FracTracker began monitoring Falcon’s construction plans in December 2016, when we discovered a significant cache of publicly visible GIS data related to the pipeline. At that time, FracTracker was looking at ways to get involved in the public discussion about Shell’s ethane cracker and felt we could contribute our expertise with mapping pipelines. Below we describe the methods we used to access and worked with this project’s data.
Finding the Data
Finding GIS data for pipeline projects is notoriously difficult but, as most research goes these days, we started with a simple Google search to see what was out there, using basic keywords, such as “Falcon” (the name of the pipeline), “ethane” (the substance being transported), “pipeline” (the topic under discussion), and “ArcGIS” (a commonly used mapping software).
In addition to news stories on the pipeline’s development, Google returned search results that included links to GIS data that included “Shell” and “Falcon” in their names. The data was located in folders labeled “HOUGEO,” presumably the project code name, as seen in the screenshot below. All of these links were accessed via Google and did not require a password or any other authentication to view their contents.
Shell’s data on the Falcon remained publicly available at this link up to the time of the Falcon Public EIA Project‘s release. However, this data is now password protected by AECOM.
Google search results related to Falcon pipeline data
Viewing the Data
The HOUGEO folder is part of a larger database maintained by AECOM, an engineering firm presumably contracted to prepare the Falcon pipeline construction plan. Data on a few other projects were also visible, such as maps of the Honolulu highway system and a sewer works in Greenville, NC. While these projects were not of interest to us, our assessment is that this publicly accessible server is used to share GIS projects with entities outside the company.
Within the HOUGEO folder is a set of 28 ArcGIS map folders, under which are hundreds of different GIS data layers pertaining to the Falcon pipeline. These maps could all be opened simply by clicking on the “ArcGIS Online map viewer” link at the top of each page. Alternatively, one can click on the “View in: Google Earth” link to view the data in Google Earth or click on the “View in: ArcMap” link to view the data in the desktop version of the ArcGIS software application. No passwords or credentials are required to access any of these folders or files.
As seen in the screenshot below, the maps were organized topically, roughly corresponding to the various components that would need to be addressed in an EIA. The “Pipeline” folder showed the route of the Falcon, its pumping stations, and work areas. “Environmental” contained data on things like water crossings and species of concern. “ClassLocations” maps the locations of building structures in proximity to the Falcon.
The HOUGEO GIS folders organized by topic
Archiving the Data
After viewing the Falcon GIS files and assessing them for relevancy, FracTracker went about archiving the data we felt was most useful for our assessing the project. The HOUGEO maps are hosted on a web server meant for viewing GIS maps and their data, either on ArcOnline, Google Earth, or ArcMap. The GIS data could not be edited in these formats. However, viewing the data allowed us to manually recreate most of the data.
For lines (e.g. the pipeline route and access roads), points (e.g. shutoff valves and shut-off valves), and certain polygons (e.g. areas of landslide risk and construction workspaces), we archived the data by manually recreating new maps. Using ArcGIS Desktop software, we created a new blank layer and manually inputted the relevant data points from the Falcon maps. This new layer was then saved locally so we could do more analysis and make our own independent maps incorporating the Falcon data. In some cases, we also archived layers by manually extracting data from data tables underlying the map features. These tables are made visible on the HOUGEO maps simply by clicking the “data table” link provided with each map layer.
Other layers were archived using screen captures of the data tables visible in the HOEGEO ArcOnline maps. For instance, the table below shows which parcels along the route had executed easements. We filtered the table in ArcGIS Online to only show the parcel ID, survey status, and easement status. Screen captures of these tables were saved as PDFs on our desktop, then converted to text using optical character recognition (OCR), and the data brought into Microsoft Excel. We then recreated the map layer by matching the parcel IDs in our newly archived spreadsheet to parcel IDs obtained from property GIS shapefiles that FracTracker purchased from county deeds offices.
Transparency & Caveats
FracTracker strives to maintain transparency in all of its work so the public understands how we obtain, analyze, and map data. A good deal of the data found in the HOUGEO folders are available through other sources, such as the U.S. Geological Survey, the Department of Transportation, and the U.S. Census, as well as numerous state and county level agencies. When possible, we opted to go to these original sources in order to minimize our reliance on the HOUGEO data. We also felt it was important to ensure that the data we used was as accurate and up-to-date as possible.
For instance, instead of manually retracing all the boundaries for properties with executed easements for the Falcon’s right-of-way, we simply purchased parcel shapefiles from county deeds and records offices and manually identified properties of interest. To read more on how each data layer was made, open any of our Falcon maps in full-screen mode and click the “Details” tab in the top left corner of the page.
Finally, some caveats. While we attempted to be as accurate as possible in our methods, there are aspects of our maps where a line, point, or polygon may deviate slightly in shape or location from the HOUGEO maps. This is the inherent downside of having to manually recreate GIS data. In other cases, we spent many hours correcting errors found in the HOUGEO datasets (such as incorrect parcel IDs) in order to get different datasets to properly match up.
FracTracker also obtained copies of Shell’s permit applications in January by conducting a file review at the PA DEP offices. While these applications — consisting of thousands of pages — only pertain to the areas in Pennsylvania where the Falcon will be built, we were surprised by the accuracy of our analysis when compared with these documents. However, it is important to note that the maps and analysis presented in the Falcon Public EIA Project should be viewed with potential errors in mind.
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
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.
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.
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:
their role in induced seismicity,
potential water and air quality issues, and
concomitant increases in truck volumes and speeds.
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/03/WV-Schools-Feature.jpg400900Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngTed Auch, PhD2017-03-13 11:27:562021-04-15 15:03:37How close are schools and hospitals to drilling activity in West Virginia and Ohio?
By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance
In an apparent move to step around compliance with comprehensive regulations outlined in the Endangered Species Act (ESA), a coalition of nine oil and gas corporations has filed a draft plan entitled the Oil & Gas Coalition Multi-State Habitat Conservation Plan (O&G HCP). The proposed plan, which would relax regulations on five species of bats, is unprecedented in scope in the eastern United States, both temporally and spatially. If approved, it would be in effect for 50 years, and cover oil and gas operations throughout the states of Ohio, Pennsylvania, and West Virginia—covering over 110,000 square miles. The oil and gas companies see the plan as a means of “streamlining” the permit processes associated with oil and gas exploration, production, and maintenance activities. Others outside of industry may wonder whether the requested permit is a broad over-reach of an existing loophole in the ESA.
Habitat fragmentation, air, and noise pollution that comes with oil and gas extraction and fossil fuel delivery activities have the potential to incidentally injure or kill bat species in the three-State plan area that are currently protected by the Endangered Species Act (ESA) of 1973. In essence, the requested “incidental take permit”, or ITP, would acknowledge that these companies would not be held to the same comprehensive regulations that are designed to safeguard the environment, particularly the flora and fauna at most risk to extirpation. Rather, they would simply be asked to insure that their impacts are “minimized and mitigated to the maximum extent practicable.”
Section 10(a)(2)(B) of the ESA contains provisions for issuing an ITP to a non-Federal entity for the take of endangered and threatened species, provided the following criteria are met:
The taking will be incidental
The applicant will, to the maximum extent practicable, minimize and mitigate the impact of such taking
The applicant will develop an HCP and ensure that adequate funding for the plan will be provided
The taking will not appreciably reduce the likelihood of survival and recovery of the species in the wild
The applicant will carry out any other measures that the Secretary may require as being necessary or appropriate for the purposes of the HCP
What activities would be involved?
The Northern Long-eared Bat is a federally-listed threatened species, also included in the ITP
The proposed plan, which would seek to exempt both upstream development activities (oil & gas wells) and midstream development activities (pipelines). Upstream activities include the creation of access roads, staging areas, seismic operations, land clearing, explosives; the development and construction of well fields, including drilling, well pad construction, disposal wells, water impoundments, communication towers; and other operations, including gas flaring and soil disturbance; and decommissioning and reclamation activities, including more land moving and excavation.
