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The Falcon Public Monitoring Project

Part of the Falcon Public EIA Project

In March of 2019, two and a half years after Shell Pipeline Co. announced plans for the Falcon Ethane Pipeline System, the imported pipes arrived at the Port of Philadelphia. As tree clearing and construction begins, we share frustration with residents that the project is underway while many of our concerns remain unaddressed.

Between 2010 and 2018, over 280 pipeline incidents were reported in Ohio, West Virginia, and Pennsylvania (the three states the Falcon crosses). Of those incidents, 70 were fires and/or explosions. As regulatory agencies and operators fail to protect the public, communities are taking the reins.

Residents of southwest PA gather along the Falcon route

Environmental organizations are training the public to spot construction violations and appealing inadequate pipeline permits. Impacted residents are running for office, testifying in court, and even spending time in prison to protect their communities.

These grassroots efforts are contributing to a shift in public perception about the safety and need of pipelines. In some cases, including with the Northeast Energy Direct Pipeline and the Constitution Pipeline, organizing efforts are helping stop projects before they begin.

We invite all residents along the Falcon route to get involved in ongoing efforts to monitor construction. Below, you’ll find a guide to reporting violations as well as high-risk areas along the Falcon route that require close monitoring.

Be a citizen watchdog

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Taking photos of pipeline development and recording your observations is a great way to monitor impacts. One tool to use while monitoring is the FracTracker mobile app (search “FracTracker” in the App Store or Google Play to download for free). The app allows the public to submit geolocated photos and descriptions of development, such as pipelines and wells, and concerns, such as spills and noise pollution. These reports help FracTracker crowdsource data and alert us to concerns that need follow up action. The app also contains a map of wells, pipelines, and compressor stations, including the Falcon pipeline route for reference in the field.

Click on the images below to view app reports of Falcon construction.

Documenting violations

During the construction phase, incidents often occur when companies cause erosion of the ground and release sediment, equipment, or discharge into waterways. Mountain Watershed Association and Clean Air Council have provided the following information on the process of looking for and documenting violations.

Step 1) Document baseline conditions. Documenting the pre-construction status of an area is crucial for understanding how it’s been impacted down the road. Document baseline conditions by taking photos, videos, and notes at different sites, and include the location and date on these materials (the Fractracker app does this for you automatically). Observing sites at different times and in different weather (such as during or after a storm) will give you the best data.

Step 2) Know what to look for. Below are images and descriptions of common construction violations.

Filtration Failure

Drilling fluid spill

For more violations, checkout Pipeline CSI’s list of Top Ten Observable Non-Compliance Issues.

3) File a Report. File an official complaint to your state environmental regulatory agency.

Your concerns can be sent to regulatory agencies using the following contact information:

4) Contact support organizations. There are several organizations ready to take action once violations have been confirmed. For confirmed violations in Beaver County, PA, contact Alex Bomstein, at the Clean Air Council (215-567-4004 x118) and for confirmed violations in Allegheny or Washington Counties, PA, contact Melissa Marshall at the Mountain Watershed Association (724-455-4200 x7#). For violations in Ohio or West Virginia, reach out to FracTracker (412-802-0273).

Reports made on the FracTracker App are shared with any app user and the FracTracker team, who look through the reports and contact users for any required follow up. App reports can also be submitted to regulatory agencies electronically. Simply visit the web version of the app, click on your report, and copy the URL (web address) of your report. Then “paste” it into the body of an email or online complaint form. The receiver will see the exact location, date, and any notes or photos you included in the report.

Where should you be monitoring?

Monitoring efforts must be limited to publicly accessible land. In general, areas that are most at-risk for environmental impact include stream and wetland crossings, steep slopes (particularly those near water crossings), flood-prone zones, and areas where storm water runoff will reach waterways. View a map of the Falcon’s water crossings here, and continue reading for more vulnerable locations to monitor.

The information below identifies high-risk areas along the pipeline route where monitoring efforts are extra necessary due to their impacts on drinking water, wetlands, undermined areas, and vulnerable species.

Drinking Water

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We found 240 private water wells within 1/4 mile of the Falcon.

While all of these wells should be assessed for their level of risk with pipeline construction, the subset of wells nearest to horizontal directional drilling (HDD) sites deserve particular attention. HDD is a way of constructing a pipeline that doesn’t involve digging a trench. Instead, a directional drilling machine is used to drill horizontally underground and the pipe is pulled through.

While an HDD is designed to avoid surface impacts, if rushed or poorly executed, it can damage surface water, groundwater, and private property. The Mariner East 2 pipeline construction left several families without water after construction crews punctured an aquifer at an HDD site.

Shell’s data highlights 24 wells that are within 1,000 feet of a proposed HDD site.

We’ve isolated the groundwater wells and HDDs in a standalone map for closer inspection below. The 24 most at-risk wells are circled in blue.

View Map Fullscreen | How FracTracker Maps Work

Testing your groundwater quality before construction begins is crucial for determining impacts later on. Two upcoming workshops in Washington County, PA and another in Beaver County, PA will discuss how to protect your water and property.

The Falcon’s HDD locations offer disturbing similarities to what caused the Mariner East pipeline spills. Many of Sunoco’s failures were due to inadequately conducted (or absent) geophysical surveys that failed to identify shallow groundwater tables, which then led to drilling mud entering streams and groundwater.

Figure 1 below shows Greene Township, Beaver County, just south of Hookstown, where the “water table depth” is shown. The groundwater at this HDD site averages 20ft on its western side and only 8ft deep on the eastern side.

Figure 1. Water table depth in Greene Township

Water Reservoirs

The Falcon also crosses the headwaters of two drinking water reservoirs: the Tappan Reservoir in Harrison County, OH (Figure 2) and the Ambridge Reservoir in Beaver County, PA (Figure 3).  The Falcon will also cross the raw water line leading out of the Ambridge Reservoir.

The Ambridge Reservoir supplies water to five townships in Beaver County (Ambridge, Baden, Economy, Harmony, and New Sewickley) and four townships in Allegheny County (Leet, Leetsdale, Bell Acres & Edgeworth). The Tappan Reservoir is the primary drinking water source for residents in Scio.

Figure 2. Tappan Reservoir and the Falcon route in Harrison County, Ohio

Figure 3. Ambridge Reservoir and the Falcon route in Beaver County, Pennsylvania

Wetlands

Wetlands that drain into Raccoon Creek in Beaver County, PA will be particularly vulnerable in 2 locations. The first is in Potter Township, off of Raccoon Creek Rd just south of Frankfort Rd, where the Falcon will run along a wooded ridge populated by half a dozen perennial and intermittent streams that lead directly to a wetland, seen in Figure 4. Complicating erosion control further, Shell’s survey data shows that this ridge is susceptible to landslides. This area is also characterized by the USGS as having a “high hazard” area for soil erosion.

Figure 4. Wetlands and streams in Potter Township, PA

The other wetland area of concern along Raccoon Creek is found in Independence Township at the Beaver County Conservation District (Figure 5). Here, the Falcon will go under the Creek using HDD (highlighted in bright green). Nevertheless, the workspace needed to execute the crossing is within the designated wetland itself. An additional 15 acres of wetland lie only 300ft east of the crossing but are not accounted for in Shell’s data. This unidentified wetland is called Independence Marsh, considered the crown jewel of the Independence Conservancy’s watershed stewardship program.

Figure 5. Wetlands and Raccoon Creek in Independence Township, PA

Subsurface concerns

Shell’s analysis shows that 16.8 miles of the Falcon pipeline travel through land that historically has or currently contains coal mines. Our analysis using the same dataset suggests the figure is closer to 20 miles. Construction through undermined areas poses a risk for ground and surface water contamination and subsidence. 

Of these 20 miles of undermined pipeline, 5.6 miles run through active coal mines and are located in Cadiz Township, OH (Harrison Mining Co. Nelms Mine, seen in Figure 6); Ross Township, OH (Rosebud Mining Co. Deep Mine 10); and in Greene Township, PA (Rosebud Mining Co. Beaver Valley Mine). 

Figure 6. Coal mines and are located in Cadiz Township, OH

For a complete map of mined areas, click here.

More than 25 of the Falcon’s 97 pipeline miles will be laid within karst landscapes, including 9 HDD sites. Karst is characterized by soluble rocks such as limestone prone to sinkholes and underground caves. A cluster of these are located in Allegheny and Washington counties, PA, with extensive historical surface mining operations.

The combination of karst and coal mines along Potato Garden Run, in Figure 7, make this portion of the pipeline route particularly risky. At this HDD site, the Falcon will cross a coal waste site identified in the permits as “Imperial Land Coal Slurry” along with a large wetland.

Figure 7. Coal mines in Imperial, Pennsylvania

Vulnerable species

Southern Redbelly Dace

The Southern Redbelly Dace, a threatened species, is especially vulnerable to physical and chemical (turbidity, temperature) changes to their environment. PA Fish and Boat Commission explicitly notes in their correspondence with Shell that “we are concerned about potential impacts to the fish, eggs and the hatching fry from any in-stream work.” Of note is that these sites of concern are located in designated “High Quality/Cold Water Fishes” streams of the Service Creek watershed (Figure 8). PFBC stated that that no in-stream work in these locations should be done between May 1 and July 31.

Figure 8. “High Quality/Cold Water Fishes” streams identified as habitat for the Southern Redbelly Dace

Northern Harriers & Short-Eared Owls

Portions of the Falcon’s workspace are located near 6 areas with known occurrences of Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species). Pennsylvania Game Commission requested a study of these areas to identify breeding and nesting locations, which were executed from April-July 2016 within a 1,000-foot buffer of the pipeline’s workspace (limited to land cover areas consisting of meadows and pasture). One Short-eared Owl observation and 67 Northern Harrier observations were recorded during the study. PGC’s determined that, “based on the unusually high number of observations at these locations” work should not be done in these areas during harrier breeding season, April 15 through August 31.

Figure 9. Surveyed areas for Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species)

Bald Eagles

A known Bald Eagle nest is located in Beaver County. Two potential “alternate nests” are located where the Falcon crosses the Ohio River. National Bald Eagle Management Guidelines bar habitat disturbances that may interfere with the ability of eagles to breed, nest, roost, and forage. The 1 active nest in close proximity to the Falcon, called the Montgomery Dam Nest, is located just west of the pipeline’s terminus at Shell’s ethane cracker facility.

U.S. Fish and Wildlife Service requested that Shell only implement setback buffers for the one active nest at Montgomery Dam (Figure 10). These include no tree clearing within 330 feet, no visible disturbances with 660 feet, and no excessive noise with 1,000 feet of an active nest. Furthermore, Shell must avoid all activities within 660ft of the nest from January 1st to July 31st that may disturb the eagles, including but not limited to “construction, excavation, use of heavy equipment, use of loud equipment or machinery, vegetation clearing, earth disturbance, planting, and landscaping.

Figure 10. Bald Eagle nest in Potter Township, Pennsylvania

Bats

The Falcon is located within the range of federally protected Indiana Bats and Northern Long-eared Bats in Pennsylvania and West Virginia. In pre-construction surveys, 17 Northern Long-eared Bats were found at 13 of the survey sites, but no Indiana Bats were captured.

A total of 9 Northern Long-eared Bat roost trees were located, with the nearest roost tree located 318 feet from the pipeline’s workspace. Figure 11 below shows a cluster of roost trees in Raccoon Township, PA. For a map of all the roost trees, click here. The U.S. Fish and Wildlife Service stated that “Due to the presence of several Northern Long-eared Bat roost trees within the vicinity of the project footprint (although outside of the 150-foot buffer), we recommend the following voluntary conservation measure: No tree removal between June 1 and July 31.”

The Pennsylvania Game Commission noted in early correspondences that Silver-haired Bats may be in the region (a PA species of special concern). PGC did not require a further study for the species, but did request a more restrictive conservation of no tree clearing between April 1 and October 31.

Figure 11. Northern long-eared bat roost trees in Raccoon Township, Pennsylvania

For more information on the wildlife impacts of the Falcon Pipeline, click here.

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To continue reading about this pipeline, visit the Falcon Public EIA Project. 

