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Urban Drilling in Los Angeles

Impact of a 2,500′ Oil and Gas Well Setback in California

Why does California need setbacks?

A new bill proposed by California State Assembly Member Al Muratsuchi (D), AB345, seeks to establish a minimum setback distance of 2,500′ between oil and gas wells and sensitive sites including occupied dwellings, schools, healthcare facilities, and playgrounds. A setback distance for oil and gas development is necessary from a public health standpoint, as the literature unequivocally shows that oil and gas wells and the associated infrastructure pose a significant risk to the communities that live near them.

FracTracker Alliance conducted a spatial analysis to understand the impact a 2,500’ well setback would have on oil and gas expansion in California. In a previous report, The Sky’s Limit California (Oil Change Internal, 2018), Fractracker data showed that 8,493 active or newly permitted oil and gas wells were located within a 2,500’ buffer of sensitive sites. At the time it was estimated that 850,000 Californians lived within the setback distance of at least one of these oil and gas wells.

This does not bode well for Californians, as a recently published FracTracker literature review found that health impacts resulting from living near oil and gas development include cancer, infant mortality, depression, pneumonia, asthma, skin-related hospitalizations, and other general health symptoms. Studies also showed that health impacts increased with the density of oil and gas development, suggesting that health impacts are dose dependent. Living closer to more oil and gas sites means you are exposed to more health-threatening contamination.

An established setback is therefore necessary to alleviate some of these health burdens carried by the most vulnerable Environmental Justice (EJ) communities. Health assessments by the Los Angeles County Department of Health and studies on ambient air quality near oil fields by Occidental College Researchers support the assumption that 2,500′ is the necessary distance to help alleviate the harsh conditions of degraded air quality. Living at a distance beyond 2,500′ from an oil and gas site does not mean you are not impacted by air and water contamination. Rather the concentrations of contaminants will be less harmful. In fact studies showed that health impacts increased with proximity to oil and gas, with associated impacts potentially experienced by communities living at distances up to 9.3 miles (Currie et al. 2017) and 10 miles (Whitworth et al. 2017).

Assembly Bill 345

This analysis assesses the potential impact of State Assembly member Al Muratsuchi’s Assembly Bill 345 on California’s oil and gas extraction and production. Specifically, AB345 establishes a minimum 2,500’ setback requirement for future oil and gas development. It does not however directly address existing oil and gas permits.

The bill includes the following stipulations and definitions:

  • All new oil and gas development, that is not on federal land, are required to be located at least 2,500′ from residences, schools, childcare facilities, playgrounds, hospitals, or health clinics.
  • In this case the redrilling of a previously plugged and abandoned oil or gas well or other rework operation is to be considered new oil and gas development.
  • “Oil and gas development” means exploration for and drilling production and processing of oil, gas or other gaseous and liquid hydrocarbons; the flowlines; and the treatment of waste associated with that exploration, drilling, production, and processing.
  • “Oil and gas development” also includes hydraulic fracturing and other stimulation activities.
  • “Rework operations” means operations performed in the well bore of an oil or gas well after the well is completed and equipped for production, done for the purpose of securing, restoring, or improving hydrocarbon production in the subsurface interval that is the open to production in the well bore.
  • The bill does not include routine repairs or well maintenance work.

Map

Figure 1. Map of Wells within a 2,500′ Setback Distance from Sensitive Receptor Sites. The map below shows the oil and gas wells and permits that fall within the 2,500′ setback distance from sensitive receptor sites.  Summaries of these well counts and discussions of these well types are included below as well.

Map of Wells within a 2,500′ Setback Distance from Sensitive Receptor Sites

View map fullscreen | How FracTracker maps work

 

Environmental Justice

The California Environmental Justice Alliance (CEJA) has just released their 2018 Environmental Justice Agency Assessment, which used FracTracker’s data and mapping to assess environmental equity in the state regulation of oil permitting and drilling. The report issued the Division of Oil, Gas, and Geothermal Resources (DOGGR) a failing grade of ‘F’. According to the report, “DOGGR is aware that the proposed locations of many drilling activities are in or near EJ communities, but approves permits irrespective of known health and safety risks associated with neighborhood drilling.”

FracTracker’s analysis of low income communities in Kern County shows the following:

  • There are 16,690 active oil and gas production wells located in census blocks with median household incomes of less than 80% of Kern’s area median income (AMI).
  • Therefore about 25% (16,690 out of 67,327 total) of Kern’s oil and gas wells are located within low-income communities.
  • Of these 16,690 wells, 5,364 of them are located within the 2,500′ setback distance from sensitive receptor sites such as schools and hospitals (32%) vs 13.1% for the rest of the state.

For more information on the breakdown of Kern County wells, see our informational table, here.

DOGGR wells

Using freshly published Division of Oil, Gas, and Geothermal Resources (DOGGR) data (6/3/19), we find that there are 9,835 active wells that fall within the 2,500’ setback distance, representing 13.1% of the total 74,775 active wells in the state.