Midstream activities include the construction of gathering, transmission, and distribution pipeline, including land grading and stream construction, construction of compressor stations, meter stations, electric substations, storage facilities, and processing plants, and installation of roads, culverts, and ditches, to name just a few.
Companies involved in the proposed “Conservation Plan” represent the major players in fossil fuel extraction, refinement, and delivery in the region, and include:
Antero Resources Corporation
Ascent Resources, LLC
Chesapeake Energy Corporation
EnLink Midstream L.P.
EQT Corporation
MarkWest Energy Partners, L.P., MPLX L.P., and Marathon Petroleum Corporation (all part of same corporate enterprise)
Rice Energy, Inc.
Southwestern Energy Company
The Williams Companies, Inc.
Focal species of the request
Populations of federally-endangered Indiana Bats could be impacted by the proposed Incidental Take Permit (ITP)
The five species listed in the ITP include the Indiana Bat (a federally-listed endangered species) and Northern Long-eared Bat (a federally-listed threatened species), the Eastern Small-footed Bat (a threatened species protected under Pennsylvania’s Game and Wildlife Code), as well as the Little Brown Bat and Tri-colored Bat. Populations of all five species are already under dire threats due to white-nose syndrome, a devastating disease that, since 2008, has killed an estimated 5.7 million bats in North America. In some cases, entire local populations have succumbed to this deadly disease. Because bats already have a naturally low birthrate, bat populations that do survive this epidemic will be slow to rebound. Only recently, wildlife biologists have begun to see hope for a treatment in a beneficial bacterium that may save affected bats. However, production and deployment details of this treatment are still under development. Best summarized in a recent article in the Pittsburgh Post-Gazette:
This [ITP] would be a huge deal because we are dealing with species in a precipitous decline,” said Jared Margolis, an attorney with the Center for Biological Diversity, a national nonprofit conservation organization headquartered in Tucson, Ariz. “I don’t see how it could be biologically defensible. Even without the drilling and energy development we don’t know if these species will survive.
In 2012, Bat Conservation International produced a report for Delaware Riverkeeper, entitled Impacts of Shale Gas Development on Bat Populations in the Northeastern United States. The report focuses on landscape scale impacts that range from water quality threats, to disruption of winter hibernacula, the locations where bats hibernate during the winter, en masse. In addition, because bats have strong site fidelity to roosting trees or groups of trees, forest clearing for pipelines, well pads or other facilities may disproportionately impact local populations.
The below map, developed by FracTracker Alliance, shows the population ranges of all five bat species, as well as the current areas impacted by existing development by the oil and gas industry through well sites, pipelines, and other facilities.
To learn more details about the extensive oil and gas development in each of the impacted states, follow these links:
Oil and gas threat map for Pennsylvania. Currently, there are ~104,000 oil and gas wells, compressors, and other related facilities here.
Oil and gas threat map for Ohio. Currently, there are ~90,000 oil and gas wells, compressors, and other related facilities here.
Oil and gas threat map for West Virginia. Currently, there are ~16,000 oil and gas wells, compressors, and other related facilities here.
Public input options
The U.S. Fish and Wildlife Service (USFWS) announced in the Federal Register in late November 2016 its intent to prepare an environmental impact statement (EIS) and hold five public scoping sessions about the permit, as well as an informational webinar. In keeping with the parameters of an environmental impact statement, USFWS is particularly interested in input and information about:
Aspects of the human environment that warrant examination such as baseline information that could inform the analyses.
Information concerning the range, distribution, population size, and population trends concerning the covered species in the plan area.
Additional biological information concerning the covered species or other federally listed species that occur in the plan area.
Direct, indirect, and/or cumulative impacts that implementation of the proposed action (i.e., covered activities) will have on the covered species or other federally listed species.
Information about measures that can be implemented to avoid, minimize, and mitigate impacts to the covered species.
Other possible alternatives to the proposed action that the Service should consider.
Whether there are connected, similar, or reasonably foreseeable cumulative actions (i.e., current or planned activities) and their potential impacts on covered species or other federally listed species in the plan area.
The presence of archaeological sites, buildings and structures, historic events, sacred and traditional areas, and other historic preservation concerns within the plan area that are required to be considered in project planning by the National Historic Preservation Act.
Any other environmental issues that should be considered with regard to the proposed HCP and potential permit issuance.
The public comment period ends on December 27, 2016. Links to more information about locations of the public hearings, as well as instructions about how to sign up for the December 20, 2016 informational webinar can be found at this website. In addition, you can electronically submit comments about the “conservation plan” by following this link.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/12/Eastern-small-footed-bat-header.jpg4301500Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKaren Edelstein2016-12-12 14:22:072021-04-15 15:04:19“Taking” Wildlife in PA, OH, WV
Cover of Dangerous and Close report. Click to view report
FracTracker Alliance has been working with the Frontier Group and Environment America on a nationwide assessment of “fracked” oil and gas wells. The report is titled Dangerous and Close, Fracking Puts the Nation’s Most Vulnerable People at Risk. The assessment analyzed the locations of fracked wells and identified where the fracking has occurred near locations where sensitive populations are commonly located. These sensitive sites include schools and daycare facilities because they house children, hospitals because the sick are not able to fight off pollution as effectively, and nursing homes where the elderly need and deserve clean environments so that they can be healthy, as well. The analysis used data on fracked wells from regulatory agencies and FracFocus in nine states. Maps of these nine states, as well as a full national map are shown below.
No one deserves to suffer the environmental degradation that can accompany oil and gas development – particularly “fracking” – in their neighborhoods. Fracked oil and gas wells are shown to have contaminated drinking water, degrade air quality, and sicken both aquatic and terrestrial ecosystems. Additionally, everybody responds differently to environmental pollutants, and some people are much more sensitive than others. In fact, certain sects of the population are known to be more sensitive in general, and exposure to pollution is much more dangerous for them. These communities and populations need to be protected from the burdens of industries, such as fracking for oil and gas, that have a negative effect on their environment. Commonly identified sensitive groups or “receptors” include children, the immuno-compromised and ill, and the elderly. These groups are the focus of this new research.
National Map
National interactive map of sensitive receptors near fracked wells
As many of you know, educating the public is a FracTracker Alliance core value – a passion, in fact. In addition to our maps and resources, we help to provide hands-on education, as well. The extraordinary Bill Hughes is a FracTracker partner who has spent decades “in the trenches” in West Virginia documenting fracking, well pad construction, water withdrawals, pipeline construction, accidents, spills, leaks, and various practices of the oil and gas industry. He regularly leads tours for college students, reporters, and other interested parties, showing them first-hand what these sites look, smell, and sound like.
While most of us have heard of fracking, few of us have seen it in action or how it has changed communities. The tours that Bill provides allow students and the like to experience in person what this kind of extraction means for the environment and for the residents who live near it.
Biking to Support FracTracker and Bill Hughes
Dave Weyant at the start of his cross-country Pedal for the Planet bike trip
In the classic spirit of non-profit organizations, we work in partnership with others whenever possible. Right now, as you read this posting, another extraordinary Friend of FracTracker, Dave Weyant (a high school teacher in San Mateo, CA), is finishing his cross-country cycling tour – from Virginia to Oregon in 70 days.
Dave believes strongly in the power of teaching to reach the hearts of students and shape their thinking about complicated issues. As such, he has dedicated his journey to raising money for FracTracker. He set up a GoFundMe campaign in conjunction with his epic adventure, and he will donate whatever he raises toward Bill’s educational tours.