By documenting the impacts of the Falcon Pipeline, you’re contributing to a growing body of work that shows the risks of fossil fuel pipelines. Not only does this evidence protect drinking water and vulnerable species, it serves as evidence against an inherently dangerous project that will contribute to climate change and the global plastics crisis.

We hope you’re inspired to take action and add your voice to a growing team in the region committed to safer and healthier environments. Thank YOU for your dedication to the cause!

By Erica Jackson, Community Outreach and Communications Specialist, FracTracker Alliance.

Portions of this article were adapted from previous posts in the Falcon Public EIA Project, written by Kirk Jalbert.

Re: Falcon ethane pipeline project

Falcon Pipeline Moves Forward Despite Unresolved Concerns

Pittsburgh, PA – Yesterday, the Pennsylvania Department of Environmental Protection (DEP) announced their decision to issue a permit for the construction of Shell’s Falcon ethane pipeline project in southwest PA. FracTracker Alliance is extremely disappointed that DEP is allowing this project to proceed despite heavy opposition from the public and unaddressed concerns for the safety and well-being of nearby residents and the surrounding environment.

The past year has seen countless issues from the construction of new pipelines in the Commonwealth – from hundreds of “inadvertent returns,” (spills of bentonite drilling mud) along the path of the Mariner East II project to the catastrophic explosion of the week-old Revolution Pipeline in Beaver County. These reoccurring and serious incidents make it clear that oil and gas midstream companies are rushing to put infrastructure in place, and DEP and other regulatory agencies have been failing in their mission to adequately supervise the process.

According to data from the US Pipeline and Hazardous Materials Safety Administration, there were 108 pipeline incidents in Pennsylvania between January 2010 and mid-July 2018, resulting in 8 fatalities, 15 injuries, requiring over 1,100 people to be evacuated from their homes, and causing more than $66 million in property damage. This track record, which does not include the Revolution Pipeline explosion in September of 2018, is frankly unacceptable.

Certainly, the Commonwealth has invested heavily in the Shell Ethane Cracker facility, offering steep tax subsidies and even paying the global petrochemical giant $2.10 for every barrel of ethane it consumes from Pennsylvania wells, equivalent to $1.6 billion over the next 25 years. It appears to FracTracker that these business arrangements have made the continued extraction and exploitation of hydrocarbons the priority for DEP, not protecting the environment and health and safety of Pennsylvanians, as the mission of the Department suggests is their focus. DEP’s decision also traces an unfortunate pattern of opaqueness and poor timing by announcing unpopular decisions right before the holidays.

Fundamentally, oil and gas companies like Shell exist to make profits, and will therefore make decisions to maximize earnings and limit their costs, if left to their own devices. This approach is often directly at odds with public safety, so Pennsylvania entrusts DEP to oversee the operations. FracTracker feels that with their decision to move forward with the project on December 20, 2018, DEP brushed over dozens of substantial concerns regarding the Falcon ethane pipeline project, and therefore failed in this mission. We remain unconvinced that the “appropriate construction techniques and special conditions” required by DEP will adequately protect the environment and health and safety of residents along the Falcon pipeline route.

Dec. 21st Update: After this article was written, FracTracker learned that Ohio’s EPA issued an air quality permit for the cracker plant in Belmont County, Ohio on December 21st. The short public comment period and the rush to issue permits again illustrates that significant public health and environmental concerns are given minimal importance versus corporate wishes and political expediency. The regulatory paradigm is broken. The public has been ill served by the agencies entrusted to safeguard their interests. A collective regional voice should be raised in protest.

Brook LenkerExecutive Director, FracTracker Alliance

About FracTracker Alliance

Started in 2010 as a southwestern Pennsylvania area website, FracTracker Alliance is now a national organization with regional offices across the United States in Pennsylvania, Washington DC, New York, Ohio, and California. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Its goal is to support advocacy groups at the local, regional and national level, informing their actions to positively shape our nation’s energy future. www.fractracker.org


Learn more about FracTracker’s coverage of the Falcon ethane pipeline project by exploring the posts below:

A map of deficiencies along the Falcon Pipeline Route

The Falcon Pipeline: Technical Deficiencies

Part of the Falcon Public EIA Project

In August 2016, Shell announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. In response to available data, FracTracker launched the Falcon Public EIA Project in January of 2018 to unearth the environmental and public health impacts of the proposed pipeline. As part of that project, today we explore Shell’s Chapter 105 application and the deficiencies the Pennsylvania Department of Environmental Protection (DEP) cited after reviewing Shell’s application.

Just a heads up… there are a lot.

Shell originally submitted a Chapter 105 application to the DEP to receive a permit for water obstruction and encroachment. The DEP began reviewing the application in January of 2018. On June 1st, they sent Shell technical deficiency letters listing several issues with the application. Shell responded to these deficiencies on August 1st.

Now, it’s up to the DEP to decide if Shell’s response is adequate, and if the department should go ahead and approve the application or require more work from Shell. Explore the technical deficiencies below for more information.

Technical Deficiencies

Below is a map that highlights several of the deficiencies the DEP found with Shell’s application and a brief explanation of each one. Expand the map full-screen to explore more layers – Some layers only become visible when you zoom in due to the level of detail they display.

View Map Full Screen | How Our Maps Work

Next, we’ll walk you through the technical deficiencies, which we have broken down into the following categories:

  1. Wetlands, rivers, streams
  2. Stormwater control
  3. Public health and safety (drinking water & trails)
  4. Conservation areas
  5. Alternative routes
  6. Geological concerns (including mining issues)
  7. Documentation issues
Legend

A = Allegheny County, B = Beaver County, W = Washington County. The numbers reference the number listed in the deficiencies letter.

1. Wetlands, Rivers, & Streams

Water withdrawal from rivers and discharge

  • B2 A2 W2 The project will discharge waste water from an industrial activity to a dry swale, surface water, ground water, or an existing sanitary sewer system or separate storm water system. The DEP requested that Shell identify and describe this discharge, as the DEP’s Clean Water Program must authorize discharges. Shell stated that water will be discharged from hydrostatic testing, (which ensures a pipeline can withstand high pressure by pumping water through it to test for leaks), and a PAG-10 permit (needed for hydrostatic test water discharge) was submitted to the DEP July 27, 2018 with the locations of discharge. Drawings of the discharges are in Attachment O. (The locations of the discharges were not included in Shell’s public response to this deficiency.)
  • B33 A31 W31 Shell will be withdrawing water for hydrostatic testing. The DEP asked Shell to explain the intake and discharge methods so the DEP can decide if these should be included as impacts. The DEP also asked Shell to provide the location of intake and discharge. The DEP’s Clean Water Program must authorize discharges. In response, Shell stated that water will be withdrawn from Raccoon Creek and the Ohio River in West Virginia. The specific locations are listed in the PAG-10 permit, submitted to the DEP in July. Drawings of the discharges are included in Attachment O.

Wetlands and Streams

  • B5 A3 W4 The DEP asked Shell to identify the presence of wetlands within the project area that are identified by the US Fish & Wildlife Service’s National Wetlands Inventory (NWI) data system, and provide data on how they may be impacted by the proposed pipeline.  Shell identified one NWI wetland in Beaver County, but did not delineate or provide information on it, due to safety concerns (it’s on a steep cliff). This wetland will be crossed via HDD (horizontal directional drill). In Allegheny County, there is an NWI wetland that Shell also did not provide data on. This wetland was not initially evident, and when staff returned to survey it, the property owner did not let them access the site because they did not want a pipeline on their property. According to Shell, this NWI wetland is not within the “Project’s Limit of Disturbance.” In Washington County, Shell stated that “all of the NWI-mapped wetlands that were determined not to be wetlands have been accounted for in Washington County. These NWI wetlands were all located in an area that had been previously strip-mined and due to mining activities, those wetlands are no longer there. Data were taken for these areas and included… separately as Attachment D.” Also in Washington County is an NWI wetland located above the Panhandle Trail, which Shell determined to be outside of the study area and therefore did not collect data on it. This wetland is not on the map, but Shell did provide this image of it.
  • B6 A4 W5 The DEP requested that Shell match off-line wetland data with sampling point locations from study area maps. In response, Shell placed offline data sheets in the order that they are in Table 3 in the Wetlands Delineation Report and in Table 4 in the Watercourse Delineation Report.
  • B7 A5 W6 Shell needed to discuss the types and conditions of riverine resources that the project impacts. Specifically, how the conditions of these resources relate to their hydrological functions, biogeochemical functions, and habitat attributes. These are discussed under question 7 for Beaver County, question 5 for Allegheny County, and question 6 for Washington County.
  • B8 A6 W7 Shell needed to discuss the types and conditions of wetlands that the project impacts. Specifically, how the conditions of these wetlands contribute to their hydrological functions, biogeochemical functions, and habitat attributes. Shell also needed to discuss impacts to wetlands that will be temporarily impacted, as it previously only discussed wetlands facing permanent impacts. These are discussed under question 8 for Beaver County, question 6 for Allegheny County, and question 7 for Washington County.
  • B9 A7 W8 The DEP asked Shell to evaluate the impact of open cut installation on wetlands with perched water tables and/or confining layers. Perched water tables have an impermeable confining layer (such as clay) between them and the main water table below. If open cut methods are used, the confining layer is destroyed and this water table will be lost. In Beaver County, Shell identified one wetland (W-PA-170222-MRK-002) will be open cut. If it is perched, Shell states it will replace the confining layer “along the same horizon during pipeline backfilling, and then [compact the layer] so that hydrology may be maintained.” Shell will also put trench plugs “on either side of the wetland on the ROW to prevent water from migrating out on the sides.” In Allegheny County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160401-MRK-006, W-PA-161220-MRK-001, and W-PA-161220-MRK-002.In Washington County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160407-JLK-002, W-PA-151203-MRK-005, and W-PA-151203-MRK-006.
  • A11 The DEP asked Shell to evaluate if any wetlands can be classified as “exceptional value” due to their proximity to nesting areas of the northern harrier (a threatened species in Pennsylvania). Wetlands are exceptional value if they serve as habitat for threatened or endangered species, or if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain habitat for the species in the wetland. Shell determined that there are six wetlands that could be nesting areas for northern harriers, and therefore are exceptional value (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003, W-PA-170207-MRK-001, W-PA-170113-MRK-008, W-PA-170113-MRK-001). Three of these wetlands are within the project’s LOD (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003).
  • B13 A10 W11 The DEP asked Shell to evaluate whether the proposed Falcon Pipeline will impact wetlands that are of “exceptional value” based on their proximity to public water systems. Wetlands can be considered “exceptional value” if they are located along public or private drinking water supplies (surface or ground water), and help maintain the quality or quantity of the supply. Shell stated that the (potentially man made) ponds near public water supply A could be considered exceptional value, however, they are located outside of the project’s study area and were not delineated, therefore Shell does not have information on them or their impact to this well. There were no other wetlands Shell considered to be exceptional value based on their proximity to public water systems.
  • B21 There were two protected plant species- harbinger of spring (PA threatened) and purple rocket (PA endangered)- located within the Raccoon Creek floodplain. The DEP asked Shell to evaluate whether there are wetlands in the project area that should be considered “exceptional value” due to their proximity to these species. Wetlands are considered “exceptional value” if they serve as habitat for a threatened or endangered plant or animal species. They are also exceptional value if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain the habitat of the species. There are six wetlands near populations of these plant populations: W-PA-151014-MRK-001, W-PA-151013-MRK-002, -003, and -004, W-PA-170407-JLK-001, W-PA151013-MRK-001. However, Shell stated that the harbinger of spring is not dependent on wetland habitat for survival and the species is considered an upland plant species (because it is not listed on Eastern Mountains and Piedmont List or on the National Wetland Plant List).  Purple rocket is listed as a “Facultative Wetland Plant” (FACW) on both lists. However, Shell stated that, “although it is a FACW, this plant is not one that occurs in wetlands,” and the population of purple rocket was found in an upland, disturbed area. Therefore, Shell determined that none of these wetlands are considered exceptional value.
  • B23 A21 W21 Shell needs to assess cumulative impacts to wetlands from the proposed pipeline and other existing projects and potential future projects. These are discussed in the Cumulative Impact Assessment document, Sections 4.1 and 4.2, and Tables B1 and B2.
  • B24 A22 W22 Shell needed to provide an explanation of how it will restore wetlands and streams disturbed during construction. The explanation needed to include information on seed mixes, shrubs, and trees that will restore stream banks and riparian areas.
  • B26 A24 W24 Shell needed to provide a table that lists, describes, and quantifies permanent impacts to wetlands and watercourses. Shell stated that there are no permanent fills associated with the project, but there will be permanent conversion impacts to the following wetlands. They total 10,862 ft2 or 0.25 acres in Beaver County, 5,166 ft2 (0.12 acres) in Allegheny County, and 4971 ft2 (0.11 acres) in Washington County. (W-PA-151013-JLK-005, W-PA-161202-MRK-001, W-PA-160404-MRK-001, W-PA-160412-CBA-004, W-PA-160412-CBA-001, W-PA-161205-WRA-003, W-PA-160401-MRK-005, W-PA-170213-JLK-003, W-PA-160406-MRK-001, W-PA-170413-RCL-005, W-PA-170214-CBA-005.)
  • B27 A25 W25 Shell needed to provide more information on the Neshannock Creek Restoration site, including a master restoration plan for the entire site. This mitigation is required to offset conversion impacts to wetlands along the pipeline route. The plan for the site is documented here.
  • B28 A26 W26 Shell needed to provide the location and resource crossing number for the HDDs in PA. They are listed in these tables:

