Data driven discussions about gas extraction and related topics.

Can Californians Escape Oil and Gas Pollution?

The city of Los Angeles is considering a 2,500-foot setback safety buffer between residences and oil and gas wells. Support for the proposal is being led by the grassroots group Stand Together Against Neighborhood Drilling (STAND-LA). The push for a setback follows a recent report by the Los Angeles County Department of Public Health. According to Stand LA:

The report, requested by both the Los Angeles County Supervisors and the Los Angeles City Council, outlines the health impacts faced by residents living, attending school or worshiping near one of Los Angeles County’s 3,468 active oil wells, 880 of which operate in the City of Los Angeles.

The Department outlines the clear health impacts on residents living near active oil wells, including: adverse birth outcomes, increased cancer risk, eye, nose and throat irritation, exacerbation of asthma and other respiratory illnesses, neurological effects such as headaches and dizziness, gastrointestinal effects such as nausea and abdominal pain, and mental health impacts such as depression, anxiety or fatigue.

This information is, of course, nothing new. Living near oil and gas extraction activities, and specifically actively producing wells, has been shown in the literature to increase risks of various health impacts – including asthma and other respiratory diseases, cardiovascular disease, cancer, birth defects, nervous disorders and dermal irritation, among others.1

Spatial Assessment

While Los Angeles would benefit the most from any type of setback regulation due to the county and city’s high population density, the rest of the state would also benefit from the same.

We conducted an assessment of the number of California citizens living proximal to active oil and gas production wells to see who all would be affected by such a change. Population counts were estimated for individuals living within 2,500 feet of an oil and gas production well for the entire state. An interactive map of the wells that fall within 2,500 feet of a residence in California is shown just below in Figure 1.

California 2,500’ oil and gas well buffer map

View map fullscreen | How FracTracker maps work | Map Data (CSV): Aquifer Exemptions, Class II Wells

Figure 1. California 2,500’ oil and gas well buffer, above. The map shows a 2,500’ buffer around active oil and gas wells in California. Wells that are located within 1,000’; 1,500’; and 2,500’ from a residence, hospital or school are also shown in the map. The counts of individuals located within 2,500’ of an active well are displayed for census tracts.

Population Statistics

The number and percentage of California residents living within 2,500 feet of an active (producing) oil and gas well are listed below:

  • Total At-Risk Population

    859,699 individuals in California live within 2,500 feet of an active oil and gas well

  • % Non-White

    Of the total, 385,067 are “Non-white” (45%)

  • % Hispanic

    Of the total, 341,231 are “Hispanic” (40%) as defined by the U.S. Census Bureau2

We calculated population counts within the setbacks for smaller census-designated areas, including counties and census tracts. The results of the calculations are presented in Table 1 below.

Table 1. Population Counts by County

County Total Pop. Impacted Pop. Impacted % Non-White Impacted % Hispanic
Los Angeles 9,818,605 541,818 0.54 0.46
Orange 3,010,232 202,450 0.25 0.19
Kern 839,631 71,506 0.34 0.43
Santa Barbara 423,895 8,821 0.44 0.71
Ventura 823,318 8,555 0.37 0.59
San Bernardino 2,035,210 6,900 0.42 0.59
Riverside 2,189,641 5,835 0.46 0.33
Fresno 930,450 2,477 0.34 0.50
San Joaquin 685,306 2,451 0.55 0.42
Solano 413,344 2,430 0.15 0.15
Colusa 21,419 1,920 0.39 0.70
Contra Costa 1,049,025 1,174 0.35 0.30

Table 1 presents the counts of individuals living within 2,500 feet of an active oil and gas well, aggregated by county. Only the top 12 counties with the highest population counts are shown. “Impacted Population” is the count of individuals estimated to live within 2,500 feet of an oil and gas well. The “% Non-white” and “% Hispanic” columns report the estimated percentage of the impacted population of said demographic. There may be some overlap in these categories.

Conclusions

California is unique in many ways, beautiful beaches and oceans, steep mountains, massive forests, but not least of all is the intensity of the oil and gas industry. Not only are some of the largest volumes of oil extracted from this state, but extraction occurs incredibly close to homes, sometimes within communities – as shown in the photo at the top of this post.

The majority of California citizens living near active production wells are located in Los Angeles County – well over half a million people. LA County makes up 61% of Californians living within 2,500 feet of an oil and gas well, and half of them are non-white minority, people of color.

Additionally, the well sample population used in this analysis is limited to only active production wells. Much more of California’s population is exposed to pollutants from the oil and gas support activities and wells. These pollutants include acidic vapors, hydrocarbons, and diesel particulate matter from exhaust.

Our numbers are, therefore, a conservative estimate of just those living near extraction wells. Including the other activities would increase both the total numbers and the demographic percentages because of the high population density in Los Angeles.

For many communities in California, therefore, it is essentially impossible for residents to escape oil and gas pollution.


The Analysis – How it was done!

Since the focus of this assessment was the potential for impacts to public health, the analysis was limited to oil and gas wells identified as active – meaning they are producing or are viable to produce oil and/or natural gas. This limitation on the dataset was justified to remain conservative to the most viable modes of exposure to contaminants from well sites. Under the assumption that “plugged,” “buried,” or “idle” wells that are not producing (or at least reporting production figures to DOGGR) do not purvey as much as a risk of air emissions, the main route of transport for pollutants to the surrounding communities is via air emissions from “producing” oil and gas wells. The status of wells was taken from DOGGR’s “AllWells.zip” dataset (downloaded 3/7/18).

Analysis Steps:

  1. The first step was to identify oil and gas wells in California affected by 2,500’ and shorter setbacks from occupied dwellings. To achieve this, the footprints of occupied dwellings were identified, and where there was not a data source available the footprints were digitized.
  2. Using GIS tools, 2,500’ buffers were generated from the boundary of the occupied dwellings and a subset of active oil and gas wells located within the buffer zone were generated.
  3. A combination of county and city zoning data and county parcel data was used to direct the selection of building footprint GIS data and the generation of additional building footprint data. Building footprint data is readily available for a number of California cities, but was not available for rural areas.
  4. Existing footprint data was vetted using zoning codes.
  5. Areas located within 2,500’ of well-heads were prioritized for screening satellite imagery in areas zoned for residential use.

Analytical Considerations

Buildings and facilities housing vulnerable populations were also included. Vulnerable populations include people such as children, the elderly, and the immunocompromised. These areas pose an elevated risk for such sensitive populations when they live near hazardous sites, such as oil fields in LA. A variety of these types of sites were included in the GIS analysis, including schools and healthcare facilities.

GIS techniques were used to buffer active oil and gas wells at 2,500 feet. GIS shapefiles and 2010 Decennial census data was downloaded from American Fact Finder via Census.gov for the entire state of California at the census block level.2 Census block GIS layers were clipped to the 2,500-foot buffers. Population data found in Summary File 1 for the 2010 census was attached to the clipped census block GIS layers.  Adjusted population counts were calculated according to the proportion of the area of the census block falling within the 2,500’ buffer.

References

  1. Shonkoff, Seth B.C.; Hays, Jake. 2015. Toward an understanding of the environmental and public health impacts of shale gas development: an analysis of the peer-reviewed scientific literature, 2009-2014. PSE Healthy Energy.
  2. U.S. Census Bureau. 2010 Census Summary File 1.