Help us celebrate Dave Weyant’s courage, vision, and generosity – and support Bill Hughes’s tireless efforts to open eyes, evoke awareness, and foster communication about fracking – by visiting Dave’s GoFundMe page and making a donation. Every gift of any size is most welcome and deeply appreciated.
100% of the funds raised from this campaign will go to support Bill’s oil and gas tours in West Virginia. FracTracker Alliance is a registered 501(c)3 organization. Your contribution is tax deductible.
And to those of you who have already donated, thank you very much for your support!
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/07/Hughes-Tour-Feature.jpg400900Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngGuest Author2016-07-27 10:30:012020-03-11 16:48:40A Cross-Country Ride to Support Oil and Gas Tours in West Virginia
For anyone who even casually follows Marcellus and Utica shale gas exploration and production, such as in the active gas fields of West Virginia or Southwestern PA or Ohio, we know there are many concerns surrounding the natural gas production process. These issues range from air pollution, water consumption and contamination, to waste disposal. We know that, after all well the pad drilling and construction traffic are done, we must also have pipelines to get the gas to compressor stations, processing plants, and to markets in the Eastern United States (and likely Europe and Asia in the near future). Gas companies in Wetzel County, WV, and in neighboring tri-state counties, are convinced that building pipelines – really big pipelines – will be the silver bullet to achieving some semblance of stability and profitability.
Problems With Proposed Pipelines
One of the new, very large diameter (42”) proposed gas pipelines getting attention in the press is the Mountain Valley Pipeline, which will originate in the village of Mobley in eastern Wetzel County, WV and extend Southeast, through national forests and over the Appalachian Mountains into the state of Virginia. Even if the residents of Wetzel County and other natural gas fields are guinea pigs for experiments with hydraulic fracturing, we know how to build pipelines, don’t we? The equipment, knowledge, and skill sets needed for pipeline construction is readily available and commonly understood compared to high pressure horizontal drilling with large volumes of slick water. So, what could go wrong?
I can answer that question first hand from my hayfield in Wetzel County. Almost two years ago, EQT wanted to survey my property for a similar proposed pipeline – this one 30” in diameter, called the Ohio Valley Connector (OVC). The application for this project has now been filed with the Federal Energy Regulatory Commission (FERC). The below map shows a section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land. Multiple routes were being explored at first. Were this version approved, it would have gone right through my hayfield and under our stream.
A section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land.
Pipeline opponents express concern about habitat fragmentation, the crossing of pristine streams and rivers, erosion and sedimentation issues, spills, gas leaks, and possible explosions. These are all very valid concerns. But the potential for other logistical errors in the building process – from very simple to potentially serious ones – are also worth consideration. In this article I will use my recent personal experience as a detailed and documented example of how a professionally surveyed location on my property contained an error of almost one mile – over 4,000 feet – as part of a pipeline construction planning project. Yes, you read that right.
Part I: How Did We Get To This Point
Before we get to my story, I should review my first contact with EQT on this issue. In February of 2014, an EQT land agent asked me for permission to walk my property for preliminary evaluation of a route that would send their 30” high-pressure pipe through our land, from south to north.
It is important to keep in mind that almost every landowner in Wetzel County has been contacted by mail, phone or in person, by land agents promising cash with a verbal assurance that all will be well. The goal is to get a landowner’s signature on a loosely worded “right of way” (RoW) lease contract, with terms favorable to the gas company, and move on. Unfortunately, pipeline lease offers cannot be ignored. Not objecting or not questioning can sometime leave the landowner with fewer choices later. This is because many of the bigger interstate transmission lines are being proposed as FERC lines. When final approval is granted by FERC, these pipelines will have the legal power of eminent domain, where the property owner is forced to comply. Just filing a FERC application does not grant eminent domain in West Virginia, as it seems to in Virginia, but the potential for eminent domain gives land agents power over landowners.
I was not ready to give them surveying permission (to drive stakes or other permanent markers). Since a natural gas pipeline would affect all my neighbors, however, I agreed to allow a preliminary walk through my property and to hang surveyor ribbons in exchange for answering my questions about the project. For instance, one of my biggest concerns was the potential for significant habitat fragmentation, splitting up the forest and endangering wildlife habitat.
There are many questions residents should consider when approached by land agent. A list of these questions can be found in the appendix below.
I never did get answers to most of my questions in the few e-mail exchanges and phone conversations with EQT. I never saw the surveyors either. They simply came and left their telltale colored ribbons. Later, at a public meeting an EQT representative said the closest they would run the pipe to any residence would be 37.5 feet. That number is correct. I asked twice. They said they had the right to run a pipeline that close to a residence but would do their best not to. The 37.5 feet is just one half of the permanent RoW of 75 feet, which was also only part of a 125 foot RoW requested for construction. A few months later, a very short e-mail said that the final pipeline route had changed and they would not be on my property. For a time we would enjoy some peace and quiet.
A Word On Surveyors
Most folks can relate to the work and responsibility of bookkeepers or Certified Public Accountants (CPAs). They measure and keep track of money. And their balance sheets and ledgers actually have to, well, BALANCE. Think of Surveyors as the CPAs of the land world. When they go up a big hill and down the other side, the keep track of every inch — they will not tolerate losing a few inches here and there. They truly are professionals, measuring and documenting everything with precision. Most of the surveyors I have spoken with are courteous and respectful. They are a credit to their profession. They are aware of the eminent domain threat and their surveying success depends on treating landowners with respect. They are good at what they do. However, as this article will show, their professional success and precision depends on whether or not they are given the correct route to survey.
Part II: Surveyor Stakes and Flags
Over the next year we enjoyed peace and quiet with no more surveyors’ intrusions. However, in my regular travels throughout the natural gas fields here, countless signs of surveyor activity were visible. Even with the temporary slowdown in drilling, the proposed pipeline installations kept these surveyors busy. Assorted types of stakes and ribbons and markings are impossible to miss along our roads. I usually notice many of the newer surveyor’s flags and the normal wooden stakes used to mark out future well pads, access roads, compressor stations, and more recently pipelines. Given that survey markings are never taken down when no longer needed, the old ones sometimes hide the new ones.
It can be difficult keeping track of all of them and hard at first to identify why they are there. Even if sometimes I am not sure what a stake and flag might indicate, when one shows up very unexpectedly in what is essentially my front yard, it is impossible to not see it. That is what happened in August of 2015. Despite being unable to get our hay cut due to excessive rain the previous month, the colored flags were highly visible. Below shows one of the stakes with surveyor’s tape, and the hay driven down where the surveyors had parked their trucks in my field alongside my access road.
A surveyor stake alongside my access road.
To call it trespassing might not be legally defensible yet. The stakes were, after all, near a public roadway – but the pins and stakes and flags were on my property. Incidents like this, whether intentional or accidental, are what have given the natural gas companies a reputation as bad neighbors. There were surveyors’ stakes and flags at two different locations, my hay was driven down, and I had no idea what all this meant given that I had no communication from anyone at EQT in over 18 months. I consider myself fortunate that the surveyors did not stray into wooded areas where trees might have been cut. It’s been known to happen.
Below shows the two sets of wooden stakes, roughly 70-80 feet apart, with flags and capped steel rebar pins. Both stakes were near the road’s gravel lane, which is a public right of way. Nevertheless, the stakes were clearly on my property. The markings on one side of the stake identify the latitude, longitude, and the elevation above sea level of the point. The other side of the stake identified it as locating the OVC pipeline (seen here as “OVC 6C):
These identifying numbers are unique to this pin which is used to denote a specific type of location called a “control point.” Control points are usually located off to the side of the center-line of the pipeline:
A control point, located off to the side of the center-line of the pipeline.
