Pennsylvania’s House Bill 1100, sponsored by state Rep. Mike Turzai, has passed through the House and Senate with broad bipartisan support. If approved, the bill would provide billions of dollars in subsidies to energy and fertilizer companies that use fracked natural gas as feedstock.
The Bill is part of “Energize PA,” a package of bills that encourage natural gas and petrochemical development by providing companies with streamlined permitting processes and subsidies. The Shell ethane cracker plant in Beaver County received $1.6 billion in state subsidies, the largest tax break in state history. HB1100 would provide similar tax credits to additional petrochemical and natural gas projects.
According to its Republican sponsors, HB1100 is “designed to make Pennsylvania attractive to outside businesses, create family-sustaining jobs and provide economic benefits to underserved regions, without creating any new fees or taxes.” Indeed, the cumulative wage impacts of the Appalachian basin shale gas build-out was around $21 billion from 2004 to 2016, according to a 2019 Carnegie Mellon University study.
March 25, 2020 Update
After weeks of sitting on the bill, the Pennsylvania General Assembly passed HB1100, and the Pennsylvania Senate submitted it to Governor Wolf on March 18. This came amidst the chaos of the COVID-19 outbreak. The Governor is still expected to veto the bill, after which point, the General Assembly is likely to attempt an override.
March 27, 2020 Update
Governor Wolf said in his press release:
“Rather than enacting this bill, which gives a significant tax credit for energy and fertilizer manufacturing projects, we need to work together in a bipartisan manner to promote job creation and to enact financial stimulus packages for the benefit of Pennsylvanians who are hurting as they struggle with the substantial economic fallout of COVID-19.” Read the full press release here.
However, both Energize PA and HB1100 have been criticized for their overall economic inefficacy and environmental externalities. The aforementioned CMU study found that the cumulative air pollution damage cost about $23 billion and the cumulative greenhouse gas damage reached $34 billion, leading the authors to conclude that the negative environmental and health externalities outweigh the benefits of shale gas development.
Diana Polson, Senior Policy Analyst at Pennsylvania Budget and Policy Center, has also raised concerns about the economics of the petrochemical buildout in Pennsylvania. At a recent town hall meeting in Millvale, Pennsylvania, she made the point that tax incentives are rarely a deciding factor in a company’s decision on where to operate. This means that initiatives like “Energize PA” have little impact in terms of private investment decisions. Many factors outweigh the impact that tax credits have on a private company’s bottom line, such as proximity to a strong workforce, other existing industries, and access to supply chains.
What about job creation? The Pennsylvania Department of Revenue estimates that the HB1100 tax credit program would cost the Commonwealth $22 million per plant per year over the next 30 years. Diana Polson estimates that this would equate to about $8.8 million per permanent job over the course of the tax break.
This cost-to-job ratio is unacceptable to representatives like Sara Innamorato. “According to Shell, the cracker plant in Beaver will support 6,000 construction jobs at the peak of work, but will only lead to a possible 600 permanent jobs. Each of these jobs costs $2.75 million in subsidies — money that could have sustained many more families currently struggling to make ends meet in our communities,” the State Representative wrote. “Imagine how many workers we could employ with that level of investment in rebuilding our crumbling roads and bridges, replacing lead pipes, and repairing bus-swallowing sinkholes.”
Corporate tax revenue has fallen to 14% of Pennsylvania’s General Fund revenue, about half of what it was in the 1970’s. Without these corporate tax cuts, Pennsylvania would have about $4 billion more in corporate tax revenue per year than it does today. Critics like Innamorato believe that the state should respond to an already large public investment deficit by subsidizing investments such as education, human services, infrastructure, and environmental protection. HB1100 runs counter such public investments, particularly Democratic Governor Tom Wolf’s efforts to instate a severance tax on fracking operations that would subsidize infrastructure projects.
Environmental & Climate Impacts
Critics of HB1100 also raise environmental concerns. Much of the petrochemical buildout in the Appalachian basin would produce plastics, exacerbating the problem of single-use plastic pollution. There are also worries about the industry’s contributions to climate change. A recent report co-authored by FracTracker Alliance and the Center for Environmental Integrity found that plastic production and incineration in 2019 contributed greenhouse gas emissions equivalent to that of 189 new 500-megawatt coal power plants. If plastic production and use grow as currently planned, these emissions could rise to the equivalent to the emissions released by more than 295 coal-fired power plants. Locking in these emissions for decades to come has some wondering how Pennsylvania will reach its carbon budget goal of 58 million tons of CO2 in 2050.
In addition to economic and environmental concerns, HB1100 has come under criticism for its potential to worsen the health impacts associated with natural gas and petrochemical development, which range from asthma attacks, cardiovascular disease, strokes, abnormal heart rhythms and heart attacks. Research has also shown that natural gas and petrochemical development increase the risk of cancer, and there is growing evidence that air pollution affects fetal development and adverse birth outcomes.
It is now in the hands of Governor Wolf to either pass or veto HB1100. Wolf’s spokesman J.J. Abbott said that the governor “believes such projects should be evaluated on a specific case-by-case basis. However, if there was a specific project, he would be open to a conversation.”
One in three jobs in Pennsylvania’s energy sector are in clean energy. Many taxpayers will continue to push for policies that support this kind of job creation and investment in public services and infrastructure. Will our Commonwealth leaders listen, or will they continue to prioritize fossil fuel companies?
Visualize the petrochemical buildout by exploring FracTracker’s maps.
Penn Future and dozens of other groups are holding a press conference in Harrisburg on March 9th.
Harrisburg Press Conference - March 9
When: Monday, March 9, 10:00 – 11:00 AM
Where: Pennsylvania State Capitol – Main Rotunda
State and Third Street
Harrisburg, PA 17101
The list of speakers is subject to change. Current confirmed speakers include: Jacquelyn Bonomo, President and C.E.O., PennFuture State Representative Sara Innamorato, (21st House District) State Representative Chris Rabb, (200th House District) State Representative Carolyn Comitta, (156th House District) State Senator Katie Muth, (44th Senatorial District) Veronica Coptis, Executive Director, The Center for Coalfield Justice Ashleigh Deemer, Deputy Director, PennEnvironment Rabbi Daniel Swartz, Temple Hesed Briann Moye, One Pennsylvania
You can contact PennFuture Western Pennsylvania Outreach Coordinator, Kelsey Krepps, at email@example.com or (412) 224 – 4477 with any questions or concerns.
Cover photo showing early construction (2016) of the Shell Ethane Cracker in Beaver County, PA. By Ted Auch, FracTracker Alliance. Aerial assistance provided by LightHawk. Provided by FracTracker Alliance, fractracker.org/photos.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/03/Shell-Ethane-Cracker-6.jpg23764364Shannon Smithhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgShannon Smith2020-03-05 12:57:122020-03-27 13:27:12House Bill 1100: What you need to know
Natural gas compressor stations (1,367) – Facilities built along a pipeline route that pressurize natural gas to keep it flowing through the pipeline.
Crude oil rail terminals (94) – Rail terminals that load and unload crude oil (liquid hydrocarbons that have yet to be processed into higher-value petroleum products).
Liquefied natural gas import/export terminals (8) – Facilities that can a) liquefy natural gas so it can be exported as LNG (liquefied natural gas) and/or b) re-gasify LNG so it can be used as natural gas. Natural gas is transported in a liquid state because it takes up less space as a liquid than as a gas.
Natural Gas Underground Storage (486) – Locations where natural gas is stored underground in aquifers, depleted gas fields, and salt formations.
Petroleum Product Terminals (1,484) – Terminals with a storage capacity of 50,000 barrels or more and/or the ability to receive volumes from tanker, barge, or pipeline. Petroleum products include products “produced from the processing of crude oil and other liquids at petroleum refineries, from extraction of liquid hydrocarbons at natural gas processing plants, and from production of finished petroleum products at blending facilities.”
Petroleum Ports (242) – A port that can import and/or export 200,000 or more short tons of petroleum products a year.
Natural gas import/export pipeline facility (54) – A facility where natural gas crosses the border of the continental United States.
Crude oil pipelines – major crude oil pipelines, including interstate truck lines and selected intrastate lines, but not including gathering lines.
Natural gas liquid pipelines – Also referred to as hydrocarbon gas liquid pipelines, they carry the heavier components of the natural gas stream which are liquid under intense pressure and extreme cold, but gas in normal conditions.
Natural gas pipelines– Interstate and intrastate natural gas pipelines. Due to the immensity of this pipeline network and lack of available data, this pipeline layer in particular varies in degree of accuracy.
Petroleum Product Pipelines – Major petroleum product pipelines.
Recent Pipeline Projects – Pipeline projects that have been announced since 2017. This includes projects in various stages, including under construction, complete, planned or canceled. Click on the pipeline for the status.
Processing & Downstream
Natural Gas Processing Plants (478) – Plants that separate impurities and components of the natural gas stream.
Chemical plants (36) – Includes two types of chemical plants – petrochemical production and ammonia manufacturing – that report to EPA’s Greenhouse Gas Reporting Program.
Ethylene Crackers (30) – Also referred to as ethane crackers, these petrochemical complexes that converts ethane (a natural gas liquid) into ethylene. Ethylene is used to make products like polyethylene plastic.
Petroleum Refineries (135) – A plant that processes crude oil into products like petroleum naphtha, diesel fuel, and gasoline.
Power Plants (9,414) – Electric generating plants with a capacity of at least one megawatt, sorted by energy source.
Wind Turbines (63,003) – Zoom in on wind power plants to see this legend item appear.
Shale Plays (45) – Tight oil and gas shale plays, which are formations where oil and gas can be extracted.
Solar Energy Potential – Potential solar energy generation, in kilowatt-hours per square meter per day – averaged annually.
This map is by no means exhaustive, but is exhausting. It takes a lot of infrastructure to meet the energy demands from industries, transportation, residents, and businesses – and the vast majority of these facilities are powered by fossil fuels. What can we learn about the state of our national energy ecosystem from visualizing this infrastructure? And with increasing urgency to decarbonize within the next one to three decades, how close are we to completely reengineering the way we make energy?
Natural gas accounts for 44% of electricity generation in the United States – more than any other source. Despite that, the cost per megawatt hour of electricity for renewable energy power plants is now cheaper than that of natural gas power plants.
The state generating the largest amount of solar energy is California, while wind energy is Texas. The state with the greatest relative solar energy is not technically a state – it’s D.C., where 18% of electricity generation is from solar, closely followed by Nevada at 17%. Iowa leads the country in relative wind energy production, at 45%.
The state generating the most amount of energy from both natural gas and coal is Texas. Relatively, West Virginia has the greatest reliance on coal for electricity (85%), and Rhode Island has the greatest percentage of natural gas (92%).
With 28% of total U.S. energy consumption for transportation, many of the refineries, crude oil and petroleum product pipelines, and terminals on this map are dedicated towards gasoline, diesel, and other fuel production.
Petrochemical production, which is expected to account for over a third of global oil demand growth by 2030, takes the form of chemical plants, ethylene crackers, and natural gas liquid pipelines on this map, largely concentrated in the Gulf Coast.
The “power plant” legend item on this map contains facilities with an electric generating capacity of at least one megawatt, and includes independent power producers, electric utilities, commercial plants, and industrial plants. What does this data reveal?
In terms of the raw number of power plants – solar plants tops the list, with 2,916 facilities, followed by natural gas at 1,747.
In terms of megawatts of electricity generated, the picture is much different – with natural gas supplying the highest percentage of electricity (44%), much more than the second place source, which is coal at 21%, and far more than solar, which generates only 3% (Figure 1).
Figure 1. Electricity generation by source in the United States, 2019. Data from EIA.
This difference speaks to the decentralized nature of the solar industry, with more facilities producing less energy. At a glance, this may seem less efficient and more costly than the natural gas alternative, which has fewer plants producing more energy. But in reality, each of these natural gas plants depend on thousands of fracked wells – and they’re anything but efficient.
The cost per megawatt hour of electricity for a renewable energy power plants is now cheaper than that of fracked gas power plants. A report by the Rocky Mountain Institute, found “even as clean energy costs continue to fall, utilities and other investors have announced plans for over $70 billion in new gas-fired power plant construction through 2025. RMI research finds that 90% of this proposed capacity is more costly than equivalent [clean energy portfolios, which consist of wind, solar, and energy storage technologies] and, if those plants are built anyway, they would be uneconomic to continue operating in 2035.”
The economics side with renewables – but with solar, wind, geothermal comprising only 12% of the energy pie, and hydropower at 7%, do renewables have the capacity to meet the nation’s energy needs? Yes! Even the Energy Information Administration, a notorious skeptic of renewable energy’s potential, forecasted renewables would beat out natural gas in terms of electricity generation by 2050 in their 2020 Annual Energy Outlook.
This prediction doesn’t take into account any future legislation limiting fossil fuel infrastructure. A ban on fracking or policies under a Green New Deal could push renewables into the lead much sooner than 2050.
In a void of national leadership on the transition to cleaner energy, a few states have bolstered their renewable portfolio.
Figure 2. Electricity generation state-wide by source, 2019. Data from EIA.
One final factor to consider – the pie pieces on these state charts aren’t weighted equally, with some states’ capacity to generate electricity far greater than others. The top five electricity producers are Texas, California, Florida, Pennsylvania, and Illinois.
In 2018, approximately 28% of total U.S. energy consumption was for transportation. To understand the scale of infrastructure that serves this sector, it’s helpful to click on the petroleum refineries, crude oil rail terminals, and crude oil pipelines on the map.
Transportation Fuel Infrastructure. Data from EIA.
