One well (Power Fishburn unit, photo below) showed signs of poor spill control when we took our October 2015 injection well tour. While we were there, a brine tanker arrived and began pumping their load into the well. The driver took pictures of our license plates while we were there watching him. A year later, there is a whole new structure at the well, including a new storage tower, and an extensively beefed-up spill control berm. Maybe we need to visit all of the facilities when they come by to use them!

Another well (Mosher unit, photo below) which hadn’t been used since 2014 according to available records, showed signs of a spill around the well. The spill control berms look as if they probably had flooded at some point. This well sits on the edge of a large crop field.


Figures 6a and 6b. Photos of Class II injection wells. Click on the images to expand them.

North of Columbus, the city of Delaware’s underground source water is at risk of becoming contaminated from underground migration of disposed wastewater over time, through wicking and seepage effects (as explained earlier in this article). They are also vulnerable to their reservoir being contaminated from surface spill migration through their watershed.

Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

Figure 7. Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

South of Columbus is another threat – drill cuttings from the drilling process have been authorized for disposal at a “remediation” landfill adjacent to the Alum Creek (Figure 7). The bioremediation treatment used is not indicated to solve the problem of removing radionuclides from the materials. This landfill had been remediated under the Ohio EPA twice when it was a toxic drum dump, after toxins were found to have been leaching into the watershed creek. Columbus’s Alum Creek well, as well as Circleville, are at risk of contamination in their drinking water if radionuclides from the cuttings leach into Alum Creek. Again, this is a long-term legacy of risk to their water.

Radiation Regulatory and Monitoring Gaps

Since The Ohio legislature deemed the radioactive content of shale cuttings to be similar to background levels in the 2013 state budget bill, cuttings can be spread around to all licensed landfills in Ohio with absolutely no accountability for the radium and other heavy metal levels in them. Unfortunately, the measuring protocol used in the pilot study for the Columbus facility to demonstrate to Ohio EPA that radium-226 was below EPA drinking water limits has been shown in a University of Iowa study to be unreliable.  The inadequate protocol was shown to indicate as little as 1% of the radium levels in shale waste samples tested.

As such, there have been hundreds of incidents where truckloads of cuttings have been turned away at landfills with crude radiation monitors. In 2013 alone, 2 loads were turned away in Ohio landfills, and over 220 were turned away from Pennsylvania landfills.

Ohio has a long way to go before it can be considered a clean energy state. The coal industry polluted significant water sources in the past. The fracking industry seems to be following suit, where contaminations will surprise us long into the future and in broader areas.


Map Data for Download

Re-imagine Beaver County meeting - Photo by Sophie Riedel

Mapping a new vision in PA: Alternatives to petrochemical development

At a Re-Imagine Beaver County gathering in Pennsylvania earlier this month, static maps became dynamic in the hands of those who live in and around the region depicted. Residents of this area in the greater Pittsburgh region gathered to depict a new vision for Beaver County, PA. This county is currently faced with the proposal of a massive Shell-owned petrochemical facility – also called a “cracker” – and further build-out that could render the area a northern version of Louisiana’s “Chemical Corridor.” Participants at this event, from Beaver County and beyond, were encouraged to collectively envision a future based on sustainable development. The picture they created was one that welcomes change – but requires it to be sustainable and for the benefit of the community that makes it happen.

Re-Imagine Beaver County Group Mapping - by Sophie Riedel

Figure 1: Participants study a map of Beaver County. Photo credit: Sophie Riedel.

Re-Imagine Beaver County Participants

Panelists from municipal government, organic agriculture, and leaders and entrepreneurs of sustainable initiatives started off the event, sponsored by the League of Women Voters of Pennsylvania and endorsed by the Beaver County Marcellus Awareness Committee. After an hour, the room of 60 or so participants dove into the lively de- and re-construction of large format maps of the area. They were invited to markup the maps, created by Carnegie Mellon University graduate student of the School of Architecture, Sophie Riedel. Each table worked from a different base map of the same area – centering on the confluence of the Ohio and Beaver rivers, including the already heavily-industrialized riverside and the site of Shell’s proposed petrochemical facility.