It seemed that somehow, without informing me or asking permission to be on my land, EQT had changed their mind on the OVC route and were again planning to run a pipeline through my property. If this was intentional, both EQT and I had a problem. If this was some kind of mistake, then only EQT would have a problem. Either way I could not fathom how this happened. Trespassing, real or perceived, is always a sensitive topic. This is especially true since, when I had initially allowed the surveyor to be on my property, I had not given permission for surveying. Given concerns about eminent domain, I wanted answers quickly. I documented all this with detailed pictures in preparation for contacting EQT representatives in Pittsburgh, PA, with my complaints.
Part III: What Happened & How?
I think it is safe to say that, in light of my well-known activism in documenting all things Marcellus, I am not your average surface owner. I have over 10,000 photographs of Marcellus operations in Wetzel County and I document every aspect of it. Frequently this leads to contacting many state agencies and gas operators directly about problems. I knew which gas company was responsible and I also knew exactly who in Pittsburgh to contact. To their credit, the person I contacted at EQT, immediately responded and it took most of the day to track down what had happen. The short story was that it was all a simple mistake—a 4,300 foot long mistake—but still just a mistake. The long story follows.
The EQT representative assured me that someone would be out to remove their stakes, flags and the steel pins. I told them that they needed to be prompt and that I would not alter or move their property and locating points. The next day, when I got home, the stakes with flags were gone. Just a small bare patch of dirt remained near the white plastic fencepost I had placed to mark the location. However, since I am a cultivated skeptic—adhering to the old Russian proverb made famous by President Reagan, “Trust but Verify”—I grabbed a garden trowel, dug around a bit, and clink, clink. The steel pin had just been driven deeper to look good, just waiting for my tiller to locate someday. I profusely re-painted the pin, photographed it, and proceeded to send another somewhat harsh e-mail to EQT. The pin was removed the next day.
After all the stakes, ribbons, and steel pins were removed, EQT provided further insights into what had transpired. Multiple pipeline routes were being evaluated by EQT in the area. Gas companies always consider a wide range of constraints to pipeline construction such as road and stream crossings, available access roads, permission and cooperation of the many landowners, steepness of terrain, etc. At a certain point in their evaluation, a final route was chosen. But for unknown reasons the surveyor crew was given the old, now abanoned, route on which to establish their control points. The magnitiude of the error can be seen on the map below. The bright blue line is the original path of the OVC pipeline through my property and the red line shows where the FERC filed pipeline route will go. A new control point has now been established near the highway where the pipeline was meant to cross.
The FERC filed OVC pipeline route vs. the accidentally surveyed route.
Part IV: Lessons To Be Learned
Given the likely impact of many proposed large-diameter, very long, pipelines being planned, it seems useful to examine how these errors can happen. What can we learn from my personal experience with the hundreds of miles of new pipelines constructed in Wetzel County over the past eight years? First, it is important to ask whether or not similar problems are likely to happen elsewhere, or if this was this just an isolated incident. Can we realistically expect better planning on the proposed Mountain Valley Pipeline, which will run for over 300 miles? Can the residents and landowners living along these pipeline RoWs expect more responsible construction and management practices?
In general, many of the pipeline projects with which landowners, such as those in Wetzel County, are familiar with fall into the unregulated, gathering line category. They might be anywhere from six inches in diameter up to sixteen inches. As we review their track record, we have seen every imaginable problem, both during construction and after they were put into operation. We have had gas leaks and condensate spills, hillside mud slips, broken pipes, erosion and sedimentation both during construction and afterwards.
Now for some apparently contradictory assumptions—I am convinced that, for the most part, truck drivers, pipeliners, equipment operators, drilling and fracturing crews, well tenders and service personnel at well sites, all do the best job they can. If they are given the proper tools and materials, accurate directions with trained and experienced supervision, the support resources and the time to do a good job, then they will complete their tasks consistently and proudly. A majority of employees in these positions are dedicated, trained, competent, and hard working. Of course, there are no perfect contractors out there. These guys are human too. And on the midnight shift, we all get tired. In the context of this story, some pipeline contractors are better and more professional than others, some are more experienced, and some have done the larger pipelines. Therefore, despite best intentions, significant errors and accidents will still occur.
The Inherent Contradictions
It seems to me that the fragile link in natural gas production and pipeline projects is simply the weakness of any large organization’s inherent business model. Every organization needs to constantly focus on what I refer to as the “four C’s—Command and Control, then Coordination and Communication—if they are to be at all successful. It is a challenge to manage these on a daily basis even when everyone is in the same big building, working for the same company, speaking the same language. This might be in a university, or a large medical complex, or an industrial manufacturing plant.
But the four C’s are nearly impossible to manage due to the simple fact that the organizational structure of the natural gas industry depends completely on hundreds of sub-contractors. And those companies, in turn, depend on a sprawling and transient, expanding and collapsing, network of hundreds of other diverse and divergent independent contractors. For example, on any given well pad, during the drilling or fracturing process, there might be a few “company” men on site. Those few guys actually work for the gas company in whose name the operating permit is drawn. Everyone else is working for another company, on site temporarily until they are ready to move on, and their loyalty is elsewhere.
In the best of situations, it is next to impossible to get the right piece of information to the right person at just the right time. Effective coordination among company men and contractors is also next to impossible. I have seen this, and listened in, when the drilling company is using one CB radio channel and the nearby pipeline company is using some private business band radio to talk to “their people.” In that case, the pipeline contractors could not talk to the well pad—and it did not matter to them. In other cases, the pilot vehicle drivers will unilaterally decide to use another CB radio channel and not tell everyone. I have also watched while a massive drill rig relocation was significantly delayed simply because a nearby new gas processing plant was simultaneously running at least a hundred dump trucks with gravel on the same narrow roadway. Constant communication is a basic requirement for traffic coordination, but next to impossible to do properly and consistently when these practices are so prevalent.
These examples illustrate how companies are often unable to coordinate their operations. Now, if you can, just try to picture this abysmal lack of command and control, and minimal communication and coordination, in the context of building a 300-mile length of pipeline. The larger the pipeline diameter, and the greater the overall length of the pipeline, the more contractors will be needed. With more contractors and sub-contractors, the more coordination and communication are essential. A FERC permit cannot fix this, nor would having a dozen FERC permits. Unfortunately, I do not envision the four Cs improving anytime soon in the natural gas industry. It seems to be the nature of the beast. If, as I know from personal experience, a major gas company can arrange to locate a surveyed control point 4,300 feet from where it should have been, then good luck with a 300 mile pipeline. Even with well-intentioned, trained employees, massive problems are still sure to come.
The FERC approvals for these pipelines might not be a done deal, but I would not bet against them. So vigilance and preparation will still be of the essence. Citizen groups must be prepared to observe, monitor, and document these projects as they unfold. If massive pipelines like the MVP and OVC are ever built, they should become the most photographed, measured, scrutinized, and documented public works projects since the aqueducts first delivered water to ancient Rome. For the sake of protecting the people and environment of Wetzel County and similar communities, I hope this is the case.
Appendix: Questions to Ask When Approached by a Land Agent (Landsman)
These questions can be modified to suit your location. The abbreviation “Gas Corp.” is used below to reference a typical natural gas company or a pipeline subsidiary to a natural gas company. These subsidiaries are frequently called Midstream Companies. Midstream companies build and manage the pipelines, gas processing, and some compressor stations on behalf of natural gas companies.
Please provide a Plain English translation of your landowner initial contract.
What will Gas Corp. be allowed to do, and not allowed to do, short term and long term?
What will Gas Corp. be required to do, and not required to do?
What is the absolute minimum distance this pipeline will be placed away from any dwelling anywhere along its entire length?
What restrictions will there be on the my land after you put in the pipelines?
Who will be overseeing and enforcing any environmental restrictions (erosion and sedimentation, slips, stream crossings, etc.)?
Who will be responsible for my access road upkeep?
Who will be responsible for long term slips and settlements of surface?
When would this construction begin?
When would all work be completed?
Who would be responsible for long term stability of my land?
