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https://www.kvpr.org/post/dormant-risky-new-state-law-aims-prevent-problems-idle-oil-and-gas-wells

Idle Wells are a Major Risk

Designating a well as “idle” is a temporary solution for operators, but comes at a great economic and environmental cost to Californians 

Idle wells are oil and gas wells which are not in use for production, injection, or other purposes, but also have not been permanently sealed. During a well’s productive phase, it is pumping and producing oil and/or natural gas which profit its operators, such as Exxon, Shell, or California Resources Corporation. When the formations of underground oil pools have been drained, production of oil and gas decreases. Certain techniques such as hydraulic fracturing may be used to stimulate additional production, but at some point operators decide a well is no longer economically sound to produce oil or gas. Operators are supposed to retire the wells by filling the well-bores with cement to permanently seal the well, a process called “plugging.”

A second, impermanent option is for operators to forego plugging the well to a later date and designate the well as idle. Instead of plugging a well, operators cap the well. Capping a well is much cheaper than plugging a well and wells can be capped and left “idle” for indefinite amounts of time.

Well plugging

Unplugged wells can leak explosive gases into neighborhoods and leach toxic fluids into drinking waters. Plugging a well helps protect groundwater and air quality, and prevents greenhouse gasses from escaping and expediting climate change. Therefore it’s important that idle wells are plugged.

While plugging a well does not entirely eliminate all risk of groundwater contamination or leaking greenhouse gases, (read more on FracTracker’s coverage of plugged wells) it does reduce these risks. The longer wells are left idle, the higher the risk of well casing failure. Over half of California’s idle wells have been idle for more than 10 years, and about 4,700 have been idle for over 25 years. A report by the U.S. EPA noted that California does not provide the necessary regulatory oversite of idle wells to protect California’s underground sources of drinking water.

Wells are left idle for two main reasons: either the cost of plugging is prohibitive, or there may be potential for future extraction when oil and gas prices will fetch a higher profit margin.  While idle wells are touted by industry as assets, they are in fact liabilities. Idle wells are often dumped to smaller or questionable operators.

Orphaned wells

Wells that have passed their production phase can also be “orphaned.” In some cases, it is possible that the owner and operator may be dead! Or, as often happens, the smaller operators go out of business with no money left over to plug their wells or resume pumping. When idle wells are orphaned from their operators, the state becomes responsible for the proper plugging and abandonment.

The cost to plug a well can be prohibitively high for small operators. If the operators (who profited from the well) don’t plug it, the costs are externalized to states, and therefore, the public. For example, the state of California plugged two wells in the Echo Park neighborhood of Los Angeles at a cost of over $1 million. The costs are much higher in urban areas than, say, the farmland and oilfields of the Central Valley.

Since 1977, California has permanently sealed about 1,400 orphan wells at a cost of $29.5 million, according to reports by the Division of Oil, Gas, and Geothermal Resources (DOGGR). That’s an average cost of about $21,000 per well, not accounting for inflation. From 2002-2018, DOGGR plugged about 600 wells at a cost of $18.6 million; an average cost of about $31,000.

Where are they?

Map of California’s Idle Wells


View map fullscreen | How FracTracker maps work

The map above shows the locations of idle wells in California.  There are 29,515 wells listed as idle and 122,467 plugged or buried wells as of the most recent DOGGR data, downloaded 3/20/19. There are a total of 245,116 oil and gas wells in the state, including active, idle, new (permitted) or plugged.

Of the over 29,000 wells are listed as idle, only 3,088 (10.4%) reported production in 2018. Operators recovered 338,201 barrels of oil and 178,871 cubic feet of gas from them in 2018. Operators injected 1,550,436,085 gallons of water/steam into idle injection wells in 2018, and 137,908,884 cubic feet of gas.

The tables below (Tables 1-3) provide the rankings for idle well counts by operator, oil field, and county (respectively).  Chevron, Aera, Shell, and California Resources Corporation have the most idle wells. The majority of the Chevron idle wells are located in the Midway Sunset Field. Well over half of all idle wells are located in Kern County.

Table 1. Idle Well Counts by Operator
Operator Name Idle Well Count
1 Chevron U.S.A. Inc. 6,292
2 Aera Energy LLC 5,811
3 California Resources Production Corporation 3,708
4 California Resources Elk Hills, LLC 2,016
5 Berry Petroleum Company, LLC 1,129
6 E & B Natural Resources Management Corporation 991
7 Sentinel Peak Resources California LLC 842
8 HVI Cat Canyon, Inc. 534
9 Seneca Resources Company, LLC 349
10 Crimson Resource Management Corp. 333

 

Table 2. Idle Well Counts by Oil Field
Oil Field Count by Field
1 Midway-Sunset 5,333
2 Unspecified 2,385
3 Kern River 2,217
4 Belridge, South 2,075
5 Coalinga 1,729
6 Elk Hills 958
7 Buena Vista 887
8 Lost Hills 731
9 Cymric 721
10 Cat Canyon 661

 

Table 3. Idle Well Counts by County
County Count by County
1 Kern 17,276
2 Los Angeles 3,217
3 Fresno 2,296
4 Ventura 2,022
5 Santa Barbara 1,336
6 Orange 752
7 Monterey 399
8 Kings 212
9 San Luis Obispo 202
10 Sutter 191

 

Risks

According to the Western States Petroleum Association (WSPA) the count of idle wells in California has increased from just over 20,000 idle wells in 2015 to nearly 30,000 wells in 2018! That’s an increase of nearly 50% in just 3 years!

Nobody knows how many orphaned wells are actually out there, beneath homes, in forests, or in the fields of farmers. The U.S. EPA estimates that there are more than 1 million of them across the country, most of them undocumented. In California, DOGGR officially reports that there are 885 orphaned wells in the state.

A U.S. EPA report on idle wells published in 2011 warned that existing monitoring requirements of idle wells in California was “not consistent with adequate protection” of underground sources of drinking water. Idle wells may have leaks and damage that go unnoticed for years, according to an assessment by the state Department of Conservation (DOC). The California Council on Science and Technology is actively researching this and many other issues associated with idle and orphaned wells. The published report will include policy recommendations considering the determined risks. The report will determine the following:

  • State liability for the plugging and abandoning of deserted and orphaned wells and decommissioning facilities attendant to such wells
  • Assessment of costs associated with plugging and abandoning deserted and orphaned wells and decommissioning facilities attendant to such wells
  • Exploration of mechanisms to ameliorate plugging, abandoning, and decommissioning burdens on the state, including examples from other regions and questions for policy makers to consider based on state policies

Current regulation

As of 2018, new CA legislation is in effect to incentivize operators to properly plug and abandon their stocks of idle wells. In California, idle wells are defined as wells that have not had a 6-month continuous period of production over a 2-year period (previously a 5-year period). The new regulations require operators to pay idle well fees.  The fees also contribute towards the plugging and proper abandonment of California’s existing stock of orphaned wells. The new fees are meant to act as bonds to cover the cost of plugging wells, but the fees are far too low:

  • $150 for each well that has been idle for 3 years or longer, but less than 8 years
  • $300 for each well that has been idle for 8 years or longer, but less than 15 years
  • $750 for each well that has been idle for 15 years or longer, but less than 20 years
  • $1,500 for each well that has been idle for 20 years or longer

Operators are also allowed to forego idle well fees if they institute long-term idle well management and elimination plans. These management plans require operators to plug a certain number of idle wells each year.

In February 2019, State Assembly member Chris Holden introduced an idle oil well emissions reporting bill. Assembly bill 1328 requires operators to monitor idle and abandoned wells for leaks. Operators are also required to report hydrocarbon emission leaks discovered during the well plugging process. The collected results will then be reported publicly by the CA Department of Conservation. According to Holden, “Assembly Bill 1328 will help solve a critical knowledge gap associated with aging oil and gas infrastructure in California.”

While the majority of idle wells are located in Kern County, many are also located in California’s South Coast region. Due to the long history and high density of wells in the Los Angeles, the city has additional regulations. City rules indicate that oil wells left idle for over one year must be shut down or reactivated within a month after the city fire chief tells them to do so.

Who is responsible?

All of California’s wells, from Kern County to three miles offshore, on private and public lands, are managed by DOGGR, a division of the state’s Department of Conservation. Responsibilities include establishing and enforcing the requirements and procedures for permitting wells, managing drilling and production, and at the end of a well’s lifecycle, plugging and “abandoning” it.

To help ensure operator liability for the entire lifetime of a well, bonds or well fees are required in most states. In 2018, California updated the bonding requirements for newly permitted oil and gas wells. These fees are in addition to the aforementioned idle well fees. Operators have the option of paying a blanket bond or a bond amount per well. In 2018, these fees raised $4.3 million.