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Cover photo by Leo Jarzomb | SGV Tribune

Shell Pipeline - Not Quite the Good Neighbor

Shell Pipeline: Not Quite the “Good Neighbor”

In August 2016, Shell Pipeline announced plans to develop the Falcon Ethane Pipeline System, a 97-mile pipeline network that will carry more than 107,000 barrels of ethane per day through Pennsylvania, West Virginia, and Ohio, to feed Shell Appalachia’s petrochemical facility currently under construction in Beaver County, PA.

FracTracker has covered the proposed Falcon pipeline extensively in recent months. Our Falcon Public EIA Project explored the project in great detail, revealing the many steps involved in risk assessments and a range of potential impacts to public and environmental health.

This work has helped communities better understand the implications of the Falcon, such as in highlighting how the pipeline threatens drinking water supplies and encroaches on densely populated neighborhoods. Growing public concern has since convinced the DEP to extend public comments on the Falcon until April 15th, as well as to host three public meetings scheduled for early April.

Shell’s response to these events has invariably focused on their intent to build and operate a pipeline that exceeds safety standards, as well as their commitments to being a good neighbor. In this article, we investigate these claims by looking at federal data on safety incidents related to Shell Pipeline.

Contrary to claims, records show that Shell’s safety record is one of the worst in the nation.

The “Good Neighbor” Narrative

Maintaining a reputation as a “good neighbor” is paramount to pipeline companies. Negotiating with landowners, working with regulators, and getting support from implicated communities can hinge on the perception that the pipeline will be built and operated in a responsible manner. This is evident in cases where Shell Pipeline has sold the Falcon in press releases as an example of the company’s commitment to safety in public comments.

Figure 1. Shell flyer

A recent flyer distributed to communities in the path of the Falcon, seen in Figure 1, also emphasizes safety, such as in claims that “Shell Pipeline has a proven track record of operating safely and responsibility and remains committed to engaging with local communities regarding impacts that may arise from its operations.”

Shell reinforced their “good neighbor” policy on several occasions at a recent Shell-sponsored information meeting held in Beaver County, stating that, everywhere they do business, Shell was committed to the reliable delivery of their product. According to project managers speaking at the event, this is achieved through “planning and training with first responders, preventative maintenance for the right-of-way and valves, and through inspections—all in the name of maintaining pipeline integrity.”

Shell Pipeline also recently created an informational website dedicated to the Falcon pipeline to provide details on the project and emphasize its minimal impact. Although, curiously, Shell’s answer to the question “Is the pipeline safe?” is blank.

U.S. Pipeline Incident Data

Every few years FracTracker revisits data on pipeline safety incidents that is maintained by the Pipeline and Hazardous Materials Safety Administration (PHMSA). In our last national analysis we found that there have been 4,215 pipeline incidents resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion.

These numbers were based on U.S. data from 2010-2016 for natural gas transmission and gathering pipelines, natural gas distribution pipelines, and hazardous liquids pipelines. It is also worth noting that incident data are heavily dependent on voluntary reporting. They also do not account for incidents that were only investigated at the state level.

Shell Pipeline has only a few assets related to transmission, gathering, and distribution lines. Almost all of their pipeline miles transport highly-volatile liquids such as crude oil, refined petroleum products, and hazardous liquids such as ethane. Therefore, to get a more accurate picture of how Shell Pipeline’s safety record stacks up to comparable operators, our analysis focuses exclusively on PHMSA’s hazardous liquids pipeline data. We also expanded our analysis to look at incidents dating back to 2002.

Shell’s Incident Record

In total, PHMSA data show that Shell was responsible for 194 pipeline incidents since 2002. These incidents spilled 59,290 barrels of petrochemical products totaling some $183-million in damages. The below map locates where most of these incidents occurred. Unfortunately, 34 incidents have no location data and so are not visible on the map. The map also shows the location of Shell’s many refineries, transport terminals, and off-shore drilling platforms.

Open the map fullscreen to see more details and tools for exploring the data.

View Map Fullscreen | How FracTracker Maps Work

Incidents Relative to Other Operators

PHMSA’s hazardous liquid pipeline data account for more than 350 known pipeline operators. Some operators are fairly small, only maintaining a few miles of pipeline. Others are hard to track subsidiaries of larger companies. However, the big players stand out from the pack — some 20 operators account for more than 60% of all pipeline miles in the U.S., and Shell Pipeline is one of these 20.

Comparing Shell Pipeline to other major operators carrying HVLs, we found that Shell ranks 2nd in the nation in the most incidents-per-mile of maintained pipeline, seen in table 1 below. These numbers are based on the total incidents since 2002 divided by the number of miles maintained by each operator as of 2016 miles. Table 2 breaks Shell’s incidents down by year and number of miles maintained for each of those years.

Table 1: U.S. Pipeline operators ranked by incidents-per-mile

Operator HVL Incidents HVL Pipeline Miles Incidents Per Mile (2016)
Kinder Morgan 387 3,370 0.115
Shell Pipeline 194 3,490 0.056
Chevron 124 2,380 0.051
Sunoco Pipeline 352 6,459 0.049
ExxonMobile 240 5,090 0.048
Colonial Pipeline 244 5,600 0.044
Enbride 258 6,490 0.04
Buckeye Pipeline 231 7,542 0.031
Magellan Pipeline 376 12,928 0.03
Marathan Pipeline 162 5,755 0.029

Table 2: Shell incidents and maintained pipeline miles by year

Year Incidents Pipeline Miles Total Damage Notes
2002 15 no PHMSA data $2,173,704
2003 20 no PHMSA data $3,233,530
2004 25 5,189 $40,344,002 Hurricane Ivan
2005 22 4,830 $62,528,595 Hurricane Katrina & Rita
2006 10 4,967 $11,561,936
2007 5 4,889 $2,217,354
2008 12 5,076 $1,543,288
2009 15 5,063 $11,349,052
2010 9 4,888 $3,401,975
2011 6 4,904 $2,754,750
2012 12 4,503 $17,268,235
2013 4 3,838 $10,058,625
2014 11 3,774 $3,852,006
2015 12 3,630 $4,061,340
2016 6 3,490 $6,875,000
2017 9 no PHMSA data $242,800
2018 1 no PHMSA data $47,000 As of 3/1/18

Cause & Location of Failure

What were the causes of Shell’s pipeline incidents? At Shell’s public informational session, it was said that “in the industry, we know that the biggest issue with pipeline accidents is third party problems – when someone, not us, hits the pipeline.” However, PHMSA data reveal that most of Shell’s incidents issues should have been under the company’s control. For instance, 66% (128) of incidents were due to equipment failure, corrosion, welding failure, structural issues, or incorrect operations (Table 3).

Table 3. Shell Pipeline incidents by cause of failure

Cause Incidents
Equipment Failure 51
Corrosion 37
Natural Forces 35
Incorrect Operation 25
Other 20
Material and/or Weld Failure 15
Excavation Damage 11
Total 194

However, not all of these incidents occurred at one of Shell’s petrochemical facilities. As Table 4 below illustrates, at least 57 incidents occurred somewhere along the pipeline’s right-of-way through public areas or migrated off Shell’s property to impact public spaces. These numbers may be higher as 47 incidents have no mention of the property where incidents occurred.

Table 4. Shell Pipeline incidents by location of failure

Location Incidents
Contained on Operator Property 88
Pipeline Right-of-Way 54
Unknwon 47
Originated on Operator Property, Migrated off Property 3
Contained on Operator-Controlled Right-of-Way 2
Total 194

On several occasions, Shell has claimed that the Falcon will be safely “unseen and out of mind” beneath at least 4ft of ground cover. However, even when this standard is exceeded, PHMSA data revealed that at least a third of Shell’s incidents occurred beneath 4ft or more of soil.

