The Captina Creek Watershed straddles the counties of Belmont and Monroe in Southeastern Ohio and feeds into the Ohio River. It is the highest quality watershed in all of Ohio and a great examples of what the Ohio River Valley’s tributaries once looked, smelled, and sounded like. Sadly, today it is caught in the cross-hairs of the oil and gas industry by way of drilling, massive amounts of water demands, pipeline construction, and fracking waste production, transport, and disposal. The images and footage presented in the story map below are testament to the risks and damage inherent to fracking in the Captina Creek watershed and to this industry at large. Data included herein includes gas gathering and interstate transmission pipelines like the Rover, NEXUS, and Utopia (Figure 1), along with Class II wastewater injection wells, compressor stations, unconventional laterals, and freshwater withdrawal sites and volumes.
The image at the top of the page captures my motivation for taking a deeper dive into this watershed. Having spent 13+ years living in Vermont and hiking throughout The Green and Adirondack Mountains, I fell in love with the two most prominent tree species in this photo: Yellow Birch (Betula alleghaniensis) and Northern Hemlock (Tsuga candadensis). This feeling of being at home was reason enough to be thankful for Captina Creek in my eyes. Seeing this region under pressure from the oil and gas industry really hit me in my botanical soul. We remain positive with regards to the area’s future, but protective action against fracking in the Captina Creek Watershed is needed immediately!
Fracking in the Captina Creek Watershed: A Story Map
In March of 2019, two and a half years after Shell Pipeline Co. announced plans for the Falcon Ethane Pipeline System, the imported pipes arrived at the Port of Philadelphia. As tree clearing and construction begins, we share frustration with residents that the project is underway while many of our concerns remain unaddressed.
Between 2010 and 2018, over 280 pipeline incidents were reported in Ohio, West Virginia, and Pennsylvania (the three states the Falcon crosses). Of those incidents, 70 were fires and/or explosions. As regulatory agencies and operators fail to protect the public, communities are taking the reins.
Residents of southwest PA gather along the Falcon route
These grassroots efforts are contributing to a shift in public perception about the safety and need of pipelines. In some cases, including with the Northeast Energy Direct Pipeline and the Constitution Pipeline, organizing efforts are helping stop projects before they begin.
We invite all residents along the Falcon route to get involved in ongoing efforts to monitor construction. Below, you’ll find a guide to reporting violations as well as high-risk areas along the Falcon route that require close monitoring.
Be a citizen watchdog
Taking photos of pipeline development and recording your observations is a great way to monitor impacts. One tool to use while monitoring is the FracTracker mobile app (search “FracTracker” in the App Store or Google Play to download for free). The app allows the public to submit geolocated photos and descriptions of development, such as pipelines and wells, and concerns, such as spills and noise pollution. These reports help FracTracker crowdsource data and alert us to concerns that need follow up action. The app also contains a map of wells, pipelines, and compressor stations, including the Falcon pipeline route for reference in the field.
Click on the images below to view app reports of Falcon construction.
During the construction phase, incidents often occur when companies cause erosion of the ground and release sediment, equipment, or discharge into waterways. Mountain Watershed Association and Clean Air Council have provided the following information on the process of looking for and documenting violations.
Step 1) Document baseline conditions. Documenting the pre-construction status of an area is crucial for understanding how it’s been impacted down the road. Document baseline conditions by taking photos, videos, and notes at different sites, and include the location and date on these materials (the Fractracker app does this for you automatically). Observing sites at different times and in different weather (such as during or after a storm) will give you the best data.
Step 2) Know what to look for. Below are images and descriptions of common construction violations.
4) Contact support organizations. There are several organizations ready to take action once violations have been confirmed. For confirmed violations in Beaver County, PA, contact Alex Bomstein, at the Clean Air Council (215-567-4004 x118) and for confirmed violations in Allegheny or Washington Counties, PA, contact Melissa Marshall at the Mountain Watershed Association (724-455-4200 x7#). For violations in Ohio or West Virginia, reach out to FracTracker (412-802-0273).
Reports made on the FracTracker App are shared with any app user and the FracTracker team, who look through the reports and contact users for any required follow up. App reports can also be submitted to regulatory agencies electronically. Simply visit the web version of the app, click on your report, and copy the URL (web address) of your report. Then “paste” it into the body of an email or online complaint form. The receiver will see the exact location, date, and any notes or photos you included in the report.
Where should you be monitoring?
Monitoring efforts must be limited to publicly accessible land. In general, areas that are most at-risk for environmental impact include stream and wetland crossings, steep slopes (particularly those near water crossings), flood-prone zones, and areas where storm water runoff will reach waterways. View a map of the Falcon’s water crossings here, and continue reading for more vulnerable locations to monitor.
The information below identifies high-risk areas along the pipeline route where monitoring efforts are extra necessary due to their impacts on drinking water, wetlands, undermined areas, and vulnerable species.
We found 240 private water wells within 1/4 mile of the Falcon.
While all of these wells should be assessed for their level of risk with pipeline construction, the subset of wells nearest to horizontal directional drilling (HDD) sites deserve particular attention. HDD is a way of constructing a pipeline that doesn’t involve digging a trench. Instead, a directional drilling machine is used to drill horizontally underground and the pipe is pulled through.
While an HDD is designed to avoid surface impacts, if rushed or poorly executed, it can damage surface water, groundwater, and private property. The Mariner East 2 pipeline construction left several families without water after construction crews punctured an aquifer at an HDD site.
Shell’s data highlights 24 wells that are within 1,000 feet of a proposed HDD site.
We’ve isolated the groundwater wells and HDDs in a standalone map for closer inspection below. The 24 most at-risk wells are circled in blue.
Testing your groundwater quality before construction begins is crucial for determining impacts later on. Two upcoming workshops in Washington County, PA and another in Beaver County, PA will discuss how to protect your water and property.
The Falcon’s HDD locations offer disturbing similarities to what caused the Mariner East pipeline spills. Many of Sunoco’s failures were due to inadequately conducted (or absent) geophysical surveys that failed to identify shallow groundwater tables, which then led to drilling mud entering streams and groundwater.
Figure 1 below shows Greene Township, Beaver County, just south of Hookstown, where the “water table depth” is shown. The groundwater at this HDD site averages 20ft on its western side and only 8ft deep on the eastern side.
Figure 1. Water table depth in Greene Township
The Falcon also crosses the headwaters of two drinking water reservoirs: the Tappan Reservoir in Harrison County, OH (Figure 2) and the Ambridge Reservoir in Beaver County, PA (Figure 3). The Falcon will also cross the raw water line leading out of the Ambridge Reservoir.
The Ambridge Reservoir supplies water to five townships in Beaver County (Ambridge, Baden, Economy, Harmony, and New Sewickley) and four townships in Allegheny County (Leet, Leetsdale, Bell Acres & Edgeworth). The Tappan Reservoir is the primary drinking water source for residents in Scio.
Figure 2. Tappan Reservoir and the Falcon route in Harrison County, Ohio
Figure 3. Ambridge Reservoir and the Falcon route in Beaver County, Pennsylvania
Wetlands that drain into Raccoon Creek in Beaver County, PA will be particularly vulnerable in 2 locations. The first is in Potter Township, off of Raccoon Creek Rd just south of Frankfort Rd, where the Falcon will run along a wooded ridge populated by half a dozen perennial and intermittent streams that lead directly to a wetland, seen in Figure 4. Complicating erosion control further, Shell’s survey data shows that this ridge is susceptible to landslides. This area is also characterized by the USGS as having a “high hazard” area for soil erosion.
Figure 4. Wetlands and streams in Potter Township, PA
The other wetland area of concern along Raccoon Creek is found in Independence Township at the Beaver County Conservation District (Figure 5). Here, the Falcon will go under the Creek using HDD (highlighted in bright green). Nevertheless, the workspace needed to execute the crossing is within the designated wetland itself. An additional 15 acres of wetland lie only 300ft east of the crossing but are not accounted for in Shell’s data. This unidentified wetland is called Independence Marsh, considered the crown jewel of the Independence Conservancy’s watershed stewardship program.
