By Kirk Jalbert, Manager of Community-Based
Research & Engagement, FracTracker Alliance
Missing the Mark in Oil & Gas Communities
Conventional oil and gas drilling for commercial purposes has existed in Pennsylvania for over 150 years. In the past decade, drilling operations have turned to extract these resources from unconventional reservoirs, such as the deep underground Marcellus Shale formation. Proponents of the oil and gas industry’s expansion promise jobs and tax revenue for regions seeking economic revitalization. However, a growing body of research suggests that these processes also negatively impact the environment and pose significant public health risks.
According to the U.S. Environmental Protection Agency, environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. How this definition applies to residents of Pennsylvania has become a hotly contested issue as regulatory agencies have begun to investigate whether or not the oil and gas industry targets marginalized communities.
PA Environmental Justice Map
The following interactive article and map illustrates how race and poverty, the two key indicators for determining environmental justice eligibility, fail to capture the nature of the industry. It also suggests that there are other ways we might assess unfair development practices. In doing so, the goal of the article is to shed light on the complexity of environmental justice issues and to offer guidance as PA’s Department of Environmental Protection (DEP) assesses its policies in coming days.
Feature image photo credit: Drilling rig and farm in PA by Schmerling (firstname.lastname@example.org)
By Danny Kallich, Southwest Pennsylvania Environmental Health ProjectThis article examines whether emergency responders are prepared in rural areas for oil and gas drilling emergencies, how people may be put at risk if the proper procedures aren’t in place, and other critical safety questions that citizens in Southwest Pennsylvania should be asking.
The rapid spread of unconventional natural gas development (UNGD) across Pennsylvania has highlighted the need for state, county, and municipal agencies to regulate industry activity and protect the public on several fronts. In particular, comprehensive emergency preparedness and response specific to natural gas development is an obvious necessity for residents living within close proximity of wells, compressor stations, and other stages of UNGD.
While experts in the field of emergency planning are rightfully responsible for creating and executing emergency plans, the Federal Emergency Planning and Community Right to Know Act of 1986 (EPCRA) defines citizens’ rights to engage in the process, both through open records requests and public meetings with local emergency planners. EPCRA establishes roles and requirements for emergency planners while clarifying the rights of citizens to engage in dialogue with those responsible for safety about potentially harmful industrial activity in their community.
Unique Emergency Preparedness Challenges
UNGD presents a unique set of challenges for residents and emergency planners. The high likelihood that UNGD will be located in a rural area not typically supporting industrial use argues for the need for special treatment by emergency planners. Furthermore, responding to a UNGD emergency requires specialized training that is not mandated for local first responders, often volunteer fire fighters. While local first responders cannot be expected to specialize in UNGD related emergencies, it takes many hours for the contracted well-fire specialists, Texas-based Wild Well Control, to arrive and mitigate an emergency situation. The interim period between the arrival of local and county first responders and the arrival of Wild Well Control is, nonetheless, a critical time during which a system for consistent updates to nearby residents should be a priority. An emergency situation, as demonstrated by the February 11, 2014 Chevron Appalachia well fire, discussed below, can affect a community in a variety of ways, even if evacuation is not necessary.
Chevron Appalachia Incident, Greene County, PA
Testing The System:
Using Right-To-Know requests to gauge transparency & citizen awareness
The opportunities for citizen comment and engagement with emergency planners are limited and not well publicized. The dearth of clear and consistent means of communication between residents and those responsible for emergency planning provides a noteworthy opportunity to test the provisions of EPCRA as they relate to UNGD.
In this regard, testing the emergency response system related to oil and gas drilling emergencies is intended to analyze existent emergency plans, municipal preparedness, communication between county, municipal, and industry emergency planners, and perhaps most importantly, how much of this information is available to citizens.
The transparency of the system was tested by filing Right-To-Know requests. These public information requests were filed with nine municipalities in various counties across the state of Pennsylvania. All filed requests specifically asked for “all available county, municipal, and company generated emergency plans” in relation to specific well sites. One request asked for emergency plans generated by an elementary school in relation to a well site within approximately a half-mile.
Of these nine requests, three were fulfilled with returned emergency plans. Of the remaining six requests, five were not fulfilled because no emergency plan existed on record in the municipality. Initially, the request for the elementary school emergency plan was unable to be met by the municipal open records officer because no plan existed. Two months after that request, an unsolicited response from the same individual was received stating that the now-existent plan could not be shared because of security issues. A final question posed to the open records officer asked what concerned parents might be able to do to prepare themselves for emergency situations. This question, too, was deemed unanswerable due to security reasons. Another unmet municipal request was redirected to a county emergency planner who stated that the company generated plan was not theirs to distribute. Of the three emergency plans received, only one made any specific mention of residents living within close proximity; this response merely stated the number of nearby houses. Excluding GPS coordinates, no plan addressed any other infrastructure specific to the surrounding area, indicating a broad generality to their application.
The fact that six out of nine queried communities in PA were unable or unwilling to provide emergency response plans is highly concerning. These findings, when considered in the broader national context, indicate a significant chance that UNGD specific emergency planning and necessary communication with the public is deficient, particularly on the municipal level.
What Communities Need
Lack of specificity, inter-agency communication, and transparency indicate that the potential of EPCRA to benefit citizens has been largely untapped during the Marcellus Shale boom relative to emergency planning. Residents living within close proximity to UNGD should not only be apprised of emergency risk and strategy before an emergency arises, they should have a clearly accessible venue through which to voice concerns, needs, and recommendations. Furthermore, residents have valid reason to demand greater public oversight of current emergency planning efforts when the overwhelming majority of publicly available emergency plans fail to provide any information useful to a layperson.