Many of the aboveground incidents occurred at sites like pumping stations and shut-off valves. For instance, a 2016 ethylene spill in Louisiana was caused by lightning striking a pumping station, leading to pump failure and an eventual fire. In numerous incidents, valves failed due to water seeping into systems from frozen pipes, or large rain events overflowing facility sump pumps. Table 5 below breaks these incidents down by the kind of commodity involved in each case.

Table 5. Shell Pipeline incidents by commodity spill volumes

Commodity Barrels
Crude Oil 51,743
Highly Volatile Liquids 6,066
Gas/Diesel/Fuel 1,156
Petroleum Products 325
Total 59,290

Impacts & Costs

None of Shell’s incidents resulted in fatalities, injuries, or major explosions. However, there is evidence of significant environmental and community impacts. Of 150 incidents that included such data, 76 resulted in soil contamination and 38 resulted in water contamination issues. Furthermore, 78 incidents occurred in high consequence areas (HCAs)—locations along the pipeline that were identified during construction as having sensitive environmental habitats, drinking water resources, or densely populated areas.

Table 6 below shows the costs of the 194 incidents. These numbers are somewhat deceiving as the “Public (other)” category includes such things as inspections, environmental cleanup, and disposal of contaminated soil. Thus, the costs incurred by private citizens and public services totaled more than $80-million.

Table 6. Costs of damage from Shell Pipeline incidents

Private Property Emergency Response Environmental Cleanup Public (other) Damage to Operator Total Cost
$266,575 $62,134,861 $11,024,900 $7,308,000 $102,778,856 $183,513,192

A number of significant incidents are worth mention. For instance, in 2013, a Shell pipeline rupture led to as much as 30,000 gallons of crude oil spilling into a waterway near Houston, Texas, that connects to the Gulf of Mexico. Shell’s initial position was that no rupture or spill had occurred, but this was later found not to be the case after investigations by the U.S. Coast Guard. The image at the top of this page depicts Shell’s cleanup efforts in the waterway.

Another incident found that a Shell crude oil pipeline ruptured twice in less than a year in the San Joaquin Valley, CA. Investigations found that the ruptures were due to “fatigue cracks” that led to 60,000 gallons of oil spilling into grasslands, resulting in more than $6 million in environmental damage and emergency response costs. Concerns raised by the State Fire Marshal’s Pipeline Safety Division following the second spill in 2016 forced Shell to replace a 12-mile stretch of the problematic pipeline, as seen in the image above.

Conclusion

These findings suggest that while Shell is obligated to stress safety to sell the Falcon pipeline to the public, people should take Shell’s “good neighbor” narrative with a degree of skepticism. The numbers presented by PHMSA’s pipeline incident data significantly undermine Shell’s claim of having a proven track record as a safe and responsible operator. In fact, Shell ranks near the top of all US operators for incidents per HVL pipeline mile maintained, as well as damage totals.

There are inherent gaps in our analysis based on data inadequacies worth noting. Incidents dealt with at the state level may not make their way into PHMSA’s data, nor would problems that are not voluntary reported by pipeline operators. Issues similar to what the state of Pennsylvania has experienced with Sunoco Pipeline’s Mariner East 2, where horizontal drilling mishaps have contaminated dozens of streams and private drinking water wells, would likely not be reflected in PHMSA’s data unless those incidents resulted in federal interventions.

Based on the available data, however, most of Shell’s pipelines support one of the company’s many refining and storage facilities, primarily located in California and the Gulf states of Texas and Louisiana. Unsurprisingly, these areas are also where we see dense clusters of pipeline incidents attributed to Shell. In addition, many of Shell’s incidents appear to be the result of inadequate maintenance and improper operations, and less so due to factors beyond their control.

As Shell’s footprint in the Appalachian region expands, their safety history suggests we could see the same proliferation of pipeline incidents in this area over time, as well.

NOTE: This article was amended on 4/9/18 to include table 2.

Header image credit: AFP Photo / Joe Raedle

By Kirk Jalbert, FracTracker Alliance

Photo by Pat Sullivan/AP https://www.houstonchronicle.com/news/houston-texas/houston/article/Fracking-research-hits-roadblock-with-Texas-law-6812820.php

California regulators need to protect groundwater from oil and gas waste this time around

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

California’s 2nd Largest Waste Stream

Every year the oil and gas industry in California generates billions of gallons of wastewater, also known as produced water. According to a study by the California Council on Science and Technology, in 2013, more than 3 billion barrels of produced water were extracted along with some 0.2 billion barrels of oil across the state. This wastewater is usually contaminated with a mixture of heavy metals, hydrocarbons, naturally occurring radioactive materials, and high levels of salts. Yet, contaminated wastewater from oil-field operations is exempt from the hazardous waste regulations enforced by the Resource Conservation and Recovery Act (RCRA).

Operators are, therefore, not required to measure or report the chemistry of this wastewater. Even with these unknowns, it is legally re-injected back into groundwater aquifers for disposal. Once an aquifer is contaminated it can be extremely difficult, if not impossible, to clean up again. Particularly in California, where water resources are already stretched thin, underground injection of oil and gas wastewater is a major environmental and economic concern.

Regulatory Deficiency

Under the Underground Injection Control program, wastewater is supposed to be injected only into geologic formations that don’t contain usable groundwater. However, a loophole in the Safe Drinking Water Act allows oil and gas companies to apply for what’s called an aquifer exemption, which allows them to inject wastewater into aquifers that potentially hold high-quality drinking water. To learn more about aquifer exemptions, see FracTracker’s summary, here.

The California department responsible for managing these aquifer exemption permits – the Division of Oil, Gas, and Geothermal Resources (DOGGR) – has for decades failed in its regulatory capacity. In 2015, for example, DOGGR admitted that at least 2,553 wells had been permitted to inject oil and gas waste into non-exempt aquifers – aquifers that could be used for drinking water. Independent audits of DOGGR showed decades of poor record-keeping, lax oversight, and in some cases, outright defiance of the law – showing the cozy relationship between regulators and the oil and gas industry. While 176 wells (those that were injecting into the cleanest drinking water) were initially shut down, most of the rest of the 2,377 permits were allowed to continue injecting into disputed wells through the following two years of the regulatory process.

The injection wells targeted by the Environmental Protection Agency (EPA), including those that were shut down, are shown in the map below (Figure 1).

Figure 1. Map of EPA-targeted Class II Injection Wells


View map fullscreen | How FracTracker maps work | Map Data (CSV): Aquifer Exemptions, Class II Wells

The timeline of all this is just as concerning. The State of California has known about these problems since 2011, when the EPA audited California’s underground injection program and identified substantial deficiencies in its program, including failure to protect some potential underground sources of drinking water, a one-size-fits-all geologic review, and inadequate and under-qualified staffing for carrying out inspections. In 2014, the Governor’s office requested that the California EPA perform an independent review of the program. EPA subsequently made a specific remediation plan and timeline for DOGGR, and in March of 2015 the State finalized a Corrective Action Plan, to be completed by February 2017.

Scientific Review of CA Oil and Gas Activities

Meanwhile, in 2013, the California Senate passed SB-4, which 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. The California Council on Science and Technology organized and led the study, in collaboration with the Lawrence Berkeley National Laboratories, which combined original technical data analyses and a review of relevant literature, all of which was extensively peer-reviewed. The report argues that both direct and indirect impacts of fracking must be accounted for, and that major deficiencies and inconsistencies in data remained which made research difficult. They also recommended that DOGGR improve and modernize their record keeping to be more transparent.