Allegheny County:Table of Resources Falcon Pipeline Crosses by HDD in Allegheny County

Washington County:

Beaver County:

Table of water resources the Falcon pipeline crosses by HDD

2. Stormwater control

  • B3 A1 W1 Shell indicated that the project was in a floodplain project by the Commonwealth, a political subdivision of the commonwealth or a public utility. The DEP asked for an identification of this floodplain project, to which Shell responded that it misunderstood the question and the pipeline will not go through a floodplain project by one of these entities, but rather a floodway. The pipeline will pass many floodways, which are listed in Table 1 in separate documents for Beaver County, Allegheny County, and Washington County.
  • W3 The DEP requested that Shell provide an analysis of impact to Act 167 plans. Act 167 requires counties to create stormwater management plans and municipalities to adopt ordinances to regulate development in accordance with these plans. The pipeline route occurs in areas with Act 167 plans in Chartiers Township, Mount Pleasant Township, and Robinson Township.

3. Public health and safety

  • B1 The proposed pipeline does not meet the provisions of a zoning ordinance or have zoning approval in a particular area. Specifically, in Independence Township, the pipeline is within setback distances of places of congregation and/or of residences. One example is the Beaver County Conservation District, considered a place of congregation. Shell responded to this deficiency, saying it is working with Independence Township to obtain necessary approvals, and the township will “officially remove the pipeline ordinance from their records and no variances or permits will be required.”
  • B10 A8 W9 The DEP requested that Shell evaluate and discuss how the pipeline may impact public water systems that are within 1 mile of the pipeline route. Shell located 12 sites within a mile, most of which are ground water wells. One site is the Ambridge Water Authority, which provides drinking water for an estimated 30,000 people. Shell stated that impacts “might include an Inadvertent Return (IR) causing a bentonite slurry mix to enter the supply, which might contaminate the supply for any wells that are located near an HDD site or construction equipment.” Shell stated that all wells are a minimum of 1000 feet outside construction zones and built in thick bedrock which will minimize threat on contamination. The sites within 1 mile include:
    • Youthtowne Barn
    • Beaver County Conservation District
    • Independence Elementary School
    • Independence Volunteer Fire Department
    • McConnell’s Farm and Market, Inc
    • Ambridge Water Authority- Independence Township
    • Ambridge Water Authority- Raccoon Township
    • Hookstown Free Methodist Church
    • Hookstown Fair
    • Hookstown Grange
    • South Side Memorial Post 952
    • Jack’s Diner
    • NOVA Chemical, Inc
  • B11 A9 W10 The DEP asked Shell to discuss efforts to avoid/minimize impacts to the above public water systems, and suggested that efforts “might include, but are not limited to, considering alternative locations, routings or design for the proposed pipeline; providing provisions for shut-off in the event of break or rupture; etc.” Shell stated that the route avoids direct impacts to groundwater wells and surface water intake. Shell will provide water buffalos if wells are contaminated, and drill new wells if necessary. There are mainline valves approximately 7 to 7.5 miles apart that can automatically shut off the flow of ethane. There will also be staff living within the project area that can quickly respond to issues.
  • B12 The pipeline crosses headwaters of the Ambridge Reservoir and the Reservoir’s raw water service pipeline, which supplies water to 30,000 residents. The DEP noted significant public concern regarding this crossing, and asked Shell to evaluate and discuss the pipeline’s potential to affect the Reservoir and public water supply service. The DEP also asked Shell to elaborate on efforts to avoid/minimize impacts, and what measures will be implemented to mitigate any unavoidable impacts. In response, Shell stated the pipeline will cross the raw water line via an HDD  31 feet below the line. Shell explained that the water service line is made of pre-stressed concrete, which cannot be retrofitted in the field if a break occurs. It can take six weeks for pipe joints to be made and delivered from Ohio if there is a rupture. Shell stated it will supply extra pipe joints so the Ambridge Water Authority can have pieces on deck in case of a break. Shell also outlined the protective coatings and design of the HDD portion of the pipeline that will cross the water line, and said valves that can shut off the pipeline are located 2.4 miles from one side of the water line and 3.5 on the other.
  • A17 W17 The DEP asked Shell to consider the proposed pipeline’s effect on the Montour Trail, a multi-use, recreational trail, and to consider re-routes that would avoid impacts to the Trail. Shell determined that routing around the trail is not feasible. Shell will use conventional bore or HDD methods. If the trail needs to be temporarily closed during construction, operation, or maintenance, Shell will notify the trail owner and provide alternate temporary access for trail users. Shell will also cross the Panhandle Trail by HDD. The entrance and exit sights of the bore will not be on the trail’s property. Shell has “unlimited ingress and egress over Owners property” for inspections, repair and maintenance of the pipeline, and in case of emergency situations.
  • B29 A27 W27 Shell needed to revise the “Shell Pipeline HDD Procedure” to include HDD site feasibility analysis, inadvertent return risk assessment, water supply protection, agency contact information, etc. Shell’s response is included in the document, Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan.
  • B30 A28 W28 Shell needed to include a preboring geologic evaluation to determine if drinking water supplies will be impacted around boring locations. Shell also needed to discuss how it will verify that drinking water sources and aquifers are protected and what measures will be taken in the event that they are impacted. Shell’s response is included as Appendix C to this document.

4. Conservation

  • B19 A18 W18 19A 19W – There are many areas important for the region’s biodiversity and natural heritage that the proposed pipeline passes near or through. The DEP asked Shell to evaluate impacts to these areas. Information on them is available from the Pennsylvania Natural Heritage Program. They include:
    • Ambridge Reservoir Valleys Natural Heritage Area
    • Lower Raccoon Creek Natural Heritage Area
    • Raccoon Creek Valley and Wildflower Reserve Natural Heritage Area
    • Raccoon Creek Floodplain Biologically Diverse Area
    • Raccoon Creek Landscape Conservation Area
    • Clinton Wetlands Biologically Diverse Area
    • Raccoon Creek Landscape Conservation Area
    • Raccoon Creek Valley & State Park Important Bird Area – Regarding the Important Bird Area, Shell stated that 23 miles of the pipeline is located within this area. Shell has not been able to get in contact with the National Audobon SW PA office. Shell added that the only waterbody large enough in the project area to support the documented waterfowl is the open water at Beaver County Conservation District. Shell stated that “an outlet has been installed at the far end of the lake to restore it to more of a wetland and less of a lake, as it was originally designed.Raccoon Creek Valley is also a passageway for migratory birds, which are protected under the Migratory Bird Treaty Act. Shell stated that less than 2% of this Important Bird Area will be permanently impacted by pipeline construction and installation.

5. Alternative locations

  • B17 A15 W15 The DEP asked Shell to revise its current alternatives and provide a more detailed “analysis of the alternative locations and routes that were considered to avoid or minimize adverse environmental impacts.” The alternatives are discussed in Section 9 of Shell’s Comprehensive Environmental Assessment.
  • B18 16A 16W According to the DEP, “18.5 of the 45 miles (41%) of the proposed pipeline are parallel to or adjacent to existing right-of-ways (ROWs).” The DEP asked Shell to see if there are additional opportunities to build the pipeline within existing ROWs, with the hope of reducing environmental impacts. In response, Shell discussed the additional ROWs that were considered (along Mariner West) but ultimately rejected. Shell discusses these routes more in Section 9.1 of the Comprehensive Environmental Assessment.
  • B32 A30 W30 The DEP asked Shell to discuss the feasibility of several changes to the proposed pipeline’s route, including avoiding impacts to wetlands, relocating resource crossings, moving valve sites outside of wetlands, moving HDD locations, and evaluating the impact to a coal refuse pile (the pipeline crosses underneath at least one pile via HDD). These reroutes are discussed under question 32 for Beaver County, question 30 for Allegheny County, and question 30 for Washington County.

6. Geological concerns

  • B14 12A 12W The pipeline is located in previously coal mined areas. The DEP asked Shell to provide a map of the pipeline that showed these mining areas, and GIS shape files with this information. Shell’s response is included in the HDD Subsurface Investigation Reports, which includes the following table of the extent of mined areas along the pipeline route:
  • B15 A13 W13 The pipeline is located in coal mined areas, which could be susceptible to subsidence and/or mine water discharge. The DEP requested that Shell revise drawings to show the limits of previously mined areas, depth of cover over the mine workings in areas the proposed pipeline crosses through, and the distance between mine workings and the proposed pipeline. Furthermore, the DEP asked Shell to “evaluate and discuss the potential for a subsidence event compromising the utility line, and the potential to create a mine water discharge.” Shell discusses this in Appendix B of this this document and in the Mining Summary Report. Shell also identifies the following areas as being at risk for coal mine discharge: HOU MM 1.2, HOU MM 8.9 (proposed HDD), HOU MM 12.1, HOU MM 12.95, HOU MM 13.1, HOU MM 13.6, HOU MM 17.4, and HOU MM 17.65 (proposed HDD).
  • B16 A14 14W The DEP requested that Shell include areas where the pipeline will cross active mining permit boundaries. There is one active mining permit boundary that intersects the proposed pipeline, the Rosebud Mine in Beaver County.
  • B31 A29 W29 Shell needed to evaluate the potential for the project to encounter areas underlain by carbonate bedrock and landslide prone areas. Carbonate bedrock is indicative of a karst landscape, meaning an area likely to have underground sinkholes and caves. The DEP also asked Shell to discuss precautionary methods taken during construction in these areas. Shell’s response is included in the Carbonate Rock Analysis and Slope Stability and Investigation Report. The Carbonate Rock Analysis report shows that carbonate bedrock was encountered in 20 out of 40 of the borings taken during the analysis.

7. Documentation

  • B4 The PA DEP asked Shell to describe the structures and activities that occur within junction sites. Shell responded that there will be a Junction Custody Transfer Meter Station at the site, and provided maps of the site.
  • B22 20A 20w The DEP requested that Shell revise their Comprehensive Environmental Assessment to include alternatives, impacts, and mitigation items that were previously included in other sections of their environmental assessment.
  • B25 A23 W23 The DEP asked Shell to provide a copy of the Mitigation Bank Credit Availability Letter from First Pennsylvania Resource, LLC. In response, Shell stated the Letter is no longer needed because “the permanent stream and wetland fills have been removed from this project.”
  • B34 A32 W32 The DEP asked Shell to include a copy of the Preparedness, Prevention, and Contingency Plan.
  • B35 A33 W33 Shell needs to include all of the above modifications to the application in the Chapter 103 permit application.