Individual well fees:

  • Wells less than 10,000 feet deep: $10,000
  • Wells more than 10,000 feet deep: $25,000

Blanket fees:

  • Less than 50 wells: $200,000
  • 50 to 500 wells: $400,000
  • 500 to 10,000 wells: $2,000,000
  • Over 10,000 wells: $3,000,000

With an average cost of at least $31,000 to plug a well, California’s new bonding requirements are still insufficient. Neither the updated individual nor blanket fees provide even half the cost required to plug a typical well.

Conclusions

Strategies for the managed decline of the fossil fuel industry are necessary to make the proposal a reality. Requiring the industry operators to shut down, plug and properly abandon wells is a step in the right direction, but California’s new bonding and idle well fees are far too low to cover the cost of orphan wells or to encourage the plugging of idle wells. Additionally, it must be stated that even properly abandoned wells have a legacy of causing groundwater contamination and leaking greenhouse gases such as methane and other toxic VOCs into the atmosphere.

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Cover photo: Kerry Klein, Valley Public Radio

DOGGR

Literally Millions of Failing, Abandoned Wells

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

In California’s Central Valley and along the South Coast, there are many communities littered with abandoned oil and gas wells, buried underground.

Many have had homes, buildings, or public parks built over top of them. Some of them were never plugged, and many of those that were plugged have since failed and are leaking oil, natural gas, and toxic formation waters (water from the geologic layer being tapped for oil and gas). Yet this issue has been largely ignored. Oil and gas wells continue to be permitted without consideration for failing and failed plugged wells. When leaking wells are found, often nothing is done to fix the issue.

As a result, greenhouse gases escape into the atmosphere and present an explosion risk for homes built over top of them. Groundwater, including sources of drinking water, is known to be impacted by abandoned wells in California, yet resources are not being used to track groundwater contamination.

Abandoned wells: plugged and orphaned

The term “abandoned” typically refers to wells that have been taken out of production. At the end of their lifetime, wells may be properly abandoned by operators such as Chevron and Shell or they may be orphaned.

When operators properly abandon wells, they plug them with cement to prevent oil, natural gas, and salty, toxic formation brine from escaping the geological formation that was tapped for production. Properly plugging a well helps prevent groundwater contamination and further air quality degradation from the well. The well-site at the surface may also be regraded to an ecological environment similar to its original state.

Wells that are improperly abandoned are either plugged incorrectly or are “orphaned” by their operators. When wells are orphaned, the financial liability for plugging the well and the environmental cleanup falls on the state, and therefore, the taxpayers.

You don’t see them?

In California’s Central Valley and South Coast abandoned wells are everywhere. Below churches, schools, homes, they even under the sidewalks in downtown Los Angeles!

FracTracker Alliance and Earthworks recently spent time in Los Angeles with an infrared camera that shows methane and volatile organic compound (VOC) emissions. We visited several active neighborhood drilling sites and filmed plumes of toxic and carcinogenic VOCs floating over the walls of well-pads and into the surrounding neighborhoods. We also visited sites where abandoned, plugged wells had failed.

In the video below, we are standing on Wilshire Blvd in LA’s Miracle Mile District. An undocumented abandoned well under the sidewalk leaks toxic and carcinogenic VOCs through the cracks in the pavement as mothers push their children in walkers through the plume. This is just one case of many that the state is not able to address.

California regulatory data shows that there are 122,466 plugged wells in the state, as shown below in the map below. Determining how many of them are orphaned or improperly plugged is difficult, but we can come up with an estimate based on the wells’ ages.

While there are no available data on the dates that wells were plugged, there are data on “spud dates,” the date when operators begin drilling into the ground. Of the 18,000 wells listing spud dates, about 70% were drilled prior to 1980. Wells drilled before 1980 have a higher risk of well casing failures and are more likely to be sources of groundwater contamination.

Additionally, wells plugged prior to 1953 are not considered effective, even by industry standards. Prior to 1950, wells either were orphaned or plugged and abandoned with very little cement. Plugging was focused on protecting the oil reservoirs from rain infiltration rather than to “confine oil, gas and water in the strata in which they are found and prevent them from escaping into other strata.” Of the wells with drilling dates in the regulatory data, 30% are listed as having been drilled prior to the use of cement in well plugging.

With a total of over 245,000 wells in the state database, and considering the lack of monitoring prior to 1950, it’s reasonable to assume there are over 80,000 improperly plugged and unplugged wells in California.

Map of California’s Plugged Wells

View map fullscreen | How FracTracker maps work

The regions with the highest counts of plugged wells are the Central Valley and the South Coast. The top 10 county ranks are listed below in Table 1. Kern County has more than half of the total plugged wells in the entire state.

Table 1. Ranks of Counties by Plugged Well Counts
  • Rank
  • 1
  • 2
  • 3
  • 4
  • 5
  • 6
  • 7
  • 8
  • 9
  • 10
  • County
  • Kern
  • Los Angeles
  • Orange
  • Fresno
  • Ventura
  • Santa Barbara
  • Monterey
  • San Luis Obispo
  • Solano
  • Yolo
  • Plugged Well Count
  • 65,733
  • 17,139
  • 7,259
  • 6,970
  • 4,302
  • 4,192
  • 2,266
  • 1,463
  • 1,456
  • 1,383

The issue is not unique to California. Nationally, an estimated 2.56 million oil and gas wells have been drilled and 1.93 million wells had been abandoned by 1975. Using interpolated data, the EPA estimates that as of 2016 there were 3.12 million abandoned wells in the U.S. and 69% of them were left unplugged.

In 2017, FracTracker Alliance organized an exercise to track down the locations of Pennsylvania’s abandoned wells that are not included in the PA Department of Environmental Protection’s digital records. Using paper maps and the FracTracker Mobile App, volunteers explored Pennsylvania woodlands in search of these hidden greenhouse gas emitters.

What are the risks?

Emissions

Studies by Kang et al. 2014, Kang et al 2016, Boothroyd et al 2016, and Townsend-Small et al. 2016 have all measured methane emissions from abandoned wells. Both properly plugged and improperly abandoned wells have been shown to leak methane and other VOCs to the atmosphere as well as into the surrounding groundwater, soil, and surface waters. Leaks were shown to begin just 10 years after operators plugged the wells.

Well density

The high density of aging and improperly plugged wells is a major risk factor for the current and future development of California’s oil and gas fields. When fields with old wells are reworked using new technology, such as hydraulic fracturing, CO2 flooding, or solvent flooding (including acidizing, water flooding, or steam flooding), the injection of additional fluid and gas increases pressure in a reservoir. Poorly plugged or aging wells often lack the integrity to avoid a blowout (the uncontrolled release of oil and/or gas from a well). There is a consistent risk that formation fluids will be forced to migrate up the plugged wellbores and bypass the existing plugs.

Groundwater

In a 2014 report, the U.S. Geological Service warned the California State Water Resources Control Board that the integrity of abandoned wells is a serious threat to groundwater sources, stating, “Even a small percentage of compromised well bores could correspond to a large number of transport pathways.”

The California Council on Science and Technology (CCST) has also suggested the need for additional research on existing aquifer contamination. In 2014, they called for widespread testing of groundwater near oil and gas fields, which has still not occurred.

Leaks

In addition to the contamination of underground sources of drinking water, abandoned well failures can even create a pathway for methane and fluids to escape to Earth’s surface. In many cases, such as in Pennsylvania, Texas, and California, where drilling began prior to the turn of the 20th century, many wells have been left unplugged. Of the abandoned wells that were plugged, the plugging process was much less adequate than it is today.

If plugged wells are allowed to leak, surface expressions can form. These leaks can travel to the Earth’s crust where oil, gas, and formation waters saturate the topsoil. A construction supervisor for Chevron named David Taylor was killed by such an event in the Midway-Sunset oil field near Bakersfield, CA. According to the LA Times, Chevron had been trying to control the pressure at the well-site. The company had stopped injections near the well, but neighboring operators continued high-pressure injections into the pool. As a result, migration pathways along old wells allowed formation fluids to saturate the Earth just under the well-site. Tragically, Taylor fell into a 10-foot diameter crater of 190° fluid and hydrogen sulfide.

California regulations

Following David Taylor’s death in 2011, California regulators vowed to make urgent reforms to the management of underground injection, and new rules finally went into effect on April 1, 2018. These regulations require more consistent monitoring of pressure and set maximum pressure standards. While this will help with the management of enhanced oil recovery operations, such as steam and water flooding and wastewater disposal, the issue of abandoned wells is not being addressed.

New requirements incentivizing operators to plug and abandon idle wells will help to reduce the number of orphan wells left to the state, but nothing has been done or is proposed to manage the risk of existing orphaned wells.

Conclusion

Why would the state of California allow new oil and gas drilling when the industry refuses to address the existing messes? Why are these messes the responsibility of private landholders and the state when operators declare bankruptcy?