There are 6,558 idle wells that fall within the 2,500’ setback distance, of nearly 30,000 total idle wells in the state. Putting these idle wells back online would be blocked if the wells require reworks to restart or ramp up production. For the most part operators do not intend for most idle wells to come back online. Rather operators are just avoiding the costs of plugging and properly abandoning the wells. To learn more about this issue, see our recent coverage of idle wells here.

Of the 3,783 permitted wells not yet in production, or “new wells,” 298 (7.8%) are located within the 2,500’ buffer zone.

Getting a count of plugged wells within the setback distance is more difficult because there is not a complete dataset, but there are over 30,000 wells in areas with active production that would be blocked from being redrilled. In total there are 122,209 plugged wells listed in the DOGGR database.

Permits

We also looked at permit applications that were approved in 2018, including permits for drilling new wells, well reworks, deepening wells and well sidetracks. This may be the most insightful of all the analyses.

Within the 2018 permit data, we find that 4,369 permits were approved. Of those 518 permits (about 12%) were granted within the proposed 2,500’ setback. Of the permits 25% were for new drilling, 73% were for reworks, and 2% were for deepening existing wells. By county, 42% were in Kern, 24% were in Los Angeles, 14% in Ventura, 6% in Santa Barbara, 3% in Fresno, and 2% or less in Glenn, Monterey, Sutter, San Joaquin, Colusa, Solano, Orange and Tehama, in descending order.

SCAQMD Notices

In LA, Rule 1148.2 requires operators to notify the South Coast Air Quality Management District (SCAQMD) of activities at well sites, including stimulations and reworks. These data points are reiterative of the “permits” discussed above, but the dataset is specific to the SCAQMD and includes additional activities. Of the 1,361 reports made to the air district since the beginning of 2018 through April 1, 2019; 634 (47%) were for wells that would be impacted by the setback distance; 412 incidences were for something other than “well maintenance” of which 348 were for gravel packing, 4 for matrix acidizing, and 65 were for well drilling. We are not sure where gravel packing falls, in reference to AB345.

A major consideration is that this rule may force many active wells into an idle status. If the onus of plugging wells falls on the state, these additional idle wells could be a major liability for the public. Fortunately AB1328 recently defined new idle well rules. The rules entice operators to plug and abandon idle wells. If rule 1328 is effective at reducing the stock of idle wells, these two bills could complement each other. (For more information on idle wells, read FracTracker’s recent analysis, here: https://www.fractracker.org/2019/04/idle-wells-are-a-major-risk/)

State Bill 4 Well Stimulation Reporting

We also analyzed data reported to DOGGR under the well stimulation requirements of CA State Bill 4 (SB4), the 2013 bill that set a framework for regulating hydraulic fracturing in California. Part of the bill required an independent scientific study to be conducted on oil and gas well stimulation, including acid well stimulation and hydraulic fracturing. Since 2016 operators have been required to secure special permits to stimulate wells, which includes hydraulic fracturing and several other techniques. To learn more about this state regulation read FracTracker’s coverage of SB4. From January 1, 2016 to April 1, 2019, there have been 576 well stimulation treatment permits granted under the SB4 regulations. Only 1 hydraulic fracturing event, permitted in Goleta, would have been impacted by a 2,500’ setback in 2018.

Support for AB345

After being approved by the CA Assembly Natural Resources Committee in a 7-6 vote, the bill did not make it up for a vote in the Senate Appropriations Committee during the 2019 legislative session.  The bill was described by the committee as “promising policies that need more time for discussion.” AB345 is now a two-year bill in the state Senate and will be reconsidered by the committee in January of 2020. The Chairperson of the Appropriations Committee, Lorena Gonzalez, indicated her general support for the policy and committed to working with the author to find a way to move the bill forward at the end of the session.

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance 

Feature image by David McNew, Getty Images

For schools and hospitals analysis, 2017

How close are schools and hospitals to drilling activity in West Virginia and Ohio?

A review of WV and OH drilling activity and its proximity to schools and medical facilities

Schools and hospitals represent places where vulnerable populations may be put at risk if they are located close to oil and gas activity. Piggybacking on some elegant work from PennEnvironment (2013) and Physicians, Scientists, and Engineers (PSE) Healthy Energy (PDF) in Pennsylvania, below is an in-depth look at the proximity of unconventional oil and gas (O&G) activity to schools and hospitals in Ohio and West Virginia.

Ohio Schools and Medical Facilities

In Ohio, presently there are 13 schools or medical facilities within a half-mile of a Utica and/or Class II injection well and an additional 344 within 2 miles (Table 1 and map below). This number increases to 1,221 schools or medical facilities when you consider those within four miles of O&G related activity.