Massive shell processing plant under construction in Beaver County PA and across the Ohio River from the town of Beaver. This massive processing plant, near residential areas, schools and hospitals, will be a serious threat to the health of the those living in the region.

Figure 2: The site of the proposed petrochemical facility in Beaver County (on left) and the Ohio River that participants hope to see reinvented as a recreational waterway buttressed by public parks. Photo credit: Garth Lenz, iLCP.

Much more than a thought exercise, the gathering represented a timely response to a growing grassroots effort around the proposed petrochemical inundation. Changes are already underway at the site, and those who live in this region have the right to give input. This right is especially salient when considering the risks associated with the petrochemical industry – including detrimental health impacts on babies before they are even born, asthma exacerbation, and increased cancer rates.

Charting a new vision

The re-invented Beaver County would be one of increased connectivity and mobility, well-equipped to provide for local needs with local means.

Many ideas included on the maps reflected a longing for transportation options independent of personal vehicles – including better, safer, more connected bike trails and walking paths, use of existing rail lines for local travel, and even the inventive suggestion of a water taxi. These inherently lower-impact means of transport coincide with preferences of millennials, according to several of the panelists, who want more walkable, bikeable communities. Ushering in such sustainable suggestions would welcome more young families to an area with an aging population. More than just about moving people, transportation ideas also included ways to get locally grown foods to those who need it, such as the elderly.

sophie-riedel-visioning-map-close-up

Figure 3: Participants modify maps to reflect a new vision. Photo credit: Sophie Riedel.

The value of beauty was a subtheme in many of the ideas to connect and mobilize the population and goods, ideas which often held a dual aim of protecting open space, creating new parks, and offering recreation possibilities. Participants ambitiously reimagined their river, the Ohio, from its current status as a closed-off corridor for industrial usage and waste, to a recreational resource for kayaking and fishing walleye.

Participants marked up the maps to show the resources that help sustain this community, and voiced a strong desire for development that would enable additional self-reliance. These forward-thinking changes included increased agriculture and use of permaculture techniques, and community gardens for growing food near the people who currently lack access. Ideas for powering the region abounded, like harnessing wind power and putting solar panels on every new building.

Participants were firm on local sourcing for another key resource: the labor required for these efforts, they insisted, must come from the local populace. Educational programs designed to channel learners into workers for sustainability might include training to rebuild homes to “greener” standards, and programs aimed at bringing a new generation of farmers to the fields. Perhaps a nod to the world-wide plastic glut that a petrochemical facility would add to, suggestions even included local ways of dealing with waste, like starting a composting program and establishing more recycling centers.

Whose vision?

Who is a part of this vision, both in creating it and living it out? Inevitably, the selection of panelists and the interests of the audience members themselves influenced the vision this group crafted. The question of inclusion and representation found articulation among many participants, and the hosts of the event welcomed suggestions on reaching a broader audience moving forward. Looking around the room, one man asked, “Where are all the young people, and families with kids?” Indeed, only several members of this demographic were present. Though indicative of the racial makeup of Beaver County, the audience appeared to be primarily white, meaning that the racially diverse communities in the region where not represented. Others pointed out that going forward, the audience should also include those residents struggling with un- and underemployment, who have a major stake in whatever vision of Beaver County comes to fruition. Another said he would like to see more elected officials and leaders present. Notably, Potter Township Board of Supervisors Chairperson, Rebecca Matsco, who is a strong advocate for the proposed petrochemical project in her township, was present for the first half of the event.

Local means for meeting local needs

People who welcome petrochemical development in Beaver County might believe that those who voice concerns about the proposed Shell plant aren’t forward-thinking, or simply oppose change. Quite in contrast, participants at Re-Imagine Beaver County went to work reinventing their community with optimism and enthusiasm. They didn’t seem to be resisting change, but instead, wanting to participate in the process of change and to ultimately see benefits to their community. For example, discussion of solar power generated substantial excitement. According to panel speaker Hal Saville, however, the biggest challenge is making it affordable for everyone, which suggests that the estimated $1.6 billion in tax breaks going to Shell for the petrochemical plant could be better allocated.