Currently, there are communities in which the questionable practice of locating UNGD within a half-mile of elementary schools and other sensitive areas continues. In such areas, every effort must be made to develop, institute, and practice emergency plans prioritizing the concerns, safety, and coordination of local residents. Recommendations for improved transparency include:
- Make publicly available site-specific plans,
- Hold regular public meetings, and
- Prioritize communication between emergency responders and residents during emergency events
We encourage residents who are concerned about what their community is doing for UNGD-specific emergency planning to contact their local emergency responders and attend Local Emergency Planning Committee meetings in their county to advocate for such measures.
The Southwest Pennsylvania Environmental Health Project (EHP) is a nonprofit environmental health organization created to assist and support Washington County residents who believe their health has been, or could be, impacted by natural gas drilling activities. Their Mission is to respond to individuals’ and communities’ need for access to accurate, timely and trusted public health information and health services associated with natural gas extraction.
By Matt Kelso, Manager of Data & Technology
In October 2014, the FracTracker Alliance performed an analysis showing an estimated 1.2 million people lived within a half mile of oil and gas wells in Pennsylvania. We have now updated the analysis, but this time, the unit of measure is one kilometer (0.62 miles).
PA Population Within 1km of Active Oil and Gas Wells
This map shows the estimated population within one kilometer of active oil and gas wells in PA – a total of nearly 2 million Pennsylvanians. To access the full set of tools and details about how the map was made, click here for the full screen version of the map.
To get as complete a picture as possible of the oil and gas industry in PA, we queried the spud date report to show all wells that were listed as being spudded between January 1, 1800 and November 12, 2015. We used the former date because it appears to be a default for unknown spud dates, and the latter being the date that the data were downloaded for the analysis. Altogether, this yielded 203,887 oil and gas wells throughout the state, but 74,900 (37%) of these lacked location coordinates. All of those missing latitude and longitude data were classified as conventional wells, and many of them were fairly old. We then filtered out wells that were reported as not being drilled, as well as those that were permanently plugged, either by the operator, or by the PA Department of Environmental Protection (PADEP). The resulting set, which we refer to as “active” oil and gas wells, included 106,970 wells, of which 9,042 (8%) are defined as unconventional wells by the state.
To obtain an estimated population, we used the Census Tract level of detail, using official 2010 population figures. We calculated the area within 1 kilometer of active wells in three categories – conventional, unconventional, and all oil and gas wells. The population was then estimated by comparing the area inside the 1 km zone to the entire Census Tract, multiplying that ratio to the population of that tract, and repeating the process for each of the three datasets.
This area calculation was performed in Albers Equal Area projection optimized for the Great Lakes Basin area. Every method of flattening an area of a globe on the map will lead to some type of distortion, but this projection prioritizes area over other factors, and is therefore appropriate for this type of analysis.
An additional year of drilling activity, a more comprehensive date range, and the slight increase of the radius distance has had a significant effect on the estimated population near wells. The 2014 analysis yielded an estimated 1,264,576 within a half-mile of wells, while the current analysis has the figure at 1,965,837, an increase of 55%. Below is a table showing differences between the two analyses:
One thing you will notice in this figure is that simply adding up the number of people who live in areas near unconventional and conventional drilling will not get you to the 1,965,837 figure we’ve presented. This is because some people live within the specified distance of both types of wells.
Additionally, it is impossible to say how many people live near the oil and gas wells that lack location data, as we obviously can’t map these wells. The majority of these wells may be in the areas that are already represented in the buffer zones, or they may extend that distance significantly.
Matt Kelso, Manager of Data & Technology
Kirk Jalbert, Manager of Community Based Research & Engagement
The Risks of Crude Oil Trains
As new oil fields boomed across North America in recent years, drillers looked for ways to get the product to refineries thousands of miles away. One solution was to use the nation’s rail infrastructure to ship hundreds of thousands of barrels of crude oil per day. The flow of oil was so great that thousands of additional tanker cars were ordered to get the oil to market. And yet, this solution of transporting crude by rail brought additional problems. Shipping large quantities of highly volatile and combustible crude oil on often antiquated rail lines has resulted in numerous accidents, at times spectacular in scale. In recent months, however, thousands of these oil tankers have been sitting idle on the tracks around the country, partially due to dropping oil prices, leading refineries to opt for cheaper imported oil and less expensive ways to get the domestic product to market such as through pipelines.
Communities Along the Tracks
The interactive story map below investigates a stretch of oil trains that have been parked for months in close proximity to homes, schools, and busy intersections in Berks County, Pennsylvania. Altogether, 30,494 people live in the seven communities through which the tracks in question pass. We began this project in response to concerns from residents who contacted FracTracker for assistance in understanding why these trains were located in their community, what hazards they might pose, and to help people bring this story to the public to foster meaningful discussions about the risks of parked oil trains.
FracTracker has covered the risks of oil trains in a series of other articles. Click here to learn more.
By Sierra Shamer, Guest Author
The Atlantic Sunrise Project or Central Penn Line is a natural gas pipeline Williams Companies has proposed for construction through eight counties of Central Pennsylvania. Williams intends to connect the Atlantic Sunrise to their two Transco pipelines, which extend from the northeast to the Gulf of Mexico. FracTracker discussed and mapped this controversial project as part of a blog entry in June of 2014; since then, the Atlantic Sunrise Project has been, and continues to be, a focus of unprecedented opposition. While supporters of the pipeline stress how it may enhance energy independence, economic growth, and job opportunities, opponents cite Williams’ poor safety records, their threats of eminent domain, and environmental hazards. This article provides details and maps pertaining to these threats and concerns.