Map of OH Drilling and Disposal Activity Near Schools, Medical Facilities

View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Table 1. Number of OH schools and hospitals within certain distances from Utica wells

Utica Class II Injection
Well Distance (Miles) Schools Medical Facilities Schools Medical Facilities
0.5 3 1 9 0
0.5-1 19 (22) 9 (10) 16 (25) 13 (13)
1-2 79 (101)  41 (51) 88 (113) 79 (92)
2-3 84 (185) 49 (100) 165 (278) 122 (214)
3-4 85 (270) 79 (179) 168 (446) 112 (326)
4-5 92 (362) 63 (242) 196 (642) 166 (492)
5-10 388 (750) 338 (580) 796 (1,438) 584 (1,076)

Ohio’s rate of Utica lateral permitting has jumped from an average of 39 per month all-time to 66 per month in the last year. OH’s drilling activity has also begun to spread to outlying counties[1]. As such, we thought a proactive analysis should include a broader geographic area, which is why we quantified the number of schools and medical facilities within 5 and 10 miles of Utica and Class II activity (Figures 1 and 2). To this end we found that ≥50% of Ohio’s schools, both public and private, are within 10 miles of this industry. Similarly 50% of the state’s medical facilities are within 10 miles of Utica permits or Class II wells.

Footnote 1: Eleven counties in Ohio are currently home to >10 Utica permits, while 23 are home to at least 1 Utica permit.


Figures 1, 2a, 2b (above). Click to expand.

Grade Level Comparisons

With respect to grade level, the majority of the schools in question are elementary schools, with 40-50 elementary schools within 2-5 miles of Ohio Utica wells. This number spikes to 216 elementary schools within ten miles of Utica permits along with an additional 153 middle or high Schools (Figure 3). Naturally, public schools constitute most of the aforementioned schools; there are approximately 75 within five miles of Utica permits and 284 within ten miles of Utica activity (Figure 4).


Figures 3 and 4 (above). Click to expand.

Public Schools in Ohio

We also found that ~4% of Ohio’s public school students attend a school within 2 miles of the state’s Utica and/or Class II Injection wells (i.e., 76,955 students) (Table 2). An additional 315,362 students or 16% of the total public school student population, live within five miles of O&G activity.

Table 2. Number of students in OH’s public schools within certain distances from Utica and Class II Injection wells

Utica Class II Injection
Well Distance (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 3 1,360 453 7 3,312 473
<1 21 7,910 377 19 7,984 420
<2 96 35,390 376 90 41,565 462
<3 169 67,713 401 215 104,752 487
<4 241 97,448 404 350 176,067 503
<5 317 137,911 435 505 254,406 504
<10 600 280,330 467 1,126 569,343 506

(Note: Ohio’s population currently stands at 11.59 million people; 2,007,667 total students).

The broadest extent of our study indicates that 42% of Ohio students attend school within ten miles of a Utica or Class II Injection well (Figure 5). As the Ohio Utica region expands from the original 11 county core to include upwards of 23-25 counties, we expect these 5-10 mile zones to be more indicative of the type of student-Utica Shale interaction we can expect to see in the near future.


Photos of drilling activity near schools, and Figure 5 (above). Click to expand.

Private Schools in Ohio

At the present time, less than one percent of Ohio’s private school students attend a school within 2 miles of Utica and/or Class II Injection wells (specifically, 208 students). An additional 11,873 students or 11% of the total student population live within five miles. When you broaden the extent, 26% of Ohio’s private primary and secondary school students attend school daily within ten miles of a Utica or Class II Injection well. Additionally, the average size of schools in the immediate vicinity of Utica production and waste activity ranges between 11 and 21 students, while those within 2-10 miles is 112-159 students. Explore Table 3 for more details.

Table 3. Number of students in Ohio’s private schools within certain distances from Utica and Class II Injection.

Utica Class II Injection
Distance from Well (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 . . . 1 . .
<1 . . . 2 25 13
<2 2 22 11 9 186 21
<3 7 874 125 30 4,460 149
<4 12 1,912 159 45 6,303 140
<5 21 2,471 118 61 9,610 158
<10 60 6,727 112 135 20,836 154

West Virginia Schools and Students

Twenty-eight percent (81,979) of West Virginia’s primary and secondary school students travel to a school every day that is within two miles of the state’s Marcellus and/or Class II Injection wells.

Map of WV Marcellus Activity and Schools

View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Compared with Ohio, 5,024 more WV students live near this industry (Table 4). An additional 97,114 students, or 34% of the West Virginia student population, live within 5 miles of O&G related wells. The broadest extent of our study indicates that more than 90% of West Virginia students attend school daily within 10 miles of a Marcellus and/or Class II Injection well.

figure6

Figure 6. West Virginia primary and secondary schools, Marcellus Shale wells, and Class II Injection wells (Note: Schools that have not reported enrollment figures to the WV Department of Education are highlighted in blue). Click image to expand.

It is worth noting that 248 private schools of 959 total schools do not report attendance to the West Virginia Department of Education, which means there are potentially an additional 69-77,000 students in private/parochial or vocational technology institutions unaccounted for in this analysis (Figure 6). Finally, we were not able to perform an analysis of West Virginia’s medical facility inventory relative to Marcellus activity because the West Virginia Department of Health and Human Resources admittedly did not have an analogous, or remotely complete, list of their facilities. The WV DHHR was only able to provide a list of Medicaid providers and the only list we were able to find was not verifiable and was limited to hospitals only.