The majority of gasoline we use in our cars in the US is produced domestically. Crude oil from wells goes to refineries to be processed into products like diesel fuel and gasoline. Gasoline is taken by pipelines, tanker, rail, or barge to storage terminals (add the “petroleum product terminal” and “petroleum product pipelines” legend items), and then by truck to be further processed and delivered to gas stations.
China leads the world in this movement. In 2018, just over half of the world’s electric vehicles sales occurred in China. Analysts predict that the country’s oil demand will peak in the next five years thanks to battery-powered vehicles and high-speed rail.
In the United States, the percentage of electric vehicles on the road is small but growing quickly. Tax credits and incentives will be important for encouraging this transition. Almost half of the country’s electric vehicle sales are in California, where incentives are added to the federal tax credit. California also has a “Zero Emission Vehicle” program, requiring electric vehicles to comprise a certain percentage of sales.
We can’t ignore where electric vehicles are sourcing their power – and for that we must go back up to the electricity generation section. If you’re charging your car in a state powered mainly by fossil fuels (as many are), then the electricity is still tied to fossil fuels.
Many of the oil and gas infrastructure on the map doesn’t go towards energy at all, but rather aids in manufacturing petrochemicals – the basis of products like plastic, fertilizer, solvents, detergents, and resins.
Natural gas processing plants separate components of the natural gas stream to extract natural gas liquids like ethane and propane – which are transported through the natural gas liquid pipelines. These natural gas liquids are key building blocks of the petrochemical industry.
Ethane crackers process natural gas liquids into polyethylene – the most common type of plastic.
The chemical plants on this map include petrochemical production plants and ammonia manufacturing. Ammonia, which is used in fertilizer production, is one of the top synthetic chemicals produced in the world, and most of it comes from steam reforming natural gas.
As we discuss ways to decarbonize the country, petrochemicals must be a major focus of our efforts. That’s because petrochemicals are expected to account for over a third of global oil demand growth by 2030 and nearly half of demand growth by 2050 – thanks largely to an increase in plastic production. The International Energy Agency calls petrochemicals a “blind spot” in the global energy debate.
Petrochemical development off the coast of Texas, November 2019. Photo by Ted Auch, aerial support provided by LightHawk.
Investing in plastic manufacturing is the fossil fuel industry’s strategy to remain relevant in a renewable energy world. As such, we can’t break up with fossil fuels without also giving up our reliance on plastic. Legislation like the Break Free From Plastic Pollution Act get to the heart of this issue, by pausing construction of new ethane crackers, ensuring the power of local governments to enact plastic bans, and phasing out certain single-use products.
“The greatest industrial challenge the world has ever faced”
Mapped out, this web of fossil fuel infrastructure seems like a permanent grid locking us into a carbon-intensive future. But even more overwhelming than the ubiquity of fossil fuels in the US is how quickly this infrastructure has all been built. Everything on this map was constructed since Industrial Revolution, and the vast majority in the last century (Figure 3) – an inch on the mile-long timeline of human civilization.
Figure 3. Global Fossil Fuel Consumption. Data from Vaclav Smil (2017)
In fact, over half of the carbon from burning fossil fuels has been released in the last 30 years. As David Wallace Wells writes in The Uninhabitable Earth, “we have done as much damage to the fate of the planet and its ability to sustain human life and civilization since Al Gore published his first book on climate than in all the centuries—all the millennia—that came before.”
What will this map look like in the next 30 years?
A recent report on the global economics of the oil industry states, “To phase out petroleum products (and fossil fuels in general), the entire global industrial ecosystem will need to be reengineered, retooled and fundamentally rebuilt…This will be perhaps the greatest industrial challenge the world has ever faced historically.”
Is it possible to build a decentralized energy grid, generated by a diverse array of renewable, local, natural resources and backed up by battery power? Could all communities have the opportunity to control their energy through member-owned cooperatives instead of profit-thirsty corporations? Could microgrids improve the resiliency of our system in the face of increasingly intense natural disasters and ensure power in remote regions? Could hydrogen provide power for energy-intensive industries like steel and iron production? Could high speed rail, electric vehicles, a robust public transportation network and bike-able cities negate the need for gasoline and diesel? Could traditional methods of farming reduce our dependency on oil and gas-based fertilizers? Could zero waste cities stop our reliance on single-use plastic?
Of course! Technology evolves at lightning speed. Thirty years ago we didn’t know what fracking was and we didn’t have smart phones. The greater challenge lies in breaking the fossil fuel industry’s hold on our political system and convincing our leaders that human health and the environment shouldn’t be externalized costs of economic growth.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/02/National-map-feature-3.png400900Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2020-02-28 17:35:142020-03-30 15:34:51National Energy and Petrochemical Map
Despite the ever-increasing heaps of violations and drilling waste, Pennsylvania’s fracked wells continue to produce an excess supply of gas, driving prices down. To cut their losses, the oil and gas industry is turning towards increased exports and petrochemical production. Continuing to expand fracking in Pennsylvania will only increase risks to the public and to the climate, all for what may amount to another boom and bust cycle that is largely unprofitable to investors.
Let’s take a look at gas production, waste, newly drilled wells, and violations in Pennsylvania in the past year to understand just how precarious the fracking industry is.
Fracked hydrocarbon production continues to rise in Pennsylvania, resulting in an increase in waste production, violations, greenhouse gas emissions, and public health concerns. There are three types of hydrocarbons produced from wells in Pennsylvania: gas, condensate, and oil. Gas is composed mostly of methane, the most basic of the hydrocarbons, but in some parts of Pennsylvania, there can be significant quantities of ethane, propane, and other so-called “natural gas liquids” (NGLs) mixed in. Each of these NGLs are actually gaseous at atmospheric conditions, but operators try to separate these with a combination of pressure and low temperatures, converting them to a liquid phase. Some of these NGLs can be separated on-site, and this is typically referred to as condensate. Fracked wells in Pennsylvania also produce a relatively tiny amount of oil.
For those of you wondering why we are looking at the November, 2018 through October, 2019 time frame, this is simply a reflection of the available data. In this 12-month period, 9,858 fracked Pennsylvania wells, classified as “unconventional,” reported producing 6.68 trillion cubic feet of gas (Tcf), 4.89 million barrels of condensate, and just over 70,000 barrels of oil.
By means of comparison, Pennsylvania consumed about 1.46 Tcf of gas across all sectors in 2018, of which just 253 billion cubic feet (Bcf) was used in the homes of Pennsylvania’s 12.8 million residents. In fact, the amount of gas produced in Pennsylvania exceeds residential consumption in the entire United States by almost 1.7 Tcf. However, less than 17% of all gas consumed in Pennsylvania is for residential use, with nearly 28% being used for industrial purposes (including petrochemical development), and more than 35% used to generate electricity.
Figure 1. Fracked gas production compared to all fracked gas consumption and residential gas consumption in Pennsylvania from 2013 through 2018. Data from ref. Energy Information Administration.
While gas production has expansive hotspots in the northeastern and southwestern portions of the state, the liquid production comes from a much more limited geography. Eighty percent of all condensate production came from Washington County, while 87% of all fracked oil came from wells in Mercer County.
Because the definition of condensate has been somewhat controversial in the past (while the oil export ban was still in effect), I asked the Department of Environmental Protection (DEP) for the definition, and was told that if hydrocarbons come out of the well as a liquid, they should be reported as oil. If they are gaseous but condense to a liquid at standard temperature and pressure (60 degrees Fahrenheit and pressure 14.7 PSIA) on-site, then it is to be reported as condensate. Any NGLs that remain gaseous but are removed from the gas supply further downstream are reported as gas in this report. For this reason, it is not really possible to use the production report to find specific amounts of NGLs produced in the state, but it certainly exceeds condensate production by an appreciable margin.
The volume of gas withdrawn from fracked wells in Pennsylvania in just one year is equal to the volume of 3.2 Mount Everests!
Hydrocarbons aren’t the only thing that come out of the ground when operators drill and frack wells in Pennsylvania. Drillers also report a staggering amount of waste products, including more than 65 million barrels (2.7 billion gallons) of liquid waste and 1.2 million tons of solid waste in the 12-month period.
Waste facilities have significant issues such as inducing earthquakes, toxic leachate, and radioactive sediments in streambeds.
Liquid Waste (Barrels)
Solid Waste (Tons)
Drilling Fluid Waste
Other Oil & Gas Wastes
Soil Contaminated by Oil & Gas Related Spills
Spent Lubricant Waste
Synthetic Liner Materials
Unused Fracturing Fluid Waste
Waste Water Treatment Sludge
Figure 2. Oil and gas waste generated by fracked wells as reported by drillers from November 1, 2018 through October 31, 2019. Data from ref: PA DEP.
Some of the waste is probably best described as sludge, and several of the categories allow for reporting in barrels or tons. Almost all of the waste was in the well bore at one time or another, although there are some site-related materials that need to be disposed of, including filter socks which separate liquid and solid waste, soils contaminated by spills, spent lubricant, liners, and unused frack fluid waste.
Where does all of this waste go? We worked with Earthworks earlier this year to take a deep dive into the data, focusing on these facilities that receive waste from Pennsylvania’s oil and gas wells. While the majority of the waste is dealt with in-state, a significant quantity crosses state lines to landfills and injection wells in neighboring states, and sometimes as far away as Idaho.
Oil and gas operators have started the drilling process for 616 fracking wells in 2019, which appear on the Pennsylvania DEP spud report. This is less than one third of the 2011 peak of 1,956 fracked wells, and 2019 is the fifth consecutive year with fewer than 1,000 wells drilled. This has the effect of making industry projections relying on 1,500 or more drilled wells per year seem rather dubious.
Figure 3. Unconventional (fracked) wells drilled from 2005 through December 23, 2019, showing totals by regional office. Data from ref: PA DEP.
Oil and gas wells in Pennsylvania fall under the jurisdiction of three different regional offices. By looking at Figure 2, it becomes apparent that the North Central Regional Office (blue line) was a huge driver of the 2009 to 2014 drilling boom, before falling back to a similar drilling rate of the Southwest Regional Office.
The slowdown in drilling for gas in recent years is related to the lack of demand for the product. In turn, this drives prices down, a phenomenon that industry refers to as a “price glut.” The situation it is forcing major players in the regions such as Range Resources to reduce their holdings in Appalachia, and some, such as Chevron, are pulling out entirely.
Disturbingly, 2019 was the fifth straight year that the number of violations issued by DEP will exceed the total number of wells drilled.
Figure 4. Unconventional (fracked) drilled wells and issued violations from 2005 through December 2019. Data from ref: DEP.
Violations related to unconventional drilling are a bit unwieldy to summarize. The 13,833 incidents reported in Pennsylvania fall into 359 different categories, representing the specific regulations in which the drilling operator fell short of expectations. The industry likes to dismiss many of these as being administrative matters, and indeed, the DEP does categorize the violations as either “Administrative” or “Environmental, Health & Safety”. However, 9,998 (72%) of the violations through December 3, 2019, are in the latter category, and even some of the ones that are categorized as administrative seem like they ought to be in environmental, health, and safety. For example, let’s look at the 15 most frequent infractions:
SWMA301 – Failure to properly store, transport, process or dispose of a residual waste.
Environmental Health & Safety
CSL 402(b) – POTENTIAL POLLUTION – Conducting an activity regulated by a permit issued pursuant to Section 402 of The Clean Streams Law to prevent the potential of pollution to waters of the Commonwealth without a permit or contrary to a permit issued under that authority by the Department.
Environmental Health & Safety
102.4 – Failure to minimize accelerated erosion, implement E&S plan, maintain E&S controls. Failure to stabilize site until total site restoration under OGA Sec 206(c)(d)
Environmental Health & Safety
SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.
Environmental Health & Safety
601.101 – O&G Act 223-General. Used only when a specific O&G Act code cannot be used
402CSL – Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution.
Environmental Health & Safety
78.54* – Failure to properly control or dispose of industrial or residual waste to prevent pollution of the waters of the Commonwealth.
Environmental Health & Safety
401 CSL – Discharge of pollutional material to waters of Commonwealth.
Environmental Health & Safety
102.4(b)1 – EROSION AND SEDIMENT CONTROL REQUIREMENTS – Person conducting earth disturbance activity failed to implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation.
Environmental Health & Safety
102.5(m)4 – PERMIT REQUIREMENTS – GENERAL PERMITS – Person failed to comply with the terms and conditions of the E & S Control General Permit.
Environmental Health & Safety
78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances.
78a53 – EROSION AND SEDIMENT CONTROL AND STORMWATER MANAGEMENT – Person proposing or conducting earth disturbance activities associated with oil and gas operations failed to comply with 25 Pa. Code § 102.
Environmental Health & Safety
102.11(a)1 – GENERAL REQUIREMENTS – BMP AND DESIGN STANDARDS – Person failed to design, implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation to protect, maintain, reclaim and restore water quality and existing and designated uses.
Environmental Health & Safety
CSL 401 – PROHIBITION AGAINST OTHER POLLUTIONS – Discharged substance of any kind or character resulting in pollution of Waters of the Commonwealth.
Environmental Health & Safety
OGA3216(C) – WELL SITE RESTORATIONS – PITS, DRILLING SUPPLIES AND EQUIPMENT – Failure to fill all pits used to contain produced fluids or industrial wastes and remove unnecessary drilling supplies/equipment not needed for production within 9 months from completion of drilling of well.
Environmental Health & Safety
Figure 5. Top 15 most frequently cited violations for unconventional drilling operations in Pennsylvania through December 3, 2019. Data from ref: DEP.
Of the 15 most common categories, only two are considered administrative violations. One of these is a general code, where we don’t know what happened to warrant the infraction without reading the written narrative that accompanies the data, and is therefore impossible to categorize. The only other administrative violation in the top 15 categories reads, “78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances,” which certainly sounds like it would have some real-world implications beyond administrative concerns.