Will the pipeline contractor(s) be bound to any of our agreements?
Who are the pipeline contractor(s)?
What will be transported in the pipeline?
Will there be more than one pipe buried?
How wide is the temporary work RoW?
How wide is the permanent RoW?
How deep will the pipeline(s) be buried?
What size pipe will it be; what wall thickness?
How often will the welds on the individual pipe segments be inspected?
Will there be any above ground pipeline components left visible?
Where will the pipe(s) originate and where will they be going to?
What will the average operating pressure be?
What will the absolute maximum pressure ever be?
At this pressure and diameter, what is the PIR—Potential Impact Radius?
Will all pipeline and excavating and laying equipment be brought in clean and totally free from any invasive species?
How will the disturbed soil be reclaimed?
Will all top soil be kept separate and replaced after pipeline is buried?
Also, After all the above is settled, how much will I be paid per linear foot of pipeline?
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2014/12/Pipeline-Feature.png400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2016-02-17 10:21:412020-03-12 17:33:44A Push For Pipelines
The following guide is a simplified description of a variety of markings that are used by land surveyors. Throughout an active shale gas field, the first signs of pending expansions are the simple markings of stakes, flags, and pins. Many months or even years before the chain saw fells the first tree or the first dozer blade cuts the dirt at a well pad location, the surveyors have “marked the target” on behalf of their corporate tactical command staff.
The three most commonly used markings are the simple stakes, flags and pins. These surveyor symbols are common to any construction project and guarantee that everything gets put in the right place. In an active gas field, these marking tools are used for all aspects of exploration and production:
access roads to well pads,
widening the traveled portion of the roadway,
well locations,
ponds and impoundment locations,
temporary water pipeline paths,
surface disturbance limits,
compressor stations,
gas processing sites, and
rights-of-way for roads and pipelines.
Quite frequently these simple markings are undecipherable by themselves, especially by non-professionals. One cannot just know what is happening, what is likely to occur, or how concerned one should be. Context and additional information are usually needed. Sometimes the simple colors and combinations of colored tapes might only make sense in conjunction with similar markings nearby. Sometimes public notices in the newspaper and regulatory permits must be used to decipher what is planned.
For an example, the proposed 30″ diameter EQT pipeline called the Ohio Valley Connector seems to be regularly marked using a combination of blue and white (see figure 10 below) surveyors tape to mark the actual pipeline location, then green and white (see figure 4 below) to mark all the proposed access roads along the routes that will be used to get pipe trucks and excavation equipment into the right of way. These access roads might be public roadways or cut across private leased property.
Common surveyor symbols & signs (click on images to zoom in)
Surveyor flags and tape: Sometime the flags or streamers are just attached to trees, fence posts, or put on a stake to make them visible above the weeds. There might be no markings on the stake, or only simple generic markings. This could just mean that this is the correct road and turn here. It could also signal a proposed or approximate location for some future work.
Simple surveyor’s flags or tape
Surveyor flags and tapes: These are a selection of typical surveyor tapes, also called flags or ribbons. Many other specialty color combinations are available to the professional surveyor.
A selection of surveyor tapes
Stakes with simple markings: Flags with some type of identification (it might be names or numbers). This one was used for a proposed well pad access road location. There are no dimensions given on these.
Stake with simple markings
Stakes with simple flags and basic identification: The stakes shown here all indicate an access route to be used for equipment and trucks to get to a proposed pipeline right of way. The “H310″ is the EQT name for the 30” OVC pipeline.
Stakes indicating an access route
Control points: These three stakes are identifying a control point that is outside the limits of disturbance (LoD). These markings surround a pin to be used for reference.
Control point stakes
Controls points: This stake is also identifying a control point location. All control points will have some type of driven metal rod, usually with a plastic cap identifying the surveyor. Frequently there are three stakes with extra flags or tape. They are always set off to the side of the intended work area. They are not to be disturbed.
Control point stake and pin
Control points: Another set of three stakes marking a Control Point location. It is common to see triple stakes with elaborate, multiple flags. Even if only two stakes are present, there always will be a driven steel pin and identifying cap.
Control point stakes and pin
Control points: This shows a close-up of the identifying cap on a metal driven steel pin. Control point locations are not meant to be disturbed as they are for future and repeated reference. They might give the latitude and longitude on the stake plus the altitude above sea level.
Control point pin and cap
Control points: This is another, older control point location. This represents a typical arrangement where the stakes somewhat try to protect the metal pin from a bulldozer blade by warning its operator.
Control point pin protection
Limit of disturbance: The “L O D” here means the limits of disturbance. Beyond this point there should not be any trees cut or dirt moved. The stakes shown here indicates that this is the outside limit of where the contractor will be disturbing the original contour of the surface soil.
Limit of disturbance stakes
Limit of disturbance: The “L O D” means the limits of disturbance of the proposed pipeline right of way. Beyond this point there should not be any trees cut or dirt moved. This could also be used for the outside edge of well pads or access roads or pond locations.
Limit of disturbance ROW stakes
Pipelines: Stakes with flags and “center line” markings are usually for pipelines. Here you see the symbol for center line: a capital letter “C” imposed on the letter “L”.
Pipelines center line
Pipelines: Again you see the capital letter “C” super imposed on top of the letter “L” used frequently for pipe line center lines, but can also be used for proposed access roads.
Pipelines center line
Pipelines: As shown here, “C” and “L” center line flags can also be used for future well pad access roads.
Road access center line
Precise location markings: Stakes like this will usually have a steel pin also associated with it. This stake gives the latitude, longitude, and elevation of the site.
Precise location stake
Permanent property lines: You may also find markings, like this one inch steel rod with an alum cap, that denote permanent property lines and corners of property.
Permanent property rod
Permanent property lines: Another kind of permanent property line or corner marker is the “boundary survey monument.” This is likely an aluminum cap on top of a one inch diameter steel bar.
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While I must commend the State for looking into this important issue, much more needs to be done, and I have serious concerns about the validity of several aspects of this study. Since the report is almost 200 pages long, I will summarize its findings and my critiques below.
Marcellus shale cuttings are radioactive: pgs. 17, 139, 142, 154
We do not know if there is a long term problem: pg. 19
About 30 million tons of waste in next few decades: pg. 176
Landfill liners leak: pg. 20
Owning & operating their own landfill would be expensive & risky for gas companies: pgs. 186-7
Toxicity and biotic risk from drill cuttings is uncharted territory: pg. 78
Landfill leachate is toxic to plants & invertebrates: pgs. 16, 95, 97
Other landfills also have radioactive waste: pgs. 14-15
We have no idea if this will get worse: pgs. 96, 154
If all systems at landfills work as designed, leachate might not affect ground water: pg. 41
Introduction
Drilling rig behind a wastewater pond in West Virginia
Any formal report comprised of 195 pages generated by a reputable school like Marshall University with additional input from Glenville State College – supported by over 2,300 pages of semi-raw data and graphs and charts and tables – requires some serious investigation prior to making comprehensive and final conclusions. However, some initial observations are needed to provide independent perspective and to help reflect on how sections of this report might be interpreted.
The overarching perspective that must be kept in mind is that the complete study was first limited by exactly what the legislature told the WV Department of Environmental Protection DEP to do. Secondly, the DEP then added other research guidelines and determined exactly what needed to be in the study and what did not belong. There were also budget and time constraints. The most constricting factor was the large body of existing data possessed by the DEP that was provided to the researchers and report writers. Because of the time restrictions, only a small amount of additional raw data could be added.
And most importantly, similar to the WVU Water Research Institute (WVU WRI) report from two years ago, it must be kept in mind that these types of studies, initiated by those elected to our well-lobbied legislature and funded and overseen by a state agency, do not occur in a political power vacuum. It was surely anticipated that the completed report might have the ability to affect the growing natural gas industry – which is supported by most in the political administration. Therefore, we must be cautious here. The presence and influence of political and economic factors need to be considered. Also, for universities to receive research contracts and government paid study requests, the focus must include keeping the customer satisfied.