New bonding rules in some states have incentivized larger operators to plug their own wells, but old low-producing or idle wells are often sold off to smaller operators or shell (not Shell) companies prior to plugging. This practice has been the main source of orphaned wells. And regardless of whether wells are plugged or not, research shows that even plugged wells release fugitive emissions that increase with the age of the plug.

If the fossil fuel industry were to plug the existing 1.666 million currently active wells, there would be nearly 5 million plugged wells that require regular inspections, maintenance, and for the majority, re-plugging, to prevent the flow of greenhouse gases. This is already unattainable, and drilling more wells adds to this climate disaster.

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Photo by Pat Sullivan/AP https://www.houstonchronicle.com/news/houston-texas/houston/article/Fracking-research-hits-roadblock-with-Texas-law-6812820.php

California regulators need to protect groundwater from oil and gas waste this time around

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

California’s 2nd Largest Waste Stream

Every year the oil and gas industry in California generates billions of gallons of wastewater, also known as produced water. According to a study by the California Council on Science and Technology, in 2013, more than 3 billion barrels of produced water were extracted along with some 0.2 billion barrels of oil across the state. This wastewater is usually contaminated with a mixture of heavy metals, hydrocarbons, naturally occurring radioactive materials, and high levels of salts. Yet, contaminated wastewater from oil-field operations is exempt from the hazardous waste regulations enforced by the Resource Conservation and Recovery Act (RCRA).

Operators are, therefore, not required to measure or report the chemistry of this wastewater. Even with these unknowns, it is legally re-injected back into groundwater aquifers for disposal. Once an aquifer is contaminated it can be extremely difficult, if not impossible, to clean up again. Particularly in California, where water resources are already stretched thin, underground injection of oil and gas wastewater is a major environmental and economic concern.

Regulatory Deficiency

Under the Underground Injection Control program, wastewater is supposed to be injected only into geologic formations that don’t contain usable groundwater. However, a loophole in the Safe Drinking Water Act allows oil and gas companies to apply for what’s called an aquifer exemption, which allows them to inject wastewater into aquifers that potentially hold high-quality drinking water. To learn more about aquifer exemptions, see FracTracker’s summary, here.

The California department responsible for managing these aquifer exemption permits – the Division of Oil, Gas, and Geothermal Resources (DOGGR) – has for decades failed in its regulatory capacity. In 2015, for example, DOGGR admitted that at least 2,553 wells had been permitted to inject oil and gas waste into non-exempt aquifers – aquifers that could be used for drinking water. Independent audits of DOGGR showed decades of poor record-keeping, lax oversight, and in some cases, outright defiance of the law – showing the cozy relationship between regulators and the oil and gas industry. While 176 wells (those that were injecting into the cleanest drinking water) were initially shut down, most of the rest of the 2,377 permits were allowed to continue injecting into disputed wells through the following two years of the regulatory process.

The injection wells targeted by the Environmental Protection Agency (EPA), including those that were shut down, are shown in the map below (Figure 1).

Figure 1. Map of EPA-targeted Class II Injection Wells


View map fullscreen | How FracTracker maps work | Map Data (CSV): Aquifer Exemptions, Class II Wells

The timeline of all this is just as concerning. The State of California has known about these problems since 2011, when the EPA audited California’s underground injection program and identified substantial deficiencies in its program, including failure to protect some potential underground sources of drinking water, a one-size-fits-all geologic review, and inadequate and under-qualified staffing for carrying out inspections. In 2014, the Governor’s office requested that the California EPA perform an independent review of the program. EPA subsequently made a specific remediation plan and timeline for DOGGR, and in March of 2015 the State finalized a Corrective Action Plan, to be completed by February 2017.

Scientific Review of CA Oil and Gas Activities

Meanwhile, in 2013, the California Senate passed SB-4, which set a framework for regulating hydraulic fracturing in California. Part of the bill required an independent scientific study to be conducted on oil and gas well stimulation, including acid well stimulation and hydraulic fracturing. The California Council on Science and Technology organized and led the study, in collaboration with the Lawrence Berkeley National Laboratories, which combined original technical data analyses and a review of relevant literature, all of which was extensively peer-reviewed. The report argues that both direct and indirect impacts of fracking must be accounted for, and that major deficiencies and inconsistencies in data remained which made research difficult. They also recommended that DOGGR improve and modernize their record keeping to be more transparent.

Figure 2. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

Figure 2*. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

A major component of the SB-4 report covered California’s Class II injection program. Researchers analyzed the depths of groundwater aquifers protected by the Safe Drinking Water Act, and found that injection and hydraulic fracturing activity was occurring within the same or neighboring geological zones as protected drinking water (Figure 2*).

*Reproduced from California Council on Science and Technology: An Independent Scientific Assessment of Well Stimulation in California Vol. 3.

More Exemptions to be Granted

Now, EPA is re-granting exemptions again. Six aquifer exemptions have been granted, and more are on the docket to be considered. In this second time around, it is imperative that regulatory agencies be more diligent in their oversight of this permitting process to protect groundwater resources. At the same time, the 2015 California bill SB 83 mandates the appointment of an independent review panel to evaluate the Underground Injection Control Program and to make recommendations on how to improve the effectiveness of the program. This process is currently in the works and a panel has been assembled, and FracTracker Alliance will be working to provide data, maps and analyses for this panel.

Stay tuned for more to come on which aquifers are being exempted, why, and what steps are being taken to protect groundwater in California.


Feature image by Pat Sullivan/AP

Mariner East 2: More Spills & Sinkholes Too?

The Mariner East 2 (ME2) pipeline, currently being built by Sunoco Pipeline (Energy Transfer Partners), is a massive 350-mile long pipeline that, if completed, will carry 275,000 barrels of propane, ethane, butane, and other hydrocarbons per day from the shale gas fields of Western Pennsylvania to a petrochemical export terminal located on the Delaware River.

ME2 has faced numerous challenges from concerned citizens since Sunoco first announced plans for the project in 2014. Fights over taking private property by eminent domain, eyebrow raising permit approvals with known technical deficiencies, as well as nearly a hundred drilling mud spills — inadvertent returns (IRs) — at horizontal directional drilling (HDD) sites have occurred since work began in 2017.

This article and the accompanying map brings us up-to-date on the number, location, and status of ME2’s HDD spills. We also summarize the growing list of violations and settlements related to these events. Finally, we highlight the most recent concerns related to ME2’s construction: sinkholes emerging along the pipeline’s path in karst geological formations.

Map of ME2 Updated HDDs, IRs & Karst

The map below shows an updated visual of ME2’s IRs, as of the DEP’s latest tally on March 1, 2018. Included on this map are HDDs where DEP ordered Sunoco reevaluate construction sites to prevent additional spills. Also identified on this map are locations where Sunoco was ordered to notify landowners in close proximity to certain HDDs prior to additional drilling. Finally, the below map illustrates how sinkholes are not a problem unique to one site of construction but are, in fact, common to many areas along ME2’s route. These topics are discussed in greater depth below.

Open the map full-screen to view additional layers not available in the embedded version below.

View Map Fullscreen | How FracTracker Maps Work

HDDs & Inadvertent Returns – Redux

In July 2017, the PA Environmental Hearing Board granted a two week halt to ME2’s HDD operations. The temporary injunction was in response to petitions from the Clean Air CouncilMountain Watershed Association, and the Delaware Riverkeeper Network following IRs­­ at more than 60 sites that contaminated dozens of private drinking water wells, as well as nearby streams and wetlands. FracTracker first wrote about these issues in this prior article.

HDD IR in Washington County
(image: Observer-Reporter)

Despite these issues, and despite Sunoco being cited for 33 violations, ME2 was allowed to proceed under an August 7th agreement that stated Sunoco must reevaluate their HDD plans to minimize additional spills. These studies were to include re-examining the site’s geology and conducting seismic surveys. Sites for reevaluation were selected based on factors such as proximity water supplies, nearby streams and wetlands, problematic geologic conditions, and if an IR had occurred at that site previously. Of ME2’s 230 HDDs, 64 were ordered for reevaluation — 22 of these were selected due to prior IRs occurring at the site.

The DEP mandated that Sunoco’s reevaluation studies be put out for public comment. A table of which HDD studies are currently out for comment can be found here. DEP’s settlement also required Sunoco to notify landowners in proximity to certain HDDs prior to commencing construction due to elevated risks. Of the 64 HDD sites under review, Sunoco must notify 17 residents within 450ft of an HDD site, and 22 residents within 150ft of other sites. The HDD reevaluation sites are shown on the FracTracker map above. Below is an illustration of one site where Sunoco is required to notify landowners within 450ft.

One issue residents have raised with these notifications is that Sunoco is allowed to offer landowners the option to connect their homes to a water buffalo during drilling as an alternative to using their groundwater well. The catch is that, if their well does become contaminated, they would also waive their right to have Sunoco drill them a new replacement well.