Figure 2. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

Figure 2*. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

A major component of the SB-4 report covered California’s Class II injection program. Researchers analyzed the depths of groundwater aquifers protected by the Safe Drinking Water Act, and found that injection and hydraulic fracturing activity was occurring within the same or neighboring geological zones as protected drinking water (Figure 2*).

*Reproduced from California Council on Science and Technology: An Independent Scientific Assessment of Well Stimulation in California Vol. 3.

More Exemptions to be Granted

Now, EPA is re-granting exemptions again. Six aquifer exemptions have been granted, and more are on the docket to be considered. In this second time around, it is imperative that regulatory agencies be more diligent in their oversight of this permitting process to protect groundwater resources. At the same time, the 2015 California bill SB 83 mandates the appointment of an independent review panel to evaluate the Underground Injection Control Program and to make recommendations on how to improve the effectiveness of the program. This process is currently in the works and a panel has been assembled, and FracTracker Alliance will be working to provide data, maps and analyses for this panel.

Stay tuned for more to come on which aquifers are being exempted, why, and what steps are being taken to protect groundwater in California.


Feature image by Pat Sullivan/AP

Report: Potential Impacts of Unconventional Oil and Gas on the Delaware River Basin

Report: Potential Impacts of Unconventional Oil and Gas on the Delaware River Basin

Mariner East 2: More Spills & Sinkholes Too?

The Mariner East 2 (ME2) pipeline, currently being built by Sunoco Pipeline (Energy Transfer Partners), is a massive 350-mile long pipeline that, if completed, will carry 275,000 barrels of propane, ethane, butane, and other hydrocarbons per day from the shale gas fields of Western Pennsylvania to a petrochemical export terminal located on the Delaware River.

ME2 has faced numerous challenges from concerned citizens since Sunoco first announced plans for the project in 2014. Fights over taking private property by eminent domain, eyebrow raising permit approvals with known technical deficiencies, as well as nearly a hundred drilling mud spills — inadvertent returns (IRs) — at horizontal directional drilling (HDD) sites have occurred since work began in 2017.

This article and the accompanying map brings us up-to-date on the number, location, and status of ME2’s HDD spills. We also summarize the growing list of violations and settlements related to these events. Finally, we highlight the most recent concerns related to ME2’s construction: sinkholes emerging along the pipeline’s path in karst geological formations.

Map of ME2 Updated HDDs, IRs & Karst

The map below shows an updated visual of ME2’s IRs, as of the DEP’s latest tally on March 1, 2018. Included on this map are HDDs where DEP ordered Sunoco reevaluate construction sites to prevent additional spills. Also identified on this map are locations where Sunoco was ordered to notify landowners in close proximity to certain HDDs prior to additional drilling. Finally, the below map illustrates how sinkholes are not a problem unique to one site of construction but are, in fact, common to many areas along ME2’s route. These topics are discussed in greater depth below.

Open the map full-screen to view additional layers not available in the embedded version below.

View Map Fullscreen | How FracTracker Maps Work



HDDs & Inadvertent Returns – Redux

In July 2017, the PA Environmental Hearing Board granted a two week halt to ME2’s HDD operations. The temporary injunction was in response to petitions from the Clean Air CouncilMountain Watershed Association, and the Delaware Riverkeeper Network following IRs­­ at more than 60 sites that contaminated dozens of private drinking water wells, as well as nearby streams and wetlands. FracTracker first wrote about these issues in this prior article.

HDD IR in Washington County
(image: Observer-Reporter)

Despite these issues, and despite Sunoco being cited for 33 violations, ME2 was allowed to proceed under an August 7th agreement that stated Sunoco must reevaluate their HDD plans to minimize additional spills. These studies were to include re-examining the site’s geology and conducting seismic surveys. Sites for reevaluation were selected based on factors such as proximity water supplies, nearby streams and wetlands, problematic geologic conditions, and if an IR had occurred at that site previously. Of ME2’s 230 HDDs, 64 were ordered for reevaluation — 22 of these were selected due to prior IRs occurring at the site.

The DEP mandated that Sunoco’s reevaluation studies be put out for public comment. A table of which HDD studies are currently out for comment can be found here. DEP’s settlement also required Sunoco to notify landowners in proximity to certain HDDs prior to commencing construction due to elevated risks. Of the 64 HDD sites under review, Sunoco must notify 17 residents within 450ft of an HDD site, and 22 residents within 150ft of other sites. The HDD reevaluation sites are shown on the FracTracker map above. Below is an illustration of one site where Sunoco is required to notify landowners within 450ft.

One issue residents have raised with these notifications is that Sunoco is allowed to offer landowners the option to connect their homes to a water buffalo during drilling as an alternative to using their groundwater well. The catch is that, if their well does become contaminated, they would also waive their right to have Sunoco drill them a new replacement well.

“Egregious Violations”

In January 2018, the DEP again suspended ME2’s construction, this time indefinitely revoking their permits, due to even more IRs. DEP also cited Sunoco for “egregious and willful” permit violations —mainly executing HDDs at sites where they had no permission to do so. The DEP noted of their decision that, “a permit suspension is one of the most significant penalties DEP can levy.”

Nevertheless, Sunoco was again allowed to resume construction on February 8, 2018, after paying a $12.6 million fine. The DEP press release accompanying the decision assured the public that, “Sunoco has demonstrated that it has taken steps to ensure the company will conduct the remaining pipeline construction activities in accordance with the law and permit conditions, and will be allowed to resume.”

A few weeks later, Sunoco ran a full-page advertisement in the Harrisburg Patriot-News, shown above, lauding their safety record. Among other notables, the piece boasts, “State and federal regulators spent more than 100 inspection days during 2017 on the Mariner East project, more inspection days than on any other pipeline in Pennsylvania.” Critics have noted that the inordinate number of inspections are due to the comedy of errors associated with ME2’s construction.

Karst Formations & Sinkholes

Which brings us to the current ME2 debacle. Last week, the PA Public Utility Commission (PUC) ordered a temporary shutdown of Mariner East 1 (ME1), another natural gas liquids pipeline owned by Sunoco/ETP. ME1 was built in the 1930s and its right-of-way is being used for most of ME2’s route across the state. This latest construction setback comes in the wake of numerous sinkholes that emerged beginning in December along Lisa Drive in West Whitehead Township, a suburb of Philadelphia in Chester County.

The most recent of these sinkholes grew into a 20ft-deep, 15ft-wide chasm that exposed portions of ME1 and came within 10ft of a house. It is worth noting that, until only a few days ago, ME1 was an operational 8in pipeline with a potential impact radius (aka “blast zone”) of some 500ft. The PUC ordered that Sunoco must now run a line inspection on ME1 for a mile upstream and a mile downstream from the sinkhole sites along Lisa Drive, seen in the image below. Note the proximity of these sinkholes to Amtrak’s Keystone rail lines (connecting Pittsburgh to Philadelphia), under which ME2 also runs. The Federal Railway Administration only recently learned of the sink holes from a nearby resident.

The Lisa Drive sinkholes are being credited to Sunoco executing an HDD in an area known to have karst geological formations. Sunoco has been ordered by the PUC to conduct more geophysical testing and seismic analyses of the area because of this. Karst is often called the “Swiss cheese” of geology — notorious for caves, sinkholes, and underground rivers. As these geological formations change shape, pipelines can bend and settle over time, ultimately leading to potentially dangerous gas leakages or explosions. For instance, the 2015 Atex-1 pipeline explosion in Follansbee, WV, was ultimately determined by the Pipeline and Hazardous Materials Safety Administration (PHSA) as having been caused by ground settling. That explosion released some 24,000 barrels of ethane, burning more than five acres of surrounding land.