Atlantic Sunrise: Project Overview
The Atlantic Sunrise Project would add 183 miles of new pipeline through the construction of the Central Penn Line North and the Central Penn Line South. The proposed Central Penn Line North (CPLN) begins in Susquehanna County, continues through Wyoming and Luzerne counties, and meets with the Transco Pipeline in Columbia County. With a 30 inch in diameter, it would allow for a maximum pressure of 1,480 psi (pounds per square inch). The proposed Central Penn Line South (CPLS) begins at the Transco Pipeline in Columbia County, and continues through Northumberland, Schuylkill, and Lebanon counties, ending in Lancaster. It would be 42 inches in diameter with a maximum pressure of 1,480 psi. The Atlantic Sunrise project also involves the construction of two new compressor stations, one in Clinton Township, Wyoming County, and the other in Orange Township, Columbia County. Finally, to accommodate the daily 1.7 million dekatherms (1 dekatherm equals 1,000 cubic feet of gas or slightly more than 1 million BTUs in energy) of additional natural gas that would flow through the system, the project proposes the expansion of 10 existing compressor stations along the Transco Pipeline in Pennsylvania, Maryland, Virginia, and North Carolina. Although the Atlantic Sunrise Pipeline would be entirely within Pennsylvania, it is permitted and regulated by the Federal Energy Regulatory Committee (FERC) because through its connection to the Transco Pipeline, it transports natural gas over state lines.
Updated Central Penn Pipeline Route
On March 31, 2015, Williams filed their formal application to FERC docket #CP15-138. Along with the formal application came changes to the pre-filing route of the pipeline that was submitted in the spring of 2014. The route of the Central Penn Line North has been modified since then by 21%, while the Central Penn Line South has been rerouted by 57%.
Williams’ application comprised of hundreds of attached documents, including pipeline alignment sheets for the entire route. Here is one example:
These alignment sheets show the extent of William’s biological investigation, the limits of disturbance, the occurrence of stream and wetland crossings, and any road or foreign pipeline crossings. Absent from the alignment sheets, however, is the area around the right-of-way that will be endangered by the presence of the pipeline. This is colloquially known as the “burn zone” or “hazard zone”.
What are “Hazard Zones”?
A natural gas pipeline moves flammable gas under extreme pressure, creating a risk of pipeline rupture and potential explosion. The “potential impact radius” or “hazard zone” is the approximate area within which there will be immediate damage in the case of an explosion. Should this occur, everything within the hazard zone would be incinerated and there would be virtually no chance of escape or survival. Based on pipeline diameter and pressure, the hazard zone can be calculated using the formula: potential impact radius = 0.69 * pipeline diameter * (√max pressure ).
Based on this formula, the hazard zone for the Central Penn Line North, with its diameter of 30 inches and maximum pressure of 1,480 psi, is approximately 796 feet (243 meters) on either side of the pipeline. The hazard zone for Central Penn Line South, with its diameter of 42 inches and maximum pressure of 1480 psi, is 1,115 feet (340 meters) on either side.
Many residents are unaware that their homes, workplaces, and schools are located within the hazard zone of the proposed Atlantic Sunrise Pipeline. Williams does not inform the public about this risk, primarily communicating with landowners along the right-of-way. The interactive, zoomable map (below) of the currently proposed route of the Atlantic Sunrise, Central Penn North and South pipelines depicts the pipeline right-of-way, as well as the hazard zones. The pipeline route was digitized using the alignments sheets included in Williams’ documents submitted to FERC. You can use this map to search home, work, and school addresses to see how the pipeline will affect residents’ lives and the lives of their communities.
Click in the upper right-hand corner of the map to expand to full-screen view, with a map legend.
Landowners & Eminent Domain
Landowners along the right-of-way are among the most directly and most negatively impacted by the Atlantic Sunrise Pipeline, and other similar projects. Typically, people first become aware that a pipeline is intended to pass through their property when they receive a notice in the mail. Landowners faced with this news are on their own to negotiate with the company, navigate the FERC permitting and public comment process, and access unbiased and pertinent information. They face on-going stress, experiencing pressure from Williams to sign easement agreements, concern about the effects of construction on their property, and fear of living near explosive infrastructure. They must also consider costs of legal representation, decreases in property value, and limited options for mortgage and refinancing.
Sometimes, landowners in a pipeline’s right-of-way choose to not allow the company onto their property to conduct a survey. Landowners may also refuse to negotiate an agreement with the pipeline company. In response, the pipeline company can threaten to seize the property through the power of eminent domain, the federal power allowing private property to be taken if it is for the “public use.”
The law of eminent domain states that landowners whose properties are condemned must be fairly compensated for their loss. However, most landowners feel that in order to be fairly compensated by the company, they must hire their own land appraiser and attorney. This decision can be costly, however, and may not be an option for many people. The legitimacy of Williams’ intent to use eminent domain is contested by opponents of the project, who cite how “public use” of the property provides no positive local impacts. The Atlantic Sunrise Pipeline is intended to transport gas out of Pennsylvania through the Transco, so the landowners in its path will not benefit from it at all. Further, it connects to a network of pipelines leading to current export terminals in the Gulf of Mexico, as well as controversial planned export facilities like Cove Point, MD .
Throughout Pennsylvania, communities have responded to the expansion of pipelines, and to the threats of large companies like Williams. The need for landowner support has been addressed by organizations such as the Shalefield Organizing Committee, Energy Justice Network, the Clean Air Council, the Gas Drilling Awareness Coalition, and We Are Lancaster County. These organizations have worked to provide information, increase public awareness, engage with FERC, and develop resistance to the exploitation of Pennsylvania’s resources and residents. Director Scott Cannon of the Gas Drilling Awareness Coalition has documented firsthand the impacts of unconventional drilling in Pennsylvania through a short film series called the Marcellus Shale Reality Tour. The most recent in the series relates the stories of two landowners impacted by the Atlantic Sunrise Pipeline in the short film Atlantic Sunrise Surprise.