Table 4. Number of students in WV schools within certain distances from Shale and Class II Injection wells

Marcellus Class II Injection
Distance from Well (Miles) # Sum Avg # Sum Avg
0.5 19 5,674 299 1 . .
<1 52 (71) 16,992 (22,666) 319 5 (6) 1,544 257
<2 169 (240) 52,737 (75,403) 314 16 (22) 5,032 (6,576) 299
<3 133 (373) 36,112 (111,515) 299 18 (40) 6,132 (12,708) 318
<4 88 (461) 25,037 (136,552) 296 21 (61) 5,235 (17,943) 294
<5 56 (517) 15,685 (152,237) 295 26 (87) 8,913 (26,856) 309
<10 118 (635) 37,131 (189,368) 298 228 (315) 69,339 (96,195) 305
Note: West Virginia population currently stands at 1.85 million people; 289,700 total students with 248 private schools of 959 total schools not reporting attendance, which means there are likely an additional 69-77,000 students in Private/Parochial or Vocational Technology institutions unaccounted for in this analysis.

Conclusion

A Trump White House will likely mean an expansion of unconventional oil and gas activity and concomitant changes in fracking waste production, transport, and disposal. As such, it seems likely that more complex and broad issues related to watershed security and/or resilience, as well as related environmental concerns, will be disproportionately forced on Central Appalachian communities throughout Ohio and West Virginia.

Will young and vulnerable populations be monitored, protected, and educated or will a Pruitt-lead EPA pursue more laissez-faire tactics with respect to environmental monitoring? Stay Tuned!

Analysis Methods

The radii we used to conduct this assessment ranged between ≤ 0.5 and 5-10 miles from a Utica or Marcellus lateral. This range is larger than the aforementioned studies. The point of using larger radii was to attempt to determine how many schools and students, as well as medical facilities, may find themselves in a more concentrated shale activity zone due to increased permitting. Another important, related issue is the fact that shale O&G exploration is proving to be more diffuse, with the industry exploring the fringes of the Utica and Marcellus shale plays. An additional difference between our analysis and that of PennEnvironment and PSE Healthy Energy is that we looked at identical radii around each state’s Class II Injection well inventory. We included these wells given the safety concerns regarding:

  1. their role in induced seismicity,
  2. potential water and air quality issues, and
  3. concomitant increases in truck volumes and speeds.

Data Downloads for Maps Above


By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Mariner East 2: At-Risk Schools and Populations

by Kirk Jalbert, Manager of Community-Based Research & Engagement
with technical assistance from Seth Kovnant

 

In September, the Pennsylvania Department of Environmental Protection (DEP) rejected a number of permits for wetland crossings and sedimentation control that were required for Sunoco Pipeline’s proposed “Mariner East 2” pipeline. According to Sunoco, the proposed Mariner East 2 is a $2.5 billion, 350-mile-long pipeline that would be one of the largest pipeline construction projects in Pennsylvania’s history.

If built, Mariner East 2 could transport up to 450,000 barrels (18,900,000 gallons) per day of propane, ethane, butane, and other liquefied hydrocarbons from the shale fields of western Pennsylvania to export terminals in Marcus Hook, located just outside Philadelphia. A second proposed pipeline, if constructed, could carry an additional 250,000 barrels (10,500,000 gallons) per day of these same materials. Sunoco submitted revised permit applications to PADEP on Tuesday, December 6th.

The industry often refers to ethane, propane and butane collectively as “natural gas liquids.” They are classified by the federal government as “hazardous, highly volatile liquids,” but that terminology is also misleading. These materials, which have not been transported through densely populated southeast Pennsylvania previously, are liquid only at very high pressure or extremely cold temperatures. At the normal atmospheric conditions experienced outside the pipeline, these materials volatilize into gas which is colorless; odorless; an asphyxiation hazard; heavier than air; and extremely flammable of explosive. This gas can travel downhill and downwind for long distances while remaining combustible. It can collect (and remain for long periods of time) in low-lying areas; and things as ordinary as a cell phone, a doorbell or a light switch are capable of providing an ignition source.

Many who have followed the proposed Mariner East 2 project note that, while much has been written about the likely environmental impacts, insufficient investigation has been conducted into safety risks to those who live, work and attend schools in the proposed pipeline’s path. We address these risks in this article, and, in doing so, emphasize the importance of regulatory agencies allowing public comments on the project’s resubmitted permit applications.

The Inherent Risks of Artificially Liquified Gas

Resident of Pennsylvania do not need to look far for examples of how pipeline accidents pose serious risk. For instance, the 2015 explosion of the Enterprise ATEX (Appalachia to Texas) pipeline near Follansbee, WV, provides a depiction of what a Mariner East 2 pipeline failure could look like. This 20-inch diameter pipeline carrying liquid ethane is similar in many ways to the proposed Mariner East 2. When it ruptured in rural West Virginia, close to the Pennsylvania border, it caused damage in an area that extended 2,000 feet—about ½ square mile—from the place where the pipeline failed.