My comments below on the report’s methods and findings are organized into three broad and overlapping categories:
GOOD – positive aspects, good suggestions, important observations
GENERAL – general comments
FLAW – problems, flaws, limitations
MOVING FORWARD – my suggestions & recommendations
I. Water Quality: EPA Test Protocols & Datasets
Marcellus Shale (at the surface)
GENERAL It is obvious that a very smart and well-trained set of researchers put a lot of long, detailed thought into analyzing all of the available data. There must be tens of thousands of data points. Meticulous attention was put into how to assemble all of the existing years’ worth of leachate chemical and radiological information.
GOOD There is an elaborate and detailed discussion of how to best analyze everything and how to utilize the best statistical methods and generate a uniform and integrated report. This was made difficult with non-uniform time intervals, some non-detect values, and some missing items. The researchers used a credible process, explaining how they applied the various appropriate statistical analysis methods to all the data. They provided some trends and observations and draw some conclusions.
FLAW 1 The most glaring flaw and the greatest limitation pertaining to the data sets is the nature of the very data set, which was provided to the researchers from the DEP. It is to the commendable credit of the DEP that the leachate at landfills receiving black shale drill cuttings from the Marcellus and other shale formations were, from the beginning, required to start bi-monthly testing of leachate samples at landfills that were burying drill waste products. And in general, when compared to on-site disposal as done for conventional wells, it was initially a good requirement to have the drill cuttings put into some type of landfill; that way we could keep track of where the drill cuttings are located when there are future problems.
To the best of my knowledge, until the states in the Marcellus region started allowing massive quantities of black shale waste material to be put into local landfills, we have never knowingly deposited large quantities of known radioactive industrial waste products into generic municipal waste landfills. The various waste products and drill cuttings of Marcellus black shales have been known for decades by geologists and radiochemists to be radioactive. We know better than to depose of hazardous radioactive waste in an improper way. Therefore, it is very understandable that we might not know how to best solve the problems of this particular waste product. This was and still is new territory.
FLAW 2 All of the years of leachate test samples were processed for radioactivity using what is called the clean drinking water test protocols, also referred to as the EPA 900 series. Three years ago, given the unfamiliarity of regulatory agencies with the uniqueness of this waste problem, we chose the wrong test protocol for assessing leachate samples. We speculated that the commonly used and familiar clean drinking water test procedure would work. So now we have a massive set of test results all derived from using the wrong test protocol for the radiologicals. Fortunately, all of the chemistry test results should still be reasonably useful and accurate.
At first, three years ago, this was understandable and possibly not an intentional error. Now it is widely known by hydrogeologists and radiochemists, however, that the plain EPA 900 series of test methods for determining the radioactivity of contaminated liquids do not work on liquids with high TDS — Total Dissolved Solids. Method 900.0 is designed for samples with low dissolved solid like finished drinking water supplies.
Despite this major and significant limitation, the effort by Marshall University still has some utility. For example, doing comparisons between and among the various landfills accepting drill waste might provide some interesting observations and correlations. It is clearly known now, however, that the protocols that were used for all samples from the start when testing for gross alpha, gross beta and radium-226 and radium-228 in leachate, can only result in very inaccurate, under-reported data. Therefore, it is not possible to draw any valid conclusions on several very important topics, including:
surface water quality,
potential ground water contamination,
exposure levels at landfills and public health implications,
and policy and regulations considerations.
Labs certified to test for radiological compounds and elements are very familiar with the 900 series of EPA test procedures. These protocols are intended to be used on clean drinking water. They are not intended to be used on “sludgy” waters or liquids contaminated with high dissolved solids like all the many liquid wastes from black shale operations like flowback and produced water and brines and leachate. The required lab process for sample size, preparation, and testing will guarantee that the results will be incorrect.
In no place in the final 195 page report have I seen any discussion of which EPA test protocol was used for the newer samples and why was it used. It has also not yet been seen in the 2,300+ pages of supportive statistical and analytical results, either. The fact that the wrong protocol was used three years ago is very understandable. However, this conventional EPA 900 series was still being used on the additional very recent (done in fall of 2014 and spring of 2015) samples that were included in the final report. The researchers, without any justification or discussion or explanations continued to use the wrong test protocol.
The clean drinking water procedures should have been used along with the 901.1M (gamma spec) process, for comparison. It is understandable for the new data to be consistent and comparable with the very large existing dataset that a case could be made for using the incorrect protocol and the proper one also. There should have been a detailed discussion of what and why any test method was being used, however. That discussion is usually one of the first topics investigated and explained in the Methods section. Having that type of discussion and justification seems to represent a basic science method and accepted research process – and that omission is a serious flaw.
MOVING FORWARD We all know that if we want to bake an appetizing and attractive cake we must use the correct measuring cups for the ingredients. If we want to take our child’s temperature we need an accurate thermometer. When our doctor helps us understand our blood test results, we all want to be confident the right test was used at the lab. The proper test instrument, recently calibrated and designed for the specific sample, is crucial to get useable test results from which conclusions can be drawn and policy enacted.
It seems that the best suggestion so far to test high TDS liquids similar to leachate would be to use what is referred to as Gamma-ray Spectrometry with a high purity germanium instrument with at least a 21-day hold period (30 days are better), while the sample is sealed then counted for at least 16 hours. Many of the old leachate test results indicate high uncertainties that might be attributed to short hold times and short counting times. This procedure is referred to as the 901.1 M (modified). If the sample is sealed, the sample will reach about 99% equilibrium after 30 days. Radon 222 (a gas) must not be allowed to escape.
The potential environmental impacts to water quality section of this report seems to demonstrate that if you do not want to find out something, there are always justifiable options to avoid some inconvenient facts. Given the very narrow scope as defined, some the Marshall University folks did not seem to have the option to stray into important scientific foundational assumptions and, for the most part, just had to work with the stale data sets given to them. All of which, as we have known for close to a year now, have used the wrong test protocol. Therefore we have incorrect results of limited value.
II. Marcellus is Radioactive
GOOD 1 Of course, geologists have known that the Marcellus Shale is radioactive for many decades, but also for decades there has been great reluctance by the natural gas exploration and production companies to acknowledge this fact to the public. And finally we now have a public report that clearly and unambiguously states that Marcellus shale is radioactive. Interestingly enough, it was not much more than a year ago that some on the WV House of Delegates Judiciary Committee, seemed to be echoing the industry’s intentional deception by declaring that:
…it was only dirt and rock…
So this report represents progress and provides a very valuable contribution to beginning to recognize some of the potential problems with shale wastes and their disposal challenges.
GOOD 2 Another very important advance is that finally after eight years of drilling here in Wetzel County, we now have a test sample from near the horizontal bore. The WVU WRI study researchers were never given access to any samples taken from the horizontal bore material itself, however. That was, of course, what they were supposed to have been allowed to do, but they were only given access to study material from the vertical section of the well bore. This report describes how we are getting closer to actually testing good samples of the black shale. It seems that we have gotten closer – but let’s see how close.
Page 11 describes that only three Antero wells in Doddridge County were chosen as the place to try to obtain samples from the horizontal bore. Considering that over 1,000 deviated/horizontal wells or wells with laterals have been drilled in the past few years, that number represents a very small fraction of wells drilled: less than .3%. Even if a high quality sample could have been obtained it might be a challenge to extrapolate test results to the waste being produced from the other wells in WV. These limitations are completely ignored in the report, however. Given the available documentation from the DEP, this seems to be a serious flaw that compromises the reliability of the entire report.