Theoretically, environmental review of this proposed pipeline would be extensive. Primary decision-making on the future of the Atlantic Sunrise rests with FERC. Due to the National Environmental Policy Act of 1969 (NEPA), all projects overseen by federal agencies are required to prepare environmental assessments (EAs) or environmental impact assessments (EIAs). Because FERC regulates interstate pipelines, EA’s or EIA’s are required in their approval process. These assessments are conducted to accurately assess the environmental impacts of projects and to ensure that the proposals comply with federal environmental laws such as the Endangered Species Act, and the Clean Air and Water Acts. On the state level, the Pennsylvania Department of Environmental Protection (PA DEP) issues permits for wetlands and waterways crossings and for compressor stations on regional basis.
Core Habitats, Supporting Landscapes
The route of the Atlantic Sunrise Pipeline will disturb numerous areas of ecological importance, including many documented in the County Natural Heritage Inventory (CNHI). The PA Department of Conservation and Natural Resources conducted the inventory to be used as a planning, economic, and infrastructural development tool, intending to avoid the destruction of habitats and species of concern. The following four maps show the CNHI landscapes affected by the current route of the Atlantic Sunrise pipeline (Figures 1-4).
The proposed pipeline would disrupt core habitats, supporting landscapes, and provisional species-of-concern sites. According to the Natural Heritage Inventory report, core habitats “contain plant or animal species of state or federal concern, exemplary natural communities, or exceptional native diversity.” The inventory notes that the species in these habitats will be significantly impacted by disturbance activities. Supporting landscapes are defined as areas that “maintain vital ecological processes or habitat for sensitive natural features.” Finally, the provisional species of concern sites are regions where species have been identified outside of core habitat and are in the process of being evaluated. The Atlantic Sunrise intersects 16 core habitats, 12 supporting landscapes, and 6 provisional sites.
Active Mine Fires
The current route of the Atlantic Sunrise intersects the Cameron/Glen Burn Colliery, considered to be the largest man-made mountain in the world and composed entirely of waste coal. This site also includes a network of abandoned mines, three of which are actively burning (Figure 5).
The pipeline right-of-way is roughly a half-mile from the closest burning mine, Hickory Swamp. These mine fire data were sourced from a 1988 report by GAI Consulting Inc. The time frame for the spread of the mine fires is unknown, and dependent on environmental factors. Mine subsidence — when voids in the earth created by mines cause the surface of the earth to collapse — is another issue of concern. Routing the pipeline through this unstable area adds to the risk of constructing the pipeline through the Glen Burn region.
The Atlantic Sunrise Project has received an unprecedented level of resistance that continues to grow as awareness and information about the threats and hazards develops. While Williams, FERC, and the PA DEP negotiate applications and permits, work is also being done by many non-profit, research, and grassroots organizations to investigate the environmental, cultural, and social costs of this pipeline. We will follow up with more information about this project as it becomes available.
This article was written by Sierra Shamer, an environmental mapper and activist. Sierra is a member of the Shalefield Organizing Committee and holds two degrees from the University of Maryland, Baltimore County: a B.A. in environmental studies and an M.S. in geography and environmental systems.
Reviewing a Pennsylvania TENORM Study
By Juliana Henao, Communications Intern
Technologically-enhanced, naturally-occurring radioactive materials, also known as TENORM, are produced when radionuclides deep in the earth are brought to the surface by human activity such as oil and gas drilling. The radioactive materials, which include uranium (U), thorium (th), potassium-40 (K-40) and their decay products, occur naturally in the environment. These materials are known to dissolve in produced water, or brine, from the hydraulic fracturing process (e.g. fracking), can be found in drilling muds, and can accumulate in drilling equipment over time.
According to the EPA, ~30% of domestic oil and gas wells produce TENORM. Surveys have shown that 90% of the wells show some TENORM concentrations, while others have nothing at all. However, with increasing natural gas exploration and production in Pennsylvania’s Marcellus Shale, there is a parallel increase in TENORM. According to Dr. Marvin Resnikoff, an international expert on radiation, drilling companies and geologists locate the Marcellus Shale layer by way of its higher level of radiation.
Bringing more of this TENORM to the surface has the potential to greatly impact public health and the environment. Since 2013, the Pennsylvania Department of Environmental Protection (PA DEP) has been gathering raw data on TENORM associated with oil and gas activity in the state. The study was initiated due to the volume of waste containing high TENORM concentrations in the state’s landfills, something that is largely unregulated at the state and federal level. In January 2015, the PA DEP released a report that outlined their findings and conclusions, including potential exposures, TENORM disposal practices, and possible environmental impacts.
Radioactivity Study Overview
This review touches on the samples tested, the findings, and the conclusions drawn after analysis. The main areas of concern included potential exposure to workers, members of the public, and the environment.
The samples gathered by the DEP came from 38 well sites, conventional and unconventional, by testing solids, liquids, ambient air, soils, and natural gas near oil and gas activity in Pennsylvania. All samples contained TENORM or were in some way impacted by TENORM due to oil and gas operations. The samples were mainly tested for radioactive isotopes, specifically radium, through radiological surveys.