In another recent instance, the Spectra Energy Texas Eastern methane natural gas pipeline ruptured in Salem, PA, this April as a result of corroded welding. The explosion, seen above (photo by PA NPR State Impact), completely destroyed a house 200ft. away. Another house, 800ft. away, sustained major damage and its owner received 3rd degree burns. These incidents are not unique. FracTracker’s recent analysis found that there have been 4,215 pipeline incidents nation-wide since 2010, resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion (“incident” is an industry term meaning “a pipeline failure or inadvertent release of its contents.” It does not necessarily connote “a minor event”).

Calculating Immediate Ignition Impact Zones

It is difficult to predict the blast radius for materials like ethane, propane and butane. Methane, while highly flammable or explosive, is lighter than air and so tends to disperse upon release into the atmosphere. Highly volatile liquids like ethane, propane and butane, on the other hand, tend to concentrate close to the ground and to spread laterally downwind. A large, dispersed vapor cloud of these materials may quickly spread great distances, even under very light wind conditions. A worst-case scenario would by highly variable since gas migration and dispersion is dependent on topography, leak characteristics, and atmospheric conditions. In this scenario, unignited gas would be allowed to migrate as an unignited vapor cloud for a couple miles before finding an ignition source that causes an explosion that encompasses the entire covered area tracing back to the leak source. Ordinary devices like light switches or cell phones can serve as an ignition source for the entire vapor cloud. One subject matter expert recently testified before a Municipal Zoning Hearing board that damage could be expected at a distance of three miles from the source of a large scale release.

The federal government’s “potential impact radius” (PIR) formula, used for natural gas (methane) isn’t directly applicable because of differences in the characteristics of the material. It may however be possible to quantify an Immediate Ignition Impact Zone. This represents the explosion radius that could occur if ignition occurs BEFORE the gas is able to migrate.

The Pipeline and Hazardous Materials Safety Administration (PHMSA) provides instructions for calculating the PIR of a methane natural gas pipeline. The PIR estimates the range within which a potential failure could have significant impact on people or property. The PIR is established using the combustion energy and pipeline-specific fuel mass of methane to determine a blast radius: PIR = 0.69*sqrt(p*d^2). Where: PIR = Potential Impact Radius (in feet), p = maximum allowable operating pressure (in pounds per square inch), d = nominal pipeline diameter (in inches), and 0.69 is a constant applicable to natural gas

The Texas Eastern pipeline can use the PIR equation as-is since it carries methane natural gas. However, since Mariner East 2 is primarily carrying ethane, propane, and butane NGLs, the equation must be altered. Ethane, propane, butane, and methane have very similar combustion energies (about 50-55 MJ/kg). Therefore, the PIR equation can be updated for each NGL based on the mass density of the flow material as follows: PIR = 0.69*sqrt(r*p*d^2). Where: r = the density ratio of hydrocarbons with similar combustion energy to methane natural gas. At 1,440 psi, methane remains a gas with a mass density 5 times less than liquid ethane at the same pressure:

ME2 PIR table 1

The methane density relationships for ethane, propane, and butane can be used to calculate an immediate-ignition blast radius for each hydrocarbon product. The below table shows the results assuming a Mariner East 2-sized 20-inch diameter pipe operating at Mariner East 2’s 1,440psi maximum operating pressure:

ME2 PIR table 2

Using these assumptions, the blast radius can be derived as a function of pressure for each hydrocarbon for the same 20in. diameter pipe:

ME2 Immediate Ignition Blast Radius

ME2 Immediate Ignition Blast Radius

Note the sharp increase in blast radius for each natural gas liquid product. The pressure at which this sharp increase occurs corresponds with the critical pressure where each product transitions to a liquid state and becomes significantly denser, and in turn, contains more explosive power. These products will always be operated above their respective critical pressures when in transport, meaning their blast radius will be relatively constant, regardless of operating pressure.

Averaging the “Immediate Ignition Blast Radius” for ethane, propane, and butane gives us a 1,300 ft (about 0.25 mile) potential impact radius. However, we must recognize that this buffer represents a best case scenario in the event of a major pipeline accident.

Additional information on these calculations can be found in the Delaware County-based Middletown Coalition for Community Safety’s written testimony to the Pennsylvania Legistlature.

Living near the Mariner East 2

FracTracker has created a new map of the Mariner East 2 pipeline using a highly-detailed GIS shapefile recently supplied by the DEP. On this map, we identify a 0.5 mile radius “buffer” from Mariner East 2’s proposed route. We then located all public and private schools, environmental justice census tracts, and estimated number of people who live within this buffer in order to get a clearer picture of the pipeline’s hidden risks.