To address the excess supply of gas, companies have tried to export the gas and liquids to other markets through pipelines. Those efforts have been fraught with trouble as well. Residents are reluctant to put up with an endless barrage of new pipelines, yielding their land and putting their safety at risk for an industry that can’t seem to move the product safely. The Revolution pipeline explosion hasn’t helped that perception, nor have all of the sinkholes and hundreds of leaky “inadvertent returns” along the path of the Mariner East pipeline system. In a sense, the industry’s best case scenario is to call these failures incompetence, because otherwise they would be forced to admit that the 2.5 million miles of hydrocarbon pipelines in the United States are inherently risky, prone to failure any time and any place.
Pennsylvania’s high content of NGLs is a selling point by the industry, because they have an added value when compared to gas. While all of these hydrocarbons can burn and produce energy in a similar manner, operators are required to remove most of them to get the energy content of the gas into an acceptable range for gas transmission lines. Because of this, enormous facilities have to be built to separate these NGLs, while even larger facilities are constructed to consume it all. Shell’s Pennsylvania Petrochemicals Complex ethane cracker being built in Beaver County, PA is scheduled to make 1.6 million metric tons of polyethylene per year, mostly for plastics.
This comes at a time when communities around the country and the world are enacting new regulations to rein in plastic pollution, which our descendants are going to finding on the beach for thousands of years, even if everyone on the planet were to stop using single-use plastics today. Of course, none of these bans or taxes are currently permitted in Pennsylvania, but adding 1.6 million metric tons per year to our current supply is unnecessary, and indeed, it is only the beginning for the region. A similar facility, known as the PTT Global Chemical cracker appears to be moving forward in Eastern Ohio, and ExxonMobil appears to be thinking about building one in the region as well. Industry analysts think the region produces enough NGLs to support five of these ethane crackers.
Despite all of these problems, the oil and gas industry still plans to fill the Ohio River Valley with new petrochemical plants, gas processing plants, and storage facilities in the hopes that someday, somebody may want what they’ve taken from the ground.
Here’s hoping that 2020 is a safer and healthier year than 2019 was. But there is no need to leave it up to chance. Together, we have the power to change things, if we all demand that our voices are heard. As a start, consider contacting your elected officials to let them know that renewing Pennsylvania’s blocking of municipal bans and taxes on plastic bags is unacceptable.
By Matt Kelso, Manager of Data & Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/01/PA-2019-Fracked-Gas-Production-Feature.jpg16673750Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgMatt Kelso, BA2020-01-07 18:02:382020-03-11 12:37:20Fracking in Pennsylvania: Not Worth It
FracTracker is closely mapping and following the petrochemical build-out in Appalachia, as the oil and gas industry invests in petrochemical manufacturing. Much of the national attention on the build-out revolves around the Appalachian Storage Hub (ASH), a venture spearheaded by Appalachian Development Group.
The ASH involves a network of infrastructure to store and transport natural gas liquids and finds support across the political spectrum. Elected officials are collaborating with the private sector and foreign investors to further development of the ASH, citing benefits such as national security, increased revenue, job creation, and energy independence.
Left out of the discussion are the increased environmental and public health burdens the ASH would place on the region, and the fact that natural gas liquids are the feedstock of products such as plastic and resins, not energy.
The “Shale Revolution” brought on by high-volume hydraulic fracturing (fracking) in this region encompasses thousands of wells drilled into the Marcellus and Utica-Point Pleasant shale plays across much of the Allegheny Plateau. This area spans from north of Scranton-Wilkes Barre, Pennsylvania, just outside the Catskills Mountains to the East in Susquehanna County, Pennsylvania, and down to the West Virginia counties of Logan, Boone, and Lincoln. The westernmost extent of the fracking experiment in the Marcellus and Utica shale plays is in Noble and Guernsey Counties in Ohio.
Along the way, producing wells have exhibited steeper and steeper declines during the first five years of production, leading the industry to develop what they refer to as “super laterals.” These laterals (the horizontal portion of a well) exceed 3 miles in length and require in excess of 15 million gallons of freshwater and 15,000 tons of silica sand (aka, “proppant”).
The resource-intense super laterals are one way the industry is dealing with growing pressure from investors, lenders, the media, state governments, and the public to reduce supply costs and turn a profit, while also maintaining production. (Note: unfortunately these sources of pressures are listed from most to least concerning to industry itself!)
Another way the fracking industry is hoping to make a profit is by investing in the region’s natural gas liquids (NGLs), such as ethane, propane, and butane, to support the petrochemical industry.
The Appalachian Storage Hub
Continued oil and gas development are part of a nascent effort to establish a mega-infrastructure petrochemical complex, the Appalachian Storage Hub (ASH). For those that aren’t familiar with the ASH it could be framed as the fracking industry’s last best attempt to lock in their necessity across Appalachia and nationwide. The ASH was defined in the West Virginia Executive as a way to revitalize the Mountain State and would consist of the following:
“a proposed underground storage facility that would be used to store and transport natural gas liquids (NGLs) extracted from the Marcellus, Utica and Rogersville shales across Kentucky, Ohio, Pennsylvania and West Virginia. Construction of this hub would not only lead to revenue and job creation in the natural gas industry but would also further enable manufacturing companies to come to the Mountain State, as the petrochemicals produced by shale are necessary materials in most manufacturing supply chains…[with] the raw materials available in the region’s Marcellus Shale alone…estimated to be worth more than $2 trillion, and an estimated 20 percent of this shale is composed largely of ethane, propane and butane NGLs that can be utilized by the petrochemical industry in the manufacturing of consumer goods.”
This is yet another example of fracking rhetoric that appeals to American’s sense of patriotism and need for cheaper consumer goods (in this case, plastics), given that they are seeing little to no growth in wages.
While a specific location for underground storage has not been announced, the infrastructure associated with the ASH (such as pipelines, compressor stations, and processing stations) would stretch from outside Pittsburgh down to Catlettsburg, Kentucky, with the latter currently the home of a sizeable Marathon Oil refinery. The ASH “would act like an interstate highway, with on-ramps and off-ramps feeding manufacturing hubs along its length and drawing from the available ethane storage fields. The piping would sit above-ground and follow the Ohio and Kanawha river valley.”
The politics of the ASH – from Columbus and Charleston to Washington DC
Elected officials across the quad-state region are supporting this effort invoking, not surprisingly, its importance for national security and energy independence.
West Virginia Senator Joe Manchin (D) went so far as to introduce “Senate Bill 1064 – Appalachian Energy for National Security Act.” This bill would require Secretary of Energy Rick Perry and his staff to “to conduct a study on the national security implications of building ethane and other natural-gas-liquids-related petrochemical infrastructure in the United States, and for other purposes.”
Interestingly, the West Virginia Senator told the West Virginia Roundtable Inc’s membership meeting that the study would not examine the “national security implications” but rather the “additional security benefits” of an Appalachian Storage Hub and cited the following to pave the way for the national security study he is proposing: “the shale resource endowment of the Appalachian Basin is so bountiful that, if the Appalachian Basin were an independent country, the Appalachian Basin would be the third largest producer of natural gas in the world.”
Senator Manchin is not the only politician of either party to unabashedly holler from the Appalachian Mountaintops the benefits of the ASH. Former Ohio Governor, and 2016 POTUS primary participant, John Kasich (R) has been a fervent supporter of such a regional planning scheme. He is particularly outspoken in favor of the joint proposal by Thailand-based PTT Global Chemical and Daelim to build an ethane cracker in Dilles Bottom, Ohio, across the Ohio River from Moundsville, West Virginia. The ethane cracker would convert the region’s fracked ethane into ethylene to make polyethylene plastic. This proposed project could be connected to the underground storage component of the ASH.
Dilles Bottom, OH ethane cracker site. Photo by Ted Auch, aerial assistance provided by LightHawk.
Not to be outdone in the ASH cheerleading department, West Virginia Governor Jim Justice (R), who can’t seem to find any common ground with Democrats in general nor Senator Manchin specifically, is collaborating with quad-state governors on the benefits of the ASH. All the while, these players ignore or dismiss the environmental, social, and economic costs of such an “all in” bet on petrochemicals and plastics.
Even the region’s land-grant universities have gotten in on the act, with West Virginia University’s Appalachian Oil and Natural Gas Research Consortium and Energy Institute leading the way. WVU’s Energy Institute Director Brian Anderson pointed out that, “Appalachia is poised for a renaissance of the petrochemical industry due to the availability of natural gas liquids. A critical path for this rebirth is through the development of infrastructure to support the industry. The Appalachian Storage Hub study is a first step for realizing that necessary infrastructure.”
utilize a new or significantly improved technology;
avoid, reduce or sequester greenhouse gases;
be located in the United States; and,
have a reasonable prospect of repayment.
This type of Public-Private Investment Program is central planning at its finest, in spite of the likelihood that the prospects of the ASH meeting the second and fourth conditions above are dubious at best (even if the project utilizes carbon capture and storage technologies).
Public-Private Investment Programs have a dubious past. In her book “Water Wars,” Vandana Shiva discusses the role of these programs globally and the involvement of institutions like the World Bank and International Monetary Fund:
“public-private partnerships”…implies public participation, democracy, and accountability. But it disguises the fact that the public-private partnership arrangements usually entail public funds being available for the privatization of public goods…[and] have mushroomed under the guise of attracting private capital and curbing public-sector employment.”
In response to the Department of Energy’s Title XVII largesse, Congresswoman Pramila Jayapal and Ilhan Omar introduced Amendment 105 in Rule II on HR 2740. According to Food and Water Watch, this amendment would restrict “the types of projects the Department of Energy could financially back. It would block the funding for ALL projects that wouldn’t mitigate climate change.”
The only condition of Department of Energy’s Title XVII loan program ASH is guaranteed to meet is the third (be located in the United States), but as we’ve already mentioned, the level of foreign money involved complicates the domestic facade.
Foreign involvement in the ASH lends credence to Senator Manchin’s and others’ concerns about where profits from the ASH will go, and who will be reaping the benefits of cheap natural gas. The fact that the ASH is being heavily backed by foreign money is the reason Senator Manchin raised an issue with the outsized role of state actors like Saudi Arabia and China as well as likely state-backed private investments like PTT Global Chemical’s. The Senator even cited how a potential $83.7 billion investment in West Virginia from China’s state-owned energy company, China Energy, would compromise “domestic manufacturing and national security opportunities.”
With all of the discussion and legislation focused on energy and national security, many don’t realize the output of the ASH would be the production of petroleum-based products: mainly plastic, but also fertilizers, paints, resins, and other chemical products.
Bills like this and the not unrelated “critical infrastructure” bills being shopped around by the American Legislative Exchange Council will amplify the rural vs urban and local vs state oversight divisions running rampant throughout the United States. The reason for this is that yet another natural resource boom/bust will be foisted on Central Appalachia to fuel urban growth and, in this instance, the growth and prosperity of foreign states like China.
Instead of working night and day to advocate for Appalachia and Americans more broadly, we have legislation in statehouses around the country that would make it harder to demonstrate or voice concerns about proposals associated with the ASH and similar regional planning projects stretching down into the Gulf of Mexico.
Producing wells mapped
Impacts from the ASH and associated ethane cracker proposals will include but are not limited to: an increase in the permitting of natural gas wells, an increase in associated gas gathering pipelines across the Allegheny Plateau, and an exponential increase in the production of plastics, all of which are harmful to the region’s environment and the planet.
The production of the region’s fracked wells will determine the long-term viability of the ASH. From our reading of things, the permitting trend we see in Ohio will have to hit another exponential inflection point to “feed the beast” as it were. Figure 1 shows an overall decline in the number of wells drilled monthly in Ohio.
Figure 2, below it, shows the relationship between the number of wells that are permitted verse those that are actually drilled.
Figures 1. Monthly (in blue) and cumulative (in orange) unconventional oil and gas wells drilled in Ohio, January, 2013 to November, 2018
Figure 2. Permitted Vs Drilled Wells in Ohio, January, 2013 to November, 2018
That supply-demand on steroids interaction will likely result in an increased reliance on “super laterals” by the high-volume hydraulic fracturing industry. These laterals require 5-8 times more water, chemicals, and proppant than unconventional laterals did between 2010 and 2012.
Given this, we felt it critical to map not just the environmental impacts of this model of fracking but also the nuts and bolts of production over time. The map below shows the supply-demand links between the fracking industry and the ASH, not as discrete pieces or groupings of infrastructure, but rather a continuum of up and downstream patterns.
The current iteration of the map shows production values for oil, natural gas, and natural gas liquids, how production for any given well changes over time, and production declines in newer wells relative to those that were fracked at the outset of the region’s “Shale Revolution.” Working with volunteer Gary Allison, we have compiled and mapped monthly (Pennsylvania and West Virginia) and quarterly (Ohio) natural gas, condensate, and natural gas liquids from 2002 to 2018.
This map includes 15,682 producing wells in Pennsylvania, 3,689 in West Virginia, and 2,064 in Ohio. We’ve also included and will be updating petrochemical projects associated with the ASH, either existing or proposed, across the quad-states including the proposed ethane cracker in Dilles Bottom, Ohio and the ethane cracker under construction in Beaver County, Pennsylvania, along with two rumored projects in West Virginia.
We will continue to update this map on a quarterly basis, will be adding Kentucky data in the coming months, and will be sure to update rumored/proposed petrochemical infrastructure as they cross our radar. However, we can’t be everywhere at once so if anyone reading this hears of legitimate rumors or conversations taking place at the county or township level that cite tapping into the ASH’s infrastructural network, please be sure to contact us directly at firstname.lastname@example.org.