“Egregious Violations”

In January 2018, the DEP again suspended ME2’s construction, this time indefinitely revoking their permits, due to even more IRs. DEP also cited Sunoco for “egregious and willful” permit violations —mainly executing HDDs at sites where they had no permission to do so. The DEP noted of their decision that, “a permit suspension is one of the most significant penalties DEP can levy.”

Nevertheless, Sunoco was again allowed to resume construction on February 8, 2018, after paying a $12.6 million fine. The DEP press release accompanying the decision assured the public that, “Sunoco has demonstrated that it has taken steps to ensure the company will conduct the remaining pipeline construction activities in accordance with the law and permit conditions, and will be allowed to resume.”

A few weeks later, Sunoco ran a full-page advertisement in the Harrisburg Patriot-News, shown above, lauding their safety record. Among other notables, the piece boasts, “State and federal regulators spent more than 100 inspection days during 2017 on the Mariner East project, more inspection days than on any other pipeline in Pennsylvania.” Critics have noted that the inordinate number of inspections are due to the comedy of errors associated with ME2’s construction.

Karst Formations & Sinkholes

Which brings us to the current ME2 debacle. Last week, the PA Public Utility Commission (PUC) ordered a temporary shutdown of Mariner East 1 (ME1), another natural gas liquids pipeline owned by Sunoco/ETP. ME1 was built in the 1930s and its right-of-way is being used for most of ME2’s route across the state. This latest construction setback comes in the wake of numerous sinkholes that emerged beginning in December along Lisa Drive in West Whitehead Township, a suburb of Philadelphia in Chester County.

The most recent of these sinkholes grew into a 20ft-deep, 15ft-wide chasm that exposed portions of ME1 and came within 10ft of a house. It is worth noting that, until only a few days ago, ME1 was an operational 8in pipeline with a potential impact radius (aka “blast zone”) of some 500ft. The PUC ordered that Sunoco must now run a line inspection on ME1 for a mile upstream and a mile downstream from the sinkhole sites along Lisa Drive, seen in the image below. Note the proximity of these sinkholes to Amtrak’s Keystone rail lines (connecting Pittsburgh to Philadelphia), under which ME2 also runs. The Federal Railway Administration only recently learned of the sink holes from a nearby resident.

The Lisa Drive sinkholes are being credited to Sunoco executing an HDD in an area known to have karst geological formations. Sunoco has been ordered by the PUC to conduct more geophysical testing and seismic analyses of the area because of this. Karst is often called the “Swiss cheese” of geology — notorious for caves, sinkholes, and underground rivers. As these geological formations change shape, pipelines can bend and settle over time, ultimately leading to potentially dangerous gas leakages or explosions. For instance, the 2015 Atex-1 pipeline explosion in Follansbee, WV, was ultimately determined by the Pipeline and Hazardous Materials Safety Administration (PHSA) as having been caused by ground settling. That explosion released some 24,000 barrels of ethane, burning more than five acres of surrounding land.

The US Geological Survey (USGS) maintains fairly detailed maps of rock formations for most states, including formations known to have karst. In PA, there are a number of “carbonate” rock families known for karst features and settlement issues: limestone and dolostone, and, to a lesser extent, shale. Meanwhile, the PA Department of Conservation and Natural Resources (DCNR) has maintained a record of karst “features” — sinkholes and surface depressions — documented since 1985. A great explanation of the different types of karst features can be found here.

Underestimating the Risks

What is concerning about the Lisa Drive sinkholes is that Sunoco had supposedly already conducted additional karst geological reviews of the area as part of the August DEP settlement, subsequently ranking a nearby HDD (#PA-CH-0219) as “low risk” for running into karst issues—despite knowing the HDD runs through a karst formation with sinkholes and surface depressions in the area. For the HDD that runs the length of Lisa Drive (#PA-CH-0256), the study rated its risk as “very low.” These two HDDs are shown below, along with the area of ME1 now under structural review.

The likely result of these inaccurate assessments led to two IRs at Lisa Drive, one in October and another in November 0f 2017. DEP’s writeup of these events note that the total volume of drilling muds spilled remains unknown because Sunoco didn’t report the incident. Then, only a month later, sinkholes emerged in the same locations. An image of the November HDD IR is shown below.

It is important to note two additional things of Sunoco’s karst study, an except of which is seen in their map of the West Whiteland area below. First, Lisa Drive is just on the edge of a karst limestone formation. USGS data suggest the location is actually mica schist, but the USGS data is also only a rough estimate of different formations. This underscores why pipeline companies must be required to conduct detailed geotechnical analysis of all HDD sites at the onset of their projects.

The other notable aspect of Sunoco’s study is that it does not fully represent all rock formations known to have karst features. In Sunoco’s map, we see orange shading for limestone, but this does not include dolostone that underlies the many surface depressions and sinkholes surrounding West Whiteland. FracTracker’s map includes these formations for greater accuracy.

Takeaways

Interestingly, as Anya Litvak of the Pittsburgh Post-Gazette observed in her reporting on the Lisa Drive incident, Sunoco’s updated karst assessment ranked the entire route of the ME2 pipeline through the state as “low to very low” risk for potential issues. Furthermore, Sunoco has tried to downplay the Lisa Drive incident, stating that “all areas have been secured,” and that additional incidents are unlikely to occur.

But the overall relationship between Mariner East 2’s IRs, HDD sites, and known karst features tells a very different story than Sunoco’s about the potential risks of ME2. In addition to the concerns about new sinkholes near Lisa Drive, FracTracker found the following in our analysis:

  • 7 sinkholes and 386 surface depressions are within 1,500ft of a ME2 HDD site.
  • Of the 230 HDDs, 87 are located in carbonate rock areas (52 in limestone/dolostone, 35 in shale).
  • Of the 99 IRs, 39 have occurred in carbonate rock areas (23 in limestone/dolostone, 16 in shale).

In other words, nearly half of the IRs caused by ME2 HDDs were located in areas known to have karst formations. Worth noting is that an additional 15 occurred in sandstone formations, also known to cause settlement over time. The remaining IRs are split across nine other formation types.

Considering that the DEP’s current review of Sunoco’s ability to safely execute future HDDs are based on the same karst study that missed the Lisa Drive HDD and ranked nearby HDDs as a “low” risk, one can only assume that additional spills will occur. There are many more HDD sites yet to be drilled, and also not likely studied fully for potential karst risks. As illustrated by the continuing saga of spills, violations, and omissions, it is clear that Sunoco has not maintained a high standard of construction in building ME2 from the onset.

We thank Eric Friedman from the Middletown Coalition for Community Safety for supplying photos of the Lisa Drive site used in this article.

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

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.

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.

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.

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

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: 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”)

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”)

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.

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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Related Articles

By Kirk Jalbert, FracTracker Alliance

Sandhill Crane

Giving Voice to the Sandhill Cranes: Place-based Arguments against Keystone XL

By Wrexie Bardaglio, guest commentator

When we hear his call, we hear no mere bird. We hear the trumpet in the orchestra of evolution. He is the symbol of our untamable past, of that incredible sweep of millennia which underlies and conditions the daily affairs of birds and men…” ~ Aldo Leopold, on the Sandhill Crane, in “Marshland Elegy”

Dilbit – or diluted bitumen – is refined from the naturally-occurring tar sands deposits in Alberta, Canada. In March 2017, I applied to the Nebraska Public Service Commission for standing as an intervenor in the Commission’s consideration of TransCanada’s request for a permit to construct a pipeline transporting dilbit – a project referred to as the Keystone XL pipeline. Below are my reflections on the battle against the permitting process, and how FracTracker’s maps ensured the Sandhill Crane’s voice made it into public record.

A Pipeline’s History

The Keystone 1 pipeline carries the dilbit from Alberta, to Steele City, Nebraska, and ultimately to Port Arthur, Texas and export refineries along the Gulf Coast. The state of Montana had already approved the Keystone XL project, as had the state of South Dakota. The decision of the South Dakota Public Utilities Commission was appealed, however, and has now worked its way to the South Dakota Supreme Court, where it is pending.

Resistance to TransCanada’s oil and gas infrastructure projects is not new. Beginning in 2010, some Nebraska farmers and ranchers joined forces with tribal nations in the Dakotas, who were also fighting TransCanada’s lack of proper tribal consultation regarding access through traditional treaty territory. The indigenous nations held certain retained rights as agreed in the 1868 Fort Laramie Treaty between the United States government and the nine tribes of the Great Sioux Nation. The tribes were also protesting TransCanada’s flaunting of the National Historic Preservation Act’s protections of Native American sacred sites and burial grounds. Further, although TransCanada was largely successful in securing the easements needed in Nebraska to construct the pipeline, there were local holdouts refusing to negotiate with the company. TransCanada’s subsequent attempts to exercise eminent domain resulted in a number of lawsuits.