Figure 5. Wetlands and Raccoon Creek in Independence Township, PA
Shell’s analysis shows that 16.8 miles of the Falcon pipeline travel through land that historically has or currently contains coal mines. Our analysis using the same dataset suggests the figure is closer to 20 miles. Construction through undermined areas poses a risk for ground and surface water contamination and subsidence.
Of these 20 miles of undermined pipeline, 5.6 miles run through active coal mines and are located in Cadiz Township, OH (Harrison Mining Co. Nelms Mine, seen in Figure 6); Ross Township, OH (Rosebud Mining Co. Deep Mine 10); and in Greene Township, PA (Rosebud Mining Co. Beaver Valley Mine).
Figure 6. Coal mines and are located in Cadiz Township, OH
More than 25 of the Falcon’s 97 pipeline miles will be laid within karst landscapes, including 9 HDD sites. Karst is characterized by soluble rocks such as limestone prone to sinkholes and underground caves. A cluster of these are located in Allegheny and Washington counties, PA, with extensive historical surface mining operations.
The combination of karst and coal mines along Potato Garden Run, in Figure 7, make this portion of the pipeline route particularly risky. At this HDD site, the Falcon will cross a coal waste site identified in the permits as “Imperial Land Coal Slurry” along with a large wetland.
Figure 7. Coal mines in Imperial, Pennsylvania
Southern Redbelly Dace
The Southern Redbelly Dace, a threatened species, is especially vulnerable to physical and chemical (turbidity, temperature) changes to their environment. PA Fish and Boat Commission explicitly notes in their correspondence with Shell that “we are concerned about potential impacts to the fish, eggs and the hatching fry from any in-stream work.” Of note is that these sites of concern are located in designated “High Quality/Cold Water Fishes” streams of the Service Creek watershed (Figure 8). PFBC stated that that no in-stream work in these locations should be done between May 1 and July 31.
Figure 8. “High Quality/Cold Water Fishes” streams identified as habitat for the Southern Redbelly Dace
Northern Harriers & Short-Eared Owls
Portions of the Falcon’s workspace are located near 6 areas with known occurrences of Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species). Pennsylvania Game Commission requested a study of these areas to identify breeding and nesting locations, which were executed from April-July 2016 within a 1,000-foot buffer of the pipeline’s workspace (limited to land cover areas consisting of meadows and pasture). One Short-eared Owl observation and 67 Northern Harrier observations were recorded during the study. PGC’s determined that, “based on the unusually high number of observations at these locations” work should not be done in these areas during harrier breeding season, April 15 through August 31.
Figure 9. Surveyed areas for Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species)
A known Bald Eagle nest is located in Beaver County. Two potential “alternate nests” are located where the Falcon crosses the Ohio River. National Bald Eagle Management Guidelines bar habitat disturbances that may interfere with the ability of eagles to breed, nest, roost, and forage. The 1 active nest in close proximity to the Falcon, called the Montgomery Dam Nest, is located just west of the pipeline’s terminus at Shell’s ethane cracker facility.
U.S. Fish and Wildlife Service requested that Shell only implement setback buffers for the one active nest at Montgomery Dam (Figure 10). These include no tree clearing within 330 feet, no visible disturbances with 660 feet, and no excessive noise with 1,000 feet of an active nest. Furthermore, Shell must avoid all activities within 660ft of the nest from January 1st to July 31st that may disturb the eagles, including but not limited to “construction, excavation, use of heavy equipment, use of loud equipment or machinery, vegetation clearing, earth disturbance, planting, and landscaping.
Figure 10. Bald Eagle nest in Potter Township, Pennsylvania
The Falcon is located within the range of federally protected Indiana Bats and Northern Long-eared Bats in Pennsylvania and West Virginia. In pre-construction surveys, 17 Northern Long-eared Bats were found at 13 of the survey sites, but no Indiana Bats were captured.
A total of 9 Northern Long-eared Bat roost trees were located, with the nearest roost tree located 318 feet from the pipeline’s workspace. Figure 11 below shows a cluster of roost trees in Raccoon Township, PA. For a map of all the roost trees, click here. The U.S. Fish and Wildlife Service stated that “Due to the presence of several Northern Long-eared Bat roost trees within the vicinity of the project footprint (although outside of the 150-foot buffer), we recommend the following voluntary conservation measure: No tree removal between June 1 and July 31.”
The Pennsylvania Game Commission noted in early correspondences that Silver-haired Bats may be in the region (a PA species of special concern). PGC did not require a further study for the species, but did request a more restrictive conservation of no tree clearing between April 1 and October 31.
Figure 11. Northern long-eared bat roost trees in Raccoon Township, Pennsylvania
For more information on the wildlife impacts of the Falcon Pipeline, click here.
By documenting the impacts of the Falcon Pipeline, you’re contributing to a growing body of work that shows the risks of fossil fuel pipelines. Not only does this evidence protect drinking water and vulnerable species, it serves as evidence against an inherently dangerous project that will contribute to climate change and the global plastics crisis.
We hope you’re inspired to take action and add your voice to a growing team in the region committed to safer and healthier environments. Thank YOU for your dedication to the cause!
By Erica Jackson, Community Outreach and Communications Specialist, FracTracker Alliance.
Portions of this article were adapted from previous posts in the Falcon Public EIA Project, written by Kirk Jalbert.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/05/PipelineConstructionFeature.png9102048Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2019-05-08 08:27:302020-03-12 14:43:14The Falcon Public Monitoring Project
Contact: Lee Ziesche, email@example.com, 954-415-6282
Interactive Map Shows Expansion of Fracked Gas Infrastructure in New York State
And showcases powerful community resistance to it
New York, NY – A little over a year after 55 New Yorkers were arrested outside of Governor Cuomo’s door calling on him to be a true climate leader and halt the expansion of fracked gas infrastructure in New York State, grassroots advocates Sane Energy Project re-launched the You Are Here (YAH) map, an interactive map that shows an expanding system of fracked infrastructure approved by the Governor.
“When Governor Cuomo announced New York’s climate goals in early 2019, it’s clear there is no room for more extractive energy, like fossil fuels.” said Kim Fraczek, Director of Sane Energy Project, “Yet, I look at the You Are Here Map, and I see a web of fracked gas pipelines and power plants trapping communities, poisoning our water, and contributing to climate change.”
Sane Energy originally launched the YAH map in 2014 on the eve of the historic People’s Climate March, and since then, has been working with communities that resist fracked gas infrastructure to update the map and tell their stories.
“If you read the paper, you might think Governor Cuomo is a climate leader, but one look at the YAH Map and you know that isn’t true. Communities across the state are living with the risks of Governor Cuomo’s unprecedented buildout of fracked gas infrastructure,” said Courtney Williams, a mother of two young children living within 400 feet of the AIM fracked gas pipeline. “The Governor has done nothing to address the risks posed by the “Algonquin” Pipeline running under Indian Point Nuclear Power Plant. That is the center of a bullseye that puts 20 million people in danger.”
Fracked gas infrastructure poses many of the same health risks as fracking and the YAH map exposes a major hypocrisy when it comes to Governor Cuomo’s environmental credentials. The Governor has promised a Green New Deal for New York, but climate science has found the expansion of fracking and fracked gas infrastructure is increasing greenhouse gas emissions in the United States.
“The YAH map has been an invaluable organizing tool. The mothers I work with see the map and instantly understand how they are connected across geography and they feel less alone. This solidarity among mothers is how we build our power ,” said Lisa Marshall who began organizing with Mothers Out Front to oppose the expansion of the Dominion fracked gas pipeline in the Southern Tier and a compressor station built near her home in Horseheads, New York. “One look at the map and it’s obvious that Governor Cuomo hasn’t done enough to preserve a livable climate for our children.”
“Community resistance beat fracking and the Constitution Pipeline in our area,” said Kate O’Donnell of Concerned Citizens of Oneonta and Compressor Free Franklin. “Yet smaller, lesser known infrastructure like bomb trucks and a proposed gas decompressor station and 25 % increase in gas supply still threaten our communities.”
The YAH map was built in partnership with FracTracker, a non-profit that shares maps, images, data, and analysis related to the oil and gas industry hoping that a better informed public will be able to make better informed decisions regarding the world’s energy future.