Conclusion

As evidenced by the list above, the proposed Falcon Pipeline poses a variety of threats to Pennsylvania’s natural resources, wildlife, and public health – but this deficiencies list is likely not complete. The pipeline also passes through West Virginia and Ohio, and if completed, will likely attract more pipelines to the area. As it feeds Shell’s ethane cracker plant in Beaver County, it is a major step towards the region becoming a hub for plastic manufacturing. Therefore, the public response to the above deficiencies and the decision the DEP makes regarding them will have major implications for the Ohio River Valley’s future.

Of note: The DEP’s letters and Shell’s response to them are available to the public in separate documents for  Allegheny, Beaver, and Washington Counties. 


By Erica Jackson, Community Outreach and Communications Specialist

Shell Pipeline - Not Quite the Good Neighbor

Shell Pipeline: Not Quite the “Good Neighbor”

In August 2016, Shell Pipeline announced plans to develop the Falcon Ethane Pipeline System, a 97-mile pipeline network that will carry more than 107,000 barrels of ethane per day through Pennsylvania, West Virginia, and Ohio, to feed Shell Appalachia’s petrochemical facility currently under construction in Beaver County, PA.

FracTracker has covered the proposed Falcon pipeline extensively in recent months. Our Falcon Public EIA Project explored the project in great detail, revealing the many steps involved in risk assessments and a range of potential impacts to public and environmental health.

This work has helped communities better understand the implications of the Falcon, such as in highlighting how the pipeline threatens drinking water supplies and encroaches on densely populated neighborhoods. Growing public concern has since convinced the DEP to extend public comments on the Falcon until April 15th, as well as to host three public meetings scheduled for early April.

Shell’s response to these events has invariably focused on their intent to build and operate a pipeline that exceeds safety standards, as well as their commitments to being a good neighbor. In this article, we investigate these claims by looking at federal data on safety incidents related to Shell Pipeline.

Contrary to claims, records show that Shell’s safety record is one of the worst in the nation.

The “Good Neighbor” Narrative

Maintaining a reputation as a “good neighbor” is paramount to pipeline companies. Negotiating with landowners, working with regulators, and getting support from implicated communities can hinge on the perception that the pipeline will be built and operated in a responsible manner. This is evident in cases where Shell Pipeline has sold the Falcon in press releases as an example of the company’s commitment to safety in public comments.

Figure 1. Shell flyer

A recent flyer distributed to communities in the path of the Falcon, seen in Figure 1, also emphasizes safety, such as in claims that “Shell Pipeline has a proven track record of operating safely and responsibility and remains committed to engaging with local communities regarding impacts that may arise from its operations.”

Shell reinforced their “good neighbor” policy on several occasions at a recent Shell-sponsored information meeting held in Beaver County, stating that, everywhere they do business, Shell was committed to the reliable delivery of their product. According to project managers speaking at the event, this is achieved through “planning and training with first responders, preventative maintenance for the right-of-way and valves, and through inspections—all in the name of maintaining pipeline integrity.”

Shell Pipeline also recently created an informational website dedicated to the Falcon pipeline to provide details on the project and emphasize its minimal impact. Although, curiously, Shell’s answer to the question “Is the pipeline safe?” is blank.

U.S. Pipeline Incident Data

Every few years FracTracker revisits data on pipeline safety incidents that is maintained by the Pipeline and Hazardous Materials Safety Administration (PHMSA). In our last national analysis we found that there have been 4,215 pipeline incidents resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion.

These numbers were based on U.S. data from 2010-2016 for natural gas transmission and gathering pipelines, natural gas distribution pipelines, and hazardous liquids pipelines. It is also worth noting that incident data are heavily dependent on voluntary reporting. They also do not account for incidents that were only investigated at the state level.

Shell Pipeline has only a few assets related to transmission, gathering, and distribution lines. Almost all of their pipeline miles transport highly-volatile liquids such as crude oil, refined petroleum products, and hazardous liquids such as ethane. Therefore, to get a more accurate picture of how Shell Pipeline’s safety record stacks up to comparable operators, our analysis focuses exclusively on PHMSA’s hazardous liquids pipeline data. We also expanded our analysis to look at incidents dating back to 2002.

Shell’s Incident Record

In total, PHMSA data show that Shell was responsible for 194 pipeline incidents since 2002. These incidents spilled 59,290 barrels of petrochemical products totaling some $183-million in damages. The below map locates where most of these incidents occurred. Unfortunately, 34 incidents have no location data and so are not visible on the map. The map also shows the location of Shell’s many refineries, transport terminals, and off-shore drilling platforms.

Open the map fullscreen to see more details and tools for exploring the data.


View Map Fullscreen | How FracTracker Maps Work

Incidents Relative to Other Operators

PHMSA’s hazardous liquid pipeline data account for more than 350 known pipeline operators. Some operators are fairly small, only maintaining a few miles of pipeline. Others are hard to track subsidiaries of larger companies. However, the big players stand out from the pack — some 20 operators account for more than 60% of all pipeline miles in the U.S., and Shell Pipeline is one of these 20.

Comparing Shell Pipeline to other major operators carrying HVLs, we found that Shell ranks 2nd in the nation in the most incidents-per-mile of maintained pipeline, seen in table 1 below. These numbers are based on the total incidents since 2002 divided by the number of miles maintained by each operator as of 2016 miles. Table 2 breaks Shell’s incidents down by year and number of miles maintained for each of those years.

Table 1: U.S. Pipeline operators ranked by incidents-per-mile

Operator HVL Incidents HVL Pipeline Miles Incidents Per Mile (2016)
Kinder Morgan 387 3,370 0.115
Shell Pipeline 194 3,490 0.056
Chevron 124 2,380 0.051
Sunoco Pipeline 352 6,459 0.049
ExxonMobile 240 5,090 0.048
Colonial Pipeline 244 5,600 0.044
Enbride 258 6,490 0.04
Buckeye Pipeline 231 7,542 0.031
Magellan Pipeline 376 12,928 0.03
Marathan Pipeline 162 5,755 0.029

Table 2: Shell incidents and maintained pipeline miles by year

Year Incidents Pipeline Miles Total Damage Notes
2002 15 no PHMSA data $2,173,704
2003 20 no PHMSA data $3,233,530
2004 25 5,189 $40,344,002 Hurricane Ivan
2005 22 4,830 $62,528,595 Hurricane Katrina & Rita
2006 10 4,967 $11,561,936
2007 5 4,889 $2,217,354
2008 12 5,076 $1,543,288
2009 15 5,063 $11,349,052
2010 9 4,888 $3,401,975
2011 6 4,904 $2,754,750
2012 12 4,503 $17,268,235
2013 4 3,838 $10,058,625
2014 11 3,774 $3,852,006
2015 12 3,630 $4,061,340
2016 6 3,490 $6,875,000
2017 9 no PHMSA data $242,800
2018 1 no PHMSA data $47,000 As of 3/1/18

Cause & Location of Failure

What were the causes of Shell’s pipeline incidents? At Shell’s public informational session, it was said that “in the industry, we know that the biggest issue with pipeline accidents is third party problems – when someone, not us, hits the pipeline.” However, PHMSA data reveal that most of Shell’s incidents issues should have been under the company’s control. For instance, 66% (128) of incidents were due to equipment failure, corrosion, welding failure, structural issues, or incorrect operations (Table 3).

Table 3. Shell Pipeline incidents by cause of failure

Cause Incidents
Equipment Failure 51
Corrosion 37
Natural Forces 35
Incorrect Operation 25
Other 20
Material and/or Weld Failure 15
Excavation Damage 11
Total 194

However, not all of these incidents occurred at one of Shell’s petrochemical facilities. As Table 4 below illustrates, at least 57 incidents occurred somewhere along the pipeline’s right-of-way through public areas or migrated off Shell’s property to impact public spaces. These numbers may be higher as 47 incidents have no mention of the property where incidents occurred.

Table 4. Shell Pipeline incidents by location of failure

Location Incidents
Contained on Operator Property 88
Pipeline Right-of-Way 54
Unknwon 47
Originated on Operator Property, Migrated off Property 3
Contained on Operator-Controlled Right-of-Way 2
Total 194

On several occasions, Shell has claimed that the Falcon will be safely “unseen and out of mind” beneath at least 4ft of ground cover. However, even when this standard is exceeded, PHMSA data revealed that at least a third of Shell’s incidents occurred beneath 4ft or more of soil.

Many of the aboveground incidents occurred at sites like pumping stations and shut-off valves. For instance, a 2016 ethylene spill in Louisiana was caused by lightning striking a pumping station, leading to pump failure and an eventual fire. In numerous incidents, valves failed due to water seeping into systems from frozen pipes, or large rain events overflowing facility sump pumps. Table 5 below breaks these incidents down by the kind of commodity involved in each case.

Table 5. Shell Pipeline incidents by commodity spill volumes

Commodity Barrels
Crude Oil 51,743
Highly Volatile Liquids 6,066
Gas/Diesel/Fuel 1,156
Petroleum Products 325
Total 59,290

Impacts & Costs

None of Shell’s incidents resulted in fatalities, injuries, or major explosions. However, there is evidence of significant environmental and community impacts. Of 150 incidents that included such data, 76 resulted in soil contamination and 38 resulted in water contamination issues. Furthermore, 78 incidents occurred in high consequence areas (HCAs)—locations along the pipeline that were identified during construction as having sensitive environmental habitats, drinking water resources, or densely populated areas.

Table 6 below shows the costs of the 194 incidents. These numbers are somewhat deceiving as the “Public (other)” category includes such things as inspections, environmental cleanup, and disposal of contaminated soil. Thus, the costs incurred by private citizens and public services totaled more than $80-million.

Table 6. Costs of damage from Shell Pipeline incidents

Private Property Emergency Response Environmental Cleanup Public (other) Damage to Operator Total Cost
$266,575 $62,134,861 $11,024,900 $7,308,000 $102,778,856 $183,513,192

A number of significant incidents are worth mention. For instance, in 2013, a Shell pipeline rupture led to as much as 30,000 gallons of crude oil spilling into a waterway near Houston, Texas, that connects to the Gulf of Mexico. Shell’s initial position was that no rupture or spill had occurred, but this was later found not to be the case after investigations by the U.S. Coast Guard. The image at the top of this page depicts Shell’s cleanup efforts in the waterway.

Another incident found that a Shell crude oil pipeline ruptured twice in less than a year in the San Joaquin Valley, CA. Investigations found that the ruptures were due to “fatigue cracks” that led to 60,000 gallons of oil spilling into grasslands, resulting in more than $6 million in environmental damage and emergency response costs. Concerns raised by the State Fire Marshal’s Pipeline Safety Division following the second spill in 2016 forced Shell to replace a 12-mile stretch of the problematic pipeline, as seen in the image above.

Conclusion

These findings suggest that while Shell is obligated to stress safety to sell the Falcon pipeline to the public, people should take Shell’s “good neighbor” narrative with a degree of skepticism. The numbers presented by PHMSA’s pipeline incident data significantly undermine Shell’s claim of having a proven track record as a safe and responsible operator. In fact, Shell ranks near the top of all US operators for incidents per HVL pipeline mile maintained, as well as damage totals.

There are inherent gaps in our analysis based on data inadequacies worth noting. Incidents dealt with at the state level may not make their way into PHMSA’s data, nor would problems that are not voluntary reported by pipeline operators. Issues similar to what the state of Pennsylvania has experienced with Sunoco Pipeline’s Mariner East 2, where horizontal drilling mishaps have contaminated dozens of streams and private drinking water wells, would likely not be reflected in PHMSA’s data unless those incidents resulted in federal interventions.

Based on the available data, however, most of Shell’s pipelines support one of the company’s many refining and storage facilities, primarily located in California and the Gulf states of Texas and Louisiana. Unsurprisingly, these areas are also where we see dense clusters of pipeline incidents attributed to Shell. In addition, many of Shell’s incidents appear to be the result of inadequate maintenance and improper operations, and less so due to factors beyond their control.

As Shell’s footprint in the Appalachian region expands, their safety history suggests we could see the same proliferation of pipeline incidents in this area over time, as well.

NOTE: This article was amended on 4/9/18 to include table 2.