The PA DEP concluded in the cases of well sites, wastewater treatment plants (POTW), centralized wastewater treatment plants, zero liquid discharge plants, landfills, natural gas in underground storage, natural gas fired power plants, compressor stations, natural gas processing plants, radon dosimetry (the calculation and assessment of the radiation dose received by the human body), and oil and gas brine-treated roads that there is little potential for internal radiation exposure to workers and members of the public. In spite of this, each section of the report typically concluded with: however, there is a potential for radiological environmental impacts…
Examples of these findings include:
- There is little potential for radiological exposure to workers and members of the public from handling and temporary storage of produced water on natural gas well sites. However, there is a potential for radiological environmental impacts from spills of produced water from unconventional natural gas well sites and from spills that could occur from the transportation of this fluid.
- There is little potential for radiological exposure to workers and members of the public from sediment-impacted soil at landfills that accepted O&G waste for disposal. However, there may be a radiological environmental impact to soil from the sediments from landfill leachate treatment facilities that treat leachate from landfills that accept O&G waste for disposal.
- Radium 226 was detected within the hydraulic fracturing fluid ranging from 64.0-21,000 pCi/L. Radium-228 was also detected ranging from 4.5-1,640 pCi/L. The hydraulic fracturing fluid was made up of a combination of fresh water, produced water, and reuse flowback fluid. There is little potential impact for radiological exposure to workers and members of the public from handling and temporary storage of flowback fluid on natural gas well sites. However, there is a potential for radiological environmental impacts from spills of flowback fluid on natural gas well sites and from spills that could occur from the transport of this fluid.
- Nine influent and seven effluent leachate samples were collected at the nine selected landfills. Radium was detected in all of the leachate samples. Radium-226 concentrations were detected in produced water samples ranging from 40.5 – 26,600 pCi/L. Radium-228 concentrations were also detected ranging from 26.0 – 1,900 pCi/L. The Ra-226 activity in unconventional well site produced water is approximately 20 times greater than that observed in conventional well site produced water. The ratio of Ra-226 to Ra-228 in unconventional well site produced water is approximately eight times greater than that found in conventional well site produced water. (Sections 3.3.4 and 3.6.3) (PA DEP TENORM study report section 9.0)
While the report comprehensively covers the processes from drilling to end users, the number of samples collected and analyzed are very sparse for a state-wide study. Just to give an idea, only 8 well sites were sampled during the flowback phase and of the 8 only 4 had enough volume to analyze. Of 14 drill mud samples collected, only 5 were analyzed as liquids, and alpha & beta analysis was only done on one sample.
Obtaining the proper sample size is often a major barrier for field studies. Additional research needs to be conducted with a larger sample size and more rigorous exposure monitoring to determine specific risk metrics for workers and the public.
Current Handling of TENORM
From drilling to distribution, there are many topics of concern associated with TENORM; however, we will focus on the current treatment of TENORM waste, the release of data, and the transparency of this issue.
On a federal level, there are no specific regulations governing many aspects of TENORM, such as sludge or solids containing TENORM from water treatment plants. Additionally, if concentrations of U or Th make up less than .05% by weight, they are seen as an “unimportant quantity” and are exempt from NRE regulation. Currently, 13 states regulate TENORM with varying degrees of standards. Hazardous waste facilities in each state can choose to accept TENORM materials as long as they don’t exceed certain concentrations.
Today, about 12 of PA’s 50 landfills accept such radioactive waste from oil and gas activity at a 1:50 dilution ratio (related to their other intake sources). Under RCRA’s Land Disposal Restrictions, “dilution is prohibited as treatment for both listed and characterized wastes.”
According to the DEP report, hydraulic fracturing produces an enormous stream of waste by-products. Safe disposal of this waste has not yet been devised. A few of the conclusions concerning TENORM disposal and treatment in the report listed some areas of concern, identified below:
- Filter cake  and its radiological environmental impact if spilled, and
- The amount of radioactive waste entering the landfills in PA, which reached 430,317 tons in the first 10 months of 2014.
In unison with the conclusions were recommendations, where the report “recommends considering limiting radioactive effluent discharge from landfills, and adding radium-226 and radium-228 to annual sample analysis of leachate from landfills.” Additionally, the report states that if something such as filter cake spills, it will bring into question the safety of long-term disposal and suggest a protocol revision.
Public Health Concerns
The report identified two places where there is a higher than average radioactive exposure risk for workers and community members of the public: specifically at centralized wastewater treatment plants and zero liquid discharge plants that treat oil and gas wastewater. An additional unknown is whether there is a potential inhalation or ingestion hazard from fixed alpha and beta surface radioactivity if materials are disturbed. As a general precaution, they recommend the evaluation of worker’s use of protective equipment under certain circumstances.
Although research has not come to a consensus regarding a safe level of radiation exposure, it should not be assumed that any exposure is safe. Past research has evaluated two types of radiation exposure: stochastic and non-stochastic, both of which have their own risks and are known to be harmful to the human body. The EPA has defined stochastic effects as those associated with long-term, low level exposure to radiation, while non-stochastic effects are associated with short-term, high-level exposure. From past scientific research, radiation is known to cause cancer and alter DNA, causing genetic mutations that can occur from both stochastic and non-stochastic exposure. Radiation sickness is also common, which involves nausea, weakness, damage to the central nervous system, and diminished organ function. Exposure levels set by the EPA and other regulatory agencies fall at 100 millirem (mrem) per year to avoid acute health effects. As a point of reference, medical X-rays deliver less than 10 mrem, and yearly background exposure can be about 300 mrem.
In the report, Radiological Dose and Risk Assessment of Landfill Disposal of TENORM in North Dakota, Argonne National Laboratory researchers suggest that the exposure to workers be limited and monitored. In many of their studies, they found the doses exceed the 100 mrem/year level in the workers when the appropriate attire is not worn during working hours, which raised some concern.