III. Samples From Vertical vs. Horizontal Well Bores
FLAW The actual samples tested from at least two of the three wells used in the study do not seem to be from the horizontal bore material. The sample from the third well might have come from the horizontal bore, but just barely. There is no way to know for sure. I will try to show this within the below chart using information provided by Antero to DEP Office of Oil & Gas. This information is in state records on Antero’s well plats, which become part of the well work application and also part of the final permit.
Table 1. Details about the samples taken from three Antero wells in Doddridge County, WV – and my concerns about the sampling process*
Antero well ID
API #
Sample’s drilling depth
Marcellus depth**
Horizontal bore length**
Comments / Issues
Morton 1H
47-017-06559
6,856 ft.
7,900 TVD***
10,600 ft.
~1,044 ft. short of reaching Marcellus formation
McGee 2H
47-017-06622
6,506 ft.
6,900 TVD
8,652 ft.
~394 ft. short of reaching Marcellus
Wentz1 H
47-017-06476
8,119 ft.
7,900 TVD
8,300 ft.
Just drilled into Marcellus by 219 ft.
* Original chart found on page 11 of report
** Based on information from Antero’s well plat
*** TVD = Total Vertical Depth
Antero is an active driller in Doddridge County. If any company knows where to find the Marcellus formation it is that company. Well plats are very detailed, technical documents provided to the DEP by the operator regarding the well location, watershed, and leased acres and property boundaries. We need to trust that the information on those plats is accurate and has been reviewed and approved by the permitting agency. Those plats also give the depth of the Marcellus and the length and heading of the lateral or horizontal bore. The Marshall University report gives the drilling depth when the sample was taken on the surface. Using these available well plat records from the DEP it appears that at two of the wells the sample (and its test results included in the report) came from material produced when the experienced drilling operator was not yet into the shale formation.
On the third well, Wentz 1H, the numbers seem to indicate that the sample was taken when the driller said that they were just barely within the shale layer – by 219 feet. Since the drill cuttings take some time to return to the surface from over 7,000 feet down, drilling just a few hundred feet would not at all guarantee that the returned cuttings were totally from the black shale. The processing of the drill cuttings at the shaker table and separator and centrifuge and the mixing in the tubs all cast some doubt on whether the sample, wherever it was taken from, was truly from the horizontal bore material.
On page 11 there is a clear and unambiguous statement:
Three representative sets of drill cuttings from the horizontal drilling activities within the Marcellus Shale formation were collected.
A successful attempt to get three such samples might have then allowed an appropriate waste characterization to be done as needed to accomplish the five required research topics listed in the report’s cover letter. Only an accurate chemical and radiological waste characterization would have allowed scientifically justifiable conclusions to be formulated and then allow for accurate legislation and regulations. It does not seem that West Virginia yet has the required scientific data upon which to confidently formulate laws and regulations to protect public health with regard to shale waste disposal.
Would it not seem prudent – if one wanted a good, representative sample – to make absolutely sure that the operator was, in fact, drilling in the black shale and that the cuttings returning to the surface were, in fact, from the Marcellus bore? That approach would have been eminently defensible and easily accomplished by just waiting for drilling to progress into the lateral bore far enough that the drill cuttings returning to the surface were in fact from the black shale. There might be plausible explanations for this apparent inconsistency or error. Of course, it might be speculated that the Antero-provided information on the well plats is incorrect and not intended to be accurate, or perhaps the driller is not really sure yet where the Marcellus layer starts. There may be many other possible scenarios of explanations. Time will tell.
IV. Research Observations Review
Landfill disposal of drill cuttings
GOOD There are a number of recommendations and suggestions in the study on landfills and leachate related conditions. It seems that a number of these proposals are very accurate and should be implemented. For example:
The report clearly restates that drill cuttings are known to contain radioactive compounds. Since all landfill liners will eventually leak, and since landfills already have ground water test wells for monitoring for potential ground water contamination due to leaking liners, then the well samples should be tested for radiological isotopes. Good idea. They are not required to do that now, but this recommendation should be implemented immediately (pgs. 17 and 21).
GOOD The report recommends that the Publicly Owned Treatment Works (POTW) or in the case of Wetzel County, the on-site wastewater treatment plants, should also test their effluent for radioactive isotopes. This is very important since there is no way to efficiently filter out many of the radioactive isotopes. Such contaminants will pass through traditional wastewater treatment plants.
It is also very useful that the report recommends that all the National Pollution Discharge Elimination System (NPDES) limits at the POTWs be reviewed and required to take into consideration the significantly more challenging chemical and radiological makeup of the shale waste products.
V. Economic Considerations on an Industry Supported Mono-Fill
The legislature asked that the DEP evaluate the feasibility of the natural gas industry to build, own, or operate its own landfill solely for the disposal of the known radioactive waste. This request seems to be a very reasonable approach, since for decades we have only put known radioactive waste products into dedicated landfills that are exclusively and specifically designed for the long term storage of the special waste material.
The discussion of the economic considerations is extremely complete and detailed. They are given in Appendix I and take into consideration a very thorough economic feasibility study of such a proposed endeavor. This section seems to have been compiled by a very talented professional team.
FLAW However, some of the basic assumptions are a bit askew. For example:
The initial Abstract of the financial analysis states that two new landfills would be needed because we do not want to have the well operators to drive any further than they do now. Interesting. This seems to be not too different than a homeowner while in search for privacy and quiet, builds a home far out into the country and then expects the public sewage lines to be extended miles to his new home so he would not have to incur the cost of a septic system. Homebuilders in rural settings should know they will have to incur expenses for their waste disposal needs. Should gas companies expect that communities to provide cheap waste disposal for them?
More than 15 pages later, the most important aspect is clearly stated that, “…the most salient benefit of establishing a separate landfill sited specifically to receive (radioactive) drill cuttings would be the preservation of existing disposal capacity of existing fills for future waste disposal”. Meaning for my (our) grandchildren. See page 175.
Comprehensive and sound financial details later explain that having the natural gas operators build, operate, and eventually close their own radioactive waste depository landfill would involve a lot of their capital and involve some risk to them. It is stated that their money would be better used drilling more wells. The conclusion then seems to be that, all around, it is simply cheaper and less risky for the gas industry to put all their waste products into our Municipal Waste Landfills, and later residents should incur the costs and risk to build another land fill for their household garbage when needed.
VI. Report Omissions
Within the report section dealing with the leachate test results, it is casually mentioned that not only do the landfills receiving shale waste materials have radioactive contaminated leachate, but the other tested landfills do, as well. However, rather than raising a very red flag and expressing concern over a problem that no one has looked into, the report implies we should not worry about any radioactive waste because it might be in all landfills (pg. 139).
Nowhere within the radiological discussion is there any mention of what might be called speciation of radioactive isotopes. The report does state that the test for both gross alpha and gross beta, are considered a “scanning procedure.” The speciation process is sort of a slice and dice procedure, showing exactly what isotopes are responsible for the activity that is being indicated. This process, however, does not seem to have been done on the landfill leachate test samples. The general scanning process cannot do that. Appendix H, pages 141-142, contains detailed facts on radiation dose, risk, and exposure. This might have been a good place to also discuss the proper EPA testing protocols, used or not used, and why.
A short discussion of the DEP-required landfill entrance radiation monitors is included on page 146. The installed monitors are the goalpost type. Trucks drive between them at the entrance and when they cross the scales. It seems that the report should have emphasized that that type of monitor will primarily only detect high-energy gamma radiation. However what is omitted on page 144 is that the primary form of decay for radium-226 is releasing alpha particles. The report is ambiguous in saying the decay products of radium-226 include both alpha particles and some gamma radiation, but radium-266 is not a strong gamma emitter. It is very unlikely that a normal steel enclosed roll-off box would ever trip the alarm setting with a load of drill cuttings. However those monitors are still useful since they will detect the high-energy gamma radiation from a truck carrying a lot of medical waste (pg. 17).