Header image credit: AFP Photo / Joe Raedle

By Kirk Jalbert, FracTracker Alliance

Falcon Public EIA Project feature image

Wingspan of the Falcon Pipeline

A Public EIA of Shell’s Ethane Cracker Pipeline

Pittsburgh, Pennsylvania – Jan. 29 – FracTracker Alliance has released a detailed environmental impact assessment (EIA), including digital maps, of the Falcon Ethane Pipeline being built to feed Shell Appalachia’s ethylene cracker plant in Beaver County, PA.

FracTracker’s Falcon Public EIA Project offers a rich series of interactive maps and articles detailing the Falcon’s proposed route through PA, WV, and OH, likely impacts to waterways, potential blast zones, ecological footprint, proximity to hazardous industrial areas, and more.

Given the issues associated with Mariner East 2 – a PA-based natural gas liquids pipeline whose history has been fraught with citations, public scrutiny is a crucial facet of pipeline construction. The Falcon Public EIA Project represents the first time that public stakeholders have been given such a significant amount of time and detail to investigate a proposed pipeline, including access to specific location information. Public comments are being accepted by the PA Department of Environmental Protection on the Falcon’s permit until February 20th.

“Companies are generally not required to publicly disclose GIS data when applying for permits,” remarked Kirk Jalbert, project lead and Manager of Community Based Research and Engagement at FracTracker. “While concerned citizens can stitch together paper maps provided by companies in their applications, that process can be complex and very labor intensive.”

With FracTracker’s project, however, digital maps and figures are front and center.

Early access to what is being proposed for the Falcon pipeline will enable nearby communities to better understand how its construction and the associated ethane cracker facility, which will produce 1 million tons of ethylene annually for making plastics, will affect their lives. Upon analyzing the data, FracTracker uncovered a number of particularly noteworthy statistics, for example:

  • There are 97.5 miles of pipeline proposed to be built through 22 townships in 3 states.
  • 2,000 properties have been surveyed; 765 easements executed.
  • Falcon will intersect 319 streams and 174 wetlands, with hundreds more proximate to work areas.
  • 550 family residences, 20 businesses, 240 groundwater wells, 12 public parks, 5 schools, 6 daycare centers, and 16 emergency response centers are within potential risk areas.
  • Learn more

“Extreme levels of risk and injustice are commonplace in petrochemical pipeline siting, as well as in where their contents come from and how they get used. This project provides context for the importance of reducing these impacts, both for curtailing environmentally unfriendly plastics as well as for moving away from fossil fuel dependencies,” said Brook Lenker, Executive Director of FracTracker.

The Falcon Public EIA Project is meant to expand public dialogue about what should be included in EIAs and how they should apply to petrochemical pipelines. The project also serves as a model for how regulatory agencies can be more transparent with data when engaging the public. This is especially important in the case of the Falcon pipeline, which will be exempt from Federal Energy Regulatory Commission (FERC) scrutiny and, therefore, not be subject to a full environmental impact assessment.

Pipeline Regulations & Impact Assessments, a Primer

Part of the Falcon Public EIA Project

Pipelines are categorized by what they carry — natural gas, oil, or natural gas liquids (NGLs) — and where they go — interstate or intrastate. The regulatory system is complicated. This primer is a quick guide to the agencies that may be involved in Falcon’s permit reviews.

Regulating Pipelines

The siting of natural gas pipelines crossing state or country boundaries is regulated by the Federal Energy Regulatory Commission (FERC). Meanwhile, determination of the location of natural gas routes that do not cross such boundaries are not jurisdictional to FERC, instead determined by the owner pipeline company. Hazardous liquids and NGL pipelines are not regulated for siting by FERC regardless of their location and destination. However, FERC does have authority over determining rates and terms of service in these cases. The U.S. Army Corps of Engineers gets involved when pipelines cross navigable waters such as large rivers and state Environmental Protection Agencies.

Pipeline design, operation, and safety regulations are established by the Pipeline and Hazardous Materials Safety Administration (PHMSA), but these regulations may vary state-by-state as long as minimal federal standards are met by the pipeline project. Notably, PHMSA’s oversight of safety issues does not determine where a pipeline is constructed as this is regulated by the different agencies mentioned above – nor are PHMSA’s safety considerations reviewed simultaneously in siting determinations done by other agencies.

An excerpt from the U.S. Army Corps’ EIS of the Atlantic Sunrise pipeline

These federal agencies are required by the National Environmental Policy Act (NEPA) to prepare an Environmental Impact Statement (EIS) investigating how the pipeline pertains to things like the Clean Water Act, the Endangered Species Act, the National Historic Preservation Act, as well as state and local laws. The image above, for instance, is a caption from the Army Corp’s assessment of the Atlantic Sunrise, a natural gas pipeline.

An EIS is based on surveying and background research conducted by the company proposing the project, then submitted to agencies as an Environmental Impact Assessment (EIA). An EIS can exceed hundreds of pages and can go through many drafts as companies are asked to refine their EIA in order to qualify for approval.

An excerpt from the PA DEP’s review of water crossings for the Mariner East 2 pipeline

Pipeline proposals are also evaluated by state and local agencies. In Pennsylvania, for instance, the PA DEP is responsible for assessing how to minimize pipeline impacts. The DEP’s mission is to protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment. The PA Fish and Boat Commission oversees the avoidance or relocation of protected species. Local township zoning codes can also apply, such as to where facilities are sited near zoned residential areas or drinking reservoirs, but these can be overruled by decisions made at the federal level, especially when eminent domain is granted to the project.

Regulating the Falcon

For the Falcon pipeline, an interstate pipeline that will transport ethane (an NGL), FERC will likely have authority over determining rates and terms of service, but not siting. Construction permitting will be left state agencies and PHMSA will retain its federal authority with the Pennsylvania Public Utilities Commission (PUC) acting as PHMSA’s state agent to ensure the project complies with federal safety standards and to investigate violations. The Army Corps will almost certainly be involved given that the Falcon will cross the Ohio River. As far as we know, the Falcon will not have eminent domain status because it supplies a private facility and, thus, does not qualify as a public utility project.

Questioning Impact Assessments

The contents of EIAs vary, but are generally organized along the lines of the thematic categories that we have created for assessing the Falcon data, as seen above. However, there is also much that EISs fail to adequately address. The Army Corp’s assessment of the Atlantic Sunrise is a good example. The final EIS resulting from the operators EIA includes considerations for socioeconomic impacts, such effects on employment and environmental justice, as seen in the excerpt below. But potential negative impact in these areas are not necessarily linked to laws requiring special accommodations. For instance, federal regulations mandate achieving environmental justice by “identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects” of projects subject to NEPA’s EIS requirement. However, there are no laws that outline thresholds of unacceptable impact that would disallow a project to proceed.

An excerpt from the Atlantic Sunrise EIS addressing environmental justice concerns

Furthermore, the narratives of EIAs are almost always written by the companies proposing the project, using sources of data that better support their claims of minimal or positive impact. This is again seen in the Atlantic Sunrise EIS, where several studies are cited on how pipelines have no affect on property values or mortgages, with no mention of other studies that contradict such findings. Other factors that may be important when considering pipeline projects, such as concerns for sustainability, climate change, or a community’s social well-being, are noticeably absent.

Complicating matters, some pipeline operators have been successful in skirting comprehensive EIAs. This was seen in the case of the Mariner East 2 pipeline. Despite being the largest pipeline project in Pennsylvania’s history, a NEPA review was never conducted for ME2.

* * *

Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Routes, Facilities & Easements

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project, we first focus on the route of the pipeline and prior routes that were considered. We take a closer look at the properties along the route that required easement agreements from landowners. Finally, we locate facilities that will be built as part of the project, such as metering stations and shut-off valves, as well as the pipeline’s construction areas and access roads.

Quick Falcon Facts

  • 97.5 miles of proposed pipeline (an additional 200+ miles surveyed during the process)
  • 2,000 parcels of land surveyed; 765 easements executed; 469 will be needed to execute the route
  • Five meter pads and 18 shut-off valves
  • 111 temporary access roads, 21 permanent access roads
  • 1,273 acres required for construction space; 650 acres for the permanent right-of-way

Map of Falcon pipeline routes, properties, and facilities

The following map will serve as our guide in breaking down these first components. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible at closer zoom levels. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work


Finding a Right-of-Way

Pipeline operators must consider a variety of factors when searching for a viable right of way (ROW) for their project—the continuous stretch of land needed to construct, maintain, and operate the pipeline. This process begins with reviewing data and maps made available by federal, state, and local agencies in order to identify features that would complicate the project. These might include such things as protected wetlands, drinking water sources, abandoned mines, or heavily populated areas.

A second step is to conduct manual field surveys along their planned route. During this stage, engineers do precise measurements to determine how the pipeline will cross individual properties as well as locate site-specific concerns that need to be accounted for, such as the presence of endangered species or archeological sites. FracTracker previously produced a guide to pipeline surveying, which can be found here.

The process of finding a viable pipeline route can undergo dozens of revisions and take months or years to complete. The example image seen below, taken from our interactive map at the top of the page, shows a few of the many different 50ft. ROWs considered by Shell. These were documented every few months as the data changed.

A section of the Falcon route with prior routes considered

The most recent route is highlighted in red, totaling 97.5 miles (Shell’s original press releases stated 94 miles). Segments that represent alternative routes considered in certain places are shown in blue (these earlier divergences total 19 miles). Other areas surveyed at some point in the process are shown in dotted purple (totaling 91.3 miles). Given that the route has changed very little in recent months, as well as the fact that Shell has submitted their permit applications for project, we believe that the route in red is likely the route proposed to regulatory agencies.

Note that, in the interactive map, there is an additional “Air Liquide” pipeline (this is the name of a gas products company) proposed by Shell that will run from the ethane cracker south for about .5 miles. Based on comments made by Shell at public hearings, we assume this will be a nitrogen pipeline feeding the plant from an unknown source.

Acquiring Easements

Perhaps the most significant factor that can determine a pipeline route is finding landowners amenable to having their land surveyed and, ultimately, willing to sign easements to allow the pipeline on their property. In some instances, pipeline companies can be granted eminent domain as a “public utility” to take land by force (ME2). However, Shell has stated publicly that eminent domain in not an option for Falcon, due to the fact that the pipeline services a private facility. FracTracker previously produced a guide for landowners who might be approached by pipeline operators seeking to survey their properties.

The Falcon pipeline will have a permanent ROW of 50ft that will cross 10 municipalities in Pennsylvania, 12 townships in Ohio, as well as northern Hancock County, West Virginia. More than 2,000 individual parcels of land were surveyed across this region. Of those 2,000, Shell approached landowners for 765 unique parcels at some point in the process to obtain easements, either for the pipeline ROW itself or for access roads.

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To date, Shell has executed 572 easements. Of these, 469 will be needed to execute the current proposed route. However, as of this time, 14 parcels along the proposed route are still listed as “landowner contacted,” meaning that the easement has not yet been executed. The image below is a page from Shell’s permit applications to the PA DEP listing properties pending in Pennsylvania.

Pending PA easements from Shell’s permit applications

Media sources have reported on some of the details of Shell’s Pipeline easement agreements. In some instances, contracts stated a transactional price of $10 per linear foot as a “placeholder” to get the process started. In other cases, Shell has paid landowners as much as $75 per linear foot of pipeline. These agreements also state that Shell reserved the right to “lay, construct, test, maintain, inspect, operate, repair, renew, relocate, replace, substitute, change the size of, upgrade, alter, mark, protect and remove or abandon in place” any pipelines on the property. Below is an example of how our interactive map represents these parcels and their status. For instance, executed easements are in green and pending or stalled agreements in yellow.

Parcels along the Falcon route and their easement status

Valves & Metering Stations

Pipelines require a number of facilities to properly manage the flow and pressure of gas from one end of the line to another. For instance, metering stations are installed to measure how much gas is in the pipeline system at given points. Falcon has five “pads” where metering stations will be located. Three of these are co-located at the origin points of the pipeline (the MarkWest separator facilities) and a fourth at the ethane cracker end-point. However, the fifth meter stations will be located where the two legs of the pipeline meet in northeast Raccoon Township, Beaver County, PA. This site is called the “Junction” meter pad.