“It has been a privilege to collaborate with Sane Energy Project to bring our different expertise to visualizing the extent of the destruction from the fossil fuel industry. We look forward to moving these detrimental projects to the WINS layer, as communities organize together to take control of their energy future. Only then, can we see a true expansion of renewable energy and sustainable communities,” said Karen Edelstein, Eastern Program Coordinator at Fractracker Alliance.
Throughout May and June Sane Energy Project and 350.org will be traveling across the state on the ‘Sit, Stand Sing’ tour to communities featured on the map to hold trainings on nonviolent direct action and building organizing skills that connect together the communities of resistance.
“Resistance to fracking infrastructure always starts with small, volunteer led community groups,” said Lee Ziesche, Sane Energy Community Engagement Coordinator. “When these fracked gas projects come to town they’re up against one of the most powerful industries in the world. The You Are Here Map and ‘Sit, Stand Sing’ tour will connect these fights and help build the power we need to stop the harm and make a just transition to community owned renewable energy.”
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/04/YouAreHereMap2.png8191843Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgGuest Author2019-04-24 15:49:052020-03-12 14:43:43Release: The 2019 You Are Here map launches, showing New York’s hurdles to climate leadership
Although the vast majority of scientists agree that we must rapidly move away from fossil fuels to avoid a human-caused climate catastrophe by the end of this century, pipeline construction remains a big business.
Pipelines are the backbone of domestic fossil fuel use and for delivering fuels to terminals for international export. Yet aside from a few high-profile pipeline controversies that show up in the media, few Americans are aware of the vast network of pipelines that transport oil and gas products from sources of extraction to industry and end-use consumers.
The United States is crisscrossed by over 1.63 million miles of fossil fuel pipelines. This includes:
Many of the country’s pipelines have been built within the last few decades, and in recent years, construction of more has been spurred on by the fracking boom. The total mile count of crude oil pipelines (currently 79,000) has increased over 60% between 2004 and 2017. Natural gas distribution and estimated service pipeline miles increased 72% between 1984 and 2017 (Figure 1).
When natural gas is imported or exported, it’s transported in a liquefied form. The product occupies much less space as a liquefied natural gas (LNG) than it does in its gaseous form, making it easier to transport.
For many years, the United States was an importer of natural gas, until 2007, when this trend quickly reversed, coinciding with the “fracking boom” in the Marcellus Shale, as well as several other shale plays in Texas, Wyoming, and elsewhere.
LNG facilities store and process natural gas to help move it between markets. Between 2010 and 2017, the number of LNG facilities increased from 122 to 152 (includes LNG storage facilities). This nearly 25% increase reflects the surplus of natural gas in the lower 48 states.
The U.S. began exporting LNG in 2016, especially to Europe and China, where demand is high. According to the United States Energy Information Administration (EIA), LNG exports doubled between 2016 and 2017 (Figure 5).
Exports are again expected to double over 2018 levels by the end of 2019, reaching a storage capacity of 9.6 billion cubic feet per day. The US is now the third largest exporter of LNG, after Australia and Qatar.
The breakdown of LNG terminals —existing and future— according to FERC is shown below. These terminals receive LNG imports or ship out LNG for export. The shift from LNG import to export activity over time is quite striking. No new import facilities are currently in the planning phase, yet there are 19 export facilities proposed and another 10 already approved.
Table 1. Import and Export LNG Terminals in the US: Current, Approved, and Proposed.
19: Pascagoula, MS; Cameron Parish, LA (2); Brownsville, TX (3); Port Arthur, TX; Jacksonville, FL; Plaquemines Parish, LA (2); Calcasieu Parish, LA; Nikiski, AK; Freeport, TX; Coos Bay, OR; Corpus Christi, TX; La Fourche Parish, LA; Sabine Pass, LA; Galveston Bay, TX
The challenge of keeping up
One of the challenges in working on oil and gas-related environmental advocacy is that from week to week, there are always changes in pipeline status. New pipelines are announced, others are delayed, others are postponed, and in some cases, projects are cancelled or defeated. Pipelines that have been under construction for years go on line. Listings are piece-meal, sometimes very vague, and sometimes reported by third and fourth party sources.
FracTracker is committed to sorting through this information, and providing a window into the expansion of oil and gas infrastructure. We have mapped and assembled information on over 60,000 miles of new and proposed oil and gas transmission pipelines and mapped over 250 projects since 2017.
Of these 60,000 pipeline miles, almost 9,800 have been completed and/or are operating. Close to 7,500 miles were cancelled or defeated. This leaves another 42,700 miles of pipeline that are currently in the replacement, reversal, planning or construction stages.
In the interactive map below, against a background of existing pipelines, we show the newest pipelines that have come “on the radar” since 2017. In addition we show LNG terminals, one of the main destinations for the gas that flows through the pipelines to the export market.
FracTracker is dedicated to bringing transparency to the landscape of oil and gas development. We use mapping tools such as GIS (geographic information systems) to illuminate developments in oil and gas infrastructure expansion.
After we create a composite list of pipelines, the research begins. We search the internet for references to each pipeline, looking for industry announcements, descriptions, news articles, and, most importantly, the docket listings of the Federal Energy Regulatory Commission (FERC).
FERC may release detailed maps of pipeline routes from the company’s Environmental Impact Statement (EIS), filed after operators have progressed past the initial phases of planning. On occasion, we’ll stumble across links to Google Earth files that grassroots groups have ground-truthed. We can convert these .kml files into our ArcGIS mapping software directly.
How do we go from online pictures of maps to data that we can use in our interactive maps? For the most part, we use a process called georeferencing, also known in some circles as “rubber-sheeting”. One of the beauties of digital cartography and GIS is that through the magic of computing, we can add information about location to mapped information. This allows us to add different features to a map, such as roads or rivers, and ensure that they line up correctly.
Let’s say I have a .jpg (image) file of a pipeline map that crosses four counties in Indiana. The .jpg shows both the pipeline and the county boundaries. I can open my GIS program and add a reference basemap of the United States, which is similar to what you see when you open Google Maps. I can zoom in to Indiana and add a second GIS layer of Indiana’s counties (already built with coordinates in the digital information), and voila! It drops right into where Indiana is on my base map. Can I do this with the pipeline .jpg? Not yet!
I have to use the clues on the pipeline image to place it in the correct location on the GIS map. Luckily, my pipeline map has county boundaries on it, so I can line up the corners (or other shapes) on the pipeline image to where they are on my map that is “smart” about location using ground control points.
Once I’m satisfied that the map I’ve added is in the correct location, I carefully trace the path of the pipeline, saving it as a GIS layer. Because it’s drawn with its own location data included, it will always appear in future maps in the same place relative to the rest of Indiana.
That’s our process in a nutshell.
Want to see this done as a demo? Here’s a nice 10-minute YouTube video:
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/02/PipelineConstructionPA.png400900Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgKaren Edelstein2019-02-28 19:24:532020-03-12 14:40:49The Growing Web of Oil and Gas Pipelines
Roughly half of the homes in America use gas for providing heat, hot water or powering appliances. If you use gas in your home, you know that leaks are bad – they waste money, they pollute the air, and, if exposed to a spark, they could spell disaster.
Our homes, however, are only the end point of a vast production and transportation system that brings gas through a network of pipelines all the way from the wellhead to our kitchens. There are opportunities for wasteful and often dangerous leaks all along the way – leaks that threaten the public’s health and safety and contribute to climate change.
How frequent are gas leaks?
Between January 2010 and November 2018, there were a reported 1,888 incidents that involved a serious injury, fatality or major financial loss related to gas leaks in the production, transmission and distribution system, according to data from the Pipeline and Hazardous Materials Safety Administration. These incidents caused 86 deaths, 487 injuries and over $1 billion in costs.
When gas lines leak, rupture, or are otherwise damaged, the gas released can explode, sometimes right in our own backyards. Roughly one in seven of the incidents referenced above – 260 in total – involved an explosion.
In September 2018, for example, a series of explosions in three Massachusetts communities caused one death, numerous injuries and the destruction of as many as 80 homes. And there are many more stories like it from communities across the U.S. From the 2010 pipeline rupture and explosion in San Bruno, California, that killed eight people and destroyed almost 40 homes to the 2014 disaster in New York City that destroyed two five-story buildings and killed eight people, these events serve as a powerful reminder of the danger posed by gas.