A key narrative from supporters of the ethane cracker centers on the pressing need for jobs in this area, though some locals have expressed concern about how many of Shell’s promised jobs would go to residents. Whoever gets hired, these jobs come with serious dangers to workers. Participants at this event proposed alternative initiatives – both ambitious and small – for creating jobs within the community, like providing “sprout funds” to encourage new business start-ups, and launching a coordinated effort to rehab aging housing stock. These ideas suggest that the people of this region feel their energy and ingenuity would be best spent making Beaver County a better place to live and work, in contrast to producing disposable petrochemical products for export around the world. The fact that so many participants emphasized local means for meeting their needs in no way downplays the need for good jobs. Rather, it points to the fact that people want jobs that are good for them and for the future of their community.

Moving the vision forward

Where do we go from here? Can the momentum of this event draw in greater representation from the region to have a voice in this process? Will these visions become animated and guide the creation of a new reality? Broader and deeper planning is in order; participants and panelists alike pointed to tools like comprehensive community plans and cleaner, “greener” industrial policies. More than anything, the group articulated a need for more deliberation and participation. As panelist and farm co-owner Don Kretschmann put it, when it comes to change, we need to “think it through before we go ahead and do it.”

The maps themselves, bearing the inspirations scrawled out during the event, have not reached the end of the road. From here, these maps will accompany an upcoming exhibition of the artworks in Petrochemical America, which locals hope to bring to the greater Pittsburgh area in the coming months. League of Women Voters, for their part, continue to move the vision forward, inviting input from all on next steps, with an emphasis on pulling in a broader cross-section of the community.

To voice your vision, and to stay in the loop on future Re-Imagine Beaver County events, contact reimaginelwvpa@gmail.com.


Many thanks to Sophie Riedel for sharing photographs from the event, and to the International League of Conservation Photographers and the Environmental Integrity Project for sharing the aerial photograph of the Shell site from their joint project, “The Human Cost of Energy Production.”

By Leann Leiter, Environmental Health Fellow

 

Dunes, Great Lakes Barrens at Risk

World Class Dunes and Great Lakes Barrens at Risk at Ludington

By Dave Dister, Consulting Ecologist, Ludington, MI

One of the prime reasons I moved to the Ludington, Michigan area in 2008 was the aesthetic and biological diversity evident at Ludington State Park (LSP). As a field biologist nearing the end of his formal career, I was eager to conduct a study of the vascular plants within the 5,300-acre park. That study consumed six years of exploring all habitats and ecosystems, and documenting (by vouchers) the flora I encountered. Although the unfortunate presence of the Sargent Sand Company operation was obvious as it cut through the south end of the park, it was not until the fracking boom a few years ago that I took special notice as a residential neighbor.

US Frac Sands and Silica Geology Map


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Above is a dynamic map of silica sands and frac sand mines, drying facilities, and other related facilities. Zoom and click on the map to explore various aspects of frac sand mining infrastructure. Click here to view the map full screen along with its legend.

Expanding Sand Mining

That “sleepy” sand mining operation suddenly turned into a 24-hour, seven-days-a-week operation, with associated noise that irritated a very light-sleeping biologist. Hamlin Township officials were only partially effective in addressing residential impacts “after hours,” and had no interest in developing reasonable ordinances upon a commercial operation. Although increased noise and truck traffic were a tangible nuisance, only when a renewal of the company’s sand mining permit was announced did it become clear that biological resources within the 372-acre private in-holding were afforded virtually no protection at all. And the more research I did into the regulatory permitting process, the more incredulous the situation appeared.


Above – Photos of Sargent Sands frac sand mining operations taken by Ted Auch, FracTracker Alliance

1979 Environmental Impact Report

My expertise as a wetlands biologist and botanist were well suited to scrutinizing the 1979 Environmental Impact Report (EIR), which was a hastily-compiled poorly-researched 24-page document.

From my perspective, there was a poor level of protection afforded to the Federal and State Threatened Pitcher’s Thistle (Cirsium pitcheri). As far as is known, Sargent Sand has no records of relocating this plant in proposed or active mining cells in its 100-year history of mining, although the Michigan Department of Natural Resources (MDNR) has known about plants on the property for more than 20 years. The MDNR and US Fish and Wildlife Service (USFWS) have been complicit in not adequately protecting this species, which has had minimal research into the success (or not) of transplanting individual plants. Young plants appear to transplant well, but long-term studies are not available. Older plants are much less likely to survive transplanting, as they depend on numerous minute root hairs to absorb moisture in a xeric habitat, and removal from a dune would strip-off most such root hairs. It requires about seven years for these plants to mature, so reproductive rates are slow.