The DEP deems certain radiation levels “allowable”, but it should be noted that allowable doses are set by federal agencies and may be arbitrary. Based on the PA DEP’s report, consumers of produced gas can get up to 17.8% of their yearly radiation allowance, while POTW workers could get up to 36.3% of their yearly allowable dose. According to the Nuclear Information and Resource Service, radiation bio-accumulates in ecosystems and in the body, which introduces a serious confounder in understanding the risk posed by a dose of 17.8% per year.
Transparency of Radiation Risk
The DEP has been gathering data for their TENORM report since 2012. In July of 2014, Delaware Riverkeeper Network filed a Right-to Know request to obtain the information that the DEP had collected in order for their expert to analyze the raw data. The department refused to release the information, insisting that “the release of preliminary invalidated data, including sample locations, could likely result in a substantial and demonstrable risk of physical harm, pose a security risk and lead to erroneous and/or misleading characterizations of the levels and effects of the radioactive risks.” Essentially, the DEP was equating the risks of radioactive material to the risks of releasing raw data — two incomparable risks. DRN appealed, claiming that they simply sought the raw information, which is presumed public unless exempt, and would have no risk on the public. PA DEP was ordered to release their records to DRN within 30 days.
One observation that you could take from this report is the lack of regulatory advancement. The study is filled with suggestions, like:
- Radium should be added to the PA spill protocol to ensure cleanups are adequately characterized,
- A limited potential was found for recreationists on roads with oil and gas brine from conventional natural gas wells–further study should be conducted, and
- More testing is needed to identify areas of contamination and any area should be cleaned up.
Intent doesn’t make the changes; action does. Will any regulations change, at least in Pennsylvania where radioactive materials are returning to the surface on a daily basis? There seems to be no urgency when it comes to regulating TENORM and its many issues at the state level. Are workers, citizens, and the environment truly being protected or will we wait for a disaster to spur action?
 This is the residue deposited on a permeable medium when a slurry, such as a drilling fluid, is forced against the medium under pressure. Filtrate is the liquid that passes through the medium, leaving the cake on the medium.
By Juliana Henao, Communications Intern
Media outlets have been very focused recently on reporting oil train derailments and explosions. Additionally, the Keystone XL pipeline has hastened political debates and arguments for years by both political parties since its initial proposal in 2008 – and the May 19th pipeline oil spill in California isn’t helping matters. In the midst of all of this commotion, a million questions are being asked, yet no one can seem to reach a conclusion about what method of transporting oil is truly safest and economically feasible – or if we are just stuck between a rock and a hard place.
Some say the solution to this problem is transporting the volatile crude via pipelines, while others believe it is a matter of increasing regulations, standards, and compliance for transport by train. The answer is simply not simple.
In light of this, a few of the folks at FracTracker gathered some facts on pipelines vs oil trains to lay out this issue in a clearer fashion.
Let’s start with trains.
Due to the increasing demand of crude oil supply, there has been increasing activity in the transportation of crude oil by rail, which provides flexibility and quick transportation throughout the U.S. and its 115 refineries. Railroads are also willing to offer shippers shorter contracts than pipelines and other transportation methods, making them a more favorable method of crude oil transportation.
In 2008, U.S. freight trains were delivering somewhere from 9-10,000 carloads of crude oil. In 2013, they delivered roughly 435,560 carloads of crude oil, showing a 20-fold increase in crude oil shipments.
Oil trains, as well as pipelines, can pose a detrimental risk to communities and public health in the case of an explosion and/or spill. Danger Around the Bend describes in detail the dangers of transporting Bakken Formation crude oil from North Dakota to parts all over the country.
Some of the risks of transporting volatile crude via train have been clearly depicted in the news with announcements of spills, derailments, and explosions in urban and suburban areas, putting many people in harm’s way. Despite the decrease in spills between 1996 and 2007, devastating train accidents like the one on July 6, 2013 have raised questions about the safety of transportation by train.
Learn more about this trend and the increasing risk of exploding oil trains in a post by Randy Sargent of CMU.
Trains and train tracks in general can be very dangerous, as demonstrated by the deadly Amtrak train derailment in Philadelphia this May. The total number of incidents in 2014, according to the Federal Railroad Administration, sum up to 11,793 – with 818 of those being fatal. These fatalities have been linked to a range of possible causes, but the numbers depict the gravity of safety issues within the railroad regulations.
When it comes to train safety and regulations, the Federal Railroad Administration (FRA) is in charge. Some of the current efforts to increase the safety of oil trains include safer tank car design, adding breaking power, reducing the train speed limits through urban areas and increasing crew size. One of the most important improvements, however, includes an increase in oil spill response, which is managed through the National Oil and Hazardous Substance Contingency Plan.
Now, let’s talk pipelines.
As we all know, finishing the Keystone XL pipeline has stirred years of controversy, since this project was initially proposed back in 2008. On January 31, 2014, the U.S. Department of State released the Final Supplemental Environmental Impact Statement (SEIS) of the Keystone XL Pipeline, which would transport up to 830,000 barrels of tar sand oil per day through an 875-mile long pipeline running from Alberta, Canada, to the Gulf Coast area. Below we have mapped the current and proposed tracks of the Keystone, along with the numerous ports, refineries, and rail lines:
The Keystone XL, Alberta oil sands, North American oil refineries and associated ports. View fullscreen and click Details for the metadata behind this map.
The SEIS discussed the impacts that the proposed pipeline would have on the environment and public health based on research, modeling, and analysis. One of the many purposes of the SEIS is to focus on whether the proposed project serves the national interest by comparing the risks to the benefits – discussed in more detail below.