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison
Feature Photo: Ethane cracker plant under construction in Beaver County, PA. Photo by Ted Auch, aerial assistance provided by LightHawk.
 For a detailed analysis of the HVHF’s increasing resource demand and how lateral length has increased in the last decade the reader is referred to our analysis titled “A Disturbing Tale of Diminishing Returns in Ohio” Figures 12 and 13.
 Note: For those Bluegrass State residents or interested parties, Kentucky data is on its way!
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/07/Cracker-Plant-2.jpg20414484Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgTed Auch, PhD2019-07-23 14:37:052020-03-12 14:46:53The Underlying Politics and Unconventional Well Fundamentals of an Appalachian Storage Hub
Last month, the Department of Energy (DOE) submitted a report titled Ethane Storage and Distribution Hub in the United States to Congress. The report sums up several other recent geologic studies and economic analyses that evaluate the potential to create a large petrochemical hub in southwest Pennsylvania, Ohio, West Virginia, and northeastern Kentucky.
Most people call this region Appalachia because of the mountains, or the Ohio River Valley because of the namesake river. The petrochemical industry looks deeper: they’ve branded it Shale Crescent USA, after the shale gas thousands of feet underground. This article summarizes recent developments on storing natural gas liquids, including ethane, in this region – whatever you prefer to call it.
The United States currently produces more natural gas than any other country in the world, with much of the fracked gas coming from the Marcellus and Utica shales in Appalachia. The DOE report predicts that production in this region will continue growing from an estimated at 8.19 trillion cubic feet (Tcf) in 2017, to 13.55 Tcf in 2025 and 19.5 Tcf in 2050.
Natural Gas Production Estimates:
8.19 Tcf in 2017
13.55 Tcf in 2025
19.5 Tcf in 2050
In addition to oil and gas, fracking produces natural gas liquids (NGLs), such as ethane, propane, and butane. NGLs are a key component of the petrochemical industry, which takes these resources and converts them into plastics and resins. As industry extracts more natural gas, it will also be left with more NGLs to manage.
Hoping to profit off NGLs, the oil and gas industry is investing in petrochemical production. In the Appalachian basin, the DOE predicts that production of ethylene from ethane will reach 640,000 barrels a day by 2025 (this is 20 times the amount the region produced in 2013). The Gulf Coast of the U.S., as well as countries in Asia and the Middle East, are also growing their production capacities. Globally, ethylene production is projected to grow 31% from 2017 to 2025.
The rise of the petrochemical industry comes at a point when there’s an increasing global awareness of the disaster that is plastic pollution. As much as 12.7 million tons of plastic waste goes into the ocean each year, affecting over 700 species of marine animals. On land, plastic waste is often shipped to less developed nations, where it ends up polluting poor communities and contaminating their drinking water and air.
Nevertheless, politicians in PA, OH, and WV are working hard to attract petrochemical build-out in Appalachia. The region already houses much of the infrastructure needed for a petrochemical hub, such as fracked wells that pump out NGLs and processing plants to separate these liquids from the rest of the natural gas stream. One thing it’s missing, however, is significant capacity to store natural gas liquids – particularly ethane.
Why does industry need storage?
Ethane storage offers several benefits to the petrochemical industry. For one, it would serve as a steady supply of ethane for plants like ethane crackers, which “crack” ethane into ethylene to make polyethylene plastic. With this constant supply (transported to crackers via pipeline), plants can operate 24 hours a day, year round, and avoid using energy to shutdown and restart. Storage also allows industry to adapt to fluctuations in demand and price.
Another argument for expanding petrochemical activity in Appalachia is to diversify the industry’s geography. The current petrochemical hub in Texas and Louisiana (where over 95% of the country’s ethylene production takes place) is subject to extreme weather events. In 2017, Hurricane Harvey caused over half of the nation’s polyethylene production capacity to shut down. The report mentions “extreme weather events” multiple times as justification for building a petrochemical hub in Appalachia. This stance strongly suggests that the DOE is preparing for increased hurricanes and flooding from climate change, although this is never explicitly stated. Unsurprisingly, the industry’s role in causing climate change is left out from the report as well.
What does storage look like?
While the term ‘natural gas liquid’ may seem like an oxymoron, it refers to the different forms the substances take depending on temperature and pressure. At normal conditions, NGLs are a gas, but when pressurized or exposed to extremely cold temperatures, they act as a liquid. NGLs occupy significantly less space as a liquid, and are therefore moved and stored as a pressurized or refrigerated liquid.
Storage can be in above ground tanks, but is often underground in gas fields or underground caverns. NGLs are highly volatile, and storing them above ground puts workers and surrounding communities at risk. For example – last week, an above ground storage tank exploded at a natural gas processing plant in Washington County, PA, sending four people to the hospital. While underground storage is perceived as “safer,” it still poses significant risks, particularly in a geography like Appalachia full of wells, coal mines, and pipelines. This underground infrastructure can cause NGLs to leak during storage or the land above them to collapse.
A study out of West Virginia University, titled “A Geologic Study to Determine the Potential to Create an Appalachian Storage Hub For Natural Gas Liquids,” identified three different types of storage opportunities along the Ohio and Kanawha river valleys:
Underground storage options
Mined-rock cavern: Companies can mine caverns in formations of limestone, dolomite, or sandstone. The formation must be at least 40 feet thick to hold NGLs. This study focused on formations of the Greenbrier Limestone, which occurs throughout southwestern Pennsylvania, West Virginia, and Kentucky.
Salt cavern: Developing salt caverns involves injecting water underground to create a void, and then pumping NGLs into the cavern. Suitable salt caverns have “walls” at least 100 feet thick above and below the cavern. The study recommended salt caverns 1,500 to 3,000 feet deep, but considered those as deep as 6,700 feet.
Gas field: NGLs can also be stored in natural gas fields or depleted gas fields in underground sandstone reservoirs. Suitable gas fields are 2,000 feet deep or more according to the WVU study.
Where could storage sites be located?
The West Virginia University study identified and ranked thousands of gas fields, several salt caverns, and many regions in the Greenbrier Limestone that could serve as NGL storage. Most of the top-ranked opportunities are in West Virginia, near the state’s borders with Ohio and Pennsylvania, and several cross beneath the Ohio or Kanawha rivers. The researchers conclude with three “prospects,” which are circled in Figure 1.
The table below lists the specific storage opportunities in each prospect, as well as the available data on depth, thickness, and acreage of the formations. Also listed are the counties that the storage facility would cross into.
Land Size (acres)
Salina F4 Salt cavern
>100 to 150
Primarily Columbiana, OH, also Hancock, WV & Beaver, PA
Salina F4 salt cavern
100 to 150
Primarily Jefferson, OH, also Brooke & Hancock WV, & Washington, PA
2 possibilities for a cavern- one in northern Putnam & Roane WV, the other in Kanawha & Boone, WV
> 530,000 and >170,000
Burdett-St. Albans Field
Depleted gas field
1,824 to 2,510
4 to 27
Primarily Putnam, also Lincoln & Kanawha, WV
The Elk-Poca (Sissonville) Field
Depleted gas field
4,140 to 5,497
Putnam, Jackson, Kanawha, WV
Campbell Creek Field
Depleted gas field
Existing natural gas storage
4,660 to 5,012
15 to 56
North Ripley Field
Depleted gas field
Depleted gas field
Kanawha, Putnam ,WV
Depleted gas field
Depleted gas field
Kanawha, Boone, WV
Existing NGL Storage
Storage in the United States
The U.S. has two major NGL storage hubs (both in salt caverns): One is in Mont Belvieu, Texas and the other in Conway, Kansas. These facilities are strategically located near the petrochemical industry’s hub along the Gulf Coast. There is also underground storage in Sarnia, Ontario.
Industry in Appalachia is connected to these storage facilities via pipelines, including Sunoco’s Mariner West that transports ethane to Sarnia, and the Appalachia-Texas-Express (ATEX) pipeline that takes ethane to Mont Belvieu. However, as suggested above, NGL storage in Appalachia is also under development.
Appalachia Storage & Trading Hub
Appalachia Development Group LLC is heading the development of the Appalachia Storage & Trading Hub initiative. The company has not announced the specific location for underground storage, but has been working hard to secure the funds for this development.
In September of 2017, Appalachia Development Group submitted part 1 of a 2-part application for a $1.9 billion loan to the US DOE Loan Program Office. The DOE approved the application the following January, inviting the company to submit the second part, which is currently pending. This second part goes through the DOE’s Title XVII innovative clean energy projects loan program.
According to the DOE, this program “provides loan guarantees to accelerate the deployment of innovative clean energy technology.” Paradoxically, this means the DOE may give clean energy funds to the petrochemical industry, which is fueled by fossil fuels and does not provide energy but rather plastic and resins.
Steven Hedrick, the CEO of Appalachia Development Group, was part of a West Virginia trade delegation that traveled to China in 2017 to meet with China’s largest energy company. This meeting, which included President Trump and China’s President Xi Jinping, resulted in China Energy agreeing to invest $83.7 billion to support natural gas and petrochemical development in West Virginia. (Of note: This agreement has faced uncertainty following Trump’s tariffs on Chinese goods). West Virginia Governor Jim Justice later criticized Hedrick’s involvement in the meeting, where he promoted the interests of his private company.
Mountaineer NGL Storage Project
Another company, Energy Storage Ventures LLC, has plans to construct NGL storage near Clarington, Ohio. This facility would be on land formerly belonging to Quarto Mining Company’s Powhatan Mine No. 4. Called “Mountaineer NGL Storage,” the project would develop salt caverns to store propane, ethane, and butane. Each cavern could store 500,000 barrels (21 million gallons) of NGLs.
The video below, made by the Energy Storage Ventures, describes the process of developing salt caverns for storage.
The Mountaineer NGL Storage Project location is about 12 miles south of the PTTGC ethane cracker (if built), in Dilles Bottom Ohio. It’s also roughly 60 miles south of the Shell ethane cracker (under construction) in Potter Township, PA. If developed, the project could supply these plants with ethane and allow them to continuously operate. According to Energy Storage Ventures President, David Hooker, the project would also trigger $500 million in new pipelines in the region and $1 billion in fractionation facilities to separate NGLs.
Energy Storage Ventures wants to build three pipelines beneath the Ohio River. Two pipelines (one for ethane and one for propane and butane) would deliver NGLs to the storage site from Blue Racer Natrium, a fractionation plant that separates dry natural gas from NGLs. A third pipeline would take salt brine water from the caverns to the Marshall County chlorine plant (currently owned by Westlake Chemical Corp). These facilities, as well as the locations of the two ethane crackers storage could serve, are in the map below. This map also includes the potential storage opportunities the researchers at West Virginia University identified.
Referring to concerns about building pipelines and caverns near the Ohio River, a drinking water source for 5 million people, the company’s president David Hooker stated, “This is not rocket science. These things have operated safely for years… Salt, at depth, is impermeable. You won’t see any migration out of the salt.”
This video is a rendering of what the 200-acre site will look like, including the salt water impoundment structure (capable of holding 3.25 million barrels), and the infrastructure needed to deliver products and equipment by rail and truck:
The company has stated that it owns both the land and mineral rights it needs to develop the caverns, but the project has also faced delays.
Where is this plastic going?
One common argument for a petrochemical hub in Appalachia is the region’s proximity to the downstream sector of petrochemical industry. Manufacturers such as PPG Industries, Dow Chemical Inc., and BASF are all based in the area and could make use of the feedstock from an Appalachian hub.
However, the report doesn’t make it clear where the plastic and resin end products will land. It does state that the demand in the United States isn’t enough to swallow up two major petrochemical hubs worth of plastic.
The DOE report states that, “the development of new petrochemical capacity in Appalachia is not necessarily in conflict with Gulf Coast expansion.” Since the Gulf Coast already has the infrastructure for export, it could focus on international markets while Appalachia meets domestic demand. Alternatively, the Appalachian hub could serve European destinations while the Gulf Coast hub delivers to Pacific Basin and South American destinations. Plastic consumption is highly correlated with population, so countries with large, growing populations such as India and China are likely markets.
It’s important to note that the U.S. isn’t the only country increasing its production of petrochemical derivatives, and as the report notes, exports from the US “may face a challenge from global capacity surplus.” Figure 2 shows that global production of ethylene is expected to surpass global consumption, shown in Figure 3. The graph of consumption likely ignores the impact of plastic-reducing policies that hundreds of countries and cities are implementing. As such, it may be an over-estimation.
Figure 2. Historical and future ethylene production by global region. Source
Figure 3. Ethylene consumption by global region. Source
In the end, it appears that the industry’s plan is to build first, and worry about markets later, hoping that a growing supply of affordable plastic will increase consumption.
Perhaps the reason industry is so eager to forge a market is because oil and gas is struggling with a lot of debt. A study out of the Sightline Institute found that as of the first half of 2018, “US fracking-focused oil and gas companies continued their eight-year cash flow losing streak.” The Center for International Environmental Law found that petrochemicals generally have a larger profit margin than oil and gas: “In 2015, ExxonMobil’s Chemicals segment accounted for roughly 10% of its revenues but more than 25% of its overall profits.”
Plastic is one way to subsidize this dying industry…
Beyond Storing Natural Gas Liquids
The motive behind developing storage is to catalyze and support a major industry. The DOE report states that the new infrastructure required “would include gathering lines, processing plants, fractionation facilities, NGLs storage facilities, ethane crackers, and then…plants for polyethylene, ethylene dichloride, ethylene oxide, and other infrastructure.” A hub would require more fracking and wastewater injection wells, cause even more heavy truck traffic that adds stress to roadways, and require additional power plant capacity to serve its electricity demand.