The financial and environmental costs
Gas leaks are also a sheer waste of resources. While some gas is released deliberately in the gas production process, large amounts are released unintentionally due to malfunctioning equipment, corrosion and natural causes like flooding. The U.S. Energy Information Administration estimates that 123,692 million cubic feet of gas were lost in 2017 alone, enough to power over 1 million homes for an entire year. That amount is likely an underestimate. On top of the major leaks reported to the government agency in charge of pipeline safety, many of our cities’ aging gas systems are riddled with smaller leaks, making it tricky to quantify just how much gas is lost from leaks in our nation’s gas system.
Leaks also threaten the stability of our climate because they release large amounts of methane, the main component of gas and a potent greenhouse gas. Gas is not the “cleaner” alternative to coal that the industry often makes it out to be. The amount of methane released during production and distribution is enough to reduce or even negate its greenhouse gas advantage over coal. The total estimated methane emissions from U.S. gas systems have roughly the same global warming impact over a 20-year period as all the carbon dioxide emissions from U.S. coal plants in 2015 – and methane emissions are likely higher than this amount, which is self-reported by the industry.
In most states, there is no strong incentive for gas companies to reduce the amount of leaked gas because they can still charge customers for it through “purchased gas adjustment clauses.” These costs to consumers are far from trivial. Between 2001 and 2011, Americans paid at least $20 billion for gas that never made it to their homes.
These and other dangers of gas leaks are described in a recent fact sheet by U.S. PIRG Education Fund and Frontier Group. At a time when climate change is focusing attention on our energy system, it is critical that communities understand the full range of problems with gas – including the ever-present risk of leaks in the extensive network of infrastructure that brings gas from the well to our homes.
We should not be using a fuel that endangers the public’s safety and threatens the stability of our climate. Luckily, we don’t have to. Switching to electric home heating and hot water systems and appliances powered by renewable energy would allow us to move toward eliminating carbon emissions from homes. Electric heat pumps are twice as efficient as gas systems in providing heat and hot water, making them a viable and commonsense replacement. Similarly, as the cost of wind and solar keep falling, they will continue to undercut gas prices in many regions.
It’s time to move beyond gas and create a cleaner, safer energy system.
By Meryl Compton, policy associate with Frontier Group, a non-profit think tank part of The Public Interest Network. She is based in Denver, Colorado.
Feature image at top of page shows San Bruno, California, following the 2010 pipeline explosion
Pittsburgh, PA – Yesterday, the Pennsylvania Department of Environmental Protection (DEP) announced their decision to issue a permit for the construction of Shell’s Falcon ethane pipeline project in southwest PA. FracTracker Alliance is extremely disappointed that DEP is allowing this project to proceed despite heavy opposition from the public and unaddressed concerns for the safety and well-being of nearby residents and the surrounding environment.
The past year has seen countless issues from the construction of new pipelines in the Commonwealth – from hundreds of “inadvertent returns,” (spills of bentonite drilling mud) along the path of the Mariner East II project to the catastrophic explosion of the week-old Revolution Pipeline in Beaver County. These reoccurring and serious incidents make it clear that oil and gas midstream companies are rushing to put infrastructure in place, and DEP and other regulatory agencies have been failing in their mission to adequately supervise the process.
According to data from the US Pipeline and Hazardous Materials Safety Administration, there were 108 pipeline incidents in Pennsylvania between January 2010 and mid-July 2018, resulting in 8 fatalities, 15 injuries, requiring over 1,100 people to be evacuated from their homes, and causing more than $66 million in property damage. This track record, which does not include the Revolution Pipeline explosion in September of 2018, is frankly unacceptable.
Certainly, the Commonwealth has invested heavily in the Shell Ethane Cracker facility, offering steep tax subsidies and even paying the global petrochemical giant $2.10 for every barrel of ethane it consumes from Pennsylvania wells, equivalent to $1.6 billion over the next 25 years. It appears to FracTracker that these business arrangements have made the continued extraction and exploitation of hydrocarbons the priority for DEP, not protecting the environment and health and safety of Pennsylvanians, as the mission of the Department suggests is their focus. DEP’s decision also traces an unfortunate pattern of opaqueness and poor timing by announcing unpopular decisions right before the holidays.
Fundamentally, oil and gas companies like Shell exist to make profits, and will therefore make decisions to maximize earnings and limit their costs, if left to their own devices. This approach is often directly at odds with public safety, so Pennsylvania entrusts DEP to oversee the operations. FracTracker feels that with their decision to move forward with the project on December 20, 2018, DEP brushed over dozens of substantial concerns regarding the Falcon ethane pipeline project, and therefore failed in this mission. We remain unconvinced that the “appropriate construction techniques and special conditions” required by DEP will adequately protect the environment and health and safety of residents along the Falcon pipeline route.
Dec. 21st Update: After this article was written, FracTracker learned that Ohio’s EPA issued an air quality permit for the cracker plant in Belmont County, Ohio on December 21st. The short public comment period and the rush to issue permits again illustrates that significant public health and environmental concerns are given minimal importance versus corporate wishes and political expediency. The regulatory paradigm is broken. The public has been ill served by the agencies entrusted to safeguard their interests. A collective regional voice should be raised in protest.
Started in 2010 as a southwestern Pennsylvania area website, FracTracker Alliance is now a national organization with regional offices across the United States in Pennsylvania, Washington DC, New York, Ohio, and California. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Its goal is to support advocacy groups at the local, regional and national level, informing their actions to positively shape our nation’s energy future. www.fractracker.org
Learn more about FracTracker’s coverage of the Falcon ethane pipeline project by exploring the posts below:
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 recent years, Pennsylvanians have had to endure numerous massive pipeline projects in the Commonwealth. Some of these, such as the Mariner East 2, the Revolution, and the Atlantic Sunrise, have been beset with continuous problems. In fact, both the Mariner East 2 and the Revolution projects had their operations suspended in 2018. The operators have struggled to grapple with a variety of issues – ranging from sinkholes near houses, erosion and sediment issues, hundreds ofbentonite spillsinto the waters and upland areas of Pennsylvania, and more.
Part of the reason for the recent spate of incidents is the fact that so many pipelines are being built right now. These lines are traversing through undermined areas and land known to have underground karst formations, which are prone to subsidence and sinkholes. With more than 90,000 miles of pipelines and 84,000 miles of streams in Pennsylvania, substantial erosion and runoff issues are unfortunately quite common.
Map of pipeline routes in southwestern PA, various pipeline incidents, and karst formations:
Click here to learn more about recent pipeline incidents in Pennsylvania, along with how users of the FracTracker App have helped to chronicle problems associated with them.
Residents keeping track
Many residents have been trying to document issues in their region of Pennsylvania for a long time. Any pipeline incident should be reported to the Department of Environmental Protection (DEP), but in some instances, people want other residents to know and see what is going on, and submission to DEP does not allow for that. FracTracker’s Mobile App allow users to submit a detailed report, including photographs, which are shared with the public. App users have submitted more than 50 photographs of pipelines in Pennsylvania, including these images below.
The FracTracker Mobile App uses crowd-sourced data to document and map a notoriously nontransparent industry. App users can also report violations, spills, or whatever they find striking. For example, the first image shows construction of the Mariner East 2 in extreme proximity to high density housing. While regulators did approve this construction, and it is therefore not a violation, the app user wanted others to see the impact to nearby residents. Other photos do show incidents, such as the second photo on the second row, showing the sinkhole that appeared along the Mariner East 1 during the construction of the nearby Mariner East 2 pipeline.
Please note that app submissions are not currently shared with DEP, so if you happen to submit an incident on our app that you think they should know about, please contact their office, as well. The FracTracker Mobile App provides latitude and longitude coordinates to make it easier for regulators to find the issue in question.
Why have there been so many problems with pipelines in recent years?
Drillers in Pennsylvania’s Marcellus Shale and other unconventional formations predicted that they would find a lot of natural gas, and they have been right about that. However, the large resulting supply of natural gas from this industrial-scaled drilling is more than the region can use. As a result, gas prices remain low, making drilling unprofitable in many cases, or keep profit margins very low in others.