Shut-off valves will also placed along the route—18 in all for Falcon—in order to section off lengths of the pipeline that can be turned off as needed. These valves will be located at fairly regular intervals of 8-10 miles in most places, but are also found just before and after sensitive locations, such as the Oho River crossing and areas and where the lines juncture.

The Risks of Proximity

Metering stations and shut-off valves bring particular risks. For instance, when valves are closed at a section of pipeline for maintenance, or in the event of an emergency, excess gasses must vented to relieve pressure. This is one reason why communities have become concerned about the location of these facilities, such as with a Mariner East 2 pipeline valve in West Goshen Township, PA. Similarly, the Falcon pipelines’ valve in New Somerset, OH, is especially close to residential areas, seen below.

A proposed Falcon shut-off valve site in New Somerset, Ohio

Workspaces & Access Roads

Finally, pipeline operators must identify in their permit applications the “workspace” needed for construction. Shell’s temporary ROW for workspace is approximately 100ft in most stretches along the Falcon’s route, similar to what is shown in the image below. Site-specific conditions, such as road, railroad crossings, and buildings make the workspace narrower in some instances, but much larger workspaces will be needed around sites like metering stations and shut-off valves.

A typical pipeline workspace; this one from the Mariner East 2

The locations of access roads must also be identified in permit applications. Access roads come in two categories and typically require a 25ft ROW. Temporary access roads are used during the construction process and often utilize existing private driveways, farm roads, or are built after clearing land acquired in the easement process. Permanent roads allow long-term access to facilities, such as valves and pumping stations, as well as for bringing in equipment to maintain the pipeline’s ROW. Shell’s plan proposes 111 temporary access roads (28 miles) and 21 permanent access roads (2.3 miles).

Shell’s permit applications state that the total disturbed workspace needed for construction and access roads is approximately 1,273 acres. About half of this will remain cleared for the permanent right-of-way and permanent access roads.

A Closer Look

When a pipeline project is subject to regulatory review, alternative routes are typically offered up by the operator for consideration in weighing different costs and benefits. Major reroutes typically deviate from the proposed route for significant distances in order to avoid significant impediments such as large cities or protected lands. Minor alternatives are shorter in length and used to avoid specific areas of concern, such as a protected wetland. An alternative route might also be selected in order to utilize an existing ROW from other pipelines.

Ohio River Crossing

As noted, there are a number of places along the Falcon route where we see examples of major route changes. Many of these reroutes appear to be due to landowners along the preferred path not signing easements for one reason or another. One of the more significant change occurred at the location where the Falcon crosses the Ohio River in Hancock County, West Virginia, seen below. For many months, Shell’s maps showed a planned crossing south of the current proposed route, but later took a dramatic diversion to the north, apparently due to an easement not having been executed for a single property. What is notable about the new route is that it utilizes property owned by the popular Mountaineer Casino, Racetrack, and Resort.

The current and former Falcon route crossing the Ohio River

Fort Cherry Golf Course Reroute

In another instance, we see a reroute near the Fort Cherry Golf Course in McDonald, Washington County, PA. An earlier route took the Falcon straight through the course, whereas the current proposed route goes further east, disrupting a smaller number of fairways. Notice in the image below that a temporary access road for the pipeline’s construction will also still utilize Fort Cherry Golf Course’s driveway.

The current and former Falcon routes crossing the Ft. Cherry Golf Course

Montour Trail Intersections

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Finally, we bring attention to what appears to be some of the few remaining properties with easements not yet settled in order to begin construction. As noted in the excerpt from Shell’s permit application at the top of this page, a number of parcels owned by the Montour Trail Council have a status of: “in negotiation and depended on submitted crossing permit applications,” presumably meaning they would agree to the easement if PA DEP approved Shell’s permits.

Falcon intersections with the Montour Trail

The Montour Trail is a 46-mile long multi-use non-motorized recreational rail-trail located in Washington and Allegheny County, PA, used by more than 400,000 people annually. It also makes up part of the Great Allegheny Passage (GAP), a trail system that stretches over 335 miles from Pittsburgh to Washington, DC. The trail is managed by the nonprofit Montour Trail Council with support from state agencies such as the Pennsylvania Department of Conservation and Natural Resources (DCNR).

We were surprised to find that the Montour Trail will be crossed by the Falcon in 9 locations: 5 by the pipeline itself, 3 by temporary access roads, and 1 by a permanent access road, as illustrated in the image above. Two of the pipeline intersections will be executed using HDD boring. The trail and its intersection with the Falcon can be seen by activating these layers on FracTracker’s interactive map, as illustrated in the image above.

 

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Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Water Crossings & Hazards

Part of the Falcon Public EIA Project

In this section of the Falcon Public EIA Project, we explore the hydrological and geological conditions of the pipeline’s construction areas. We first identify the many streams, wetlands, and ponds the Falcon must cross, as well as describe techniques Shell will likely use in these water crossings. The second segment of this section highlights how the areas in the Falcon’s path are known for their complex geological features, such as porous karst limestone and shallow water tables that can complicate construction.

Quick Falcon Facts

  • Intersects 319 streams; 361 additional streams located only 500ft from construction areas
  • Intersects 174 wetlands; 470 additional wetlands located only 500ft from construction areas
  • Majority of crossings will be open cuts and dry-ditch trenching
  • A total of 19 horizontal directional drilling (HDD) sites; 40 conventional boring sites
  • 25 miles of pipeline overlap karst limestone formations, including 9 HDD sites
  • 240 groundwater wells within 1/4 mile of the pipeline; 24 within 1,000ft of an HDD site

Map of Falcon water crossings and hazards

The following map will serve as our guide in breaking down the Falcon’s risks to water bodies. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional features of the map are not shown by default, but can be turned on in the “layers” tab. These include information on geological features, water tables, soil erosion characteristics, as well as drinking reservoir boundaries. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

Defining Water Bodies

The parts of Pennsylvania, West Virginia, and Ohio where the Falcon pipeline will be built lie within the Ohio River Basin. This landscape contains thousands of streams, wetlands, and lakes, making it one of the most water rich regions in the United States. Pipeline operators are required to identify waters likely to be impacted by their project. This two-step process involves first mapping out waters provided by the U.S. Geological Survey’s national hydrological dataset. Detailed field surveys are then conducted in order to locate additional waters that may not yet be accounted for. Many of the streams and wetlands we see in our backyards are not represented in the national dataset because conditions can change on the ground over time. Yet, plans for crossing these must also be present in pipeline operator’s permit applications.

Streams

Streams (and rivers) have three general classifications. “Perennial” streams flow year-round, are typically supplied by smaller up-stream headwaters, and are supplemented by groundwater. In a sense, the Ohio River would be the ultimate perennial stream of the region as all smaller and larger streams eventually end up there. “Intermittent” streams flow for only a portion of the year and are dry at times, such as during the summer when water tables are low. Finally, “ephemeral” streams flow only during precipitation events.

These classifications are important because they can determine the extent of aquatic habitat that streams can support. Working in streams that have no dry period can put aquatic lifeforms at elevated risk. For this and other reasons, many states further designate streams based on their aquatic life “use” and water quality. In Pennsylvania, for instance, the PA DEP uses the designations: Warm Water Fishes (WWF), Trout Stocked (TSF), Cold Water Fisheries (CWF) and Migratory Fishes (MF). Streams with exceptional water quality may receive an additional designation of High Quality Waters (HQ) and Exceptional Value Waters (EV).

Wetlands

Similar to streams, wetlands also have unique designations. These are based on the U.S. Fish and Wildlife Services’ national wetlands inventory. Wetlands are generally defined as “lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water.” As such, wetlands are categorized by their location (such as a tidal estuary or an inland wetland that lacks flowing water), its substrate (bedrock, sand, etc.), and plant life that might be present. While there are hundreds of such categories, only four pertain to the wetlands present in the regions where the Falcon pipeline will be built. Their designations roughly translate to the following:

  • Palustrine Emergent (PEM): Marshes and wet meadows hosting perennial small trees, shrubs, mosses, or lichens
  • Palustrine Shrub (PSS): Similar to PEMs, but characterized by also having well-established shrubs
  • Palustrine Forested (PFO): Similar to PEMs and PSSs, but having trees larger than 6 meters high
  • Palustrine Unconsolidated Bottom (PUB) and Palustrine Opem Water (POW) (aka ponds)

Pipeline operators are required to report the crossing length of each wetland they will encounter, as well as the area of permanent and temporary disturbance that would occur in each of these wetlands. When building the pipeline, operators are required to ensure that all measures are taken to protect wetlands by minimizing impacts to plant life, as well as by taking “upland protective measures” to prevent sedimentation runoff during precipitation events. When undergoing FERC EIA scrutiny, operators are also required to limit the width of wetland construction areas to 75 feet or less.

Crossing Methods

Open-Cut Trenching

Pipeline operators use a variety of methods when crossing streams, wetlands, and ponds. Shorter length crossings often employ a rudimentary trench. After the cuts, construction crews attempts to repair damage done in the process of laying the pipeline. For longer crossings, operators can use boring techniques to go underneath water features.

Open-cut trenching

There are two general types of trenches. The first, “open-cut” crossings, are typically used for smaller waterbodies, such as in intermittent streams where flow may not be present during time of construction, or when construction can be completed in a short period of time (typically 24-48 hours). In this process, a trench is laid through the water body without other provisions in place.

The second type, “dry-ditch” crossing, are required by FERC for waterbodies up to 30 feet wide “that are state-designated as either coldwater or significant coolwater or warmwater fisheries, or federally-designated as critical habitat.” In these spaces, pumps are used to transfer stream flow around the area where trenching occurs. In places where sensitive species are present, dry-ditches must include a flume to allow these species to pass through the work area.

Conventional Boring

Conventional boring consists of creating a tunnel for the pipeline to be installed below roads, waterbodies, and other sensitive resources. Bore pits are excavated on either sides of the site. A boring machine is then used to tunnel under the resource and the pipeline is pushed through the bore hole.

Horizontal Directional Drilling

In more difficult or lengthy crossings, operators may choose to bore under a water feature, road, or neighborhood. Horizontal directional drilling (HDD) involves constructing large staging areas on either side of the crossing. A large drill bit is piloted through the ground along with thousands of gallons of water and bentonite clay for lubricant (commonly referred to as drilling muds). HDDs are designed to protect sensitive areas, but operators prefer not to use them as HDDs can be expensive and require in-depth planning in order for things to go well.

Bentonite sediment pollutes a stream at a Mariner East HDD spill site
(source: Washington, PA, Observer-Reporter)


An example of what happens when things are rushed can be seen in Sunoco’s Mariner East 2 pipeline. The PA DEP has cited Sunoco for over 130 inadvertent returns (accidental releases of drilling muds) since construction began. These spills led to damaged water wells and heavy sedimentation in protected streams, as exemplified in the image above. Making matters worse, Sunoco later violated terms of a settlement that required them to re-survey before recommencing construction. See FracTracker’s article on these spills.

Footprint of the Falcon

The overwhelming majority of Falcon’s water body crossings will be executed with either open-cut or dry-ditch methods. There are 40 locations where conventional boring will be used, but only a 3 are used for crossing water resources. Shell intends to use 19 HDDs and, of these, only 13 are used for crossing water bodies of some kind (the longest of which crosses the Ohio River). All other conventional and HDD boring locations will be used to cross under roads and built structures. This is not entirely unusual for pipelines. However, we noted a number of locations where one would expect to see HDDs but did not, such as in the headwaters of the Ambridge and Tappen Reservoirs, as was seen in the images above.

Stream Impacts

Shell identified and/or surveyed a total of 993 stream sections in planning for the Falcon’s construction. As shown on FracTracker’s map, the pipeline’s workspace and access roads will directly intersect 319 of these streams with the following classifications: perennial (96), ephemeral (79), and intermittent (114). An additional 361 streams are located only 500ft from construction areas.

A number of these streams have special designations assigned by state agencies. For instance, in Pennsylvania, we found 10 stream segments listed as Trout Stocked (TS), which are shown on our interactive map.