The current risks associated with pipelines are similar to the risks associated with other modes of transporting oil across the United States. Oil spills are among the highest risks, but with the XL pipeline, it’s a more profound risk due to the type of oil being carried: tar sand oil. Tar sand oil, also known as heavy oil, is known for its tedious processing and its many environmental implications. Burning one single barrel of oil produced from Canadian tar sands generally emits 170 pounds of greenhouse gases into the atmosphere. It also requires large amounts of energy and water, much of which cannot be recycled, to separate the oil from the tar sands and transform the oil into a form of petroleum that can be processed by refineries.
According to the final SEIS:
The proposed project would emit approximately 24 million metric tons of carbon dioxide per year during the construction period (up to three times as much than producing conventional crude), which would be directly emitted through fuel use in construction vehicles and equipment as well as land clearing activities including open burning, and indirectly from electricity usage.
Additional risks associated with the XL pipeline include potential groundwater contamination of major aquifers – particularly the Ogallala Aquifer – as well as deforestation, habitat destruction, and fragmentation.
In the event of an oil spill from the Keystone XL or other pipelines crossing the U.S., the responsibility for who cleans it up does not fall on TransCanada. According to a report from the Natural Resource Defense Council (NRDC), tar sand oils are exempt from paying into the Oil Spill Liability Trust Fund. Amendments that would require TransCanada to pay the 8-cent-per-barrel fee to the fund have not been passed.
Devastating oil spills such as the one in Santa Barbara in mid May reflect the impact it not only has on wildlife, but on the local culture, especially on those who depend on fisheries and whose lives revolves around surfing in the brisk waters of the Pacific Ocean. 21,000 gallons of crude oil covers roughly 4 miles of Santa Barbara’s coast now, extending about 50 yards into the water.
Jobs, jobs, jobs. The economic stimulus is one purported advantage to the XL pipeline. During construction, proposed project spending would support approximately 42,100 jobs, directly and indirectly and around $2 billion in earnings throughout the US, according to the final SEIS. Despite different job creation estimates, any number will contribute significantly to the US gross domestic product, associating a huge economic growth with the construction of the proposed XL pipeline. (TransCanada estimates around 13,000 construction jobs and 7,000 manufacturing jobs, which is about 3 times higher than the State Department’s estimate.) In addition, the cost of paying for the Keystone XL project ($3.3 billion) would not be placed on the U.S. but on Keystone.
According to the Pipeline and Hazardous Materials Safety Administration (PHSMA), the industry and their operators have reduced the risk of hazardous materials transportation incidents with death or major injury by 4% every 3 years, and since 2002, they have reduced the risk of a pipeline spill with environmental consequences by an average of 5% per year.1
Still, there is more work to be done. Safety issues that the pipeline industry is aiming to fix include:
- Infrastructure: Repair obsolete pipeline infrastructure through a pipeline integrity management program and investigate new technologies that can detect pipeline risks.
- Improving human error and safety culture: Increase the focus on safety beyond compliance standards and evaluate the potential value of safety management systems.
- Adding secondary containment: Limit the spread of HAZMAT in the event of a failure in the primary container, and improve leak detection.
- Transparency: Increasing transparency for companies and their accountability
Check out the infographic below for a summary of all of these pros and cons:
All methods of transporting oil present various risks and benefits based on the available data. Explaining both sides of this coin allows us to assess each method’s impacts on our economy, environment, and public health. Through these assessments, we can make more informed decisions on what truly serves the nation’s interests. Oil and gas transport is a dangerous business, but all transportation industries are improving their management programs and increasing their regulations to provide citizens peace of mind and the safety they deserve. In light of ongoing issues, however, some would ask if these risks are even necessary.
For example, the growth of safer energy resources such as solar energy would significantly cut down the risks mentioned above in addition to providing jobs and stimulating the overall economy. According to the Bureau of Labor Statistics and the Solar Foundation, the growth in direct industry jobs for solar has outweighed oil and gas for the past 3 years. In 2014, new jobs created for the solar industry were more than twice the jobs created for the oil and gas industry. Based on 2014’s economics, Kepler Cheuvreux stated that all renewables are already more competitive than oil priced at $100 per barrel — This is because renewables have a higher net energy return on capital invested (EROCI).
As a reader and a citizen, it is important to know the pros and cons of the current activities taking place in our country today. We must be aware of loopholes that may be putting our states, cities, or counties into harm’s way, as well as recognize alternative energy sources and regulatory oversight that lessen the threats that oil extraction and transport pose to our health and environment.
1. These statistics are based from the Census Bureau analysis and Bureau of Transportation Statistics as of July 2012.
By Randy Sargent, Carnegie Mellon CREATE Lab and Samantha Malone, FracTracker Alliance
In the past two years, crude oil trains have exploded 10 times, killing 47 people.
It could have been much worse. Eight of the ten trains exploded in rural areas. The train that flattened half the business district of the small town of Lac-Mégantic might have killed hundreds of people if it had exploded during business hours. Residents in Philadelphia have dodged a bullet several times already; they’ve seen two oil train derailments there that fortunately did not explode. And last week’s Amtrak train derailment in Philadelphia that killed 8 people and injured more than 200 could have been much worse, had it impacted an oil train in that area.
Today we ship 17 times as much oil by rail as we did in 2010. This past year we shipped 14.5 billion gallons of oil — that’s 6,700 oil trains the size that destroyed Lac-Mégantic:
This chart above and the ones that follow are derived from the U.S. Energy Information Administration’s recently provided data tracking crude oil movements by rail.
Why do oil trains explode so easily?
Like a carbonated beverage with dissolved CO2, oil extracted from Bakken wells naturally has lighter hydrocarbons in it, such as methane, ethane, propane, and butane. Methane — natural gas — is the lightest of the gases and boils out quickly at surface pressure. But ethane, propane, and butanes, known as light ends or natural gas liquids in the oil industry, take time and/or heat to boil out.
