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Mapping the Petrochemical Build-Out Along the Ohio River

New maps show the build-out of oil and gas infrastructure that converts the upper Ohio River Valley’s fracked gas into petrochemical products

In 2004, Range Resources purchased land in Washington County, Pennsylvania and “fracked” the first well in the Marcellus Shale, opening the flood gates to a wave of natural gas development.

Since then, oil and gas companies have fracked thousands of wells in the upper Ohio River Valley, from the river’s headwaters in Pennsylvania, through Ohio and West Virginia, and into Kentucky.

Industry sold natural gas as a “bridge fuel” to renewable energy, but 15 years since the first fracked Marcellus well, it’s clear that natural gas is more of a barrier than a bridge. In fact, oil and gas companies are not bridging towards clean energy at all, but rather investing in the petrochemical industry- which converts fracked gas into plastic.

This article dives into the expanding oil, gas, and petrochemical industry in the Ohio River Valley, with six maps and over 16,000 data points detailing the build-out of polluting infrastructure required to make plastic and other petrochemical products from fossil fuels.

Fracking for plastic

The petrochemical industry is expanding rapidly, with $164 billion planned for new infrastructure in the United States alone. Much of the build-out involves expanding the nation’s current petrochemical hub in the Gulf Coast, yet industry is also eager to build a second petrochemical hub in the Ohio River Valley.

The shale rock below the Ohio River Valley releases more than methane gas used for energy. Fracked wells also extract natural gas liquids (NGLs) which the petrochemical industry manufactures into products such as plastic and resins. Investing in the petrochemical industry is one way to capitalize on gases that would otherwise be released to the atmosphere via venting and flaring. As companies continue to spend billions more on drilling than they’re bringing in, many are looking towards NGLs as their saving grace.

These maps look at a two-county radius along the upper Ohio River where industry is most heavily concentrated.

Step 1. Extraction

The petrochemical lifecycle begins at the well, and there are a lot of wells in the Ohio River Valley. The majority of the natural gas produced here is extracted from the Marcellus and Utica Shale plays, which also contain “wet gas,” or NGLs, such as ethane, propane, and butane.

Rig in Greene County, PA. Photo by Ted Auch.

12,507

active, unconventional wells in the upper Ohio River Valley

Of particular interest to the petrochemical industry is the ethane in the region, which can be “cracked” into ethylene at high temperatures and converted into polyethylene, the most common type of plastic. The Department of Energy predicts that production of ethylene from ethane in the Appalachian Basin will reach 640,000 barrels a day by 2025 – that’s 20 times the amount produced in 2013.

In our first map, we attempted to show only active and unconventional (fracked) wells, a difficult task as states do not have a uniform definition for “unconventional” or “active.” As such, we used different criteria for each state, detailed below.

This map shows 12,660 wells, including:

  • 12,507 shale oil and gas wells:
    • 5,033 wells designated as “active” and “unconventional” in Pennsylvania
    • 2,971 wells designated as “drilled,” “permitted,” or “producing,” and are drilled in the Utica-Point Pleasant and Marcellus Shale in Ohio
    • 4,269 wells designated as “active” or “drilled” in the Marcellus Shale in West Virginia
    • 234 wells designated as “horizontal” and are not listed as abandoned or plugged in Kentucky
  • 153 Class II injection wells, which are used for the disposal of fracking wastewater
    • 2 in Pennsylvania
    • 101 in Ohio
    • 42 in West Virginia
    • 8 in Kentucky

The map also shows the Marcellus and Utica Shale plays, and a line demarcating the portions of these plays that contain higher quantities of wet gas. These wet gas regions are of particular interest to the petrochemical industry. Finally, the Devonian-Ohio Shale play is visible as you zoom in.



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Step 2. Transportation

Burned hillside near Ivy Lane after the Revolution Pipeline Exploded

Site of the Revolution Pipeline explosion. Photo: Darrell Sapp, Post Gazette.

A vast network of pipelines transports the oil and gas from these wells to processing stations, refineries, power plants, businesses, and homes. Some are interstate pipelines passing through the region on their way to domestic and international markets.