The industry’s solution to this has been two-pronged. First, there is a massive effort underway to export the gas to other markets. Although there are already more than 2.5 million miles of natural gas pipelines in the United States, or more than 10 times the distance from the Earth to the Moon, it was apparently an insufficient network to achieve the desired outcome in commodity prices. The long list of recent and proposed pipeline projects, complete with information about their status, can be downloaded from the Energy Information Administration (Excel format).
The industry’s other grand effort is to create demand for natural gas liquids (NGLs, mostly ethane, propane, and butane) that accompanies the methane produced in the southwestern portion of the state. The centerpiece of this plan is the construction of multiple ethane crackers, such as the one currently being built in Beaver County by Royal Dutch Shell, for the creation of a new plastics industry in northern Appalachia. These sites will be massive consumers of NGLs which will have to be piped in through pressurized hazardous liquid routes, and would presumably serve to lock in production of unconventional gas in the region for decades to come.
Are regulators doing enough to help prevent these pipeline development problems?
In 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) led the formation of an advisory group called Pipelines and Informed Planning Alliance (PIPA), comprised mostly of industry and various state and local officials. Appendix D of their report includes a long list of activities that should not occur in pipeline rights-of-way, from all-terrain vehicle use to orchards to water wells. These activities could impact the structural integrity of the pipeline or impede the operator’s ability to promptly respond to an incident and excavate the pipe.
However, we find this list to be decidedly one-directional. While the document states that these activities should be restricted in the vicinity of pipelines, it does not infer that pipelines shouldn’t be constructed where the activities already occur:
This table should not be interpreted as guidance for the construction of new pipelines amongst existing land uses as they may require different considerations or limitations. Managing land use activities is a challenge for all stakeholders. Land use activities can contribute to the occurrence of a transmission pipeline incident and expose those working or living near a transmission pipeline to harm should an incident occur.
Pipeline being constructed near a home
While we understand the need to be flexible, and we certainly agree that every measure should be taken by those engaging in the dozens of use types listed in the PIPA report, it equally makes sense for the midstream industry to take its own advice, and refrain from building pipelines where these other land uses are already in place, as well. If a carport is disallowed because, “Access for transmission pipeline maintenance, inspection, and repair activities preclude this use,” then what possible excuse can there be to building pipelines adjacent to homes?
What distance is far enough away to escape catastrophic failure in the event of a pipeline fire or blast?
This chart shows varying hazard distances from natural gas pipelines, based on the pipe’s diameter and pressure. Source: Mark J. Stephens, A Model for Sizing High Consequence Areas Associated with Natural Gas Pipelines
It turns out that it depends pretty dramatically on the diameter and pressure of the pipe, as well as the nature of the hydrocarbon being transported. A 2000 report estimates that it could be as little as a 150-foot radius for low-pressure 6-inch pipes carrying methane, whereas a 42-inch pipe at 1,400 pounds per square inch (psi) could be a threat to structures more than 1,000 feet away on either side of the pipeline. There is no way that the general public, or even local officials, could know the hazard zone for something so variable.
While contacting Pennsylvania One Call before any excavation is required, many people may not consider a large portion of the other use cases outlined in the PIPA document to be a risk, and therefore may not know to contact One Call. To that end, we think that hazard placards would be useful, not just at the placement of the pipeline itself, but along its calculated hazard zone, so that residents are aware of the underlying risks.
If there is an incident, it is obviously critical for operators to be able to respond as quickly as possible. In most cases, a part of this process will be shutting off the flow at the nearest upstream valve, thereby stopping the flow of the hydrocarbons to the atmosphere in the case of a leak, and cutting the source of fuel in the event of a fire. Speed is only one factor in ameliorating the problem, however, with the spacing between shutoff valves being another important component.
Comprehensive datasets on pipeline valves are difficult to come by, but in FracTracker’s deep dive into the Falcon ethane pipeline project, which is proposed to supply the Shell ethane cracker facility under construction Beaver County, we see that there are 18 shutoff valves planned for the 97.5 mile route, or one per every 5.4 miles of pipe. We also know that the Falcon will operate at a maximum pressure of 1,440 psi, and has pipe diameters ranging from 10 to 16 inches. The amount of ethane that could escape is considerable, even if Shell were able to shut the flow off at the valve instantly. It stands to reason that more shutoff valves would serve to lessen the impact of releases or the severity of fires and explosions, by reducing the flow of fuel to impacted area.
Groups promoting the oil and gas industry like to speak of natural gas development as clean and safe, but unless we are comparing the industry to something else that is dirtier or more dangerous, these words are really just used to provoke an emotional response. Even governmental agencies like PHMSA are using the rhetoric.
PHMSA’s mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives.
If the safe transportation of hazardous materials sounds oxymoronic, it should. Oil and gas, and related processed hydrocarbons, are inherently dangerous and polluting.
Gas Transmission / Gathering
Impacts of pipeline incidents in Pennsylvania from January 1, 2010 through July 13, 2018. National totals for the same time include 5,308 incidents resulting 125 fatalities, 550 injuries, 283 explosions, and nearly $4 billion in property damage.
Current investments in large-scale transmission pipelines and those facilitating massive petrochemical facilities like ethane crackers are designed to lock Pennsylvania into decades of exposure to this hazardous industry, which will not only adversely the environment and the people who live here, but keep us stuck on old technology. Innovations in renewable energy such as solar and wind will continue, and Pennsylvania’s impressive research and manufacturing capacity could make us well positioned to be a leader of that energy transformation. But Pennsylvania needs to make that decision, and cease being champions of an industry that is hurting us.
Industry, not deterred by resistance from regulators and environmentalists, has developed a new work-around method to get their product to market. Rather than build pipelines across rugged, remote, or highly-populated terrain, a new “solution” called “virtual pipelines” has come on the scene, with roots in New England in 2011.
The term “virtual pipeline,” itself, is so new that it is trademarked by Xpress Natural Gas (XNG), Boston, MA. XNG and other virtual pipeline companies use specially-designed tanker trucks to move compressed natural gas (CNG) or liquefied natural gas (LNG) via our public roads and highways. CNG in this system is under very high pressure — up to 3,600 psi when tank trailers are full. Rail and barge shipments are also considered part of the system, and trailers are designed to be easily loaded onto train cars or boats.
For the gas industry, virtual pipelines can be used in locales where gas is only needed for a limited time period, the pipeline network is not developed, or opposition by landowners is too contentious to make eminent domain an option, among other issues.
Restricted only by permissible weight limits on roads (up to 80,000 pounds or more), 5-axle trucks may make in excess of 100 round trips a day from the fueling location to their destination — sometimes hundreds of miles away. These trucks, which may travel alone or in caravans, are identifiable by the hazard class 2.1 placard they carry: 1971, indicative of flammable, compressed natural gas or methane. Manufacturers of these virtual pipeline rigs tout the safety considerations that go into their engineered design. These considerations include special pressure monitoring for the dozens of tanks and super-strength materials to protect against ruptures.
Specialized equipment has been created to load compressed gas tanks into the trailers that will carry them to their destinations. Here’s a promotional video from Quantum:
Loading CNG into specialized trailers for transport
Impacts on Communities
Following New York State’s rejection of the Constitution Pipeline in 2016 based on water quality concerns, industry has been looking for ways to move natural gas from Pennsylvania’s Marcellus gas fields to the Iroquois Pipeline. The current strategy is to load the gas in canisters from a special compressor facility, and re-inject the gas to a pipeline at the journey’s endpoint. The extent to which virtual pipelines may be utilized in New York State and New England is not well known, but the natural gas industry does speak in sanguine terms about this strategy as a solution to many of its transportation issues.
Citizen blogger/activist Bill Huston has compiled a list accidents that have occurred with CNG transport trucks along the virtual pipeline that runs from a “mother station” at Forest Lake, PA to Manheim, NY, near the Iroquois pipeline. While there have been no explosions or loss of life as a result of these accidents, there are a number of reported incidents of trucks tipping or rolling over, sliding off the road, or spontaneously venting.
To move CNG from “Point A” to “Point B,” truck traffic through populated areas is unavoidable. In central New York, public outcry about virtual pipelines is rising, due in large part to the safety issues associated with increased truck traffic on state highways. In rural New York, state highways run through towns, villages, and cities. They are not separated from population centers in the way that interstate highways typically are. Traffic from CNG transport trucks clogs roadways, in some cases burdening the pass-through communities with 100 or more tractor trailers a day. Routes pass directly in front of schools and health care facilities.