The US Geological Survey (USGS) maintains fairly detailed maps of rock formations for most states, including formations known to have karst. In PA, there are a number of “carbonate” rock families known for karst features and settlement issues: limestone and dolostone, and, to a lesser extent, shale. Meanwhile, the PA Department of Conservation and Natural Resources (DCNR) has maintained a record of karst “features” — sinkholes and surface depressions — documented since 1985. A great explanation of the different types of karst features can be found here.

Underestimating the Risks

What is concerning about the Lisa Drive sinkholes is that Sunoco had supposedly already conducted additional karst geological reviews of the area as part of the August DEP settlement, subsequently ranking a nearby HDD (#PA-CH-0219) as “low risk” for running into karst issues—despite knowing the HDD runs through a karst formation with sinkholes and surface depressions in the area. For the HDD that runs the length of Lisa Drive (#PA-CH-0256), the study rated its risk as “very low.” These two HDDs are shown below, along with the area of ME1 now under structural review.

The likely result of these inaccurate assessments led to two IRs at Lisa Drive, one in October and another in November 0f 2017. DEP’s writeup of these events note that the total volume of drilling muds spilled remains unknown because Sunoco didn’t report the incident. Then, only a month later, sinkholes emerged in the same locations. An image of the November HDD IR is shown below.

It is important to note two additional things of Sunoco’s karst study, an except of which is seen in their map of the West Whiteland area below. First, Lisa Drive is just on the edge of a karst limestone formation. USGS data suggest the location is actually mica schist, but the USGS data is also only a rough estimate of different formations. This underscores why pipeline companies must be required to conduct detailed geotechnical analysis of all HDD sites at the onset of their projects.

The other notable aspect of Sunoco’s study is that it does not fully represent all rock formations known to have karst features. In Sunoco’s map, we see orange shading for limestone, but this does not include dolostone that underlies the many surface depressions and sinkholes surrounding West Whiteland. FracTracker’s map includes these formations for greater accuracy.

Takeaways

Interestingly, as Anya Litvak of the Pittsburgh Post-Gazette observed in her reporting on the Lisa Drive incident, Sunoco’s updated karst assessment ranked the entire route of the ME2 pipeline through the state as “low to very low” risk for potential issues. Furthermore, Sunoco has tried to downplay the Lisa Drive incident, stating that “all areas have been secured,” and that additional incidents are unlikely to occur.

But the overall relationship between Mariner East 2’s IRs, HDD sites, and known karst features tells a very different story than Sunoco’s about the potential risks of ME2. In addition to the concerns about new sinkholes near Lisa Drive, FracTracker found the following in our analysis:

  • 7 sinkholes and 386 surface depressions are within 1,500ft of a ME2 HDD site.
  • Of the 230 HDDs, 87 are located in carbonate rock areas (52 in limestone/dolostone, 35 in shale).
  • Of the 99 IRs, 39 have occurred in carbonate rock areas (23 in limestone/dolostone, 16 in shale).

In other words, nearly half of the IRs caused by ME2 HDDs were located in areas known to have karst formations. Worth noting is that an additional 15 occurred in sandstone formations, also known to cause settlement over time. The remaining IRs are split across nine other formation types.

Considering that the DEP’s current review of Sunoco’s ability to safely execute future HDDs are based on the same karst study that missed the Lisa Drive HDD and ranked nearby HDDs as a “low” risk, one can only assume that additional spills will occur. There are many more HDD sites yet to be drilled, and also not likely studied fully for potential karst risks. As illustrated by the continuing saga of spills, violations, and omissions, it is clear that Sunoco has not maintained a high standard of construction in building ME2 from the onset.

We thank Eric Friedman from the Middletown Coalition for Community Safety for supplying photos of the Lisa Drive site used in this article.

By Kirk Jalbert, FracTracker Alliance

Aerial image of fracking activity in Marshall County, WV, next to the Ohio River on January 26th, 2018 from approximately 1,000 to 1,200 feet, courtesy of a partnership with SouthWings and pilot Dave Warner. The camera we used was a Nikon D5300. Photo by Ted Auch, FracTracker Alliance, January 2018

Fracking’s Freshwater Supply and Demand in Eastern Ohio

Mapping Hydraulic Fracturing Freshwater Supply and Demand in Ohio

Below is a map of annual and cumulative water withdrawal volumes by the hydraulic fracturing industry across Ohio between 2010 and 2016. It displays 312 unique sites, as well as water usage per lateral. The digital map, which can be expanded fullscreen for more features, includes data up until May 2017 for 1,480 Ohio laterals (vertical wells can host more than one lateral well).


View map fullscreen | How FracTracker maps work

The primary take-home message from this analysis and the resulting map is that we can only account for approximately 73% of the industry’s more than 13-billion-gallon freshwater demand by considering withdrawals alone. Another source or sources must be supplying water for these hydraulic fracturing operations.

Hydraulic fracturing rig on the banks of the Ohio River in Marshall County, West Virginia, Winter 2018 (Flight provided by SouthWings)

When Leatra Harper at Freshwater Accountability Project and Thriving Earth Exchange and I brought up this issue with Ohio Division of Water Resources Water Inventory and Planning Program Manager, Michael Hallfrisch, the following correspondence took place on January 24, 2018:

Mr. Hallfrisch: “Where did the water usage per lateral data come from?  Does the water usage include reused/recycled water?  I know that many of the larger operators reuse a significant amount of their flow back because of the high cost of disposal in class II injection wells.”

FracTracker: “[We’]ve been looking at Class II disposal economics in several states and frankly the costs here in Ohio are quite cheap and many of the same players in Ohio operate in the other states [We]’ve looked at.  Granted they usually own their own Class II wells in those other states (i.e., OK, or CO) but the fact that they are “vertically integrated” still doesn’t excuse the fact that the cost of disposing of waste in Ohio is dirt cheap.  As for recycling that % was always a rounding error and last [we] checked the data it was going down by about 0.25-0.35% per year from an average of about 5.5-8.0%.  [We respectfully] doubt the recycling % would fill this 25% gap in where water is coming from.  This gap lends credence to what Lea and [FracTracker] hear time and again in counties like Belmont, Monroe, Noble etc with people telling us about frequent trenches being dug in 1st and 2nd order streams with operators topping off their demands in undocumented ways/means.  Apologies for coming down hard on this thing but we’ve been looking/mapping this thing since 2012 and increasingly frustrated with the gap in our basic understanding of flows/stocks of freshwater and waste cycling within Ohio and coming into the state from PA and WV.”

Broader Implications

The fracking industry in Ohio uses roughly 10-14 million gallons per well, up from 4-5 million gallon demands in 2010, which means that freshwater demand for this industry is increasing 15% per year (Figures 1 and 2). (This rate is more than double the volumes cited in a recent publication by the American Chemical Society, by the way.) If such exponential growth in hydraulic fracturing’s freshwater demand in Appalachia continues, by 2022 each well in Ohio and West Virginia will likely require[1*] at least 43 million gallons of freshwater (Table 1).

Table 1. Projected annual average freshwater demand per well (gallons) for the hydraulic fracturing industry in Ohio and West Virginia based on a 15% increase per year.