In other words, an Appalachian petrochemical hub would profoundly impact the region. The report contains an in-depth analysis of the economic impacts, but fails to mention any environmental concerns, social impacts on communities, or health effects. The other major studies on this buildout, mentioned above, follow a similar pattern.
A quick look at industry along the Gulf Coast tells you that environmental, social, and health concerns are very real and produce their own economic debts. The petrochemical industry has created a “cancer alley” in Texas and Louisiana, disproportionately impacting low-income and minority communities. Yet, industry is preparing another hub without a single comprehensive environmental impact assessment or health assessment for the region. As each pipeline, fracked well, and plant is permitted separately, we can’t properly assess the cumulative negative impacts this development will have on our waterways, forests, soil, or air quality. Therefore, we also won’t know how it will affect our health.
Looking into the future
The report analyzes the industry through 2050. It states that NGL output in Appalachia:
… will continue to grow throughout the forecast period. As natural gas production gradually migrates away from liquids-rich gas areas, which are expected to slowly deplete, to dryer areas, the rate of growth in NGPL production will slow relative to the rate of natural gas production growth.
In 31 years, the kids growing up in Appalachia right now could be left with brownfields, dried-up wells, and abandoned ethane crackers. But it doesn’t have to be this way. Last year, the DOE reported that there are more jobs in clean energy, energy efficiency, and alternative vehicles than in fossil fuels. By using funds such as the DOE’s Title XVII innovative clean energy loan – for actual clean energy – we can bring economic development to the region that will be relevant past 2050 and that won’t sacrifice our health and natural resources for short-term private gains.
By Erica Jackson, Community Outreach and Communications Specialist
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/12/Appalachian-Storage-Feature.jpg400900Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2018-12-19 12:31:022020-03-12 14:52:33Storing Natural Gas Liquids in Appalachia
Pipelines play a major role in the oil and gas extraction industry, allowing for the transport of hydrocarbons from well sites to a variety of infrastructure, including processing plants, petrochemical facilities, power generation plants, and ultimately consumers. There are more than 2.7 million miles of natural gas and hazardous liquid pipelines in the United States, or more than 11 times the distance from Earth to the moon.
With all of this infrastructure in place, pipelines are inevitably routed close to homes, schools, and other culturally or ecologically important locations. But how safe are pipelines, really? While they are typically buried underground and out of sight, many residents are concerned about the constant passage of volatile materials through these pipes in close proximity to these areas, with persistent but often unstated possibility that something might go wrong some day.
Safety talking points
In an attempt to assuage these fears, industry representatives and regulators tend to throw around variants of the word “safe” quite a bit:
Pipelines are the safest and most reliable means of transporting the nation’s energy products.
— Keith Coyle, Marcellus Shale Coalition
Although pipelines exist in all fifty states, most of us are unaware that this vast network even exists. This is due to the strong safety record of pipelines and the fact that most of them are located underground. Installing pipelines underground protects them from damage and helps protect our communities as well.
— Pipeline and Hazardous Materials Safety Administration (PHMSA)
Pipelines are an extremely safe way to transport energy across the country.
— Pipeline 101
Knowing how important pipelines are to everyday living is a big reason why we as pipeline operators strive to keep them safe. Pipelines themselves are one of the safest ways to transport energy with a barrel of crude oil or petroleum product reaching its destination safely by pipeline 99.999% of the time.
— American Petroleum Institute
But are pipelines really safe?
Given these talking points, the general public can be excused for being under the impression that pipelines are no big deal. However, PHMSA keeps records on pipeline incidents in the US, and the cumulative impact of these events is staggering. These incidents are broken into three separate reports:
Gas Distribution (lines that take gas to residents and other consumers),
Gas Transmission & Gathering (collectively bringing gas from well sites to processing facilities and distant markets), and
Hazardous Liquids (including crude oil, refined petroleum products, and natural gas liquids).
Below in Table 1 is a summary of pipeline incident data from 2010 through mid-November of this year. Of note: Some details from recent events are still pending, and are therefore not yet reflected in these reports.
Table 1: Summary of pipeline incidents from 1/1/2010 through 11/14/2018
Gas Transmission & Gathering
Based on this data, on average each day in the US 1.7 pipeline incidents are reported (a number in line with our previous analyses), requiring 9 people to be evacuated, and causing almost $1.3 million in property damage. A pipeline catches fire every 4 days and results in an explosion every 11 days. These incidents result in an injury every 5 days, on average, and a fatality every 26 days.
While the PHMSA datasets are extremely thorough, they do have some limitations. Unfortunately, in some cases, these limitations tend to minimize our understanding of the true impacts. A notable recent example is a series of explosions and fires on September 13, 2018 in the towns of Lawrence, Andover, and North Andover, in the Merrimack Valley region of Massachusetts. Cumulatively, these incidents resulted in the death of a young man and the injuries to 25 other people. There were 60-80 structure fires, according to early reports, as gas distribution lines became over-pressurized.
The preliminary PHMSA report lists all of these Massachusetts fires as a single event, so it is counted as one fire and one explosion in Table 1. As of the November 14 download of the data, property damage has not been calculated, and is listed as $0. The number of evacuees in the report also stands at zero. This serves as a reminder that analysis of the oil and gas industry can only be as good as the available data, and relying on operators to accurately self-report the full extent of the impacts is a somewhat dubious practice.
This map shows pipeline incidents in the US from 1/1/2010 through 11/14/2018. Source: PHMSA. One record without coordinates was discarded, and 10 records had missing decimal points or negative (-) signs added to the longitude values. A few obvious errors remain, such as a 2012 incident near Winnipeg that should be in Texas, but we are not in a position to guess at the correct latitude and longitude values for each of the 5,512 incidents.
Another recent incident occurred in Center Township, a small community in Beaver County, Pennsylvania near Aliquippa on September 10, 2018. According to the PHMSA Gas Transmission & Gathering report, this incident on the brand new Revolution gathering line caused over $7 million in damage, destroying a house and multiple vehicles, and required 49 people to evacuate. The incident was indicated as a fire, but not an explosion. However, reporting by local media station WPXI quoted this description from a neighbor:
A major explosion, I thought it was a plane crash honestly. My wife and I jumped out of bed and it was just like a light. It looked like daylight. It was a ball of flame like I’ve never seen before.
From the standpoint of the data, this error is not particularly egregious. On the other hand, it does serve to falsely represent the overall safety of the system, at least if we consider explosions to be more hazardous than fires.
Big picture findings
Comparing the three reports against one another, we can see that the majority of incidents (64%) and damages (also 64%) are caused by hazardous liquids pipelines, even though the liquids account for less than 8% of the total mileage of the network. In all of the other categories, however, gas distribution lines account for more than half of the cumulative damage, including injuries (79%), deaths (73%), evacuees (62%), fires (71%), and explosions (78%). This is perhaps due to the vast network (more than 2.2 million miles) of gas distribution mains and service lines, as well as their nature of taking these hazardous products directly into populated areas. Comparatively, transmission and hazardous liquids lines ostensibly attempt to avoid those locations.
Is the age of the pipeline a factor in incidents?
Among the available attributes in the incident datasets is a field indicating the year the pipeline was installed. While this data point is not always completed, there is enough of a sample size to look for trends in the data. We determined the age of the pipe by subtracting the year the pipe was installed from the year of the incident, eliminating nonsensical values that were created when the pipeline age was not provided. In the following section, we will look at two tables for each of the three reports. The first table shows the cause of the failure compared to the average age, and the second breaks down results by the content that the pipe was carrying. We’ll also include a histogram of the pipe age, so we can get a sense of how representative the average age actually is within the sample.
A. Gas distribution
Each table shows some fluctuation in the average age of pipeline incidents depending on other variables, although the variation in the product contained in the pipe (Table 3) are minor, and may be due to relatively small sample sizes in some of the categories. When examining the nature of the failure in relation to the age of the pipe (Table 2), it does make sense that incidents involving corrosion would be more likely to afflict older pipelines, (although again, the number of incidents in this category is relatively small). On average, distribution pipeline incidents occur on pipes that are 33 years old.
When we look at the histogram (Figure 1) for the overall distribution of the age of the pipeline, we see that those in the first bin, representing routes under 10 years of age, are actually the most frequent. In fact, the overall trend, excepting those in the 40 t0 50 year old bin, is that the older the pipeline, the fewer the number of incidents. This may reflect the massive scale of pipeline construction in recent decades, or perhaps pipeline safety protocol has regressed over time.
Age of Pipeline - Histogram
Figure 1. Age of pipeline histogram for gas distribution line incidents between 1/1/2010 and 11/14/2018. Incidents where the age of the pipe is unknown are excluded.
Age/Cause of Incidents - Table 2
Table 2. Average age of pipe and cause for failure in gas distribution line incidents
Cause of Failure
Incidents – Total
Incidents – Pipe Age Known
Avg. Pipe Age
Material Failure Of Pipe Or Weld
Natural Force Damage
Other Incident Cause
Other Outside Force Damage
Age/Product Transported - Table 3
Table 3. Average age of pipe and material being transported in gas distribution lines
Incidents – Total
Incidents – Pipe Age Known
Ave. Pipe Age
B. Gas Transmission & Gathering
Transmission & Gathering line incidents occur on pipelines routes that are, on average, five years older than their distribution counterparts. Corrosion, natural force damage, and material failures on pipes and welds occur on pipelines with an average age above the overall mean, while excavation and “other outside force” incidents tend to occur on newer pipes (Table 4). The latter category would include things like being struck by vehicles, damaged in wildfires, or vandalism. The contents of the pipe does not seem to have any significant correlation with the age of the pipe when we take sample size into consideration (Table 5).
The histogram (Figure 2) for the age of pipes on transmission & gathering line incidents below shows a more normal distribution, with the noticeable exception of the first bin (0 to 10 years old) ranking second in frequency to the fifth bin (40 to 50 years old).
It is worth mentioning that, “PHMSA estimates that only about 5% of gas gathering pipelines are currently subject to PHMSA pipeline safety regulations.” My correspondence with the agency verified that the remainder is not factored into their pipeline mileage or incident reports in any fashion. Therefore, we should not consider the PHMSA data to completely represent the extent of the gathering line network or incidents that occur on those routes.
Age of Pipeline - Histogram
Figure 2. Age of pipeline histogram for transmission & gathering line incidents between 1/1/2010 and 11/14/2018. Incidents where the age of the pipe is unknown are excluded.
Age/Cause of Incidents - Table 4
Table 4. Average age of pipe and cause for failure in gas transmission & gathering line incidents
Cause of Failure
Incidents – Total
Incidents – Pipe Age Known
Ave. Pipe Age
Material Failure Of Pipe Or Weld
Natural Force Damage
Other Incident Cause
Other Outside Force Damage
Age/Material Transported - Table 5
Table 5. Average age of pipe and material being transported in gas transmission & gathering lines
Incidents – Total
Incidents – Pipe Age Known
Ave. Pipe Age
C. Hazardous Liquids
The average incident on hazardous liquid lines occurs on pipelines that are 27 years old, which is 6 years younger than for distribution incidents, and 11 years younger than their transmission & gathering counterparts. This appears to be heavily skewed by the equipment failure and incorrect operation categories, both of which occur on pipes averaging 15 years old, and both with substantial numbers of incidents. On the other hand, excavation damage, corrosion, and material/weld failures tend to occur on pipes that are at least 40 years old (Table 6).
In terms of content, pipelines carrying carbon dioxide happen on pipes that average just 11 years old, although there are not enough of these incidents to account for the overall departure from the other two datasets (Table 7).
The overall shape of the histogram (Figure 3) is similar to that of transmission & gathering line incidents, except that the first bin (0 to 10 years old) is by far the most frequent, with more than 3 and a half times as many incidents as the next closest bin (4o to 50 years old). Operators of new hazardous liquid routes are failing at an alarming rate. In descending order, these incidents are blamed on equipment failure (61%), incorrect operation (21%), and corrosion (7%), followed by smaller amounts in other categories. The data indicate that pipelines installed in previous decades were not subject to this degree of failure.
Age of Pipeline - Histogram
Figure 3. Age of pipeline histogram for hazardous liquid line incidents between 1/1/2010 and 11/14/2018. Incidents where the age of the pipe is unknown are excluded.
Age/Cause of Incidents - Table 6
Table 6. Average age of pipe and cause for failure in hazardous liquid line incidents
Cause of Failure
Incidents – Total
Incidents – Pipe Age Known
Avg. Pipe Age
Material Failure Of Pipe Or Weld
Natural Force Damage
Other Incident Cause
Other Outside Force Damage
Age/Material Transported - Table 7
Table 7. Average age of pipe and material being transported in hazardous liquid lines
Incidents – Total
Incidents – Pipe Age Known
Avg. Pipe Age
Biofuel / Ethanol Blends
CO2 (Carbon Dioxide)
Highly Volatile Liquids*
Refined Petroleum Product
* Highly volatile liquids are transported as liquids but would revert to a gaseous state in ambient conditions, including natural gas liquids like ethane, propane, and butane.
When evaluating quotes, like those listed above, that portray pipelines as a safe way of transporting hydrocarbons, it’s worth taking a closer look at what they are saying.
Are pipelines the safest way of transporting our nation’s energy products? This presupposes that our energy must be met with liquid or gaseous fossil fuels. Certainly, crude shipments by rail and other modes of transport are also concerning, but movements of solar panels and wind turbines are far less risky.
Does the industry have the “strong safety record” that PHMSA proclaims? Here, we have to grapple with the fact that the word “safety” is inherently subjective, and the agency’s own data could certainly argue that the industry is falling short of reasonable safety benchmarks.