In short, virtual pipelines present a public safety hazard that has yet to be addressed.
Virtual Pipelines and the Cayuga Power Plant
In Lansing, NY, there is an inefficient and economically-beleaguered power plant, currently run on coal, that the power utility would prefer to see shut down. The Cayuga Power Plant was cited in 2016 for exceeding mercury emissions by nearly 2000%. Its inherently inefficient design makes it a significant greenhouse gas contributor. Years ago, it provided considerable tax benefits to its host community of Lansing, and as such has some lingering support. After both a devastating fire in one stack and mechanical failure in another, the plant has been barely running for the past 3 or 4 years. It is currently used as a “peaker plant“, operating only during periods of excessive demand on the electric grid, during summer months.
New York State’s Governor, Andrew Cuomo, has stated that all coal-power plants will be shut down by 2020.
Cayuga Power Plant in Lansing, NY.
Nonetheless, the plant owners are pushing to re-power the Cayuga Power Plant with natural gas. Currently, however, there is no pipeline to deliver the gas to the plant. Without support by the public nor the Public Service Commission for the construction of a supply pipeline, Cayuga Power Plant has revealed they plan to receive gas deliveries via truck.
FracTracker has modeled the five most likely scenarios that would take compressed natural gas from a loading station in northern Pennsylvania to the Cayuga Power Plant in Lansing. All of the scenarios bring the trucks through populated communities, in dangerous proximity to high-risk facilities where both human safety and evacuations are problematic. The routes also pass through intersections and road stretches that have some of the highest accident rates in the area.
Route 1: This route passes within a half mile of homes of 36,669 people in the Villages of Lansing, Candor, Spencer, Owego; Towns of Ithaca, Lansing, Newfield, Danby, Candor, Spencer, Tioga, Owego, Vestal; and the City of Ithaca. Within the half-mile evacuation zone of this route, should there be an accident, are:
17 health care facilities
20 day care centers
4 private school
21 public schools
Route 2: This route passes within a half mile of homes of 54,182 people in the Villages of Groton, Marathon, Whitney Point, Johnson City; Towns of Lansing, Dryden, Cortlandville, Groton, Virgil, Lapeer, Marathon, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and Cities of Cortland and Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
31 health care facilities
37 day care centers
3 private school
19 public schools
Route 3: This route passes within a half mile of homes of 39,638 people in the Villages of Dryden, Lisle, Whitney Point, Johnson City; Towns of Lansing, Dryden, Groton, Harford, Richford, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and the City of Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
17 health care facilities
23 day care centers
1 private school
14 public schools
Route 4: This route passes within a half mile of homes of 44,804 people in the Villages of Homer, Marathon, Whitney Point, Johnson City; Towns of Lansing, Summerhill, Locke, Genoa, Homer, Cortlandville, Virgil, Lapeer, Marathon, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and Cities of Cortland and Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
24 health care facilities
31 day care centers
2 private school
15 public schools
Route 5: This route passes within a half mile of homes of 59,731 people in the Villages of Lansing, Lisle, Whitney Point, Johnson City; Towns of Lansing, Dryden, Ithaca, Caroline, Richford, Lisle, Triangle, Barker, Chenango, Dickinson, Union, Vestal; and Cities of Ithaca and Binghamton. Within the half-mile evacuation zone of this route, should there be an accident, are:
26 health care facilities
37 day care centers
3 private school
21 public schools
Click on the tabs in the box above to explore the five potential truck routes with maps.
For a full interactive map of the potential routes for CNG delivery to the Cayuga Power Plant, and the schools, health care facilities, etc. within a half-mile evacuation zone of the routes, view the interactive map below.
Despite the apparent convenience that virtual pipelines present for the fossil fuel industry, they are not the solution the future energy supply needs. Yes, they present an alternative to pipeline transportation — but they also play a disastrous role in continuing our descent into climate chaos caused by increasing greenhouse gas concentrations in the atmosphere.
Methane leakage is an unavoidable component of the entire life cycle of natural gas usage — from “cradle to grave” — or more precisely, from the moment a well is drilled to when the gas is combusted by its end-user. And methane, as a greenhouse gas, is up to 100 times more potent than carbon dioxide. The Intergovernmental Panel on Climate Change’s (IPCC) recent report (see summary here) is unflinching in its clarion call for immediate, and extreme, cut-backs in greenhouse gas production. If we choose not to heed this call, much of humanity’s future survival is called into question.
More of the details about the Cayuga Power Plant will be explained in the upcoming weeks in a related guest blog by environmental activist and organizer, Irene Weiser, of Tompkins County, NY.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/10/VirtualPipelines-Feature-Map.png400900Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgKaren Edelstein2018-10-30 15:49:512020-03-12 14:57:13Virtual pipelines: Convenient for Industry, a Burden on Communities
In August 2016, Shell announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. In response to available data, FracTracker launched the Falcon Public EIA Project in January of 2018 to unearth the environmental and public health impacts of the proposed pipeline. As part of that project, today we explore Shell’s Chapter 105 application and the deficiencies the Pennsylvania Department of Environmental Protection (DEP) cited after reviewing Shell’s application.
Just a heads up… there are a lot.
Shell originally submitted a Chapter 105 application to the DEP to receive a permit for water obstruction and encroachment. The DEP began reviewing the application in January of 2018. On June 1st, they sent Shell technical deficiency letters listing several issues with the application. Shell responded to these deficiencies on August 1st.
Now, it’s up to the DEP to decide if Shell’s response is adequate, and if the department should go ahead and approve the application or require more work from Shell. Explore the technical deficiencies below for more information.
Below is a map that highlights several of the deficiencies the DEP found with Shell’s application and a brief explanation of each one. Expand the map full-screen to explore more layers – Some layers only become visible when you zoom in due to the level of detail they display.
Next, we’ll walk you through the technical deficiencies, which we have broken down into the following categories:
Wetlands, rivers, streams
Public health and safety (drinking water & trails)
Geological concerns (including mining issues)
A = Allegheny County, B = Beaver County, W = Washington County. The numbers reference the number listed in the deficiencies letter.
1. Wetlands, Rivers, & Streams
Water withdrawal from rivers and discharge
B2A2W2 The project will discharge waste water from an industrial activity to a dry swale, surface water, ground water, or an existing sanitary sewer system or separate storm water system. The DEP requested that Shell identify and describe this discharge, as the DEP’s Clean Water Program must authorize discharges. Shell stated that water will be discharged from hydrostatic testing, (which ensures a pipeline can withstand high pressure by pumping water through it to test for leaks), and a PAG-10 permit (needed for hydrostatic test water discharge) was submitted to the DEP July 27, 2018 with the locations of discharge. Drawings of the discharges are in Attachment O. (The locations of the discharges were not included in Shell’s public response to this deficiency.)
B33 A31 W31 Shell will be withdrawing water for hydrostatic testing. The DEP asked Shell to explain the intake and discharge methods so the DEP can decide if these should be included as impacts. The DEP also asked Shell to provide the location of intake and discharge. The DEP’s Clean Water Program must authorize discharges. In response, Shell stated that water will be withdrawn from Raccoon Creek and the Ohio River in West Virginia. The specific locations are listed in the PAG-10 permit, submitted to the DEP in July. Drawings of the discharges are included in Attachment O.
Wetlands and Streams
B5 A3 W4 The DEP asked Shell to identify the presence of wetlands within the project area that are identified by the US Fish & Wildlife Service’s National Wetlands Inventory (NWI) data system, and provide data on how they may be impacted by the proposed pipeline.Shell identified one NWI wetland in Beaver County, but did not delineate or provide information on it, due to safety concerns (it’s on a steep cliff). This wetland will be crossed via HDD (horizontal directional drill). In Allegheny County, there is an NWI wetland that Shell also did not provide data on. This wetland was not initially evident, and when staff returned to survey it, the property owner did not let them access the site becausethey did not want a pipeline on their property. According to Shell, this NWI wetland is not within the “Project’s Limit of Disturbance.” In Washington County, Shell stated that “all of the NWI-mapped wetlands that were determined not to be wetlands have been accounted for in Washington County. These NWI wetlands were all located in an area that had been previously strip-mined and due to mining activities, those wetlands are no longer there. Data were taken for these areas and included… separately as Attachment D.” Also in Washington County is an NWI wetland located above the Panhandle Trail, which Shell determined to be outside of the study area and therefore did not collect data on it. This wetland is not on the map, but Shell did provide this image of it.