A number of controversial pipeline projects cross the Ohio River Valley. Construction of the Mariner East II Pipeline is under criminal investigation, the Revolution Pipeline exploded six days after it came on line, protesters are blocking the construction of the Mountain Valley Pipeline, and the Atlantic Coast Pipeline is in the Supreme Court over permits to cross the Appalachian Trail.

Accurate pipeline data is not typically provided to the public, ostensibly for national security reasons.  The result of this lack of transparency is that residents along the route are often unaware of the infrastructure, or whether or not they might live in harm’s way. While pipeline data has improved in recent years, much of the pipeline data that exists remains inaccurate. In general, if a route is composed of very straight segments throughout the rolling hills of the Upper Ohio River Valley, it is likely to be highly generalized.

The pipeline map below includes:

  • natural gas interstate and intrastate pipelines
  • 8 natural gas liquid pipelines
  • 7 petroleum product pipelines
  • 3 crude oil pipelines
  • 18 pipeline projects that are planned or under construction for the region, including 15 natural gas pipelines and 3 natural gas liquids pipelines. To view a spreadsheet of these pipelines, click here.



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Step 3. Oil and Gas Transport and Processing

Pipelines transport oil and the natural gas stream to an array of facilities. Compressor stations and pumping stations aid the movement of the products through pipelines, while processing stations separate out the natural gas stream into its different components, including NGLs, methane, and various impurities.

At this step, a portion of the extracted fossil fuels are converted into sources of energy: power plants can use the methane from the natural gas stream to produce electricity and heat, and oil refineries transform crude oil into products such as gasoline, diesel fuel, or jet fuel.

A separate portion of the fuels will continue down the petrochemical path to be converted into products such as plastics and resins. Additionally, a significant portion of extracted natural gas leaks unintentionally as “fugitive emissions” (an estimated 2-3%) or is intentionally vented into the atmosphere when production exceeds demand.

This map shows 756 facilities, including:

  • 29 petroleum and natural gas power plants
    • 3 electric utilities
    • 24 independent power producers
    • 1 industrial combined heat and power (CHP) plant
    • 1 industrial power producer (non CHP)
  • 10 pumping stations, which assist in the transmission of petroleum products in pipelines
  • 645 compressor stations to push natural gas through pipelines
  • 21 gas processing plants which separate out NGLs, methane, and various impurities from the natural gas stream
  • 46 petroleum terminals, which are storage facilities for crude and refined petroleum products, often adjacent to intermodal transit networks
  • 3 oil refineries, which convert crude oil into a variety of petroleum-based products, ranging from gasoline to fertilizer to plastics
  • 2 petroleum ports, which are maritime ports that process more than 200 short tons (400,000 pounds) of petroleum products per year

*A small portion of these facilities are proposed or in construction, but not yet built. Click on the facilities for more information. 



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Step 4. Storage

After natural gas is extracted from underground, transported via pipeline, and separated into dry gas (methane) and wet gas (NGLs), its components are often pumped back underground for storage. With the expansion of the petrochemical industry, companies are eager to find opportunities for NGL storage.

Underground storage offers a steady supply for petrochemical manufacturers and allows industry to adapt to fluctuations in demand. A study out of West Virginia University identified three different types of NGL storage opportunities along the Ohio and Kanawha River valleys:

  1. Mined-rock cavern: Companies can mine caverns in formations of limestone, dolomite, or sandstone. This study focused on caverns in formations of Greenbrier Limestone.
  2. Salt cavern: Developing caverns in salt formations involves injecting water underground to create a void, and then pumping NGLs into the cavern.
  3. Gas field: NGLs can also be stored in natural gas fields or depleted gas fields in underground sandstone reservoirs.

Above-ground tanks offer a fourth storage option.