In January of 2015, then-President Barack Obama denied the international permit TransCanada needed. While that denial was celebrated by many, everyone also understood that a new president could well restore the international permit. Indeed, as one of his first actions in January 2017, the new Republican president signed an executive order granting the permit, and the struggle in Nebraska was reignited.

“What Waters Run Through My Veins…”

While I am a long-time resident of New York, I grew up in the Platte River Valley of South Central Nebraska, in a town where my family had and continues to have roots – even before Nebraska became a state. There was never a question in my mind that in this particular permitting process I would request status as an intervenor; for me, the matter of the Keystone XL Pipeline went far beyond the legal and political and energy policy questions that were raised and were about to be considered. It was about who I am, how I was raised, what I was taught, what waters run through my veins as surely as blood, and who my own spirit animals are, the Sandhill Cranes.

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Bardaglio (age 3) and her father, along the banks of the Platte River

When we were growing up, our father told us over and over and over about why Nebraska was so green. The Ogallala Aquifer, he said, was deep and vast, and while eight states partially sat atop this ancient natural cistern, nearly all of Nebraska floated on this body. Nebraska was green, its fields stretching to the horizon, because, as our father explained, the snow runoff from the Rockies that flowed into our state and was used eleven times over was cleansed in water-bearing sand and gravel on its way to the Missouri on our eastern boundary, thence to the Mississippi, and finally to the Gulf.

I grew up understanding that the Ogallala Aquifer was a unique treasure, the largest freshwater aquifer in the world, the lifeblood for Nebraska’s agriculture and U.S. agriculture generally, and worthy of protection. I thought about the peril to the aquifer because of TransCanada’s plans, should there be a spill, and the additional threats an accident would potentially pose to Nebraska’s rivers, waterways and private wells.

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The Ogallala Aquifer

Knowing that climate change is real, terrifying, and accelerating, I recognized that a warming world would increasingly depend on this aquifer in the nation’s midsection for life itself.

Migration of the Sandhill Cranes

As I thought about how I would fight the KXL, another narrative took shape rising out of my concern for the aquifer. Growing up in the South Central Platte River Valley, I – and I daresay most everyone who lives there – have been captivated by the annual migration of the Sandhill Cranes, plying the skies known as the Central Flyway. As sure as early spring comes, so do the birds. It may still be bitterly cold, but these birds know that it is time to fly. And so they do – the forward scouts appearing in winter grey skies, soon followed by some 500,000 – 600,000 thousand of them, darkening the skies, their cries deafening and their gorgeous archaeopteryx silhouettes coming in wave after wave like flying Roman Legions.

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To this day, no matter where I am, the first thing in my sinews and bones when winter begins to give way is the certainty that the birds are coming, I feel them; they are back. They are roosting on the sandbars in the braided river that is the Platte and gleaning in the stubbled fields abutting it… they are home.

According to The Nature Conservancy:

Scientists estimate that at least one-third of the entire North American population of Sandhill Cranes breed in the boreal forest of Canada and Alaska…

Scientists estimate that approximately 80 percent of all Sandhill Cranes in North America use a 75-mile stretch of Nebraska’s Platte River during spring migration. From March to April, more than 500,000 birds spend time in the area preparing for the long journey north to their breeding grounds in Canada and Alaska. During migration, the birds may fly as much as 400 miles in one day.

Sandhill Cranes rely on open freshwater wetlands for most of their lifecycle. Degradation of these kinds of wetland habitats is among the most pressing threats to the survival of Sandhill Cranes. (Emphasis added)

Giving Sandhill Cranes a Voice

But how could I make the point about the threat TransCanada posed to the migratory habitat of the Sandhill Cranes (and endangered Whooping Cranes, pelicans, and hummingbirds among the other thermal riders who also migrate with them)? Books, scientific papers, lectures – all the words in the world – cannot describe this ancient rite, this mysterious primal navigation of the unique pathway focusing on this slim stretch of river, when viewed from a global perspective a fragile skein in a fragile web in a biosphere in peril.

In my head I called it a river of birds in the grassland of sky. And I am so grateful to my friend, Karen Edelstein at FracTracker Alliance, for her willingness to help map and illustrate the magnificence of the migration flyway in the context of the three proposed options for the KXL pipeline.

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Karen prepared two maps for me, but my favorite is the one above.

It shows an ancient, near-primordial, near-mystical event. Guided by rudders and instinct we can barely comprehend, in concert with earth’s intrinsic and exquisitely-designed balance, and as certain as a sunrise, a sunset or a moon rise, these oldest of crane species find their ways through the heavens. They hew to certainties that eclipse the greed of multinational corporations like TransCanada, who barely even pay lip service to the integrity of anything over which they can’t exert dominion. To say they don’t respect the inherent rights of species other than our own, or to ecological communities that don’t directly include us, is an understatement, and a damning comment on their values.

I was prepared for pushback on these maps from TransCanada. And in truth, the company was successful in an in limine motion to have certain exhibits and parts of my testimony stricken from the official record of the proceedings.

But not the maps.

In fact, too many other intervenors to count, as well as several of the lawyers involved in the proceedings commented to me on the beauty and accuracy of the maps. And not only are they now a part of the permanent record of the Nebraska Public Service Commission, should there be an appeal (which all of us expect), on both sides of the issue, there is a very good possibility they will be incorporated into the formal testimonies by the lawyers as the matter moves through the appeals process.

Taking Action, Speaking Out

Ordinary citizens must figure out how to confront the near-impenetrable stranglehold of multi-national corporations whose wealth is predicated on the continuance of fossil fuels as the primary sources of energy. We have had to become more educated, more activist, and more determined to fight the destruction that is now assured if we fail to slow down the impacts of climate change and shift the aggregate will of nations towards renewable energy.

Many activists do not realize that they can formally intervene at the state level in pipeline and infrastructure permitting processes. In doing so, the voice of the educated citizen is amplified and becomes a threat to these corporations whose business models didn’t account for systematic and informed resistance in public agencies’ heretofore pro forma proceedings. The publicly-available documents and filings from corporations can be important tools for “speaking truth to power” when paired with the creative tools born of necessity by the environmental movement.

Technology is value-neutral, but as I learned – as did many others in the Keystone XL Pipeline fight – in skilled hands it becomes a weapon in the struggle for the greater good.

I will be forever grateful for FracTracker, and will be interested to see how others use this tool in the fights that are sure to come.

EXCELSIOR!

For more background on the natural history of Sandhill Cranes, please view this video produced by The Crane Trust.


Wrexie Bardaglio is a Nebraska native living in Covert, New York. She worked for ten years for a member of Congress as a legislative assistant with a focus on Indian affairs and for a DC law firm as legislative specialist in Indian affairs. She left politics to open a bookstore in suburban Baltimore. She has been active in the Keystone XL fights in Nebraska and South Dakota and in fracking and gas infrastructure fights in New York.

This article’s feature image of a Sandhill Crane is the work of a U.S. Fish and Wildlife Service employee, taken or made as part of that person’s official duties. As a work of the U.S. federal government, the image is in the public domain.

FracTracker Alliance makes hundreds of maps, analyses, and photos available for free to frontline communities, grassroots groups, NGO’s, and many other organizations concerned about the industry to use in their oil and gas campaigns. To address an issue, you need to be able to see it.

However, we rely on funders and donations – and couldn’t do all of this without your help!

JOSHUA DOUBEK / WIKIMEDIA COMMONS

Groundwater risks in Colorado due to Safe Drinking Water Act exemptions

Oil and gas operators are polluting groundwater in Colorado, and the state and U.S. EPA are granting them permission with exemptions from the Safe Drinking Water Act.

FracTracker Alliance’s newest analysis attempts to identify groundwater risks in Colorado groundwater from the injection of oil and gas waste. Specifically, we look at groundwater monitoring data near Class II underground injection control (UIC) disposal wells and in areas that have been granted aquifer exemptions from the underground source of drinking water rules of the Safe Drinking Water Act (SDWA). Momentum to remove amend the SDWA and remove these exemption.

Learn more about Class II injection wells.

Aquifer exemptions are granted to allow corporations to inject hazardous wastewater into groundwater aquifers. The majority, two-thirds, of these injection wells are Class II, specifically for oil and gas wastes.

What exactly are aquifer exemptions?

The results of this assessment provide insight into high-risk issues with aquifer exemptions and Class II UIC well permitting standards in Colorado. We identify areas where aquifer exemptions have been granted in high quality groundwater formations, and where deep underground aquifers are at risk or have become contaminated from Class II disposal wells that may have failed.