B6 A4W5 The DEP requested that Shell match off-line wetland data with sampling point locations from study area maps. In response, Shell placed offline data sheets in the order that they are in Table 3 in the Wetlands Delineation Report and in Table 4 in the Watercourse Delineation Report.
B7 A5W6 Shell needed to discuss the types and conditions of riverine resources that the project impacts. Specifically, how the conditions of these resources relate to their hydrological functions, biogeochemical functions, and habitat attributes. These are discussed under question 7 for Beaver County, question 5 for Allegheny County, and question 6 for Washington County.
B8 A6 W7 Shell needed to discuss the types and conditions of wetlands that the project impacts. Specifically, how the conditions of these wetlands contribute to their hydrological functions, biogeochemical functions, and habitat attributes. Shell also needed to discuss impacts to wetlands that will be temporarily impacted, as it previously only discussed wetlands facing permanent impacts. These are discussed under question 8 for Beaver County, question 6 for Allegheny County, and question 7 for Washington County.
B9 A7 W8 The DEP asked Shell to evaluate the impact of open cut installation on wetlands with perched water tables and/or confining layers. Perched water tables have an impermeable confining layer (such as clay) between them and the main water table below. If open cut methods are used, the confining layer is destroyed and this water table will be lost. In Beaver County, Shell identified one wetland (W-PA-170222-MRK-002) will be open cut. If it is perched, Shell states it will replace the confining layer “along the same horizon during pipeline backfilling, and then [compact the layer] so that hydrology may be maintained.” Shell will also put trench plugs “on either side of the wetland on the ROW to prevent water from migrating out on the sides.” In Allegheny County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160401-MRK-006, W-PA-161220-MRK-001, and W-PA-161220-MRK-002.In Washington County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160407-JLK-002, W-PA-151203-MRK-005, and W-PA-151203-MRK-006.
A11 The DEP asked Shell to evaluate if any wetlands can be classified as “exceptional value” due to their proximity to nesting areas of the northern harrier (a threatened species in Pennsylvania). Wetlands are exceptional value if they serve as habitat for threatened or endangered species, or if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain habitat for the species in the wetland. Shell determined that there are six wetlands that could be nesting areas for northern harriers, and therefore are exceptional value (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003, W-PA-170207-MRK-001, W-PA-170113-MRK-008, W-PA-170113-MRK-001). Three of these wetlands are within the project’s LOD (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003).
B13 A10W11 The DEP asked Shell to evaluate whether the proposed Falcon Pipeline will impact wetlands that are of “exceptional value” based on their proximity to public water systems. Wetlands can be considered “exceptional value” if they are located along public or private drinking water supplies (surface or ground water), and help maintain the quality or quantity of the supply. Shell stated that the (potentially man made) ponds near public water supply A could be considered exceptional value, however, they are located outside of the project’s study area and were not delineated, therefore Shell does not have information on them or their impact to this well. There were no other wetlands Shell considered to be exceptional value based on their proximity to public water systems.
B21 There were two protected plant species- harbinger of spring (PA threatened) and purple rocket (PA endangered)- located within the Raccoon Creek floodplain. The DEP asked Shell to evaluate whether there are wetlands in the project area that should be considered “exceptional value” due to their proximity to these species. Wetlands are considered “exceptional value” if they serve as habitat for a threatened or endangered plant or animal species. They are also exceptional value if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain the habitat of the species. There are six wetlands near populations of these plant populations: W-PA-151014-MRK-001, W-PA-151013-MRK-002, -003, and -004, W-PA-170407-JLK-001, W-PA151013-MRK-001. However, Shell stated that the harbinger of spring is not dependent on wetland habitat for survival and the species is considered an upland plant species (because it is not listed on Eastern Mountains and Piedmont List or on the National Wetland Plant List). Purple rocket is listed as a “Facultative Wetland Plant” (FACW) on both lists. However, Shell stated that, “although it is a FACW, this plant is not one that occurs in wetlands,” and the population of purple rocket was found in an upland, disturbed area. Therefore, Shell determined that none of these wetlands are considered exceptional value.
B23 A21 W21 Shell needs to assess cumulative impacts to wetlands from the proposed pipeline and other existing projects and potential future projects. These are discussed in the Cumulative Impact Assessment document, Sections 4.1 and 4.2, and Tables B1 and B2.
B24 A22 W22 Shell needed to provide an explanation of how it will restore wetlands and streams disturbed during construction. The explanation needed to include information on seed mixes, shrubs, and trees that will restore stream banks and riparian areas.
B26 A24 W24 Shell needed to provide a table that lists, describes, and quantifies permanent impacts to wetlands and watercourses. Shell stated that there are no permanent fills associated with the project, but there will be permanent conversion impacts to the following wetlands. They total 10,862 ft2 or 0.25 acres in Beaver County, 5,166 ft2 (0.12 acres) in Allegheny County, and 4971 ft2 (0.11 acres) in Washington County. (W-PA-151013-JLK-005, W-PA-161202-MRK-001, W-PA-160404-MRK-001, W-PA-160412-CBA-004, W-PA-160412-CBA-001, W-PA-161205-WRA-003, W-PA-160401-MRK-005, W-PA-170213-JLK-003, W-PA-160406-MRK-001, W-PA-170413-RCL-005, W-PA-170214-CBA-005.)
B27 A25 W25 Shell needed to provide more information on the Neshannock Creek Restoration site, including a master restoration plan for the entire site. This mitigation is required to offset conversion impacts to wetlands along the pipeline route. The plan for the site is documented here.
B28 A26 W26 Shell needed to provide the location and resource crossing number for the HDDs in PA. They are listed in these tables:
2. Stormwater control
B3 A1 W1 Shell indicated that the project was in a floodplain project by the Commonwealth, a political subdivision of the commonwealth or a public utility. The DEP asked for an identification of this floodplain project, to which Shell responded that it misunderstood the question and the pipeline will not go through a floodplain project by one of these entities, but rather a floodway. The pipeline will pass many floodways, which are listed in Table 1 in separate documents for Beaver County, Allegheny County, and Washington County.
W3 The DEP requested that Shell provide an analysis of impact to Act 167 plans. Act 167 requires counties to create stormwater management plans and municipalities to adopt ordinances to regulate development in accordance with these plans. The pipeline route occurs in areas with Act 167 plans in Chartiers Township, Mount Pleasant Township, and Robinson Township.
3. Public health and safety
B1 The proposed pipeline does not meet the provisions of a zoning ordinance or have zoning approval in a particular area. Specifically, in Independence Township, the pipeline is within setback distances of places of congregation and/or of residences. One example is the Beaver County Conservation District, considered a place of congregation. Shell responded to this deficiency, saying it is working with Independence Township to obtain necessary approvals, and the township will “officially remove the pipeline ordinance from their records and no variances or permits will be required.”
B10 A8W9 The DEP requested that Shell evaluate and discuss how the pipeline may impact public water systems that are within 1 mile of the pipeline route. Shell located 12 sites within a mile, most of which are ground water wells. One site is the Ambridge Water Authority, which provides drinking water for an estimated 30,000 people. Shell stated that impacts “might include an Inadvertent Return (IR) causing a bentonite slurry mix to enter the supply, which might contaminate the supply for any wells that are located near an HDD site or construction equipment.” Shell stated that all wells are a minimum of 1000 feet outside construction zones and built in thick bedrock which will minimize threat on contamination. The sites within 1 mile include:
Beaver County Conservation District
Independence Elementary School
Independence Volunteer Fire Department
McConnell’s Farm and Market, Inc
Ambridge Water Authority- Independence Township
Ambridge Water Authority- Raccoon Township
Hookstown Free Methodist Church
South Side Memorial Post 952
NOVA Chemical, Inc
B11 A9 W10 The DEP asked Shell to discuss efforts to avoid/minimize impacts to the above public water systems, and suggested that efforts “might include, but are not limited to, considering alternative locations, routings or design for the proposed pipeline; providing provisions for shut-off in the event of break or rupture; etc.” Shell stated that the route avoids direct impacts to groundwater wells and surface water intake. Shell will provide water buffalos if wells are contaminated, and drill new wells if necessary. There are mainline valves approximately 7 to 7.5 miles apart that can automatically shut off the flow of ethane. There will also be staff living within the project area that can quickly respond to issues.