Year Water Use Per Well (gallons)
Ohio West Virginia
2019 19,370,077 19,717,522
2020 23,658,666 23,938,971
2021 28,896,760 29,064,215
2022 35,294,582 35,286,756
2023 43,108,900 42,841,519

Water quantity and associated watershed security issues are both acute and chronic concerns at the local level, where fracking’s freshwater demands equal 14% of residential demands across Ohio. These quantities actually exceed 85% of residential demand in several Ohio counties (e.g., Carroll and Harrison), as well as West Virginia (e.g., Doddridge, Marshall, and Wetzel). Interestingly the dramatic uptick in Ohio freshwater demand that began at the end of 2013 coincides with a 50% decline in the price of oil and gas (Figure 3).  The implication here is that as the price of gas and oil drops and/or unproductive wells are drilled at an unacceptable rate, the industry uses more freshwater and sand to ensure acceptable financial returns on investments.

Figures 1-3

Note: Data from U.S. Energy Information Administration (EIA) Petroleum & Other Liquids Overview

Total Water Used

To date, the fracking industry has taken on average 90 million gallons of freshwater per county out of Ohio’s underlying watersheds, resulting in the production of 9.6 million gallons of brine waste that cannot be reintroduced into waterways. This massive waste stream is destined for one of Ohio’s Class II Injection wells, but the industry spends less than 1.25% of available capital on water demand(s) and waste disposal. All of this means that the current incentive (cost) to become more efficient is too low. Sellers of water to the industry like the Muskingum Watershed Conservancy District, which we’ve chronicled frequently in the past[2], have actually dropped their price for every 1,000 gallons of water – from roughly $9 to now just $4-6 – for the fracking industry in recent years.

Hydraulic fracturing’s demand is becoming an increasingly larger component of total water withdrawals in Ohio, as other industries, agriculture, and mining become more efficient. Oil and gas wells drilled at the perimeter of the Utica Shale are utilizing 1.25 to 2.5 times more water than those that are staged in the shale “Sweet Spots.” Furthermore, the rise in permitting of so called “Super Laterals” would render all of our water utilization projections null and void. Laterals are the horizontal wells that extend out underground from the vertical well. Most well pads are home to multiple laterals in the range of 4-7 laterals per pad across Ohio and West Virginia.

These laterals, which can reach up to 21,000 feet or almost 4 miles, demand as much as 87 million gallons of freshwater each.

Even accounting for the fact that the super laterals are 17-21,000 feet in length – vs. an average of 7,452 feet – such water demand would dwarf current demands and their associated pressures on watershed security and/or resilience; typically, Ohio’s hydraulically fractured laterals require 970-1,080 gallons of freshwater per lateral foot (GPLF), but super laterals would need an astounding 4,470 GLPF.

Conclusions and Next Steps

The map above illustrates the acute pressures being put upon watersheds and public water supplies in the name of “energy independence.” Yet, Ohio regulators and county officials aren’t putting any pressure on the high volume hydraulic fracturing (HVHF) industry to use less water and produce less waste. We can’t determine exactly how water demand will change in the future. The problem is not going away, however, especially as climate change results in more volatile year-to-year fluctuations in temperature and precipitation. This means that freshwater that was/is viewed as a surplus “commodity” will become more valuable and hopefully priced accordingly.

Furthermore, the Appalachian Ohio landscape is undergoing dramatic transformations at the hands of the coal and more recently the HVHF industry with strip-mines, cracking plants, cryogenic facilities, compressor stations, gas gathering lines – and more – becoming ubiquitous.

We are seeing significant acreage of deciduous forests, cropland, or pasture that once covered the region replaced with the types of impervious surfaces and/or “clean fill” soil that has come to dominate HVHF landscapes in other states like North Dakota, Texas, and Oklahoma.

This landscape change in concert with climate change will mean that the region will not be able to receive, processes, and store water as effectively as it has in the past.

It is too late to accurately and/or more holistically price the HVHF’s current and past water demand in Ohio, however, such holistic pricing would do wonders for how the industry uses freshwater in the future. After all, for an industry that believes so devotedly in the laws of supply and demand, one would think they could get on board with applying such laws to their #1 resource demand in Appalachia. The water the HVHF industry uses is permanently removed from the hydrological cycle. Now is the time to act to prevent long term impacts on Ohio’s freshwater quantity and quality.


Relevant Data

  • Ohio hydraulic fracturing lateral freshwater demand by individual well between 2010 and the end of 2016. Download
  • Ohio hydraulic fracturing lateral freshwater withdrawals by site between 2010 and the end of 2016. Download

Endnotes

  1. *Certainty, with respect to this change in freshwater demand, is in the range of 86-90% assuming the exponential functions we fit to the Ohio and West Virginia data persist for the foreseeable future. Downing, Bob, 2014, “Ohio Drillers’ Growing Use of Fresh Water Concerns Environmental Activists”, March 19th, Akron, Ohio
  2. Downing, Bob, 2014, “Group Reacts to Muskingum Watershed Leasing Deal with Antero”, April 22nd, Akron, Ohio

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

High Impact Areas and Donut Holes - Variability in PA's Unconventional O&G Industry map

High Impact Areas and Donut Holes – A Look at Unconventional O&G Activity in PA

FracTracker Alliance has been mapping the impacts of unconventional oil and gas (O&G) drilling activity in Pennsylvania since 2010, and the Pennsylvania Shale Viewer is our most complete map to show the impacts of the industry.

While it can rightly be said that the development of the Marcellus Shale and other unconventional formations have affected half the state since 2005, this analysis takes a look at high impact areas, as well as a closer look at areas that have been avoided so far.


By Matt Kelso, Manager of Data and Technology, FracTracker Alliance

http://www.bakersfield.com/news/arvin-looks-to-impose-more-regulations-on-oil-gas-operators/article_2beb26d6-cbdc-11e7-ba1a-4b0ac35a0fa8.html

Arvin, CA – a City in the Most Drilled County in the Country – files for a Setback Ordinance

The City of Arvin, with a population of about 20,000, is located in Kern County, California just 15 miles southeast of Bakersfield. Nicknamed ‘The Garden in the Sun,’ Arvin is moving forward with establishing new regulations that would limit oil and gas development within the city limits.

Setback Map

The new ordinance proposes setback distances for sensitive sites including hospitals and schools, as well as residentially and commercially zoned parcels. The proposal establishes a 300-foot buffer for new development and 600’ for new operations.

In the map below, FracTracker Alliance has mapped out the zoning districts in Arvin and mapped the reach of the buffers around those districts. The areas where oil and gas well permits will be blocked by the ordinance are shown in green, labeled “Buffered Protected Zones.” The “Unprotected Zones” will still allow oil and gas permits for new development.

There are currently 13 producing oil and gas wells within the city limits of Arvin, 11 of them are located in the protected zones. Those within the protected zones are operated by Sun Mountain Oil and Gas and Petro Capital Resources. They were all drilled prior to 1980, and are shown in the map below.

Map 1. Arvin, CA Proposed setback ordinance

View map fullscreen | How FracTracker maps work

Information on the public hearings and proposals can be found in the Arvin city website, where the city posts public notices. As of January 24, 2018, these are the current documents related to the proposed ordinance that you will find on the webpage:

Earlier Proposals in Arvin

The proposed 2017 setback ordinance is in response to a previously proposed 2016 ordinance that would allow Kern County to fast track permits for oil and gas activities without environmental review or any public notice for the next 20 years. This could mean 72,000 new wells without review, in an area that already possesses the worst air quality in the country. Communities of color would of course be disproportionately impacted by such policy. In Kern County, the large percentage of Latinx residents suffer the impacts of oil drilling and fracking operations near their homes schools and public spaces.

In December of 2016, Committee for a Better Arvin, Committee for a Better Shafter, and Greenfield Walking Group, represented by Center for Race, Poverty and the Environment, sued Kern County. The lawsuit was filed in coordination with EarthJustice, Sierra Club, Natural Resources Defense Council, and the Center for Biological Diversity.