Natural gas and NGL storage contains many risks. These substances are highly flammable, and accidents or leaks can be fatal. A historically industrialized region, the Ohio River Valley is full of coal mines, pipelines, and wells (including abandoned wells with unknown locations). All of this infrastructure creates passages for NGLs to leak and can cause the land above them to collapse. As many of these storage options are beneath the Ohio River, a drinking water supply for over 5 million people, any leak could have catastrophic consequences.

Furthermore, there are natural characteristics that make the geology unsuitable for underground storage, such as karst geological formations, prone to sinkholes and caves.

Notable Storage Projects

Appalachia Development Group LLC is heading the development of the Appalachia Storage & Trading Hub initiative, “a regional network of transportation, storage and trading of Natural Gas Liquids and chemical intermediates.” The company has not announced the specific location for the project’s storage component. Funding for this project is the subject of national debate; the company applied for a loan guarantee through a federal clean energy program, in a move that may be blocked by Congress.

Energy Storage Ventures LLC plans to construct the Mountaineer NGL Storage facility near Clarington, Ohio along the Ohio River. This facility involves salt cavern storage for propane, ethane, and butane. To supply the facility, the company plans to build three pipelines beneath the Ohio River: two pipelines (one for ethane and one for propane and butane) would deliver NGLs to the site from Blue Racer Natrium processing plant. A third pipeline would take salt brine water from the caverns to the Marshall County chlorine plant (currently owned by Westlake Chemical Corp).

The storage map below shows potential NGL storage sites to feed petrochemical infrastructure as well as natural gas storage for energy production:



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Step 5. Petrochemical Manufacturing

While conventional oil and gas extraction has occurred in the region for decades, and fracking for 15 years, the recent petrochemical build-out adds an additional environmental and health burdens to the Ohio River Valley. Our final map represents the facilities located “downstream” in the petrochemical process which convert fossil fuels into petrochemical products.

An image of plastic pellets

Polyethylene pellets, also called nurdles, manufactured by ethane crackers. Image source.

Ethane Crackers

Much of the petrochemical build-out revolves around ethane crackers, which convert ethane from fracked wells into small, polyethylene plastic pellets. They rely on a regional network of fracking, pipelines, compressor stations, processing stations, and storage to operate.

In 2017, Royal Dutch Shell began construction on the first ethane cracker to be built outside of the Gulf Coast in 20 years. Located in Beaver County, Pennsylvania, this plant is expected to produce 1.6 million tons of polyethylene plastic pellets per year. In the process, it will release an annual 2.2 million tons of carbon dioxide (CO2).

A second ethane cracker has been permitted in Belmont County, Ohio. Several organizations, including the Sierra Club, Center for Biological Diversity, FreshWater Accountability Project, and Earthworks have filed an appeal against Ohio EPA’s issuance of the air permit for the PTTGC Ethane Cracker.

Shell Ethane Cracker

The Shell Ethane Cracker, under construction in Beaver County, is expected to produce 1.6 million tons of plastic per year. Photo by Ted Auch, aerial assistance provided by LightHawk.

Methanol plants also convert part of the natural gas stream (methane) into feedstock for a petrochemical product (methanol). Methanol is commonly used to make formaldehyde, a component of adhesives, coatings, building materials, and many other products. In addition to methanol plants and ethane crackers, the map below also shows the facilities that make products from feedstocks, such as fertilizer (made from combining natural gas with nitrogen to form ammonia, the basis of nitrogen fertilizer), paints, and of course, plastic.

These facilities were determined by searching the EPA’s database of industrial sites using the North American Industry Classification System (NAICS).