Crossing HQ headwater streams of the Ambridge Reservoir

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Perhaps more concerning, the Falcon will cross tributaries to the Service Creek watershed 13 times. These feed into three High Quality Cold Water Fishes (HQ/CWF) headwater streams of the Ambridge Reservoir in Beaver County, PA, shown in the image above. They also support the endangered Southern Redbelly Dace (discussed in greater depth here). On the eastern edge of the watershed, the Falcon will cross the raw water line leading out of the reservoir.

The reservoir supplies 6.5 million gallons of water a day to five townships in Beaver County (Ambridge, Baden, Economy, Harmony, and New Sewickley) and four townships in Allegheny County (Leet, Leetsdale, Bell Acres & Edgeworth). This includes drinking water services to 30,000 people.

We found a similar concern in Ohio where the Falcon will cross protected headwaters in the Tappan Reservoir watershed at six different locations. The Tappan is the primary drinking water source for residents in Scio. Below is a page from Shell’s permit applications to the PA DEP outlining the crossing of one of the Ambridge Reservoir’s CWF/HQ headwater streams.

Wetland Impacts

Shell identified a total of 682 wetland features relevant to Falcon’s construction, as well as 6 ponds. Of these, the pipeline’s workspace and access roads will directly intersect 174 wetlands with the following classifications: PEM (141), PSS (13), PFO (7), PUB (10), POW (3). An additional 470 of these wetlands, plus the 6 ponds, are located only 500ft from construction areas.

Example 1: Lower Raccoon Creek

A few wetland locations stand out as problematic in Shell’s construction plans. For instance, wetlands that drain into Raccoon Creek in Beaver County will be particularly vulnerable in two locations. The first is in Potter Township, where the Falcon will run along a wooded ridge populated by half a dozen perennial and intermittent streams that lead directly to a wetland of approximately 14 acres in size, seen below. Complicating erosion control further, Shell’s survey data shows that this ridge is susceptible to landslides, shown in the first map below in dotted red.

Landslide areas along Raccoon Creek wetlands and streams

This area is also characterized by the USGS as having a “high hazard” area for soil erosion, as seen in this second image. Shell’s engineers referenced this soil data in selecting their route. The erosion hazard status within 1/4 mile of the Falcon is a layer on our map and can be activated in the full-screen version.

High erosion hazard zones along Raccoon Creek

Shell’s permit applications to the PA DEP requires plans be submitted for erosion and sedimentation control of all areas along the Falcon route. Below are the pages that pertain to these high hazard areas.

Example 2: Independence Marsh

The other wetland area of concern along Raccoon Creek is found in Independence Township. Here, the Falcon will go under the Creek using horizontal drilling (highlighted in bright green), a process discussed in the next section. Nevertheless, the workspace needed to execute the crossing is within the designated wetland itself. An additional 15 acres of wetland lie only 300ft east of the crossing but are not accounted for in Shell’s data.

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This unidentified wetland is called Independence Marsh, considered the crown jewel of the Independence Conservancy’s watershed stewardship program. Furthermore, the marsh and the property where the HDD will be executed are owned by the Beaver County Conservation District, meaning that the CCD signed an easement with Shell to cross publicly-owned land.

Independence Marsh, unidentified in Shell’s survey data

 

Groundwater Hazards

The Falcon’s HDD locations offer a few disturbing similarities to what caused the Mariner East pipeline spills. Many of Sunoco’s failures were due to inadequately conducted (or absent) geophysical surveys prior to drilling that failed to identify karst limestone formations and shallow groundwater tables, which then led to drilling muds entering nearby streams and groundwater wells.

Karst Limestone

Karst landscapes are known for containing sinkholes, caves, springs, and surface water streams that weave in and out of underground tunnels. Limestone formations are where we are most likely to see karst landscapes along the Falcon’s route.

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In fact, more than 25 of the Falcon’s 97 pipeline miles will be laid within karst landscapes, including 9 HDD sites. However, only three of these HDDs sites are identified in Shell’s data as candidates for potential geophysical survey areas. The fact that the geology of the other 10 HDD sites will not be investigated is a concern.

One site where a geophysical survey is planned can be seen in the image below where the Falcon crosses under PA Highway 576. Note that this image shows a “geological formations” layer (with limestone in green). This layer shows the formation types within 1/4 mile of the Falcon and can activated in the full-screen version of our interactive map.

A potential HDD geophysical survey area in karst limestone

Water Tables

We also assessed the Falcon’s HDDs relative to the groundwater depths and nearby private groundwater wells. The USGS maintains information on minimum water table depths at different times of the year. In the image below we see the optional “water table depth” layer activated on the FracTracker map. The groundwater at this HDD site averages 20ft on its western side and only 8ft deep on the eastern side.

Shallow groundwater and private wells near a planned HDD site

Groundwater Wells

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Also seen in the above image is the “groundwater wells” layer from the FracTracker map. We found 240 private water wells within 1/4 mile of the Falcon. This data is maintained by the PA Department of Natural Resources as well as by the Ohio Department of Natural Resources. Comparable GIS data for West Virginia were not readily available thus not shown on our map.

While all of these wells should be assessed for their level of risk with pipeline construction, the subset of wells nearest to HDD sites deserve particular attention. In fact, Shell’s data highlights 24 wells that are within 1,000 feet of a proposed HDD site. We’ve isolated the groundwater wells and HDD sites in a standalone map for closer inspection below. The 24 most at-risk wells are circled in blue.

View Map Fullscreen | How FracTracker Maps Work

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Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Class Locations, Buildings & Recreational Areas

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project we begin to explore the different ways that pipelines are assessed for potential risk to populated areas. We outline a methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called Class Locations. This methods identifies occupied structures in proximity to a pipeline.

Quick Falcon Facts

  • 67% of the Falcon route will qualify as Class 1, 27% as Class 2, and 3% as Class 3.
  • More than 557 single family residences and 20 businesses within 660ft of the pipeline.
  • Three recreational parks and a planned luxury housing development also at risk.

Map of Falcon Class Locations

The following map will serve as our guide in breaking down the Falcon’s Class Locations. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.



View Map Fullscreen | How FracTracker Maps Work

Pipeline Class Locations

Pipeline “Class locations” determine certain aspects of how a pipeline is constructed. Essentially, a pipeline’s route is segmented into lengths that are each given different classifications as outlined in PHMSA guidelinesIn general terms, a segment’s Class is established by first calculating a buffer that extends 220 yards (660ft) on either side of the pipeline’s center in 1-mile continuous lengths. This buffer area is then analyzed for how many building structures are present. Classes are then assigned to each 1-mile segment using the follow criteria:

  • Class 1: a segment with 10 or fewer buildings intended for human occupancy
  • Class 2: a segment with more than 10, but less than 46 buildings intended for human occupancy
  • Class 3: a segment with 46 or more buildings intended for human occupancy, or where the pipeline lies within 100 yards of any building, or small well-defined outside area occupied by 20 or more people on at least 5 days a week for 10 weeks in any 12-month period (i.e. schools, businesses, recreation areas, churches)
  • Class 4: a segment where buildings with four or more stories aboveground are prevalent

The finer details of these calculations and their adjustments are complex, however. For instance, Class locations can be shortened to less than 1-mile lengths if building densities change dramatically in an certain area. The example image below shows one of the ways available to operators for doing this, called the “continuous sliding” method:

Calculating Class Locations
(source: PHMSA)

Class location designations may also be adjusted over time as densities change. For instance, if new homes were built in proximity to a previously constructed pipeline, the operator may be required to reduce their operating pressure, strengthen the pipeline, or conduct pressure tests to ensure the segment would technically meet the requirements of a higher Class. Alternatively, operators can apply for a special permit to avoid such changes.

What Class Locations Dictate

Pipeline segments with higher Classes must meet more rigorous safety standards, which are enforced either by PHMSA or by their state equivalent, such as the Pennsylvania Utility Commission. These include:

  • Soil depth: Class 1 locations must be installed with a minimum soil depth of 30 inches (18 inches in consolidated rock). Class 2, 3, and 4 locations require a minimum soil depth of 36 inches (24 inches in consolidated rock)
  • Shut-off valves: Class locations determine the maximum distance from shut-off valves to populated areas, as follows: Class 1 (10 miles), Class 2 (7.5 miles), Class 3 (4 miles), and Class 4 (2.5 miles).
  • Operating pressure: Classes also regulate the maximum allowable operating pressure (MAOP) of pipeline segments
  • Structural integrity: Classes determine where thicker walled materials must be used to withstand higher pressures, as well as different structural testing methods used in safety inspections

By replicating the 600 foot buffer from the Falcon’s centerline (used as the standard distance for determining Class Locations) we found that 67% of the Falcon route will qualify as Class 1, 27% as Class 2, and 3% as Class 3. These are represented on our interactive maps as green, yellow, and orange segments, respectively. An additional segment is marked as having an “unknown” Class on our maps (shaded in gray). This is the stretch crossing the Ohio River, where Shell’s Class location analysis has not been updated to reflect the route change that occurred in the summer of 2017.

Residential Structures

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In total, there are 557 single family residences, 20 businesses, and a church within the 660ft buffer. Shell’s data also identify non-occupied structures along the route, such as sheds, garages, and other outbuildings. There are 535 such structures, but we did not have the time to replicate the locations of these sites. It is also important to note that the points on our interactive map represent only those identified by Shell, which we believe is an incomplete assessment of occupied structures based on our quick review of satellite maps.

Three residential structures lie directly within the 50-foot right-of-way. One of these homes, located in a Class 2 segment in Independence Township, is shown below. The Falcon will come as close as 20 feet to the edge of the structure and surround the home on three sides.

An occupied residence in the right-of-way

Neighborhoods in the following five communities account for the entirety of Falcon’s Class 3 locations. These would be considered the most “at risk” areas along the route in terms of proximity to the number of occupied structures. For instance, below is a satellite view of the Class 3 section of Raccoon Township.

  • Rumley Township, Harrison OH
  • Knox Township, Jefferson County OH
  • Raccoon Township, Beaver County PA
  • Independence Township, Beaver County PA
  • Mount Pleasant Township, Washington County PA

Raccoon Township residences & Municipal Park in a Class 3

Recreational Areas

In the above image we also see the location of Raccoon Township Municipal Park (in purple), home to a number of ballfields. Two similar recreation areas are located in the 660ft Class Location buffer: Mill Creek Ballpark, in Beaver County PA, and Clinton Community Park, in Allegheny County PA.

However, the Raccoon Township park is notable in that the Falcon cuts directly through its property boundary. Shell intends to bore under the park using HDD techniques, as stated in their permit applications, “to avoid disturbance to Beaver County baseball field/recreational park,” also stating that, “this HDD may be removed if the recreational group will allow laying the pipeline along the entrance roadway.”

New Housing Developments

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One discovery worth attention is that the Falcon runs straight through an under-construction luxury housing development. Located in Allegheny County, PA, its developer, Maronda Homes, bills this growing community as having “picturesque landscapes, waterfront views and a peaceful collection of homes.” Shell mentions this development in their permit applications, stating:

Maronda Homes is in the planning and design stage of a very large housing development and SPLC [Shell Pipeline LC] worked closely with the developer and the Project was rerouted to avoid most of the housing sites.

It stands to reason that this neighborhood will eventually rank as one of the densest Class 3 areas along the Falcon route. Whether or not the pipeline is updated with higher safety standards as a result remains to be seen. The image below illustrates where the Falcon will go relative to lots marked for new homes. This property lots diagram was obtained from Shell’s GIS data layer and can be viewed on the FracTracker interactive map as well.

The Falcon intersects a luxury home development

[av_font_icon icon=’ue836′ font=’entypo-fontello’ style=” caption=” link=” linktarget=” size=’40px’ position=’left’ color=”][/av_font_icon]1/31/18 Note: the Pittsburg Post-Gazette obtained newer lot line records for a portion of the Maronda Farms during their investigation into this story. These new records appear to have some alterations to the development, as seen below.