Of note: On March 23, 2016, NRDC submitted a formal petition urging the EPA to repeal or amend the aquifer exemption rules to protect drinking water sources and uphold the Safe Drinking Water Act. Learn more

Research shows injection wells do fail

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Class II injection well in Colorado explodes and catches fire. Photo by Kelsey Brunner for the Greeley Tribune.

Disposal of oil and gas wastewater by underground injection has not yet been specifically researched as a source of systemic groundwater contamination nationally or on a state level. Regardless, this issue is particularly pertinent to Colorado, since there are about 3,300 aquifer exemptions in the US (view map), and the majority of these are located in Montana, Wyoming, and Colorado. There is both a physical risk of danger as well as the risk of groundwater contamination. The picture to the right shows an explosion of a Class II injection well in Greeley, CO, for example.

Applicable and existing research on injection wells shows that a risk of groundwater contamination of – not wastewater – but migrated methane due to a leak from an injection well was estimated to be between 0.12 percent of all the water wells in the Colorado region, and was measured at 4.5 percent of the water wells that were tested in the study.

A recent article by ProPublica quoted Mario Salazar, an engineer who worked for 25 years as a technical expert with the EPA’s underground injection program in Washington:

In 10 to 100 years we are going to find out that most of our groundwater is polluted … A lot of people are going to get sick, and a lot of people may die.

Also in the ProPublic article was a study by Abrahm Lustgarten, wherein he reviewed well records and data from more than 220,000 oil and gas well inspections, and found:

  1. Structural failures inside injection wells are routine.
  2. Between 2007-2010, one in six injection wells received a well integrity violation.
  3. More than 7,000 production and injection wells showed signs of well casing failures and leakage.

This means disposal wells can and do fail regularly, putting groundwater at risk. According to Chester Rail, noted groundwater contamination textbook author:

…groundwater contamination problems related to the subsurface disposal of liquid wastes by deep-well injection have been reviewed in the literature since 1950 (Morganwalp, 1993) and groundwater contamination accordingly is a serious problem.

According to his textbook, a 1974 U.S. EPA report specifically warns of the risk of corrosion by oil and gas waste brines on handling equipment and within the wells. The potential effects of injection wells on groundwater can even be reviewed in the U.S. EPA publications (1976, 1996, 1997).

As early as 1969, researchers Evans and Bradford, who reported on the dangers that could occur from earthquakes on injection wells near Denver in 1966, had warned that deep well injection techniques offered temporary and not long-term safety from the permanent toxic wastes injected.

Will existing Class II wells fail?

For those that might consider data and literature on wells from the 1960’s as being unrepresentative of activities occurring today, of the 587 wells reported by the Colorado’s oil and gas regulatory body, COGCC, as “injecting,” 161 of those wells were drilled prior to 1980. And 104 were drilled prior to 1960!

Wells drilled prior to 1980 are most likely to use engineering standards that result in “single-point-of-failure” well casings. As outlined in the recent report from researchers at Harvard on underground natural gas storage wells, these single-point-of-failure wells are at a higher risk of leaking.

It is also important to note that the U.S. EPA reports only 569 injection wells for Colorado, 373 of which may be disposal wells. This is a discrepancy from the number of injection wells reported by the COGCC.

Aquifer Exemptions in Colorado

According to COGCC, prior to granting a permit for a Class II injection well, an aquifer exemption is required if the aquifer’s groundwater test shows total dissolved solids (TDS) is between 3,000 and 10,000 milligrams per liter (mg/l). For those aquifer exemptions that are simply deeper than the majority of current groundwater wells, the right conditions, such as drought, or the needs of the future may require drilling deeper or treating high TDS waters for drinking and irrigation. How the state of Colorado or the U.S. EPA accounts for economic viability is therefore ill-conceived.

Data Note: The data for the following analysis came by way of FOIA request by Clean Water Action focused on the aquifer exemption permitting process. The FOIA returned additional data not reported by the US EPA in the public dataset. That dataset contained target formation sampling data that included TDS values. The FOIA documents were attached to the EPA dataset using GIS techniques. These GIS files can be found for download in the link at the bottom of this page.

Map 1. Aquifer exemptions in Colorado


View map fullscreen | How FracTracker maps work

Map 1 above shows the locations of aquifer exemptions in Colorado, as well as the locations of Class II injection wells. These sites are overlaid on a spatial assessment of groundwater quality (a map of the groundwater’s quality), which was generated for the entire state. The changing colors on the map’s background show spatial trends of TDS values, a general indicator of overall groundwater quality.

In Map 1 above, we see that the majority of Class II injection wells and aquifer exemptions are located in regions with higher quality water. This is a common trend across the state, and needs to be addressed.

Our review of aquifer exemption data in Colorado shows that aquifer exemption applications were granted for areas reporting TDS values less than 3,000 mg/l, which contradicts the information reported by the COGCC as permitting guidelines. Additionally, of the 175 granted aquifer exemptions for which the FOIA returned data, 141 were formations with groundwater samples reported at less than 10,000 mg/l TDS. This is half of the total number (283) of aquifer exemptions in the state of Colorado.

When we mapped where class II injection wells are permitted, a total of 587 class II wells were identified in Colorado, outside of an aquifer exemption area. Of the UIC-approved injection wells identified specifically as disposal wells, at least 21 were permitted outside aquifer exemptions and were drilled into formations that were not hydrocarbon producing. Why these injection wells are allowed to operate outside of an aquifer exemption is unknown – a question for regulators.

You can see in the map that most of the aquifer exemptions and injection wells in Colorado are located in areas with lower TDS values. We then used GIS to conduct a spatial analysis that selected groundwater wells within five miles of the 21 that were permitted outside aquifer exemptions. Results show that groundwater wells near these sites had consistently low-TDS values, meaning good water quality. In Colorado, where groundwater is an important commodity for a booming agricultural industry and growing cities that need to prioritize municipal sources, permitting a Class II disposal well in areas with high quality groundwater is irresponsible.

Groundwater Monitoring Data Maps

Map 2. Water quality and depths of groundwater wells in Colorado
Groundwater risks in Colorado - Map 2
View live map | How FracTracker maps work

In Map 2, above, the locations of groundwater wells in Colorado are shown. The colors of the dots represent the concentration of TDS on the right and well depth on the left side of the screen. By sliding the bar on the map, users can visualize both. This feature allows people to explore where deep wells also are characterized by high levels of TDS. Users can also see that areas with high quality low TDS groundwater are the same areas that are the most developed with oil and gas production wells and Class II injection wells, shown in gradients of purple.

Statistical analysis of this spatial data gives a clearer picture of which regions are of particular concern; see below in Map 3.

Map 3. Spatial “hot-spot” analysis of groundwater quality and depth of groundwater wells in Colorado
Groundwater risks in Colorado - Map 3
View live map | How FracTracker maps work

In Map 3, above, the data visualized in Map 2 were input into a hot-spots analysis, highlighting where high and low values of TDS and depth differ significantly from the rest of the data. The region of the Front Range near Denver has significantly deeper wells, as a result of population density and the need to drill municipal groundwater wells.

The Front Range is, therefore, a high-risk region for the development of oil and gas, particularly from Class II injection wells that are necessary to support development.

Methods Notes: The COGCC publishes groundwater monitoring data for the state of Colorado, and groundwater data is also compiled nationally by the Advisory Committee on Water Information (ACWI). (Data from the National Groundwater Monitoring Network is sponsored by the ACWI Subcommittee on Ground Water.) These datasets were cleaned, combined, revised, and queried to develop FracTracker’s dataset of Colorado groundwater wells. We cleaned the data by removing sites without coordinates. Duplicates in the data set were removed by selecting for the deepest well sample. Our dataset of water wells consisted of 5,620 wells. Depth data was reported for 3,925 wells. We combined this dataset with groundwater data exported from ACWI. Final count for total wells with TDS data was 11,754 wells. Depth data was reported for 7,984 wells. The GIS files can be downloaded in the compressed folder at the bottom of this page.

Site Assessments – Exploring Specific Regions

Particular regions were further investigated for impacts to groundwater, and to identify areas that may be at a high risk of contamination. There are numerous ways that groundwater wells can be contaminated from other underground activity, such as hydrocarbon exploration and production or waste injection and disposal. Contamination could be from hydraulic fracturing fluids, methane, other hydrocarbons, or from formation brines.

From the literature, brines and methane are the most common contaminants. This analysis focuses on potential contamination events from brines, which can be detected by measuring TDS, a general measure for the mixture of minerals, salts, metals and other ions dissolved in waters. Brines from hydrocarbon-producing formations may include heavy metals, radionuclides, and small amounts of organic matter.

Wells with high or increasing levels of TDS are a red flag for potential contamination events.