Proposed Mariner East 2  and At-Risk Schools and Populations

View map fullscreenHow FracTracker maps work

 

Populations at Risk

In order to estimate the number of people who live within this 0.5 mile radius, we first identified census blocks that intersect the hazardous buffer. Second, we calculated the percentage of that census block’s area that lies within the buffer. Finally, we used the ratio to determine the percentage of the block’s population that lies within the buffer. In total, there are an estimated 105,419 people living within the proposed Mariner East 2’s 0.5 mile radius impact zone. The totals for each of the 17 counties in Mariner East 2’s trajectory can be found in the interactive map. The top five counties with the greatest number of at-risk residents are:

  1. Chester County (31,632 residents in zone)
  2. Delaware County (17,791 residents in zone)
  3. Westmoreland County (11,183 residents in zone)
  4. Cumberland County (10,498 residents in zone)
  5. Berks County (7,644 residents in zone)

Environmental Justice Areas

Environmental justice designations are defined by the DEP as any census tract where 20% or more of the population lives in poverty and/or 30% or more of the population identifies as a minority. These numbers are based on data from the U.S. Census Bureau, last updated in 2010, and by the federal poverty guidelines. Mariner East 2 crosses through four environmental justice areas:

  • Census Tract 4064.02, Delaware County
  • Census Tract 125, Cambria County
  • Census Tract 8026, Westmoreland County
  • Census Tract 8028, Westmoreland County

DEP policies promise enhanced public participation opportunities in environmental justice communities during permitting processes for large development projects. No additional public participation opportunities were provided to these communities. Furthermore, no public hearings were held whatsoever in Cambria County and Delaware County. The hearing held in Westmoreland County took place in Youngwood, nine miles away from Jeanette. Pipelines are not specified on the “trigger list” that determines what permits receive additional scrutiny, however the policy does allow for “opt-in permits” if the DEP believes they warrant special consideration. One would assume that a proposed pipeline project with the potential to affect the safety of tens of thousands of Pennsylvanians qualifies for additional attention.

At-Risk Schools

One of the most concerning aspects of our findings is the astounding number of schools in the path of Mariner East 2. Based on data obtained from the U.S. Department of Education on the locations of schools in Pennsylvania, a shocking 23 public (common core) schools and 17 private schools were found within Mariner East 2’s 0.5 mile impact zone. In one instance, a school was discovered to be only 7 feet away from the pipeline’s intended path. Students and staff at these schools have virtually no chance to exercise their only possible response to a large scale release of highly volatile liquids, which is immediate on-foot evacuation.

me2-middletown-high

Middletown High School in Dauphin County in close proximity to ME2

One reason for the high number of at-risk schools is that Mariner East 2 is proposed to roughly follow the same right of way as an older pipeline built in the 1930s (now marketed by Sunoco as “Mariner East 1.”). A great deal of development has occurred since that time, including many new neighborhoods, businesses and public buildings. It is worth noting that the U.S. Department of Education’s data represents the center point of schools. In many cases, we found playgrounds and other school facilities were much closer to Mariner East 2, as can be seen in the above photograph. Also of note is the high percentage of students who qualify for free or reduced lunch programs at these schools, suggesting that many are located in disproportionately poorer communities.

 

Conclusion

Now that PADEP has received revised permit applications from Sunoco, presumably addressing September’s long list of technical deficiencies, the agency will soon make a decision as to whether or not additional public participation is required before approving the project. Given the findings in our analysis, it should be clear that the public must have an extended opportunity to review and comment on the proposed Mariner East 2. In fact, public participation was extremely helpful to DEP in the initial review process, providing technical and contextual information.

It is, furthermore, imperative that investigations into the potential impacts of Mariner East 2 extend to assess the safety of nearby residents and students, particularly in marginalized communities. Thus far, no indication has been made by the DEP that this will be the case. However, the Pennsylvania Sierra Club has established a petition for residents to voice their desire for a public comment period and additional hearings.

Seth Kovnat is the chief structural engineer for an aerospace engineering firm in Southeastern PA, and regularly consults with regard to the proposed Mariner East 2 pipeline. In November, Seth’s expertise in structural engineering and his extensive knowledge of piping and hazardous materials under pressure were instrumental in providing testimony at a Pennsylvania Senate and House Veterans Affairs and Emergency Preparedness Committee discussion during the Pennsylvania Pipeline Infrastructure Citizens Panel. Seth serves on the board of Middletown Coalition for Community Safety and is a member of the Mariner East 2 Safety Advisory Committee for Middletown Township, PA. He is committed to demonstrating diligence in gathering, truth sourcing, and evaluating technical information in pipeline safety matters in order to provide data driven information-sharing on a community level.

NOTE: This article was modified on 12/9/16 at 4pm to provide additional clarification on how the 1,300ft PIR was calculated.

Drilling Bella Romero: Children at Risk in Greeley, Colorado

By
Kirk Jalbert, Manager of Community Based Research & Engagement
Kyle Ferrar, Western Program Coordinator

Weld County, Colorado, is one of the top producing shale oil and gas regions in the United States, boasting more than 12,000 active horizontal or directional wells, which account for 50% of all horizontal or directional wells in the state. To put this into perspective, the entire state of Pennsylvania has ten times the land area with “only” 9,663 horizontal or directional wells. At the center of Weld County is the city of Greeley, population 92,889. Greeley has experienced dramatic changes in the past decade as extraction companies compete to acquire oil and gas mineral rights. Extensive housing developments on the outskirts of the city are being built to accommodate future well pads on neighboring lots. Meanwhile, a number of massive well pads are proposed within or on the border of city limits.