Maronda Farms, updated lot lines

Issues with Setbacks

There are no setback restrictions for building new homes in proximity to a pipeline. Parcels will eventually be sectioned off and sold to home buyers, begging the question of whether or not people in this community will realize a hazardous liquid pipeline runs past their driveways and backyards. This is a dilemma that residents in a similar development in Firestone, Colorado, are now grappling with following a recent pipeline explosion that killed two people, seen below, due to inadequate building setbacks.

A pipeline explodes in a Colorado home development
(source: InsideEnergy, CO)

Interestingly, we researched these same Maronda Farms parcels in FracTracker’s Allegheny County Lease Mapping Project only to discover that Maronda Homes also auctioned off their mineral rights for future oil and gas drilling. New homeowners would become victims of split-estate, where drilling companies can explore for oil and gas without having to seek permission from property owners, amplifying their level of risk.

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Related Articles

The Falcon: High Consequence Areas & Potential Impact Zones

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project we continue to explore the different ways that pipelines are assessed for potential risk – in this case, relative to population centers, drinking water systems, and sensitive habitats. We outline methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called “high consequence areas” (HCAs) and how they determine potential impact zones for highly volatile liquid (HVL) pipelines. These methods are then applied to the Falcon to understand its possible dangers.

Quick Falcon Facts

  • An estimated 940-foot potential impact radius (PIR)
  • 60 of 97 pipeline miles qualifying as High Consequence Areas (HCA)
  • More than 8,700 people living in the “vapor zone”
  • 5 schools, 6 daycare centers, and 16 emergency response centers in “vapor zone”
  • In proximity to 8 source-water (drinking water) protection areas
  • Affecting habitats populated by 11 endangered, protected, or threatened species

Map of Falcon High Consequence Areas

The following map will serve as our guide in breaking down the Falcon’s High Consequence Areas. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

High Consequence Areas

While Class Locations, discussed in a prior project article, dictate the construction and maintenance of a pipeline, high consequence areas (HCAs) designate when operators must implement integrity management programs (IMP) where pipeline failures could cause major impacts to populated areas, as well as drinking water systems and ecological resources — otherwise defined as unusually sensitive areas (USAs).

Populated Areas

Two considerations are used when determining pipeline proximity to population centers:

  1. High Population Areas – an urbanized area delineated by the Census Bureau as having 50,000 or more people and a population density of at least 1,000 people per square mile; and
  2. Other Populated Areas – a Census Bureau designated “place” that contains a concentrated population, such as an incorporated or unincorporated city, town, village, or other designated residential or commercial area – including work camps.

USAs: Drinking Water

PHMSA’s definition of drinking water sources include things such as:

  • Community Water Systems (CWS) – serving at least 15 service connections and at least 25 year-round residents
  • Non-transient Non-community Water Systems (NTNCWS) – schools, businesses, and hospitals with their own water supplies
  • Source Water Protection Areas (SWPA) for a CWS or a NTNCWS
  • Wellhead Protection Areas (WHPA)
  • Sole-source karst aquifer recharge areas

These locations are typically supplied by regulatory agencies in individual states.

With the exception of sole-source aquifers, drinking water sources are only considered if they lack an alternative water source. However, PHMSA is strict on what alternative source means, stating that they must be immediately usable, of minimal financial impact, with equal water quality, and capable of supporting communities for at least one month for a surface water sources of water and at least six months for a groundwater sources.

One very important note in all of these “drinking water” USA designations is that they do not include privately owned groundwater wells used by residences or businesses.

USAs: Ecological Resource

Ecological resource areas are established based on any number of qualities with different variations. In general terms, they contain imperiled, threatened, or endangered aquatic or terrestrial species; are known to have a concentration of migratory waterbirds; or are a “multi-species assemblage” area (where three or more of the above species can be found).

Calculating HCAs

Like Class locations, HCAs are calculated based on proximity. The first step in this process is to determine the pipeline’s Potential Impact Radius (PIR) — the distance beyond which a person standing outdoors in the vicinity of a pipeline rupture and fire would have a 99% chance of survival; or in which death, injury, or significant property damage could occur. PIR is calculated based on the pipeline’s maximum allowable operating pressure (MAOP), diameter, and the type of gas. An example of this calculation is demonstrated in FracTracker’s recent article on the Mariner East 2 pipeline’s PIR.

Once the PIR is known, operators then determine HCAs in one of two ways, illustrated in the image below:

  • Method 1: A Class 3 or Class 4 location, or a Class 1 or Class 2 location where “the potential impact radius is greater than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human occupancy”; or a Class 1 or Class 2 location where “the potential impact circle contains an “identified site.”
  • Method 2: An area within PIR containing an “identified site” or 20 or more buildings intended for human occupancy.

Calculating HCAs
(source: PHMSA)

In these definitions, “identified sites” include such things as playgrounds, recreational facilities, stadiums, churches, office buildings, community centers, hospitals, prisons, schools, and assisted-living facilities. However, there is a notable difference in how HCAs are calculated for natural gas pipelines vs. hazardous liquid pipelines.

Beyond just looking at what lies within the PIR, pipelines that contain gasses such as ethane potentially impact a much broader area as vapors flow over land or within a river, stream, lake, or other means. A truly accurate HCA analysis for an ethane pipeline leak requires extensive atmospheric modeling for likely vapor dispersions, such as seen in the example image below (part of a recent ESRI GIS conference presentation).

Vapor dispersion modelling
(source: TRC Solutions)

 

What HCAs Dictate

HCAs determine if a pipeline segment is included in an operator’s integrity management program (IMP) overseen by PHMSA or its state equivalent. IMPs must include risk assessments that identify the most likely impact scenarios in each HCA, enhanced management and repair schedules, as well as mitigation procedures in the event of an accident. Some IMPs also include the addition of automatic shut-off valves and leak detection systems, as well as coordination plans with local first responders.

The Falcon Risk Zones

Shell’s permit applications to the PA DEP state the pipeline:

…is not located in or within 100 feet of a national, state, or local park, forest, or recreation area. It is not located in or within 100 feet of a national natural landmark, national wildlife refuge, or federal, state, local or private wildlife or plant sanctuaries, state game lands. It is also not located in or within 100 feet of a national wild or scenic river, the Commonwealth’s Scenic Rivers System, or any areas designated as a Federal Wilderness Area. Additionally, there are no public water supplies located within the Project vicinity.

This is a partial truth, as “site” and “vicinity” are vague terms here. A number of these notable areas are within the PIR and HCA zones. Let’s take a closer look.

The PIR (or “Blast Zone”)

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Shell’s permit applications state a number of different pipeline dimensions will be used throughout the project. Most of the Falcon will be built with 12-inch steel pipe, with two exceptions: 1) The segment running from the Cadiz, OH, separator facility to its junction with line running from Scio, OH, will be a 10-inch diameter pipe; 2) 16-inch diameter pipe will be used from the junction of the Falcon’s two main legs located four miles south of Monaca, PA, to its end destination at the ethane cracker. We also know from comments made by Shell in public presentations that the Falcon’s maximum allowable operating pressure (MOAP) will be 1,440 psi. These numbers allow us to calculate the Falcon’s PIR which, for a 16″ ethane pipeline at 1,440psi, is about 940 feet. We’ve termed this the “blast zone” on our maps.

The HCA (or “Vapor Zone”)

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Shell’s analysis uses an HCA impact radius of 1.25 miles. This much larger buffer reflects the fact that vapors from hazardous liquid pipelines can travel unpredictably at high concentrations for long distances before ignition. This expanded buffer might be called the “vapor zone,” a term we used on our map. Within the HCA “vapor zone” we find that 60 of the Falcon’s 97 miles qualify as high consequence areas, with 35 miles triggered due to their proximity to drinking water sources, 25 miles trigger for proximity to populated areas, and 3 miles for proximity to ecological areas.

Populated Areas

Shell’s HCA buffer intersects 14 US Census-designated populated areas, shown in the table below. Falcon’s right-of-way directly intersects two of these areas: Cadiz Village in Harrison County, Ohio, and Southview CDP (Census Designated Place) in Washington County, PA. These areas are listed below. Additionally, we included on the FracTracker map the locations of public facilities that were found inside the HCA buffer. These include 5 public schools, 6 daycare centers, 10 fire stations, and 6 EMS stations.

Area Population State HCA
Pittsburgh Urbanized Area High PA Indirect
Weirton-Steubenville Urbanized Area High WV/OH/PA Indirect
Scio Village Other OH Indirect
Cadiz Village* Other OH Direct
Amsterdam Village Other OH Indirect
Shippingport Borough Other PA Indirect
Industry Borough Other PA Indirect
Hookstown Borough Other PA Indirect
Midway Borough Other PA Indirect
Clinton CDP Other PA Indirect
Imperial CDP Other PA Indirect
Southview CDP* Other PA Direct
Hickory CDP Other PA Indirect
Westland CDP Other PA Indirect
* Indicates an area the Falcon’s right-of-way will directly intersect

While it is difficult to determine the actual number of people living in the PIR and HCA vapor zone, there are ways one can estimate populations. In order to calculate the number of people who may live within the HCA and PIR zones, we first identified U.S. Census blocks that intersect each respective buffer. Second, we calculated the percentage of that census block’s area that lies within each buffer. Finally, we used the ratio of the two to determine the percentage of the block’s population that lies within the buffer.

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Based on 2010 Census data, we estimate that 2,499 people live within a reasonable projection of the Falcon’s PIR blast zone. When expanded to the HCA vapor zone, this total increases to 8,738 people. These numbers are relatively small compared to some pipelines due to the fact that a significant portion of the Falcon runs through fairly rural areas in most places.

PIR est. pop. HCA est. pop.
OHIO
Carroll County 11 47
Harrison County 274 915
Jefferson County 334 1,210
Total 619 2,172
WEST VIRGINIA
Hancock County 242 1,155
Total 242 1,155
PENNSYLVANIA
Allegheny County 186 969
Beaver County 990 3,023
Washington County 461 1,419
Total 1,637 5,410
Grand Total 2,499 8,738


Drinking Water Sources

Shell’s data identified a number of drinking water features considered in their HCA analysis. Metadata for this information show these sites were obtained from the Ohio Division of Drinking and Ground Waters, the West Virginia Source Water Assessment and Wellhead Protection Program, and the Pennsylvania DEP Wellhead Protection Program. The exact locations of public drinking water wells and intake points are generally protected by states for safety reasons. However, we duplicated the 5-mile buffer zones used on Shell’s map around these points, presumably denoting the boundaries of source water protection areas, wellhead protection areas, or intake points.

Drinking water buffers in Shell’s HCA analysis

As shown on FracTracker’s interactive map, five of these areas serve communities in the northern portions of Beaver County, shown in the image above, as well as the Cadiz and Weirton-Steubenville designated populated areas. Recall that HCA drinking water analysis only requires consideration of groundwater wells and not surface waters. This is an important distinction, as the Ambridge Reservoir is within the HCA zone but not part of Shell’s analysis — despite considerable risks outlined in our Falcon article on water body crossings.

Ecological Areas

Shell’s permits state that they consulted with the U.S. Fish and Wildlife Service (USFWS), Pennsylvania Game Commission (PGC), Pennsylvania Fish & Boat Commission (PFBC), and the Pennsylvania Department of Conservation and Natural Resources (DCNR) on their intended route in order to determine potential risks to protected species and ecologically sensitive areas.

DCNR responded that the pipeline had the potential to impact six sensitive plant species: Vase-vine Leather-Flower, Harbinger-of-spring, White Trout-Lily, Purple Rocket, Declined Trillium, and Snow Trillium. PFBC responded that the project may impact the Southern Redbelly Dace, a threatened temperate freshwater fish, within the Service Creek watershed. PGC responded that the pipeline had potential impact to habitats used by the Short-Eared Owl, Northern Harrier, and Silver-Haired Bat. Finally, the USFWS noted the presence of freshwater mussels in a number of water features crossed by the Falcon.

The presence of these species, as well as the proximity of protected lands illustrated on our map, factored into the Falcon’s HCA designations. A more detailed analysis of these issues is provided in the Falcon Public EIA Project article on Protected Habitats & Species of Concern.

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By Kirk Jalbert, FracTracker Alliance

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