Yep, it’s a fact of life – plants simply are not nearly as charismatic as animals, and consequently are treated as “second-class organisms” in the world of environmental protection. Sadly, the Michigan Department of Environmental Quality (MDEQ) just renewed the sand mining permit that allows Sargent Sand to “self-monitor” for this threatened species, and to “move plants” encountered in areas proposed for development. Does anyone really think a mining company will give two hoots about a thistle plant?!

Great Lakes Barrens Ecosystem

The rarity and value of Great Lakes Barrens (GLB) was not addressed when the 1979 EIR was written, though such ecosystems are clearly visible on aerial photographs of Sargent Sand Company property and surrounding LSP. These natural communities are known to be imperiled ecosystems at both the state and global levels. The Michigan Natural Features Inventory classifies “Great Lakes Barrens” – that include jack pine stands with associated xeric-loving shrubs and forbs – as S2 natural communities:

Imperiled in the state because of rarity due to very restricted range, very few occurrences, steep declines, or other factors making it very vulnerable to extirpation from the state. – Michigan Natural Features Inventory

Globally, Great Lakes Barrens have a similar designation. Consequently, mitigation measures must be strengthened and avoidance of impacts considered. Any Restoration Plan of such habitats must include high quality GLB plants such as buffaloberry (Shepherdia canadensis), bearberry (Arctostaphylos uva-ursi), ground juniper (Juniperus communis), sand cherry (Prunus pumila), sand-dune willow (Salix cordata), blueleaf willow (Salix myricoides), beach-heath (Hudsonia tomentosa), harebell (Campanula rotundifolia), white camas (Anticlea elegans), and wild wormwood (Artemisia campestris), among others.

Again, unfortunately the MDNR has not enforced strong protections against the destruction of Great Lakes Barrens. The “reclamation” of destroyed dunes and jack pine barrens for a mere “one-year period at 80 percent vegetative cover” comes nowhere close to a viable mitigation plan, as trees and shrubs impacted in such areas take decades to recover.

Furthermore, other state-listed plants, such as ram’s head lady-slipper orchid (Cypripedium arietinum) are known to be adjacent to Sargent Sand property but are not legally protected as they are only “Special Concern” species. Lastly, the Lake Huron locust (Trimerotropsis huroniana) is a state Threatened insect known to occur within Ludington State Park, and suitable “sparsely vegetated dune” habitat is common within Sargent Sand’s property. If you thought rare plants get little respect, try to protect a threatened grasshopper!

Great Lakes Barrens often include seasonal wetlands that are protected under Section 404 of the Clean Water Act of 1972, but which often lack surface waters much of the year. Not surprisingly, the 1979 EIR does not mention “wetlands” at all. At best, there is a comment that “There are three or four very small swamp areas on the property…”  However, a review of recent aerial photography indicates many Interdunal Wetlands remain within the northern half of Sargent Sand property. The largest of these appears to be at least 0.5 acre in size, and it is likely that several acres of such wetlands exist on the property.

Consequently, a formal Wetland Delineation is needed to determine the exact location and amount of Jurisdictional Wetlands on Sargent Sand property. Any impact to such wetlands requires mitigation measures that include avoidance, minimization, and/or wetland creation elsewhere within the watershed. Additionally, Interdunal Wetlands are ranked S2 Natural Communities by the State of Michigan, and have a rank of G2 globally. Both of these designations indicate these areas are “Imperiled,” so mitigation ratios should be high (e.g., 10:1 or 20:1).

Current Political Climate in Ludington

The current political leadership in Michigan, as well as the nation, has presented a formidable challenge for environmentalists and scientists. Additionally, the system certainly appears rigged when the agency – the MDEQ – that issues permits and permit renewals is also a lobbyist for the oil, gas, and minerals industry. Nevertheless, the battle to protect this natural heritage is a noble and vital one that will persist. As with every other sensitive and rare environmental resource, if no one scrutinizes the lax protection of our natural heritage, before you know it, it will be gone.