In the most prolific oilfield in the U.S. today, North Dakota’s Bakken formation, most of light ends are left in the oil before loading on the train, to maximize value of what is sent to the refinery. But much like a soda bottle, the pressure increases with temperature and motion, with pressurized ethane, propane, and butane at the top. With those highly volatile gases under pressure, all it takes to create an explosion is a leak and a spark, and both commonly happen in a derailment or collision.
All ten exploding crude trains carried oil from the Bakken.
In contrast, shale oilfields in Texas do stabilize crude by removing light ends prior to shipment by rail.
Where are the exploding Bakken oil trains going?
Bakken trains travel through much of the US and Canada, heading to refineries on the coasts. Increasingly, they are traveling to East coast refineries, which now handle over half of Bakken crude oil production.
Closer to home for the authors, Pittsburgh is a popular waypoint for Bakken oil trains. Known for its steel industry in the 20th century, Pittsburgh continues to sport a large rail infrastructure. Its rails go through very densely populated areas, a good thing when the rails carried ore and steel and coal for the mills. But it’s a disaster waiting to happen now that the rails are bringing explosive oil trains through the city.
A significant and growing fraction of Bakken oil trains carrying 1 million gallons or more transit Pittsburgh, with ~30 a week based on Pennsylvania Emergency Management Agency data released for five days in October 2014. Prior to the disclosure, volunteers spent a day with us in 2014 recording traffic along one of several routes into the city to learn more about whether / how the trains might pose a risk to city residents and workers. Learn more about what we found here.
Why does this matter?
As crude-by-rail traffic continues to increase, it is only a matter of time before an oil train explodes in a populated area again. Imagine any of the 10 explosions so far taking place instead in downtown Philadelphia or Pittsburgh, or flattening a school in suburban Chicago, for example.
Learn more about the Lac-Megantic disaster through the eyes of those who lived through it.
What can be done
One attempt to make these trains safer, by requiring new tanker cars be built to a safer standard, does not appear to have helped; the most recent 5 exploding trains used the newest, “safer” tanker cars.
But there are effective measures that are in our power to take:
- Stabilize Bakken oil before shipment, by removing the light ends (a.k.a. natural gas liquids), as is currently done in Texas.
- Reroute trains around densely populated areas. St Louis has been successful in this.
- If you are concerned about these oil trains, please engage in the democratic process and tell your representatives and friends what you think. The Department of Transportation regulates interstate rail traffic. And local governments can be effective in rerouting traffic, as we’ve seen in St. Louis.
- More ways to engage, at Forest Ethics
Photo and Video Credits
- Lac Mégantic: video by Jimmy Charbonneau, map by the Toronto Star
- Outside Aliceville, AL image from WBRC Fox 6
- Outside Casselton, ND video from CCTV News 24/7
- Outside Plaster Rock, New Brunswick video from Global News
- Outside Lynchburg, VA image by Paula Mays via Richmond Times-Dispatch
- Outside Mount Carbon, WV video via Guardian Wires
- Outside Galena, IL image via WKOW ABC 27
- Outside Gogama, Ontario image by Steve Patriquin via BayToday.ca
- Outside Heimdal, ND image by Jennifer Willis
- The direction that the ignited oil flowed after the incident also played a significant role in the path of the damage and fatalities.
- Light Ends information
One of the potentially troubling aspects of oil and gas development is that there are usually people who live in the vicinity of the wells. Pennsylvania now has over 8,000 active unconventional wells; there are any number of issues that can occur with these modern, industrial-scale sites, including road degradation, contaminated water, and health impacts, among others. In addition, there are over 93,000 of the smaller, conventional wells in operation throughout the Commonwealth. While these garner far less attention than their unconventional counterparts, they are also prone to producing similar impacts, not to mention that since many of them are older wells, they not only have potentially been subject to deterioration and occasional neglect, but were constructed during a period with less stringent requirements than are currently expected.
Petroleum engineers are now capable of drilling horizontally for tens of thousands of feet. For the most part, however, this technology is employed to maximize production, rather than to ameliorate impacts on people who live near the product. But who are these people? To help to answer this question, the FracTracker Alliance calculated the number of people living in a half-mile radius around active wells in the state.
More than 1.2 million Pennsylvanians live within the impact area.
Of the 93,754 wells that have been drilled in the state since 1950 that have not yet been plugged, the Pennsylvania DEP only has location data for 79,118 of them. All but one of the 14,636 missing locations are for wells that are categorized as Conventional. While one must presume that there is some overlap in coverage within the half-mile zone, the extent of this region – and therefore the population that lives within it – cannot be determined.
Fig. 1. PA Populations Near Oil and Gas Wells. Click here to access written description and additional map tools.
To maximize the reliability of our calculations, this map was created using a custom Albers equal-area projection centered on Pennsylvania. A half-mile buffer around each well type was created, and the resulting layer was clipped to Census tract data. The ratio of the smaller clipped area to the full Census tract area was calculated, and that ratio was then multiplied by the population totals from the 2010 Census to obtain our population estimates of the half-mile zone. The area in the study area is larger than six states, while the calculated population is larger than that of eight states.
The county most impacted, in terms of area, for unconventional wells is Bradford, with 353 square miles (See Figure 2). Washington County had the most people living in the zone, however, with 20,566. For conventional wells, the drilling landscape is the largest in Indiana County, affecting 761 square miles, while Erie County has the most people in the half-mile zone, with 212,900. When considering all wells together, the numbers are almost identical to conventional wells. Indiana County leads with 762 square miles, while the drill zone in Erie County represents 211,903 people, or 76% of the county’s population in 2010.
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