Methods

Groundwater wells at deep depths with high TDS readings are, therefore, the focus of this assessment. Using GIS methods we screened our dataset of groundwater wells to only identify those located within a buffer zone of five miles from Class II injection wells. This distance was chosen based on a conservative model for groundwater contamination events, as well as the number of returned sample groundwater wells and the time and resources necessary for analysis. We then filtered the groundwater wells dataset for high TDS values and deep well depths to assess for potential impacts that already exist. We, of course, explored the data as we explored the spatial relationships. We prioritized areas that suggested trends in high TDS readings, and then identified individual wells in these areas. The data initially visualized were the most recent sampling events. For the wells prioritized, prior sampling events were pulled from the data. The results were graphed to see how the groundwater quality has changed over time.

Case of Increasing TDS Readings

If you zoom to the southwest section of Colorado in Map 2, you can see that groundwater wells located near the injection well 1 Fasset SWD (EPA) (05-067-08397) by Operator Elm Ridge Exploration Company LLC were disproportionately high (common). Groundwater wells located near this injection well were selected for, and longitudinal TDS readings were plotted to look for trends in time. (Figure 1.)

The graphs in Figure 1, below, show a consistent increase of TDS values in wells near the injection activity. While the trends are apparent, the data is limited by low numbers of repeated samples at each well, and the majority of these groundwater wells have not been sampled in the last 10 years. With the increased use of well stimulation and enhanced oil recovery techniques over the course of the last 10 years, the volumes of injected wastewater has also increased. The impacts may, therefore, be greater than documented here.

This area deserves additional sampling and monitoring to assess whether contamination has occurred.


Figures 1a and 1b. The graphs above show increasing TDS values in samples from groundwater wells in close proximity to the 1 Fassett SWD wellsite, between the years 2004-2015. Each well is labeled with a different color. The data for the USGS well in the graph on the right was not included with the other groundwater wells due to the difference in magnitude of TDS values (it would have been off the chart).

Groundwater Contamination Case in 2007

We also uncovered a situation where a disposal well caused groundwater contamination. Well records for Class II injection wells in the southeast corner of Colorado were reviewed in response to significantly high readings of TDS values in groundwater wells surrounding the Mckinley #1-20-WD disposal well.

When the disposal well was first permitted, farmers and ranchers neighboring the well site petitioned to block the permit. Language in the grant application is shown below in Figure 2. The petitioners identified the target formation as their source of water for drinking, watering livestock, and irrigation. Regardless of this petition, the injection well was approved. Figure 3 shows the language used by the operator Energy Alliance Company (EAC) for the permit approval, which directly contradicts the information provided by the community surrounding the wellsite. Nevertheless, the Class II disposal well was approved, and failed and leaked in 2007, leading to the high TDS readings in the groundwater in this region.

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Figure 2. Petition by local landowners opposing the use of their drinking water source formation for the site of a Class II injection disposal well.

 

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Figure 3. The oil and gas operation EAC claims the Glorietta formation is not a viable fresh water source, directly contradicting the neighboring farmers and ranchers who rely on it.

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Figure 4. The COGCC well log report shows a casing failure, and as a result a leak that contaminated groundwater in the region.

Areas where lack of data restricted analyses

In other areas of Colorado, the lack of recent sampling data and longitudinal sampling schemes made it even more difficult to track potential contamination events. For these regions, FracTracker recommends more thorough sampling by the regulatory agencies COGCC and USGS. This includes much of the state, as described below.

Southeastern Colorado

Our review of the groundwater data in southeastern Colorado showed a risk of contamination considering the overlap of injection well depths with the depths of drinking water wells. Oil and gas extraction and Class II injections are permitted where the aquifers include the Raton formation, Vermejo Formation, Poison Canyon Formation and Trinidad Sandstone. Groundwater samples were taken at depths up to 2,200 ft with a TDS value of 385 mg/l. At shallower depths, TDS values in these formations reached as high as 6,000 mg/l, and 15 disposal wells are permitted in aquifer exemptions in this region. Injections in this area start at around 4,200 ft.

In Southwestern Colorado, groundwater wells in the San Jose Formation are drilled to documented depths of up to 6,000 feet with TDS values near 2,000 mg/l. Injection wells in this region begin at 565 feet, and those used specifically for disposal begin at below 5,000 feet in areas with aquifer exemptions. There are also four disposal wells outside of aquifer exemptions injecting at 5,844 feet, two of which are not injecting into active production zones at depths of 7,600 and 9,100 feet.

Western Colorado

In western Colorado well Number 1-32D VANETA (05-057-06467) by Operator Sandridge Exploration and Production LLC’s North Park Horizontal Niobara Field in the Dakota-Lokota Formation has an aquifer exemption. The sampling data from two groundwater wells to the southeast, near Coalmont, CO, were reviewed, but we can’t get a good picture due to the lack of repeat sampling.

Northwestern Colorado

http://digital.denverlibrary.org/cdm/ref/collection/p16079coll32/id/346073

A crew from Bonanza Creek repairs an existing well in the McCallum oil field. Photo by Ken Papaleo / Rocky Mountain News

In Northwestern Colorado near Walden, CO and the McCallum oil field, two groundwater wells with TDS above 10,000 ppm were selected for review. There are 21 injection wells in the McCallum field to the northwest. Beyond the McCallum field is the Battleship field with two wastewater disposal wells with an aquifer exemption. West of Grover, Colorado, there are several wells with high TDS values reported for shallow wells. Similar trends can be seen near Vernon. The data on these wells and wells from along the northern section of the Front Range, which includes the communities of Fort Collins, Greeley, and Longmont, suffered from the same issue. Lack of deep groundwater well data coupled with the lack of repeat samples, as well as recent sampling inhibited the ability to thoroughly investigate the threat of contamination.

Trends and Future Development

Current trends in exploration and development of unconventional resources show the industry branching southwest of Weld County towards Fort Collins, Longmont, Broomfield and Boulder, CO.

These regions are more densely populated than the Front Range county of Weld, and as can be seen in the maps, the drinking water wells that access groundwaters in these regions are some of the deepest in the state.

This analysis shows where Class II injection has already contaminated groundwater resources in Colorado. The region where the contamination has occurred is not unique; the drinking water wells are not particularly deep, and the density of Class II wells is far from the highest in the state.

Well casing failures and other injection issues are not exactly predictable due to the variety of conditions that can lead to a well casing failure or blow-out scenario, but they are systemic. The result is a hazardous scenario where it is currently difficult to mitigate risk after the injection wells are drilled.

Allowing Class II wells to expand into Front Range communities that rely on deep wells for municipal supplies is irresponsible and dangerous.

The encroachment of extraction into these regions, coupled with the support of Class II injection wells to handle the wastewater, would put these groundwater wells at particular risk of contamination. Based on this analysis, we recommend that regulators take extra care to avoid permitting Class II wells in these regions as the oil and gas industry expands into new areas of the Front Range, particularly in areas with dense populations.


Feature Image: Joshua Doubek / WIKIMEDIA COMMONS

Article by: Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

 

October 31, 2017 Edit: This post originally cited the Clean Water Act instead of the Safe Drinking Water Act as the source that EPA uses to grant aquifer exemptions.

Northeast Ohio Class II injection wells taken via FracTracker's mobile app, May 2015

What are aquifer exemptions? Permitted exemptions from the Safe Drinking Water Act

We’d like to give our readers a bit of background on aquifer exemptions, because we’re going to be covering this topic in a few upcoming blog posts. Stay tuned!

Liquid Waste Disposal

Drilling for oil and gas produces both liquid and solid waste that must be disposed of. The liquid waste from this industry is considered a “Class II waste” according to the US EPA. Aquifers are places underground capable of holding or transmitting groundwater. To dispose of Class II waste, operators are granted aquifer exemptions, by the EPA based on the state’s recommendations. The term “exemption,” specifically, refers to the Safe Drinking Water Act, which protects underground sources of drinking water (USDWs).

Therefore, these exemptions grant oil and gas operators the right to contaminate groundwaters, albeit many of the groundwater formations used for disposal in Class II wells are very deep.

Learn more about disposal well classes and aquifer exemptions on this story map by the US EPA

Aquifer Exemption Criteria

There are several qualifiers for a USDW to be granted exempt from the Safe Drinking Water Act. Aquifer exemptions are granted for underground formations that are not currently used as a source of drinking water and meet one of the following criteria:

  • The formation contains commercially producible minerals or hydrocarbons;
  • The formation is so deep that recovery of water for drinking water purposes is economically or technologically impractical; or,
  • The formation is so contaminated that it would be economically or technologically impractical to render the water fit for human consumption.
  • In some states, aquifer exemptions are not approved for formations with Total Dissolved Solids (TDS*) equal to or less than 3,000 mg/l TDS.