B12 The pipeline crosses headwaters of the Ambridge Reservoir and the Reservoir’s raw water service pipeline, which supplies water to 30,000 residents. The DEP noted significant public concern regarding this crossing, and asked Shell to evaluate and discuss the pipeline’s potential to affect the Reservoir and public water supply service. The DEP also asked Shell to elaborate on efforts to avoid/minimize impacts, and what measures will be implemented to mitigate any unavoidable impacts. In response, Shell stated the pipeline will cross the raw water line via an HDD 31 feet below the line. Shell explained that the water service line is made of pre-stressed concrete, which cannot be retrofitted in the field if a break occurs. It can take six weeks for pipe joints to be made and delivered from Ohio if there is a rupture. Shell stated it will supply extra pipe joints so the Ambridge Water Authority can have pieces on deck in case of a break. Shell also outlined the protective coatings and design of the HDD portion of the pipeline that will cross the water line, and said valves that can shut off the pipeline are located 2.4 miles from one side of the water line and 3.5 on the other.
A17W17 The DEP asked Shell to consider the proposed pipeline’s effect on the Montour Trail, a multi-use, recreational trail, and to consider re-routes that would avoid impacts to the Trail. Shell determined that routing around the trail is not feasible. Shell will use conventional bore or HDD methods. If the trail needs to be temporarily closed during construction, operation, or maintenance, Shell will notify the trail owner and provide alternate temporary access for trail users. Shell will also cross the Panhandle Trail by HDD. The entrance and exit sights of the bore will not be on the trail’s property. Shell has “unlimited ingress and egress over Owners property” for inspections, repair and maintenance of the pipeline, and in case of emergency situations.
B30 A28 W28 Shell needed to include a preboring geologic evaluation to determine if drinking water supplies will be impacted around boring locations. Shell also needed to discuss how it will verify that drinking water sources and aquifers are protected and what measures will be taken in the event that they are impacted. Shell’s response is included as Appendix C to this document.
B19 A18 W18 19A 19W – There are many areas important for the region’s biodiversity and natural heritage that the proposed pipeline passes near or through. The DEP asked Shell to evaluate impacts to these areas. Information on them is available from the Pennsylvania Natural Heritage Program. They include:
Ambridge Reservoir Valleys Natural Heritage Area
Lower Raccoon Creek Natural Heritage Area
Raccoon Creek Valley and Wildflower Reserve Natural Heritage Area
Raccoon Creek Floodplain Biologically Diverse Area
Raccoon Creek Landscape Conservation Area
Clinton Wetlands Biologically Diverse Area
Raccoon Creek Landscape Conservation Area
Raccoon Creek Valley & State Park Important Bird Area – Regarding the Important Bird Area, Shell stated that 23 miles of the pipeline is located within this area. Shell has not been able to get in contact with the National Audobon SW PA office. Shell added that the only waterbody large enough in the project area to support the documented waterfowl is the open water at Beaver County Conservation District.Shell stated that “an outlet has been installed at the far end of the lake to restore it to more of a wetland and less of a lake, as it was originally designed.” Raccoon Creek Valley is also a passageway for migratory birds, which are protected under the Migratory Bird Treaty Act. Shell stated that less than 2% of this Important Bird Area will be permanently impacted by pipeline construction and installation.
5. Alternative locations
B17 A15 W15 The DEP asked Shell to revise its current alternatives and provide a more detailed “analysis of the alternative locations and routes that were considered to avoid or minimize adverse environmental impacts.” The alternatives are discussed in Section 9 of Shell’s Comprehensive Environmental Assessment.
B18 16A16W According to the DEP, “18.5 of the 45 miles (41%) of the proposed pipeline are parallel to or adjacent to existing right-of-ways (ROWs).” The DEP asked Shell to see if there are additional opportunities to build the pipeline within existing ROWs, with the hope of reducing environmental impacts. In response, Shell discussed the additional ROWs that were considered (along Mariner West) but ultimately rejected. Shell discusses these routes more in Section 9.1 of the Comprehensive Environmental Assessment.
B32 A30 W30 The DEP asked Shell to discuss the feasibility of several changes to the proposed pipeline’s route, including avoiding impacts to wetlands, relocating resource crossings, moving valve sites outside of wetlands, moving HDD locations, and evaluating the impact to a coal refuse pile (the pipeline crosses underneath at least one pile via HDD). These reroutes are discussed under question 32 for Beaver County, question 30 for Allegheny County, and question 30 for Washington County.
6. Geological concerns
B14 12A 12W The pipeline is located in previously coal mined areas. The DEP asked Shell to provide a map of the pipeline that showed these mining areas, and GIS shape files with this information. Shell’s response is included in the HDD Subsurface Investigation Reports, which includes the following table of the extent of mined areas along the pipeline route:
B15 A13 W13 The pipeline is located in coal mined areas, which could be susceptible to subsidence and/or mine water discharge. The DEP requested that Shell revise drawings to show the limits of previously mined areas, depth of cover over the mine workings in areas the proposed pipeline crosses through, and the distance between mine workings and the proposed pipeline. Furthermore, the DEP asked Shell to “evaluate and discuss the potential for a subsidence event compromising the utility line, and the potential to create a mine water discharge.” Shell discusses this in Appendix B of this this document and in the Mining Summary Report. Shell also identifies the following areas as being at risk for coal mine discharge: HOU MM 1.2, HOU MM 8.9 (proposed HDD), HOU MM 12.1, HOU MM 12.95, HOU MM 13.1, HOU MM 13.6, HOU MM 17.4, and HOU MM 17.65 (proposed HDD).
B16 A1414W The DEP requested that Shell include areas where the pipeline will cross active mining permit boundaries. There is one active mining permit boundary that intersects the proposed pipeline, the Rosebud Mine in Beaver County.
B31 A29 W29 Shell needed to evaluate the potential for the project to encounter areas underlain by carbonate bedrock and landslide prone areas. Carbonate bedrock is indicative of a karst landscape, meaning an area likely to have underground sinkholes and caves. The DEP also asked Shell to discuss precautionary methods taken during construction in these areas. Shell’s response is included in the Carbonate Rock Analysis and Slope Stability and Investigation Report. The Carbonate Rock Analysis report shows that carbonate bedrock was encountered in 20 out of 40 of the borings taken during the analysis.
B4 The PA DEP asked Shell to describe the structures and activities that occur within junction sites. Shell responded that there will be a Junction Custody Transfer Meter Station at the site, and provided maps of the site.
B22 20A 20w The DEP requested that Shell revise their Comprehensive Environmental Assessment to include alternatives, impacts, and mitigation items that were previously included in other sections of their environmental assessment.
B25 A23W23 The DEP asked Shell to provide a copy of the Mitigation Bank Credit Availability Letter from First Pennsylvania Resource, LLC. In response, Shell stated the Letter is no longer needed because “the permanent stream and wetland fills have been removed from this project.”
B35 A33 W33 Shell needs to include all of the above modifications to the application in the Chapter 103 permit application.
As evidenced by the list above, the proposed Falcon Pipeline poses a variety of threats to Pennsylvania’s natural resources, wildlife, and public health – but this deficiencies list is likely not complete. The pipeline also passes through West Virginia and Ohio, and if completed, will likely attract more pipelines to the area. As it feeds Shell’s ethane cracker plant in Beaver County, it is a major step towards the region becoming a hub for plastic manufacturing. Therefore, the public response to the above deficiencies and the decision the DEP makes regarding them will have major implications for the Ohio River Valley’s future.
Of note: The DEP’s letters and Shell’s response to them are available to the public in separate documents for Allegheny, Beaver, and Washington Counties.
By Erica Jackson, Community Outreach and Communications Specialist