And what about the claim that barrels of oil or petroleum products reach their destination “99.999% of the time? First, it’s worth noting that this claim excludes gas pipelines, which account for 92% of the pipelines, even before considering that PHMSA only has records on about 5% of gas gathering lines in their pipeline mileage calculations. But more to the point, while a 99.999% success rate sounds fantastic, in this context, it isn’t good enough, as this means that one barrel in every 100,000 will spill.
For example, the Dakota Access Pipeline has a daily capacity of 470,000 barrels per day (bpd). In an average year, we can expect 1,715 barrels (72,030 gallons) to fail to reach its destination, and indeed, there are numerous spills reported in the course of routine operation on the route. The 590,000 bpd Keystone pipeline leaked 9,700 barrels (407,400 gallons) late last year in South Dakota, or what we might expect from four and a half years of normal operation, given the o.001% failure rate. In all, PHMSA’s hazardous liquid report lists 712,763 barrels (29.9 million gallons) were unintentionally released, while an additional 328,074 barrels (13.8 million gallons) were intentionally released in this time period. Of this, 284,887 barrels (12 million gallons) were recovered, meaning 755,950 barrels (31.7 million gallons) were not.
Beyond that, we must wonder whether the recent spate of pipeline incidents in new routes is a trend that can be corrected. Between the three reports, 1,283 out of the 3,853 (32%) incidents occurred in pipelines that were 10 years old or younger (where the year the pipeline’s age is known). A large number of these incidents are unforced errors, due to poor quality equipment or operator error.
One wonders why regulators are allowing such shoddy workmanship to repeatedly occur on their watch.
By Matt Kelso, Manager of Data and Technology, FracTracker Alliance
In 2012, a battle between Ohio, West Virginia, and Pennsylvania was underway. Politicians and businesses from each state were eagerly campaigning for the opportunity to host Royal Dutch Shell’s “world-class” petrochemical facility. The facility in question was an ethane cracker, the first of its kind to be built outside of the Gulf Coast in 20 years. In the end, Pennsylvania’s record-breaking tax incentive package won Shell over, and construction on the ethane cracker plant began in 2017.
Once completed, the ethane cracker will convert ethane from fracked wells into 1.6 million tons of polyethylene plastic pellets per year.
Shell’s ethane cracker, under construction in Beaver County, PA. Image by Ted Auch, FracTracker.
Aerial support provided by LightHawk.
Ohio and West Virginia, however, have not been left out of the petrochemical game. In addition to the NGL pipelines, cryogenic plants, and fractionation facilities in these states, plans for ethane cracker projects are also in the works.
In 2017, PTT Global Chemical (PTTGC) put Ohio in second place in the “race to build an ethane cracker,” when it decided to build a plant in Belmont County, Ohio.
But first, why is the petrochemical industry expanding in the Ohio River Valley?
Fracking has opened up huge volumes of natural gas in the Marcellus and Utica shales in Pennsylvania, Ohio, and West Virginia. Fracked wells in these states extract methane, which is then transported in pipelines and used as a residential, industrial, or commercial energy source. The gas in this region, however, contains more than just methane. Classified as “wet gas,” the natural gas stream from regional wells also contains natural gas liquids (NGLs). These NGLs include propane, ethane, and butane, and industry is eager to create a market for them.
Plastic pellets, also called “nurdles,” the end product of ethane crackers.
Major processing facilities, such as cryogenic and fractionation plants, receive natural gas streams and separate the NGLs, such as ethane, from the methane. After ethane is separated, it can be “cracked” into ethylene, and converted to polyethylene, the most common type of plastic. The plastic is shipped in pellet form to manufacturers in the U.S. and abroad, where it is made into a variety of plastic products.
By building ethane crackers in the Ohio River Valley, industry is taking advantage of the region’s vast underground resources.
PTTGC ethane cracker: The facts
PTTGC’s website states that the company “is Thailand’s largest and Asia’s leading integrated petrochemical and refining company.” While this ethane cracker has been years in the making, the company states that “a final investment decision has not been made.” The image below shows land that PTTGC has purchased for the plant, totaling roughly 500 acres, in Dilles Bottom, Mead Township.
According to the Ohio EPA, the plant will turn ethylene into:
700,000 tons of high density polyethylene (HDPE) per year
900,000 tons Linear low-density polyethylene (LLDPE)
HDPE is a common type of plastic, used in many products such as bags, bottles, or crates. Look for it on containers with a “2” in the recycling triangle. LLDPE is another common type of plastic that’s weaker and more flexible; it’s marked with a “4.”
The ethane cracker complex will contain:
An ethylene plant
Four ethylene-based derivatives plants.
Six 552 MMBtu/hour cracking furnaces fueled by natural gas and tail gas with ethane backup
Three 400 MMBTU/hr steam boilers fueled by natural gas and ethane
A primary and backup 6.2 MMBtu/hour thermal oxidizer
A high pressure ground flare (1.8 MMBtu/hour)
A low pressure ground flare (0.78 MMBtu/hour)
Wastewater treatment systems
Equipment to capture fugitive emissions
Railcars for pygas (liquid product) and HDPE and LLDPE pellets
Emergency firewater pumps
Emergency diesel-fired generator engines
A cooling tower
Impacts on air quality
The plant received water permits last year, and air permits are currently under review. On November 29, 2018, the Ohio EPA held an information session and hearing for a draft air permit (the permit can be viewed here, by entering permit number P0124972).
The plant will be built in the community of Dilles Bottom, on the former property of FirstEnergy’s R.E. Burger Power Station, a coal power plant that shut down in 2011. The site was demolished in 2016 in preparation for PTTGC’s ethane cracker. In 2018, PTTGC also purchased property from Ohio-West Virginia Excavating Company. In total, the ethane cracker will occupy 500 acres.
R.E. Burger Power Station, which has been demolished for the PTTGC Ethane Cracker. Image Source
Table 1, below, is a comparison of the previous major source of air pollution source, the R.E. Burger Power Station, and predictions of the future emissions from the PTTGC ethane cracker. The far right column shows what percent of the former emissions the ethane cracker will release.
Table 1: Former and Future Air Emissions in Dilles Bottom, Ohio
R.E.Burger Power Station (2010 emissions)
PTTGC Ethane Cracker (predicted emissions)
Percent of former emissions
CO (carbon monoxide)
NOx (nitrogen oxides)
SO2 (sulfur dioxide)
PM10 (particulate matter, 10)
PM2.5 (particulate matter, 2.5)
VOCs (volatile organic compounds)
As you can see, the ethane cracker will emit substantially less sulfur dioxide and nitrogen dioxides compared with the R.E. Burger site. This makes sense, as these two pollutants are associated with burning coal. On the flip side, the ethane cracker will emit almost four times as much carbon monoxide and 263,900% more volatile organic compounds (percentages bolded in Table 1, above).
In addition to these pollutants, the ethane cracker will emit 38 tons per year of Hazardous Air Pollutants (HAPS), a group of pollutants that includes benzene, chlorine, and ethyl chloride. These pollutants are characterized by the EPA as being “known or suspected to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental effects.”
While these emission numbers seem high, they still meet federal requirements and nearly all state guidelines. If the ethane cracker becomes operational, pollutant monitoring will be important to ensure the plant is in compliance and how emissions impact air quality. The plant will also attract more development to an already heavily industrialized area; brine trucks, trains, pipelines, fracked wells, compressor stations, cryogenic facilities, and natural gas liquid storage are all part of the ethane-to-plastic manufacturing process. The plastics coming from the plant will travel to facilities in the U.S. and abroad to create different plastic products. These facilities are an additional source of emissions.
Air permitting does not consider the full life cycle of the plant, from construction of the plant to its demolition, or the development associated with it.
As such, this plant will be major step back for local air quality, erasing recent improvements in the Wheeling metropolitan area, historically listed as one of the most polluted metropolitan areas in the country. Furthermore, the pollutants that will be increasing the most are associated with serious health effects. Over short term exposure, high levels of VOCs are associated with headaches and respiratory symptoms, and over long term exposure, cancer, liver and kidney damage.
In addition to air quality impacts, ethane cracker plants also pose risks from fires, explosions, and other types of unplanned accidents. In 2013, a ruptured boiler at an ethane cracker in Louisiana caused an explosion that sent 30,000 lbs. of flammable hydrocarbons into the air. Three hundred workers evacuated, but sadly there were 167 suffered injuries and 2 deaths.
While researching Shell’s ethane cracker in Beaver County, FracTracker worked with the Emergency Operations Center (EOC) in St. Charles Parish, Louisiana, to learn about emergency planning around the petrochemical industry. Emergency planners map out two and five mile zones around facilities, called emergency planning zones, and identify vulnerabilities and emergency responders within them.
With this in mind, the map below shows a two and five-mile radius around PTTGC’s property, as reported by Belmont County Auditor. Within these emergency planning zones are the locations of schools, day cares, hospitals, fire stations, emergency medical services, hospitals, and local law enforcement offices, reported by Homeland Infrastructure Foundation Level Data.
The map also includes census data from the EPA that identifies potential environmental justice concerns. By clicking on the census block groups, you will see demographic information, such as income status, age, and education level. These data are important in recognizing populations that may already be disproportionately burdened by or more vulnerable to environmental hazards.
Finally, the map displays environmental data, also from the EPA, including a visualization of particulate matter along the Ohio River Valley, where massive petrochemical development is occurring. By clicking on a census block and then the arrow at the top, you will find a number of other statistics on local environmental concerns.
Emergency planning zones for Shell’s ethane cracker are available here.
Within the 5 mile emergency planning zone, there are:
9 fire or EMS stations
17 schools and/or day cares
6 local law enforcement offices
Within the 2 mile emergency planning zone, there are:
3 fire or EMS stations
7 schools and/or day cares
3 local law enforcement offices
Sites of capacity, such as the fire and EMS stations, could provide emergency support in the case of an accident. Sites of vulnerability, such as the many schools and day cares, should be aware of and prepared to respond to the various physical and chemical risks associated with ethane crackers.
The census block where the ethane cracker is planned has a population of 1,252. Of this population, 359 are 65 years or older. That is well above national average and important to note; air pollutants released from the plant are associated with health effects such as cardiovascular and respiratory disease, to which older populations are more vulnerable.
PTTGC’s ethane cracker, if built, will drastically alter the air quality of Belmont County, OH, and the adjacent Marshall County, WV. Everyday, the thousands of people in the surrounding region, including the students of over a dozen schools, will breathe in its emissions.
This population is also vulnerable to unpredictable accidents and explosions that are a risk when manufacturing products from ethane, a highly flammable liquid. Many of these concerns were recently voiced by local residents at the air permit hearing.
Despite these concerns and pushback, PTTGC’s website for this ethane cracker, pttgcbelmontcountyoh.com, does not address emergency plans for the area. It also fails to acknowledge the potential for any adverse environmental impacts associated with the plant or the pipelines, fracked wells, and train and truck traffic it will attract to the region.
With this in mind, we call upon PTTGC to acknowledge the risks of its facility to Belmont County and provide the public with emergency preparedness plans, before the permitting process continues.
If you have thoughts or concerns regarding PTTGC’s ethane cracker and its impact on air quality, the Ohio EPA is accepting written comments through December 11, 2018. We encourage you to look through the data on this map or conduct your own investigations and submit comments on air permit #P0124972.
How fragmented approvals and infrastructure favor petrochemical development
By Leann Leiter and Lisa Graves-Marcucci
Let’s think back to 2009, when oil and gas companies like Range Resources began drilling the northeast shale plays in earnest. Picture the various stages involved in drilling – such as leasing of land, clearing of trees, boring of wells, siting of compressor stations, and construction of pipelines to gather the gas. Envision the geographic scope of the gas infrastructure, with thousands of wells in Pennsylvania alone, and thousands of miles of pipelines stretching as far as Louisiana.
Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter
Now, picture the present, where a homeowner looks out over her yard and wonders how a lease she signed with Shell several years prior made it possible for the company to run an ethane pipeline across her property and between her house and her garage.
Think forward in time, to 2022, the year when a world-scale ethane cracker is set to go online in Beaver County, Pennsylvania, to begin churning through natural gas liquids from wells in PA and others, producing a variety of disposable plastic products.
At each of these moments in gas development, which of the many stakeholders – industry leaders, local governments, state regulatory agencies, or landowners and residents – were granted a view of the full picture?
The proposed Shell ethane cracker in Beaver County is an illustration of the fragmented nature of gas development. From the extensive web of drilling infrastructure required to supply this massive facility, to several years of construction, this project is a case-study in piecemeal permitting. Such fragmentation creates a serious barrier to transparency and to the informed decision-making that relies upon it.
In the first two articles in this series on the petrochemical development in Beaver County, we focused on ethane cracker emergency scenarios and how the area might prepare. In this article, we draw the lens back to take in the larger picture of this region-altering project and highlight the effects of limited transparency.
The “Piecemeal” Nature of Gas Development
All across the Pennsylvania, proposed industrial development – even coal operations – have historically provided to the public, elected officials, and regulatory agencies the extent or footprint of their planned operations. Nonetheless, the oil and gas industry has in several instances undertaken a practice of developing its extensive infrastructure piece-by-piece. Operators of these facilities first acquire a GP-5 General Permit, which is only available to certain oil and gas operations with “minor” emissions and which allows them to avoid having the permit undergo public notice or comment. These operators then add emissions sources and increases through a series of minor amendments. While they are required to obtain a “major” source permit once their modifications result in major emissions, they avoid the scrutiny required for a major source by this fragmented process.