FracTracker visited Colorado back in November 2015 and met with regional advocacy organizations including Coloradans Against Fracking, Protect our Loveland, Weld Air and Water, and Our Longmont to determine how we could assist with data analysis, mapping, and digital storytelling. FracTracker returned in June 2016 to explore conditions unique to Weld County’s oil and gas fields. During our visit we interviewed residents of Greeley and found that one of their greatest concerns was the dangers of siting oil and gas wells near schools. While there is much more we will be publishing in coming weeks about our visit, this article focuses on one troubling project that would bring gas drilling to within 1,300ft of a public school. The proposal goes before the Weld County Commissioners on Wednesday, June 29th for final approval. As such, we will be brief in pointing out what is at stake in siting industrial oil and gas facilities near schools in Colorado and why residents of Greeley have cause for concern.

Drilling Bella Romero

On June 7th, the Weld County Planning Commission unanimously approved a proposal from Denver-based Extraction Oil & Gas to develop “Vetting 15H”—a 24-head directional well pad in close proximity to Bella Romero Academy, a middle school just outside Greeley city limits. In addition to the 24-head well pad would be a battery of wastewater tanks, separators, and vapor recovery units on an adjacent lot. The permit submitted to the Colorado Oil & Gas Conservation Commission (COGCC) also states that six more wells may be drilled on the site in the future.

As was detailed in a recent FracTracker article, Colorado regulations require a minimum setback distance of 500ft from buildings and an additional 350ft from outdoor recreational areas. In more populated areas, or where a well pad would be within 1,000ft of high occupancy buildings, schools, and hospitals, drilling companies must apply for special variances to minimize community impacts. Setbacks are measured from the well head to the nearest wall of the building. For well pads with multiple heads, each well must comply with the respective setback requirements.

bella_romero_playground

Bella Romero’s playground with Vetting 15H’s proposed site just beyond the fence.

Vetting 15H would prove to be one of the larger well pads in the county. And while its well heads remain just beyond the 1,000ft setback requirement from Bella Romero buildings, a significant portion of the school’s ballfields are within 1,000ft of the proposed site. When setbacks for the well pad and the processing facility are taken together—something not explicitly demonstrated in the permit—almost the entirety of school grounds are within 1,000ft and the school itself lies only 1,300ft from the pad. The below figures show the images supplied by Extraction Oil & Gas in their permit as well as a more detailed graphic generated by FracTracker.

 

Youth: A High Risk Population

The difference between 1,000ft and 1,300ft may be negligible when considering the risks of locating industrial scale oil and gas facilities near populated areas. The COGCC has issued 1,262 regulatory violations to drilling companies since 2010 (Extraction Oil & Gas ranks 51st of 305 operators in the state for number of violations). Some of these violations are for minor infractions such as failing to file proper paperwork. Others are for major incidents; these issues most often occur during the construction phases of drilling, where a number have resulted in explosions and emergency evacuations. Toxic releases of air and water pollution are not uncommon at these sites. In fact, the permit shows drainage and potential spills from the site would flow directly towards Bella Romero school grounds as is shown in the figure below.

Vetting 15H post-development drainage map.

Vetting 15H post-development drainage map.

A host of recent research suggests that people in close proximity to oil and gas wells experience disproportionate health impacts. Emissions from diesel engine exhaust contribute to excessive levels of particular matter, and fumes from separators generate high levels of volatile organic compounds. These pollutants decrease lung capacity and increase the likelihood of asthma attacks, cardiovascular disease, and cancer (read more on that issue here). Exposure to oil and gas facilities is also linked to skin rashes and nose bleeds.

As we’ve mentioned in our analysis of oil and gas drilling near schools in California, children are more vulnerable to these pollutants. The same amount of contaminants entering a child’s body, as opposed to an adult body, can be far more toxic due to differences in body size and respiratory rates. A child’s developing endocrine system and neural pathways are also more susceptible to chemical interactions. These risks are increased by children’s lifestyles, as they tend to spend more hours playing outdoors than adults and, when at school, the rest of their day is spent at a central location.

At the June 7th public hearing Extraction Oil & Gas noted that they intend to use pipelines instead of trucks to transport water and gas to and from Vetting 15H to reduce possible exposures. But, as residents of Greeley noted of other projects where similar promises were made and later rescinded, this is dependent on additional approvals for pipelines. Extraction Oil & Gas also said they would use electric drilling techniques rather than diesel engines, but this would not eliminate the need for an estimated 22,000 trucking runs over 520 days of construction.

Below is a table from the Vetting 15H permit that shows daily anticipated truck traffic associated with each phase of drilling. The estimated duration and operational hours of each activity are based on only 12 wells since construction is planned in two phases of 12 wells at a time. These numbers do not account for the trucking of water for completions activities, however. The figures could be much higher if pipelines are not approved, as well as if long-term trucking activities needed to maintain the site are included in the estimates.