It is stated on page 144 that the greatest health risk due to the presence of radium-226 is the fact that its daughter product is radon-222. Radium-226 has a half-life of 1,600 years, compared to radon’s 3.8 days. This difference might seem to imply that radon is less of a concern. Given the multitude of radium-226 going into our landfills means that we will be producing radon for a very long time.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2015/05/Drill-cuttings-at-landfill-3894-crop-e1432757459333.jpg400899FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2015-08-18 09:06:432020-03-12 14:04:17Landfill Disposal of WV Oil and Gas Waste – A Report Review
In February 2014, the FracTracker Alliance produced our first version of a national well data file and map, showing over 1.1 million active oil and gas wells in the United States. We have now updated that data, with the total of wells up to 1,666,715 active wells accounted for.
Density by state of active oil and gas wells in the United States. Click here to access the legend, details, and full map controls. Zoom in to see summaries by county, and zoom in further to see individual well data. Texas contains state and county totals only, and North Carolina is not included in this map.
While 1.7 million wells is a substantial increase over last year’s total of 1.1 million, it is mostly attributable to differences in how we counted wells this time around, and should not be interpreted as a huge increase in activity over the past 15 months or so. Last year, we attempted to capture those wells that seemed to be producing oil and gas, or about ready to produce. This year, we took a more inclusive definition. Primarily, the additional half-million wells can be accounted for by including wells listed as dry holes, and the inclusion of more types of injection wells. Basically anything with an API number that was not described as permanently plugged was included this time around.
Data for North Carolina are not included, because they did not respond to three email inquiries about their oil and gas data. However, in last year’s national map aggregation, we were told that there were only two active wells in the state. Similarly, we do not have individual well data for Texas, and we use a published list of well counts by county in its place. Last year, we assumed that because there was a charge for the dataset, we would be unable to republish well data. In discussions with the Railroad Commission, we have learned that the data can in fact be republished. However, technical difficulties with their datasets persist, and data that we have purchased lacked location values, despite metadata suggesting that it would be included. So in short, we still don’t have Texas well data, even though it is technically available.
Wells by Type and Status
Each state is responsible for what their oil and gas data looks like, so a simple analysis of something as ostensibly straightforward as what type of well has been drilled can be surprisingly complicated when looking across state lines. Additionally, some states combine the well type and well status into a single data field, making comparisons even more opaque.
Top 10 of 371 published well types for wells in the United States.
Among all of the oil producing states, there are 371 different published well types. This data is “raw,” meaning that no effort has been made to combine similar entries, so “gas, oil” is counted separately from “GAS OIL,” and “Bad Data” has not been combined with “N/A,” either. Conforming data from different sources is an exercise that gets out of hand rather quickly, and utility over using the original published data is questionable, as well. We share this information, primarily to demonstrate the messy state of the data. Many states combine their well type and well status data into a single column, while others keep them separate. Unfortunately, the most frequent well type was blank, either because states did not publish well types, or they did not publish them for all of their wells.
There are no national standards for publishing oil and gas data – a serious barrier to data transparency and the most important takeaway from this exercise…
Wells by Location
Active oil and gas wells in 2015 by state. Except for Texas, all data were aggregated published well coordinates.
There are oil and gas wells in 35 of the 50 states (70%) in the United States, and 1,673 out of 3,144 (53%) of all county and county equivalent areas. The number of wells per state ranges from 57 in Maryland to 291,996 in Texas. There are 135 counties with a single well, while the highest count is in Kern County, California, host to 77,497 active wells.
With the exception of Texas, where the data are based on published lists of well county by county, the state and county well counts were determined by the location of the well coordinates. Because of this, any errors in the original well’s location data could lead to mistakes in the state and county summary files. Any wells that are offshore are not included, either. Altogether, there are about 6,000 wells (0.4%) are missing from the state and county files.
Wells by Operator
There are a staggering number of oil and gas operators in the United States. In a recent project with the National Resources Defense Council, we looked at violations across the few states that publish such data, and only for the 68 operators that were identified previously as having the largest lease acreage nationwide. Even for this task, we had to follow a spreadsheet of which companies were subsidiaries of others, and sometimes the inclusion of an entity like “Williams” on the list came down to a judgement call as to whether we had the correct company or not.
No such effort was undertaken for this analysis. So in Pennsylvania, wells drilled by the operator Exco Resources PA, Inc. are not included with those drilled by Exco Resources PA, Llc., even though they are presumably the same entity. It just isn’t feasible to systematically go through thousands of operators to determine which operators are owned by whom, so we left the data as is. Results, therefore, should be taken with a brine truck’s worth of salt.
Top 10 wells by operator in the US, excluding Texas. Unknown operators are highlighted in red.
Texas does publish wells by operator, but as with so much of their data, it’s just not worth the effort that it takes to process it. First, they process it into thirteen different files, then publish it in PDF format, requiring special software to convert the data to spreadsheet format. Suffice to say, there are thousands of operators of active oil and gas wells in the Lone Star State.
Not counting Texas, there are 39,693 different operators listed in the United States. However, many of those listed are some version of “we don’t know whose well this is.” Sorting the operators by the number of wells that they are listed as having, we see four of the top ten operators are in fact unknown, including the top three positions.
Summary
The state of oil and gas data in the United States is clearly in shambles. As long as there are no national standards for data transparency, we can expect this trend to continue. The data that we looked for in this file is what we consider to be bare bones: well name, well type, well status, slant (directional, vertical, or horizontal), operator, and location. In none of these categories can we say that we have a satisfactory sense of what is going on nationally.
Click on the above button to download the three sets of data we used to make the dynamic map (once you are zoomed in to a state level). The full dataset was broken into three parts due to the large file sizes.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2015/08/2015Update-Feature.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2015-08-03 14:19:532020-07-21 10:30:051.7 Million Wells in the U.S. – A 2015 Update
Finding GIS data for pipeline projects is notoriously difficult but, as most research goes these days, we started with a simple Google search to see what was out there, using basic keywords, such as “Falcon” (the name of the pipeline), “ethane” (the substance being transported), “pipeline” (the topic under discussion), and “ArcGIS” (a commonly used mapping software).
The HOUGEO folder is part of a larger database maintained by AECOM, an engineering firm presumably contracted to prepare the Falcon pipeline construction plan. Data on a few other projects were also visible, such as maps of the Honolulu highway system and a sewer works in Greenville, NC. While these projects were not of interest to us, our assessment is that this publicly accessible server is used to share GIS projects with entities outside the company.
After viewing the Falcon GIS files and assessing them for relevancy, FracTracker went about archiving the data we felt was most useful for our assessing the project. The HOUGEO maps are hosted on a web server meant for viewing GIS maps and their data, either on ArcOnline, Google Earth, or ArcMap. The GIS data could not be edited in these formats. However, viewing the data allowed us to manually recreate most of the data.
FracTracker strives to maintain transparency in all of its work so the public understands how we obtain, analyze, and map data. A good deal of the data found in the HOUGEO folders are available through other sources, such as the U.S. Geological Survey, the Department of Transportation, and the U.S. Census, as well as numerous state and county level agencies. When possible, we opted to go to these original sources in order to minimize our reliance on the HOUGEO data. We also felt it was important to ensure that the data we used was as accurate and up-to-date as possible.
FracTracker also obtained copies of Shell’s permit applications in January by conducting a file review at the PA DEP offices. While these applications — consisting of thousands of pages — only pertain to the areas in Pennsylvania where the Falcon will be built, we were surprised by the accuracy of our analysis when compared with these documents. However, it is important to note that the maps and analysis presented in the Falcon Public EIA Project should be viewed with potential errors in mind.
There are many questions residents should consider when approached by land agent. A list of these questions can be found in the appendix below.