Unlike most other industrial permitting, the gas industry has enjoyed a much less transparent process. Instead of presenting their entire planned operation at the time of initial permit application, gas operators having been seeking – and receiving – incremental permits in a piecemeal fashion. This process puts local decision makers and the women, men, and children who live, work, and go to school near gas development at a severe disadvantage in the following ways:
Without full disclosure of the entirety of the planned project, neither regulatory bodies nor the public can conduct a full and factual assessment of land use impacts;
Incremental approvals allow for ever-expanding operations, including issuance of permits without additional public notification and participation;
Piecemeal approvals allow operations to continuously alter a community and its landscape;
The fragmented approval process prevents consideration of cumulative impacts; and
Without full transparency of key components of the proposed operations, emergency planning is hampered or non-existent.
From the Well to the Ethane Cracker
In the fragmented approval process of gas development, the proposed ethane cracker in Beaver County represents a pertinent example. Developers of this massive, multi-year, and many-stage project have only revealed the size and scope in a piecemeal fashion, quietly making inroads on the project (like securing land leases along the route of the pipeline required for the cracker, years in advance of permit approvals for the facility itself). By rolling out each piece over several years, the entirety of the petrochemical project only becomes clear in retrospect.
A World-Scale Petrochemical Hub
While Shell is still pursuing key approval from the PA Department of Environmental Protection, industry leaders treat the ethane cracker as a foregone conclusion, promising that this facility is but one step in turning the area into a “petrochemical hub.”
The cracker facility, alone, will push existing air pollution levels further beyond their already health-threatening state. Abundant vacant parcels around Shell’s cracker site are attractive sites for additional spin-off petrochemical facilities in the coming “new industry cluster.” These facilities would add their own risks to the equation, including yet-unknown chemical outputs emitted into the air and their resulting cumulative impacts. Likewise, disaster risks associated with the ethane cracker remain unclear, because in the piecemeal permitting process, the industry is not required to submit Preparedness, Prevention, and Contingency (PPC) Plans until after receiving approval to build.
Figure 2. A portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh’s Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.
92.3 Miles of Explosive Pipeline
More than just a major local expansion, communities downriver and downwind will be susceptible to the impacts, including major land disturbance, emissions, and the potential for “incidents,” including explosion. The pipeline required to feed the cracker with highly flammable, explosive ethane would tie the tri-state region into the equation, expanding the zone of risk into Ohio and crossing through West Virginia.
Figure 3. The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP
Renewed Demand at the Wellhead
No one piece of the gas infrastructure stands alone; all work in tandem. According to the Energy Information Administration (EIA), the new US ethane crackers will drive consumption of ethane up by a 26% by the end of 2018. Gas wells in the northeast already supply ethane; new ethane crackers in the region introduce a way to profit from this by-product of harvesting methane without piping it to the Gulf Coast. How this renewed demand for ethane will play out at fracked wells will be the result of complex variables, but it will undoubtedly continue to drive demand at Pennsylvania’s 10,000 existing unconventional oil and gas wells and those of other states, and may promote bringing new ones online.
Figure 4. Excerpt from Executive Summary of IHS Markit Report, “Prospects to Enhance Pennsylvania’s Opportunities in Petrochemical Manufacturing.”
Along with drilling comes a growing network of gathering and transmission lines, which add to the existing 88,000 miles of natural gas pipeline in Pennsylvania alone, fragment wildlife habitat, and put people at risk from leaks and explosions. Facilities along the supply stream that add their own pollution and risks include pump stations along the route and the three cryogenic facilities at the starting points of the Falcon Pipeline (see Fig. 6).
Figure 5. Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter
The infrastructure investment required for ethane crackers in this region could reach $3.7 billion in processing facilities, pipelines for transmitting natural gas liquids including ethane, and storage facilities. A report commissioned by Team Pennsylvania and the PA Department of Community and Economic Development asserts that “the significant feedstock and transportation infrastructure required” will “exceed what is typically required for a similar facility” in the Gulf Coast petrochemical hub, indicating a scale of petrochemical development that rivals that of the southern states. This begs the question of how the health impacts in Pennsylvania will compare to those in the Gulf Coast’s “Cancer Alley.”
Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP
Water Impacts, from the Ohio River to the Arctic Ocean
Shell’s facility is only one of the ethane crackers proposed for the region that, once operational, would be permitted to discharge waste into the already-beleaguered Ohio River. This waterway, which traverses six separate states, supplies the drinking water for over 3 million people. Extending the potential water impact even further, the primary product of the Shell facility is plastics, whose inevitable disposal would unnecessarily add to the glut of plastic waste entering our oceans. Plastic is accumulating at the alarming rate of 3,500 pieces a day on one island in the South Pacific and as far away as the waters of the Arctic.
Figure 7. View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.
How does fragmentation favor industry?
The gas and petrochemical industry would likely defend the logistical flexibility the piecemeal process affords them, allowing them to tackle projects, make investments, and involve new players as needed overtime. But in what other ways do the incredibly fragmented approval processes, and the limited requirements on transparency, favor companies like Shell and their region-changing petrochemical projects? And what effect does the absence of full transparency have on local communities like those in Beaver County? We conclude that it:
“Divides and conquers” the region. The piecemeal approach to gas development, and major projects like the Shell ethane cracker, deny any sense of solidarity between the people along the pipeline route resisting these potentially explosive channels cutting through their yards, and residents of Beaver County who fear the cracker’s emissions that will surround their homes.
Makes the project seem a foregone conclusion, putting pressure on others to approve. For example, before Shell formally announced its intention to build the facility in Potter Township, it rerouted a state-owned road to facilitate construction and increased traffic flow. Likewise, though a key permit is still outstanding with the PA DEP, first responders, including local volunteer firefighters, have already begun dedicating their uncompensated time to training with Shell. While this is a positive step from a preparedness standpoint, it is one of many displays of confidence by Shell that the cracker is a done deal.
Puts major decisions in the hands of those with limited resources to carry them out and who do not represent the region to be affected. In the case of the Shell ethane cracker, three township supervisors in Potter Township granted approvals for the project. The impacts, however, extend well beyond Potter or even Beaver county and include major air impacts for Allegheny County and the Pittsburgh area. Effects will also be felt by landowners and residents in numerous counties and two states along the pipeline route, those near cryogenic facilities in Ohio and Pennsylvania, plus those living on the Marcellus and Utica shale plays who will see gas well production continue and potentially increase.
Figures 8a and 8b. Potter Township Supervisors give the go-ahead to draft approval of Shell’s proposed ethane cracker at a January meeting, while confronted with public concern about deficiencies in Shell’s permit applications. Photos courtesy of the Air Quality Collaborative.
The piecemeal, incremental, and fragmented approval processes for the ethane cracker – and other gas-related facilities in the making – create one major problem. They make it nearly impossible for locals, elected officials, and regulatory agencies to see the whole picture as they make decisions. The bit-by-bit approach to gas development amounts to far-reaching development with irreversible impacts to environmental and human health.
We ask readers, as they contemplate the impacts closest to them – be it a fracked well, a hazardous cryogenic facility, the heavily polluted Ohio River, a swath of land taken up for the pipeline’s right-of-way, or Shell’s ethane cracker itself – to insist that they, their elected officials, and regulators have access to the whole picture before approvals are granted. It’s hard to do with a project so enormous and far-reaching, but essential because the picture includes so many of us.
To The International League of Conservation Photographers, The Ohio Environmental Council, and The Air Quality Collaborative for sharing photographs.
To Sophie Riedel for sharing her visualizations of natural gas interstate pipelines.
To Lisa Hallowell at the Environmental Integrity Project, and Samantha Rubright and Kirk Jalbert at FracTracker, for their review of and and invaluable contributions to this series.
Feature image: Map of US counties and natural gas interstate pipeline system describes the wide-diameter (20-42 inch), high capacity trunklines that carry most of the natural gas that is transported throughout the nation. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/05/Pipelines-US-Graphic-Riedel-Feature.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgFracTracker Alliance2017-05-31 09:12:492020-03-11 15:44:40Piecing Together an Ethane Cracker
By Leann Leiter and Lisa Graves Marcucci Maps and data analysis by Kirk Jalbert
Highly industrialized operations like petrochemical plants inherently carry risks, including the possibility of large-scale disasters. In an effort to prepare, it is incumbent upon all stakeholders to fully understand the risk potential. Yet, the planned Shell ethane cracker and additional petrochemical operations being proposed for Western Pennsylvania are the first of their kind in our region. This means that residents and elected officials are without a frame of reference as they consider approving these operations. Officials find themselves tasked with reviewing and approving highly complicated permit applications, and the public remains uncertain of what questions to ask and scenarios to consider. Often overlooked in the decision-making process is valuable expertise from local first responders like police, fire and emergency crew members, HAZMAT teams, and those who protect vulnerable populations, like emergency room personnel, nursing home staff, and school officials.
Example of cracker producing ethylene, located at BASF’s Ludwigshafen site. Photo credit: BASF
In the first article in this series , we tried to identify the known hazards associated with ethane crackers. In this article, we look more closely at how that risk could play out in Beaver County, PA and strive to initiate an important dialogue that invites valuable, local expertise.
In keeping with the first article in this series, we use the terms vulnerability and capacity. Vulnerability refers to the conditions and factors that increase the disaster impact that a community might experience, and capacity consists of the strengths that mitigate those impacts. Importantly, vulnerability and capacity frequently intertwine and overlap. We might, for example, consider a fire station to be a site of “capacity,” but if it lies within an Emergency Planning Zone (discussed more below), an explosion at the plant could render it a vulnerability. Likewise, “vulnerable” populations such as the elderly may have special skills and local knowledge, making them a source of capacity.
Emergency Planning: Learning from Louisiana
FracTracker got in touch with the Emergency Operations Center (EOC) in St. Charles Parish, Louisiana, to learn how a community already living with Shell-owned and other petrochemical facilities manages risk and disclosure. The Emergency Manager we spoke with explained that they designate a two- and a five-mile area around each new facility in their jurisdiction, like ethane crackers, during their emergency planning process. They call these areas “ emergency planning zones ” or EPZs, and they maintain records of the vulnerabilities and sites of capacity within each zone. In case of a fire, explosion, or other unplanned event at any facility, having the EPZs designated in advance allows them to mobilize first responders, and notify and evacuate everyone living, working, and attending school within the zone. Whether they activate a two- or a five-mile EPZ depends on the type of incident, and factors like wind speed and direction.
Based on those procedures, the map below shows similar likely zones for the proposed plant in Beaver County, along with sites of vulnerability and capacity.
The map helps us visualize the vulnerability and capacity of this area, relative to the proposed ethane cracker. It includes three main elements: the Shell site and parcels likely to be targeted for buildout of related facilities, two Emergency Planning Zones (EPZs) around the Shell facility, and infrastructure and facilities of the area that represent vulnerability and capacity.
Vacant parcels near the site
It is important to note that the proposed ethane cracker in Beaver County is merely the first of an influx of petrochemical spin-off facilities promised for the area, potentially occupying the various empty parcels indicated on the map above as “vacant properties” and presented in light gray in the screenshot left.
Each new facility would add its own risks and cumulative impacts to the equation. It would be impossible to project these additional risks without knowing what facilities will be built here, so in this article, we stick to what we do know – the risks already articulated by Shell, lessons learned from other communities hosting petrochemical industry in other parts of the country, and past disasters at similar facilities.
Vulnerability and Capacity in Beaver County
Red, blue, and green points on the map above and in the screenshot below stand in for hospitals like Heritage Valley Beaver; fire and emergency medical services like Vanport Volunteer Fire Company; police stations like the Beaver County Sheriff’s office; and daycares and schools like Center Grange Primary School.
Transportation routes, if impacted, could challenge evacuation. Potter Township Fire Chief Vicki Carlton pointed out that evacuations due to an event at this facility could also be complicated by the need to stay upwind, when evacuations would likely move in a downwind direction. This map lacks drinking water intakes and other essential features upon which lives depend, but which nonetheless also sit within this zone of vulnerability.
Points within EPZS
Vulnerability/capacity within 2-mile zone:
5 police stations
10 fire/EMS stations
23 schools/daycare facilities
When expanded to 5-mile zone:
9 police stations
23 fire/EMS stations
40 schools/daycare facilities
*Note: For census tracts that are partly within a zone, a ratio is determined based on the percentage of land area in the tract within the zone. This ratio is then used to estimate the fraction of the population likely within the zone.
Stakeholders’ Right to Know
No person or community should be subjected to risk without the opportunity to be fully informed and to give meaningful input. Likewise, no group of people should have to bear a disproportionate share of environmental risks, particularly stakeholders who are already frequently disenfranchised in environmental decision-making. “Environmental justice” (EJ) refers to those simple principles, and DEP designates environmental justice areas based on communities of color and poverty indicators.
Presented as blue fields on the map and shown in the screenshot below, several state-designated EJ areas fall partially or entirely within the 2- and 5-mile EPZs (a portion of two EJ areas home to 2,851 people, and when expanded to five miles, two entire EJ areas and a portion of seven more, home to 18,679 people, respectively).
EJ Areas and Emergency Planning Zones around the Site
The basic ideas behind environmental justice have major bearing in emergency scenarios. For example, those living below the poverty line tend to have less access to information and news sources, meaning they might not learn of dangerous unexpected emissions plumes coming their way. They also may not have access to a personal vehicle, rendering them dependent upon a functioning public transportation system to evacuate in an emergency. Living below poverty level may also mean fewer resources at home for sheltering-in-place during a disaster, and having less financial resources, like personal savings, may lead to more difficult post-disaster recovery.
FracTracker recently consulted with the Emergency Management Director for Beaver County, Eric Brewer, and with Potter Township Fire Chief Vicki Carlton. Both indicated that their staff have already begun training exercises with Shell -including a live drill on site that simulated a fire in a work trailer. But when asked, neither reported that they had been consulted in the permit approval process. Neither had been informed of the chemicals to be held on site, and both referred to emergency planning considerations as something to come in the future, after the plant was built.