The Importance of Local Rule

Self-determination by local rule is fundamental of United States democracy, but is often derailed by corporate industry interests by the way of state pre-emption. There is a general understanding that local governments are able to institute policies that protect the interests of their constituents, as long as they do not conflict with the laws of the state or federal government. Typically, local municipalities are able to pass laws that are more constrictive than regional, state, and the federal government.

Unfortunately, when it comes to environmental health regulations, states commonly institute policies that preserve the rights of extractive industries to access mineral resources. In such cases, the state law “pre-empts” the ability of local municipalities to regulate. Local laws can be considered the mandate of the people, rather than the influence of outside interest on representatives. Therefore, when it comes to land use and issues of environmental health, local self-determination must be preserved so that communities are empowered in their decision making to best protect the health of their citizens.

For more on local policies that regulate oil and gas operations in California, see FracTracker’s pieces, Local Actions in California, as well as What Does Los Angeles Mean for Local Bans?


By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Feature image by: Henry A. Barrios / The Californian

Pipeline Regulations & Impact Assessments, a Primer

Part of the Falcon Public EIA Project

Pipelines are categorized by what they carry — natural gas, oil, or natural gas liquids (NGLs) — and where they go — interstate or intrastate. The regulatory system is complicated. This primer is a quick guide to the agencies that may be involved in Falcon’s permit reviews.

Regulating Pipelines

The siting of natural gas pipelines crossing state or country boundaries is regulated by the Federal Energy Regulatory Commission (FERC). Meanwhile, determination of the location of natural gas routes that do not cross such boundaries are not jurisdictional to FERC, instead determined by the owner pipeline company. Hazardous liquids and NGL pipelines are not regulated for siting by FERC regardless of their location and destination. However, FERC does have authority over determining rates and terms of service in these cases. The U.S. Army Corps of Engineers gets involved when pipelines cross navigable waters such as large rivers and state Environmental Protection Agencies.

Pipeline design, operation, and safety regulations are established by the Pipeline and Hazardous Materials Safety Administration (PHMSA), but these regulations may vary state-by-state as long as minimal federal standards are met by the pipeline project. Notably, PHMSA’s oversight of safety issues does not determine where a pipeline is constructed as this is regulated by the different agencies mentioned above – nor are PHMSA’s safety considerations reviewed simultaneously in siting determinations done by other agencies.

An excerpt from the U.S. Army Corps’ EIS of the Atlantic Sunrise pipeline

These federal agencies are required by the National Environmental Policy Act (NEPA) to prepare an Environmental Impact Statement (EIS) investigating how the pipeline pertains to things like the Clean Water Act, the Endangered Species Act, the National Historic Preservation Act, as well as state and local laws. The image above, for instance, is a caption from the Army Corp’s assessment of the Atlantic Sunrise, a natural gas pipeline.

An EIS is based on surveying and background research conducted by the company proposing the project, then submitted to agencies as an Environmental Impact Assessment (EIA). An EIS can exceed hundreds of pages and can go through many drafts as companies are asked to refine their EIA in order to qualify for approval.

An excerpt from the PA DEP’s review of water crossings for the Mariner East 2 pipeline

Pipeline proposals are also evaluated by state and local agencies. In Pennsylvania, for instance, the PA DEP is responsible for assessing how to minimize pipeline impacts. The DEP’s mission is to protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment. The PA Fish and Boat Commission oversees the avoidance or relocation of protected species. Local township zoning codes can also apply, such as to where facilities are sited near zoned residential areas or drinking reservoirs, but these can be overruled by decisions made at the federal level, especially when eminent domain is granted to the project.

Regulating the Falcon

For the Falcon pipeline, an interstate pipeline that will transport ethane (an NGL), FERC will likely have authority over determining rates and terms of service, but not siting. Construction permitting will be left state agencies and PHMSA will retain its federal authority with the Pennsylvania Public Utilities Commission (PUC) acting as PHMSA’s state agent to ensure the project complies with federal safety standards and to investigate violations. The Army Corps will almost certainly be involved given that the Falcon will cross the Ohio River. As far as we know, the Falcon will not have eminent domain status because it supplies a private facility and, thus, does not qualify as a public utility project.

Questioning Impact Assessments

The contents of EIAs vary, but are generally organized along the lines of the thematic categories that we have created for assessing the Falcon data, as seen above. However, there is also much that EISs fail to adequately address. The Army Corp’s assessment of the Atlantic Sunrise is a good example. The final EIS resulting from the operators EIA includes considerations for socioeconomic impacts, such effects on employment and environmental justice, as seen in the excerpt below. But potential negative impact in these areas are not necessarily linked to laws requiring special accommodations. For instance, federal regulations mandate achieving environmental justice by “identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects” of projects subject to NEPA’s EIS requirement. However, there are no laws that outline thresholds of unacceptable impact that would disallow a project to proceed.

An excerpt from the Atlantic Sunrise EIS addressing environmental justice concerns

Furthermore, the narratives of EIAs are almost always written by the companies proposing the project, using sources of data that better support their claims of minimal or positive impact. This is again seen in the Atlantic Sunrise EIS, where several studies are cited on how pipelines have no affect on property values or mortgages, with no mention of other studies that contradict such findings. Other factors that may be important when considering pipeline projects, such as concerns for sustainability, climate change, or a community’s social well-being, are noticeably absent.

Complicating matters, some pipeline operators have been successful in skirting comprehensive EIAs. This was seen in the case of the Mariner East 2 pipeline. Despite being the largest pipeline project in Pennsylvania’s history, a NEPA review was never conducted for ME2.

* * *

Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Routes, Facilities & Easements

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project, we first focus on the route of the pipeline and prior routes that were considered. We take a closer look at the properties along the route that required easement agreements from landowners. Finally, we locate facilities that will be built as part of the project, such as metering stations and shut-off valves, as well as the pipeline’s construction areas and access roads.

Quick Falcon Facts

  • 97.5 miles of proposed pipeline (an additional 200+ miles surveyed during the process)
  • 2,000 parcels of land surveyed; 765 easements executed; 469 will be needed to execute the route
  • Five meter pads and 18 shut-off valves
  • 111 temporary access roads, 21 permanent access roads
  • 1,273 acres required for construction space; 650 acres for the permanent right-of-way

Map of Falcon pipeline routes, properties, and facilities

The following map will serve as our guide in breaking down these first components. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible at closer zoom levels. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work


Finding a Right-of-Way

Pipeline operators must consider a variety of factors when searching for a viable right of way (ROW) for their project—the continuous stretch of land needed to construct, maintain, and operate the pipeline. This process begins with reviewing data and maps made available by federal, state, and local agencies in order to identify features that would complicate the project. These might include such things as protected wetlands, drinking water sources, abandoned mines, or heavily populated areas.

A second step is to conduct manual field surveys along their planned route. During this stage, engineers do precise measurements to determine how the pipeline will cross individual properties as well as locate site-specific concerns that need to be accounted for, such as the presence of endangered species or archeological sites. FracTracker previously produced a guide to pipeline surveying, which can be found here.

The process of finding a viable pipeline route can undergo dozens of revisions and take months or years to complete. The example image seen below, taken from our interactive map at the top of the page, shows a few of the many different 50ft. ROWs considered by Shell. These were documented every few months as the data changed.