Vetting 15H daily vehicle estimates.

Vetting 15H daily vehicle estimates from permit

 

At the Top of the Most Vulnerable List

Bella Romero Academy has the unfortunate distinction of being one of the few schools in Colorado in close proximity to a horizontal or directional well amongst 1,750 public and 90 private schools in the state. Based on our analysis, there are six public schools within 1,000ft of a horizontal or directional well. At 2,500ft we found 39 public schools and five private schools. Bella Romero is presently at the top of the list of all schools when ranked by number of well heads located within a 1,000ft buffer. An 8-head well pad is only 800ft across the street from its front door. If the Vetting 15H 24-head well pad was to be constructed, Bella Romero would be far and above the most vulnerable school within 1,000ft of a well. It would also rank 3rd in the state for well heads located within 2,500ft of a school. The tables below summarize our findings of this proximity analysis.

Colorado public schools within 1,000ft of a horizontal or directional well

Colorado public schools within 1,000ft of a horizontal or directional well

Colorado public schools within 2,500ft of a horizontal or directional well with 5 or more well heads. There are 39 schools in total.

Colorado public schools within 2,500ft of a horizontal or directional well with 5 or more well heads. There are 39 schools in total

Colorado private schools within 2,500ft of a horizontal or directional well

Colorado private schools within 2,500ft of a horizontal or directional well

The following interactive map shows which schools in Colorado are within a range of 2,500ft from a directional and horizontal well. Additional buffer rings show 1,000ft and 500ft buffers for comparison. 1,000ft was selected as this is the minimum distance required by Colorado regulations from densely populated areas and schools without requiring special variances. Environmental advocacy groups are presently working to change this number to 2,500ft. The map is zoomed in to show the area around Bella Romero. Zoom out see additional schools and click on features to see more details. [NOTE: The Colorado school dataset lists Bella Romero Academy as an elementary/middle school. Bella Romero was recently split, with the elementary school moving a few blocks west.]

Map of schools and setbacks in Colorado

View map full screen | How FracTracker maps work

Environmental Injustice

Drilling near Bella Romero is also arguably an environmental justice issue, as its student population has some of the highest minority rates in the county and are amongst the poorest. According to coloradoschoolgrades.com, Bella Romero is 89% Hispanic or Latino and 3% African American whereas, according to the U.S. Census Bureau, Greeley as a whole is 59% White and 36% Hispanic or Latino. 92% of Bella Romero’s students are also from low income families. Furthermore, according to the EPA’s Environmental Justice Screening Tool, which is used by the agency to assess high risk populations and environments, the community surrounding Bella Romero is within the 90-95% percentile range nationally for linguistically isolated communities.

Many of Bella Romero's students come from low-income communities surrounding Greeley.

Many of Bella Romero’s students come from low-income communities surrounding Greeley.

 

Implications

These statistics are significant for a number of reasons. Firstly, oil and gas permitting in Colorado only requires operators to notify residents immediately surrounding proposed well pads. This rule does not include residents who may live further from the site but send their students to schools like Bella Romero. Parents who might comment on the project would need to hear about it from local papers or neighbors, but language barriers can prevent this from occurring. Another factor we witnessed in our June visit to Latino communities in Weld County is that many students have undocumented family members who are hesitant to speak out in public, leaving them with no voice to question risks to their children.

Residents of Greeley speak out at the June 7th Planning Commission meeting.

Residents of Greeley speak out at the June 7th Planning Commission meeting

Nevertheless, at the June 7th Planning Commission hearing, Weld County administrators insisted that their decisions would not take race and poverty into consideration, which is a blatant disregard for EPA guidelines in siting industrial development in poor minority communities. Weld County’s Planning Commission claimed that their ruling on the site would be the same regardless of the school’s demographics. By comparison, another proposed Extraction Oil & Gas site that would have brought a 22-head well pad to within 1,000ft of homes in a more well off part of town was denied on a 0-6 vote by the City of Greeley’s Planning Commission earlier this year after nearby residents voiced concerns about the potential impacts. Extraction Oil & Gas appealed the ruling and Greeley City Council passed the proposal in a 5-2 vote pending additional urban mitigation area permit approval. While the Greeley Planning Commission and the Weld County Planning Commission are distinct entities, the contrast of these two decisions should emphasize concerns about fair treatment.

Conclusion

There are very real health concerns associated with siting oil and gas wells near schools.  When evaluating this project, county administrators should assess not only the immediate impacts of constructing the well pad but also the long-term effects of allowing an industrial facility to operate so close to a sensitive youth population. There are obvious environmental justice issues at stake, as well. Public institutions have a responsibility to protect marginalized communities such as those who send their children to Bella Romero. Finally, approving the Vetting 15H project would place Bella Romero far at the top of the list for schools in Colorado within 1,000ft of oil and gas wells. School board administrators should be concerned about this activity, as it will undoubtedly put their students’ health and academic performance at risk. We hope that, when the County Commissions review the proposal, these concerns will be taken into account.