Unfortunately, the lack of input from public safety professionals during the permit approval stage isn’t unique to Beaver County. Our emergency management contact in Louisiana pointed to the same disturbing reality: Those who best understand the disaster implications of these dangerous developments and who would be mobilized to respond in the case of a disaster are not given a say in their approval or denial. This valuable local expertise – in Louisiana and in Beaver County – is being overlooked.
All Beaver County first responders who spoke with FracTracker clearly showed their willingness to perform their duties in any way that Shell’s new facility might demand, hopefulness about its safety, and a generally positive relationship with the company so far. Chief Carlton believes that the ethane cracker will be an improvement over the previous facility on the same site, the Horsehead zinc smelter, though a regional air pollution report characterizes this as a trade off of one type of dangerous pollution for another. Director Brewer pointed to the existing emergency plans for the county’s nuclear facility as giving Beaver County an important leg-up on preparedness.
But the conversations also raised concern about what the future relationship between the community and the industry will look like. Will funds be allocated to these first responders for the additional burdens brought on by new, unprecedented facilities, in what amount, and for how long into the future? Chief Carlton pointed out that until Shell’s on-site fire brigade is in place two or three years from now, her all-volunteer department would be the first line of defense in case of a fire or other incident. In the meantime, her fire company has ordered a much-needed equipment upgrade to replace a 30-year old, outdated tanker at a cost of $400,000. They are formally requesting all corporate businesses in the township, including Shell, to share the cost. Hopefully, the fire company will see this cost covered by their corporate neighbors who use their services. But further down the road? Once all is said and done, and Shell has what they need to operate unfettered, Chief Carlton wonders, “where do we stand with them?”
Waiting for disclosure of the risks
Emergency preparedness and planning should be a process characterized by transparency and inclusion of all stakeholders. However, when it comes to the Shell ethane cracker, those who will share a fence line with such operations have not yet been granted access to the full picture. Currently, the DEP allows industrial operations like the proposed ethane cracker to wait until immediately before operations begin to disclose emergency planning information, in the form of Preparedness, Prevention, and Contingency (PPC) plans. In other words, when permits are up for approval or denial prior to construction, permit applicants are not currently required to provide PPC plans, and the public and emergency managers cannot weigh the risks or provide crucial input.
According to Shell, possible risks of the proposed Beaver County petrochemical facility include fire, explosion, leaks, and equipment failures. More than mere potentialities, examples of each are already on the books. The above table presents a sampling. Shell also points out the increased risk of traffic accidents, not explored in this chart. It is worth noting, however, that the proposed facility, and likely spin-off facilities, would greatly increase vehicular and rail traffic.
The ethane cracker in Beaver County plant has not yet been constructed. However, Shell operates similar operations with documented risks and their own histories of emergency events. Going forward, the various governmental agencies tasked with reviewing permit applications should require industrial operations like Shell, to make this information public as part of the review and planning process. Currently they can relegate safety information to a few vague references and get a free pass to mark it as “confidential” in permit applications. Strengthening risk disclosure requirements would be a logical and basic step toward ensuring that all stakeholders – including those with special emergency planning expertise – can have input on whether those risks are acceptable before permits are approved and site prep begins.
Until regulations are tightened, we invite Shell to fulfill its own stated objective of being a “good neighbor” by being forthcoming about what risks will be moving in next door. Shell can and should take the initiative to share information about its existing facilities, as well as lessons learned from past emergencies at those sites. Instead of waiting for the post-construction, or the “implementation” stage, all stakeholders deserve disclosure of Shell’s plans to prevent and respond to emergencies now.
In our next article, we will explore the infrastructure for the proposed Shell facility, which spans multiple states, and sort out the piecemeal approval processes of building an ethane cracker in Pennsylvania.
Emergency Managers and First Responders in St. Charles Parish, Louisiana and Potter Township and Center Township, PA.
Lisa Hallowell, Senior Attorney at the Environmental Integrity Project, for her review of this article series and contributions to our understanding of relevant regulations.
Kirk Jalbert, in addition to maps and analysis, for contributing key points of consideration for and expertise on environmental justice.
The International League of Conservation Photographers for sharing the feature image used in this article.
The image used on our homepage of the steam cracker at BASF’s Ludwigshafen site was taken by BASF.
By Leann Leiter, Environmental Health Fellow for FracTracker Alliance and the Southwest PA Environmental Health Project and Lisa Graves Marcucci, PA Coordinator, Community Outreach of Environmental Integrity Project
With maps and analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/05/Cracker-2-Feature-iLCP.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgFracTracker Alliance2017-05-03 13:56:332020-03-12 15:56:34Understanding in Order to Prepare: Ethane Cracker Risk and Disclosure
by Leann Leiter, Environmental Health Fellow
map & analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement
in partnership with the Environmental Integrity Project
On January 18, 2016, Potter Township Supervisors approved conditional use permits for Shell Chemical Appalachia’s proposed ethane cracker facility in Beaver County, PA. A type of petrochemical facility, an ethane cracker uses energy and the by-products of so-called natural gas to make ethylene, a building block of plastics. FracTracker Alliance has produced informative articles on the jobs numbers touted by the industry, and the considerable negative air impacts of the proposed facility. In the first in a series of new articles, we look at the potential hazards of ethane cracker plants in order to begin calculating the risk of a disaster in Beaver County.
As those who stand to be affected by — or make crucial decisions on — the ethane cracker contemplate the potential risks and promised rewards of this massive project, they should also carefully consider what could go wrong. In addition to the serious environmental and human health effects, which might only reveal themselves over time, what acute events, emergencies, and disasters could potentially occur? What is the disaster risk, the potential for “losses, in lives, health status, livelihoods, assets and services,” of this massive petrochemical facility?
Known Ethane Cracker Risks
A well-accepted formula in disaster studies for determining risk, cited by, among others, the United Nations International Strategy for Disaster Reduction (UNISDR), is Disaster Risk = (Hazard x Vulnerability)/Capacity, as defined in the diagram below. In this article, we consider the first of these factors: hazard. Future articles will examine the remaining factors of vulnerability and capacity that are specific to this location and its population.
Applied to Shell’s self-described “world-scale petrochemical project,” it is challenging to quantify the first of these inputs, hazard. Not only would a facility of this size be unprecedented in this region, but Shell has closely controlled the “public” information on the proposed facility. What compounds the uncertainty much further is the fact that the proposed massive cracker plant is a welcome mat for further development in the area—for a complex network of pipelines and infrastructure to support the plant and its related facilities, and for a long-term commitment to continued gas extraction in the Marcellus and Utica shale plays.
We can use what we do know about the hazards presented by ethane crackers and nearby existing vulnerabilities to establish some lower limit of risk. Large petrochemical facilities of this type are known to produce sizable unplanned releases of carcinogenic benzene and other toxic pollutants during “plant upsets,” a term that refers to a “shut down because of a mechanical problem, power outage or some other unplanned event.” A sampling of actual emergency events at other ethane crackers also includes fires and explosions, evacuations, injuries, and deaths.
For instance, a ruptured boiler at the Williams Company ethane cracker plant in Geismar, Louisiana, led to an explosion and fire in 2013. The event resulted in the unplanned and unpermitted release of at least 30,000 lbs. of flammable hydrocarbons into the air, including ethylene, propylene, benzene, 1-3 butadiene, and other volatile organic chemicals, as well as the release of pollutants through the discharge of untreated fire waters, according to the Louisiana Department of Environmental Quality. According to the Times-Picayune, “workers scrambl(ed) over gates to get out of the plant.” The event required the evacuation of 300 workers, injured 167, and resulted in two deaths.
The community’s emergency response involved deployment of hundreds of personnel and extensive resources, including 20 ambulances, four rescue helicopters, and buses to move the injured to multiple area hospitals. The U.S. Chemical Safety and Hazard Investigation Board chalked up the incident to poor “process safety culture” at the plant and “gaps in a key industry standard by the American Petroleum Institute (API).” The accident shut the plant down for a year and a half.
Potential Risks & Shell’s Mixed Messages
Shell has done little to define the potential for emergencies at the proposed Beaver County ethane cracker plant, at least in materials made available to the public. Shell has revealed that general hazards include “fire, explosion, traffic accidents, leaks and equipment failures.”
However, we located numerous versions of Shell’s handout and found one notable difference among them—the brochure distributed to community members at a December 2016 public hearing held by the Pennsylvania Department of Environmental Protection (PA DEP) excluded the word “explosion” from the list of “potential safety concerns.” The difference is seen in comparing the two documents.
Figure #1 below: Excerpt of online version of a handout for Beaver County, dated May 2015, with “explosion” included in list of “potential safety concerns.” (Other Shell-produced safety documents, like the one included as an exhibit in the conditional use permit application on file with the township, and Shell’s webpage for the project, also include “explosion” in the list of hazards.)
Figure #2 below: Excerpt of handout, dated November 2016 and provided to the community at December 15, 2016 meeting, with the word “explosion” no longer included.
Additional hints about risks are peppered throughout the voluminous permit applications submitted by Shell to the PA DEP and Potter Township, such as references to mitigating acts of terror against the plant, strategies for reducing water contamination, and the possibility of unplanned upsets. But the sheer volume of these documents, coupled with their limitedaccessibility challenge the public’s ability to digest this information. The conditional use permit application submitted by Shell indicates the existence of an Emergency Response Plan for the construction phase, but the submission is marked as confidential.
Per Pennsylvania law, and as set forth in PA DEP guidelines, Shell must submit a Preparedness, Prevention, and Contingency Plan (PPC Plan) at an unspecified point prior to operation. But at that likely too-late stage, who would hear objections to the identified hazards, when construction of the plant is already a done deal? Even then, can we trust that the plan outlined by that document is a solid and executable one?
Shell’s defense of the Beaver County plant is quick to point out differences between other plants and the one to come, making the case that technical advances will result in safety improvements. But it is noteworthy that the U.S. Chemical Safety and Hazard Investigation Board attributes failures at the Williams Geismar plant, in part, to “the ineffective implementation of…process safety management programs… as well as weaknesses in Williams’ written programs themselves.” The Geismar explosion demonstrates some of the tangible hazards that communities experience in living near ethane cracker plants. It is worth noting that the proposed Beaver County facility will have about 2½ times more ethylene processing capacity than the Geismar plant had at the time of the 2013 explosion.
Opening the Floodgates
In an effort to expand our understanding of risk associated with the proposed Beaver County ethane cracker and the extent of related developments promised by industry leaders, FracTracker Alliance has constructed the below map. It shows the site of the Shell facility and nearby land marked by Beaver County as “abandoned” or “unused.” These land parcels are potential targets for future build-out of associated facilities. Two “emergency planning zones” are indicated—a radius of 2 miles and a radius of 5 miles from the perimeter of Shell’s site. These projections are based upon FracTracker’s discussions with officials at the Saint Charles Parish Department of Homeland Security and Emergency Preparedness, who are responsible for emergency planning procedures in Norco, Louisiana, the site of another Shell ethane cracker facility. The emergency zones are also noted in the 2015 Saint Charles Hazard Mitigation Plan.
Also shown on the map is an estimated route of the Falcon pipeline system Shell intends to build, which will bring ethane from the shale gas fields of Ohio and Pennsylvania. Note that this is an estimated route based on images shown in Shell’s announcement of the project. Finally, our map includes resources and sites of vulnerability, including schools, fire stations, and hospitals. The importance of these sites will be discussed in the next article of this series.
While the site of the Shell cracker is worth attending to, it would be a mistake to limit assessments of disaster risk to the site of the facility alone. Shell’s proposed plant is but one component in a larger plan to expand ethane-based processing and use in the region, with the potential to rival the Gulf Coast as a major U.S. petrochemical hub. An upcoming conference on petrochemical construction in the region, scheduled for June 2017 in Pittsburgh, shows the industry’s commitment to further development. These associated facilities (from plants producing fertilizers to plastics) would utilize their own mix of chemicals, and their potential interactions would produce additional, unforeseen hazards. Ultimately, a cumulative impact assessment is needed, and should take into account these promised facilities as well as existing resources and vulnerabilities. The below Google Earth window gives a sense of what this regional build-out might look like.
What might an ethane cracker and related petrochemical facilities look like in Beaver County? For an idea of the potential build-out, take a tour of Norco, Louisiana, which includes Shell-owned petrochemical facilities.
As discussed in the introduction, “hazard,” “vulnerability,” and “capacity” are the elements of the formula that, in turn, exacerbate or mitigate disaster risk. While much of this article has focused on drastic “hazards,” such as disastrous explosions or unplanned chemical releases, these should not overshadow the more commonplace public health threats associated with petrochemical facilities, such as detrimental impact on air quality and the psychological harm of living under the looming threat of something going wrong.
The second and third articles in this series will dig deeper into “vulnerability” and “capacity.” These terms remind us of the needs and strengths of the community in question, but also that there is a community in question.
Formulas, terminology, and calculations should not obscure the fact that people’s lives are in the balance. The public should not be satisfied with preliminary and incomplete risk assessments when major documents that should detail the disaster implications of the ethane cracker are not yet available, as well as when the full scale of future build-out in the area remains an unknown.
Much gratitude to Lisa Graves-Marcucci and Lisa Hallowell of the Environmental Integrity Project for their expertise and feedback on this article.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/02/ethane-cracker-hazards-1-header.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgFracTracker Alliance2017-02-08 13:30:042020-03-12 16:05:27A Formula for Disaster: Calculating Risk at the Ethane Cracker
FracTracker Alliance studies, maps, and communicates the risks of oil and gas development to protect our planet and support the renewable energy transformation.