A section of the Falcon route with prior routes considered

The most recent route is highlighted in red, totaling 97.5 miles (Shell’s original press releases stated 94 miles). Segments that represent alternative routes considered in certain places are shown in blue (these earlier divergences total 19 miles). Other areas surveyed at some point in the process are shown in dotted purple (totaling 91.3 miles). Given that the route has changed very little in recent months, as well as the fact that Shell has submitted their permit applications for project, we believe that the route in red is likely the route proposed to regulatory agencies.

Note that, in the interactive map, there is an additional “Air Liquide” pipeline (this is the name of a gas products company) proposed by Shell that will run from the ethane cracker south for about .5 miles. Based on comments made by Shell at public hearings, we assume this will be a nitrogen pipeline feeding the plant from an unknown source.

Acquiring Easements

Perhaps the most significant factor that can determine a pipeline route is finding landowners amenable to having their land surveyed and, ultimately, willing to sign easements to allow the pipeline on their property. In some instances, pipeline companies can be granted eminent domain as a “public utility” to take land by force (ME2). However, Shell has stated publicly that eminent domain in not an option for Falcon, due to the fact that the pipeline services a private facility. FracTracker previously produced a guide for landowners who might be approached by pipeline operators seeking to survey their properties.

The Falcon pipeline will have a permanent ROW of 50ft that will cross 10 municipalities in Pennsylvania, 12 townships in Ohio, as well as northern Hancock County, West Virginia. More than 2,000 individual parcels of land were surveyed across this region. Of those 2,000, Shell approached landowners for 765 unique parcels at some point in the process to obtain easements, either for the pipeline ROW itself or for access roads.

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To date, Shell has executed 572 easements. Of these, 469 will be needed to execute the current proposed route. However, as of this time, 14 parcels along the proposed route are still listed as “landowner contacted,” meaning that the easement has not yet been executed. The image below is a page from Shell’s permit applications to the PA DEP listing properties pending in Pennsylvania.

Pending PA easements from Shell’s permit applications

Media sources have reported on some of the details of Shell’s Pipeline easement agreements. In some instances, contracts stated a transactional price of $10 per linear foot as a “placeholder” to get the process started. In other cases, Shell has paid landowners as much as $75 per linear foot of pipeline. These agreements also state that Shell reserved the right to “lay, construct, test, maintain, inspect, operate, repair, renew, relocate, replace, substitute, change the size of, upgrade, alter, mark, protect and remove or abandon in place” any pipelines on the property. Below is an example of how our interactive map represents these parcels and their status. For instance, executed easements are in green and pending or stalled agreements in yellow.

Parcels along the Falcon route and their easement status

Valves & Metering Stations

Pipelines require a number of facilities to properly manage the flow and pressure of gas from one end of the line to another. For instance, metering stations are installed to measure how much gas is in the pipeline system at given points. Falcon has five “pads” where metering stations will be located. Three of these are co-located at the origin points of the pipeline (the MarkWest separator facilities) and a fourth at the ethane cracker end-point. However, the fifth meter stations will be located where the two legs of the pipeline meet in northeast Raccoon Township, Beaver County, PA. This site is called the “Junction” meter pad.

Shut-off valves will also placed along the route—18 in all for Falcon—in order to section off lengths of the pipeline that can be turned off as needed. These valves will be located at fairly regular intervals of 8-10 miles in most places, but are also found just before and after sensitive locations, such as the Oho River crossing and areas and where the lines juncture.

The Risks of Proximity

Metering stations and shut-off valves bring particular risks. For instance, when valves are closed at a section of pipeline for maintenance, or in the event of an emergency, excess gasses must vented to relieve pressure. This is one reason why communities have become concerned about the location of these facilities, such as with a Mariner East 2 pipeline valve in West Goshen Township, PA. Similarly, the Falcon pipelines’ valve in New Somerset, OH, is especially close to residential areas, seen below.

A proposed Falcon shut-off valve site in New Somerset, Ohio

Workspaces & Access Roads

Finally, pipeline operators must identify in their permit applications the “workspace” needed for construction. Shell’s temporary ROW for workspace is approximately 100ft in most stretches along the Falcon’s route, similar to what is shown in the image below. Site-specific conditions, such as road, railroad crossings, and buildings make the workspace narrower in some instances, but much larger workspaces will be needed around sites like metering stations and shut-off valves.

A typical pipeline workspace; this one from the Mariner East 2

The locations of access roads must also be identified in permit applications. Access roads come in two categories and typically require a 25ft ROW. Temporary access roads are used during the construction process and often utilize existing private driveways, farm roads, or are built after clearing land acquired in the easement process. Permanent roads allow long-term access to facilities, such as valves and pumping stations, as well as for bringing in equipment to maintain the pipeline’s ROW. Shell’s plan proposes 111 temporary access roads (28 miles) and 21 permanent access roads (2.3 miles).

Shell’s permit applications state that the total disturbed workspace needed for construction and access roads is approximately 1,273 acres. About half of this will remain cleared for the permanent right-of-way and permanent access roads.

A Closer Look

When a pipeline project is subject to regulatory review, alternative routes are typically offered up by the operator for consideration in weighing different costs and benefits. Major reroutes typically deviate from the proposed route for significant distances in order to avoid significant impediments such as large cities or protected lands. Minor alternatives are shorter in length and used to avoid specific areas of concern, such as a protected wetland. An alternative route might also be selected in order to utilize an existing ROW from other pipelines.

Ohio River Crossing

As noted, there are a number of places along the Falcon route where we see examples of major route changes. Many of these reroutes appear to be due to landowners along the preferred path not signing easements for one reason or another. One of the more significant change occurred at the location where the Falcon crosses the Ohio River in Hancock County, West Virginia, seen below. For many months, Shell’s maps showed a planned crossing south of the current proposed route, but later took a dramatic diversion to the north, apparently due to an easement not having been executed for a single property. What is notable about the new route is that it utilizes property owned by the popular Mountaineer Casino, Racetrack, and Resort.

The current and former Falcon route crossing the Ohio River

Fort Cherry Golf Course Reroute

In another instance, we see a reroute near the Fort Cherry Golf Course in McDonald, Washington County, PA. An earlier route took the Falcon straight through the course, whereas the current proposed route goes further east, disrupting a smaller number of fairways. Notice in the image below that a temporary access road for the pipeline’s construction will also still utilize Fort Cherry Golf Course’s driveway.

The current and former Falcon routes crossing the Ft. Cherry Golf Course

Montour Trail Intersections

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Finally, we bring attention to what appears to be some of the few remaining properties with easements not yet settled in order to begin construction. As noted in the excerpt from Shell’s permit application at the top of this page, a number of parcels owned by the Montour Trail Council have a status of: “in negotiation and depended on submitted crossing permit applications,” presumably meaning they would agree to the easement if PA DEP approved Shell’s permits.

Falcon intersections with the Montour Trail

The Montour Trail is a 46-mile long multi-use non-motorized recreational rail-trail located in Washington and Allegheny County, PA, used by more than 400,000 people annually. It also makes up part of the Great Allegheny Passage (GAP), a trail system that stretches over 335 miles from Pittsburgh to Washington, DC. The trail is managed by the nonprofit Montour Trail Council with support from state agencies such as the Pennsylvania Department of Conservation and Natural Resources (DCNR).

We were surprised to find that the Montour Trail will be crossed by the Falcon in 9 locations: 5 by the pipeline itself, 3 by temporary access roads, and 1 by a permanent access road, as illustrated in the image above. Two of the pipeline intersections will be executed using HDD boring. The trail and its intersection with the Falcon can be seen by activating these layers on FracTracker’s interactive map, as illustrated in the image above.

 

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By Kirk Jalbert, FracTracker Alliance