If an underground formation qualifies for an exemption, it does not mean that groundwater cannot be used for drinking water, just that it is not currently a source of drinking water. The most precarious criteria requirement, therefore, is the determination that a USDW is simply not “economically viable” or it is “technologically impractical,” meaning that the cost of drilling a groundwater well to the depth of the aquifer (under the condition of the current need for water) may make the investment impractical. In the near future, this water may be needed and highly valued, however.

TDS = Total dissolved solids are inorganic salts (e.g. calcium, magnesium, potassium, sodium, bicarbonates, chlorides, and sulfates), as well as some organic matter, dissolved in water.

The Lay of the Land

Below, we have put together a map of aquifer exemptions in the U.S. Click on the dots and shaded areas to learn more about a particular aquifer.

Map of all aquifer exemptions in the U.S.

View map fullscreen | How FracTracker maps work


By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Water supplies article

Risks to Water Supplies in PA’s Susquehanna Basin

In this series of articles on the Susquehanna River Basin, FracTracker has explored the relationship between oil and gas extraction and the overall health of the watershed relative to oil and gas extraction impacts. We began with a basic overview of likely relationships, followed by an analysis of oil and gas violations relative to resources available for monitoring water quality changes. In the most recent article we assessed the corresponding effects of extraction on deforestation and habitat loss. With the rapid expansion of oil and gas drilling over the past decade, many have also formed legitimate concerns about threats to public and private water supplies. In the final article of the series we look closely at this issue, at the complexities of assessing risks to water supplies, while also highlighting recent research shedding new light on the nature of these risks.

Pennsylvania’s Hydrological System

The Susquehanna River is home to more than 3.3 million people who depend on the river and its tributaries for drinking water. The basin also feeds thousands of businesses that require water for their operations, such as manufacturing facilities, farms, golf courses, and more. In some instances, water supplies are fed by groundwater wells, which are in turn fed by underground aquifers of different depths. In other cases, water supplies are drawn from intake points in nearby lakes, rivers, and streams.

Map of PA's groundwater aquifer system.

Figure 1: Map of PA’s groundwater aquifer system.

While many believe underground and surface water systems are somehow discrete, this is far from the case. Groundwater is a major contributor to rivers, lakes, and wetlands – as they are all connected through the hydrological cycle. Some precipitation runs directly into streams. But much of it filters through soil and rock into shallow and deep aquifers. Aquifers then carry water over the course of months, years, and even centuries, into larger water bodies. The most common discharge points are from springs and from low-lying wetlands. The figures above (figure 1) and below (figure 2) illustrate Pennsylvania’s four major aquifer types, compiled by Penn State Extension.

Figure 3: Types of groundwater aquifers in PA.

Figure 2: Types of groundwater aquifers in PA.

Assessing Groundwater Supply Risks

Managing the overall health of the hydrological cycle is of critical importance to the 3.3 million people who live in the Susquehanna River Basin. However, oil and gas extraction poses significant risks to the state’s water sources. As we have detailed in prior articles in this series, accidents and spills can cause chemicals and hydraulic fracturing fluids to run off into nearby watersheds. Growing evidence also suggests that groundwater can be contaminated by migrating hydraulic fracturing fluids.

Figure 4: Number of household and public water supply groundwater wells by state (DCNR).

Figure 3: Number of household and public water supply groundwater wells by state (DCNR).

In one study, conducted by Columbia University in 2016, researchers found elevated levels of dissolved calcium, chlorine, sulfates and iron in lowland drinking wells within one kilometer of a drilling site compared to baseline averages. In lowland wells more than a kilometer away, they found elevated levels of methane, sodium, and manganese. Elevated levels dropped off in wells on higher ground, which suggests the hydraulic fracturing process affects shallow and deep groundwater sources along different timelines.

According to the PA Department of Conservation and Natural Resources (DCNR), Pennsylvania ranks second in the nation for total number of groundwater wells, second for number of private drinking wells, and third for number of public water supplies dependent on groundwater wells (figure 4). However, determining how many groundwater wells may be at risk to oil and gas extraction is complicated for a variety of reasons. First, DCNR acknowledges that only about half (480,000) of the 1 million groundwater wells in the state are documented. Registration of groundwater wells only began in 1955, and detailed information including latitude and longitudinal coordinates only came into being in the 1980s. These records are now maintained in the PA Groundwater Inventory System (PAGWIS). It is worth noting that the PA Department of Environmental Protection (DEP) does not regulate private drinking water wells. They are only required to respond to pollution complaints.

Correlating O&G Wells to Complaints Data

Despite these data gaps, we can still learn a lot from the wells that are documented in PAGWIS. For instance, we compared the location of groundwater wells to oil and gas related complaints and found some interesting correlations. The below map can be used to explore these relationships.

Map of at-risk groundwater wells, public water supplies, and citizen complaints


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The first stage our analysis involved narrowing the PGWIS registered groundwater wells in the Susquehanna Basin to those that are actively used for drinking water, agriculture, and irrigation (66,306 total). We then limited to those within 1 kilometer of an oil and gas well, essentially mirroring the distances used by the Columbia University study. We found 2,551 groundwater wells within this “risk zone” of 1 kilometer.

For our second stage, we utilized research conducted by Public Herald, an investigative reporting team that spent three years reviewing oil and gas related complaints submitted to the DEP from 2004-2016. They found 9,442 total complaints, of which 43% were water related (surface and groundwater), and that the frequency of complaints track with the rise and fall of unconventional oil and gas development (figure 5).

Figure 5: Relationship of complaints to O&G development (Public Herald).

Figure 4: Relationship of complaints to O&G development (Public Herald).

From the Public Herald dataset, we found 1,573 total complaints were in the Susquehanna River Basin, of which 65% were water related complaints — a much higher percentage than the larger dataset’s average. We then compare the location of these complaints to our “risk zone” groundwater wells and found a statistically significant correlation between the number of groundwater wells within 1km of oil and gas activity and higher numbers of complaints by residents. What do these findings tell us?

In short, where we see more groundwater wells in proximity to an oil and gas well, we also see more water related complaints to the DEP.

The below graph illustrates this relationship (figure 6).

Figure 6: Relationship of complaints to at-risk groundwater wells.

Figure 5: Relationship of complaints to at-risk groundwater wells.

Groundwater to Surface Water Risks

DCNR estimates that Pennsylvania’s streams and wetlands get about 2/3 of their flow from groundwater sources. Meanwhile, there are 786 public water suppliers in the Susquehanna River Basin that are fed by different arrangements of groundwater and surface water sources. These suppliers are included in the interactive map for reference.

Assessing risks to public water supply systems is equally complicated to that of groundwater wells. The DEP regulates public water suppliers under the Safe Drinking Water Act, but the general public is not permitted to know the location of actual water sources or intake points due to security risks. This restriction poses a problem for nongovernmental organizations when doing analyses that would benefit from knowing the locations of these source points. Nevertheless, like our breakdown of risk zone groundwater wells, we can still learn a great deal from what we do know of public water supplies.

Figure 6: Wellsboro, PA, public water supply along with O&G wells and water-related citizen complaints in the supply watershed.

Figure 6: Wellsboro, PA, public water supply with O&G wells and citizen complaints in the supply’s watershed.

For instance, the town of Wellsboro, in Tioga County, is home to an estimated 3,300 people. The Wellsboro Municipal Authority supplies water to Wellsboro residents as well as to 1,000 people in surrounding Charleston and Delmar Townships. According to DEP records, groundwater and surface water sources for this system come from Hamilton Lake and tributaries of the Charleston Creek Watershed, much of which is designated as high-quality coldwater fisheries. Nevertheless, there are seven unconventional oil and gas wells in this watershed, one of which is only 400ft from Charleston Creek, just upstream from Hamilton Lake.

The area is also one of the brightest hot-spots for complaints to the DEP in the Public Herald dataset, with 40 water related complaints in Charleston and Delmar townships.

These relationships should be of particular concern to residents who believe their water is protected from extraction industry activities. In addition, while recent research suggests homes values can be negatively affected in neighborhoods dependent on private well water near drilling activity, correlations between potential groundwater and surface water pollution suggest that any changes in home value are more a matter of perceived rather than actual risk—homes on public water supplies should also be considered at risk in communities experiencing extraction.

Conclusion

Returning to the hydrological cycle, we can assume that pollutants from oil and gas extraction, like precipitation, will eventually find their way into larger water bodies, either directly through runoff into watershed tributaries or through groundwater migrations. While this article has primarily focused on the Pennsylvania headwaters of the Susquehanna, home to 570,000 residents, and risks to their water sources, groundwater complaints are not the exclusive problem of residents who are dependent on private drinking water wells. “We all live downstream” as the saying goes, and those who rely on the watershed for their drinking water and other water resource needs throughout the watershed should be concerned by the correlations illustrated in our analysis.


By Kirk Jalbert, Manager of Community based Research & Engagement, FracTracker Alliance

Feature image: Hydrologic cycle graphic by Watershed-Watch.org