In total, we mapped 61 such facilities:

  • 2 methanol plants (both in construction)
  • 3 ethane crackers (one in construction, one under appeal, and one uncertain project)
  • 12 petrochemical manufacturing facilities (NAICS code 32511)
  • 31 plastic manufacturing facilities
    • 2 plastic bag and pouch manufacturing facilities (NAICS code 326111)
    • 2 plastic packaging materials and unlaminated film and sheet manufacturing facilities (NAICS code 32611)
    • 2 plastic packaging film and sheet (including laminated) manufacturing facilities (NAICS code 326112)
    • 1 unlaminated plastic film and sheet (except packaging) manufacturing facility (NAICS code 326113)
    • 1 unlaminated plastics profile shape manufacturing facility (NAICS code 326121)
    • 2 laminated plastics plate, sheet (except packaging), and shape manufacturing facilities (NAICS code 32613)
    • 21 facilities listed as “all other plastics product manufacturing” (NAICS code 326199)
  • 11 paint and coating manufacturing facilities (NAICS code 325510)
  • 2 nitrogenous fertilizer manufacturing facilities (NAICS code 325311)



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Visualizing the Build-Out

How are these facilities all connected? Our final map combines the data above to show the connections between the fossil fuel infrastructure. To avoid data overload, not all of the map’s features appear automatically on the map. To add features, view the map full screen and click the “Layers” tab in the top right tool bar.



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A better future for the Valley

The expansion of oil and gas infrastructure, in addition to the downstream facilities listed above, has rapidly increased in the last few years. According to the Environmental Integrity Project, regulatory agencies in these four states have authorized an additional 15,516,958 tons of carbon dioxide equivalents to be emitted from oil and gas infrastructure since 2012. That’s in addition to emissions from older oil and gas infrastructure, wells, and the region’s many coal, steel, and other industrial sites.

View the Environmental Integrity Project’s national map of emission increases here, which also includes permit documents for these new and expanding facilities.

The petrochemical build-out will lock in greenhouse gas emissions and plastic production for decades to come, ignoring increasingly dire warnings about plastic pollution and climate change. A recent report co-authored by FracTracker Alliance found that the greenhouse gas emissions across the plastic lifecycle were equivalent to emissions from 189 coal power plants in 2019 – a number that’s predicted to rise in coming years.

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What does the petrochemical build out look like in the Ohio River Valley?

 

But it doesn’t have to be this way. The oil and gas industry’s plan to increase plastic manufacturing capacity is a desperate attempt to stay relevant as fracking companies “hemorrhage cash” and renewable energy operating costs beat out those of fossil fuels. Investing instead in clean energy, a less mechanized and more labor intensive industry, will offer more jobs and economic opportunities that will remain relevant as the world transitions away from fossil fuels.

In fact, the United States already has more jobs in clean energy, energy efficiency, and alternative vehicles than jobs in fossil fuels. It’s time to bring these opportunities to the Ohio River Valley and bust the myth that Appalachian communities must sacrifice their health and natural resources for economic growth.

People gather at the headwaters of the Ohio River to advocate for the sustainable development of the region. Add your voice to the movement advocating for People Over Petro by signing up for the coalition’s email updates today!

Download the maps

 

 

 

 

 

 

 

This data in this article are not exhaustive. FracTracker will be updating these maps as data becomes available.

By Erica Jackson, Community Outreach and Communications Specialist, FracTracker Alliance

The Hidden Costs of a Plastic Planet

Plastic has been getting a lot of negative press lately.

It’s killing marine life, forming vortexes in the ocean, and being burned instead of recycled. But until recently, most of the attention has focused on plastic pollution – the waste that turns up after a product has served its purpose.

Now that’s changed- the Center for International Environmental Law (CIEL) has recently released “Hidden Costs of a Plastic Planet;” two reports that show us the consequences of plastic across its entire lifecycle. The first, Plastic & Health, explores human health impacts, while the second Plastic & Climate, tackles greenhouse gas emissions.

For the first time, we know the full scope of plastic’s impact – and it’s not looking good.

FracTracker is proud to partner with CIEL and several other organizations, including Earthworks, 5 Gyres, TEJAS, UPSTREAM, GAIA, Exeter University, and Environmental Integrity Project to release these reports.

Access the full reports and executives summaries here:

 

You know, now what?

These reports make it clear: the impacts of plastic are serious, and they’re everywhere. We have the evidence to justify an immediate global move away from our disposable, single-use lifestyle. Tackling this toxic crisis will require action across all levels of society- corporations must consider the full life cycle of their products, policy makers must enact plastic reduction measures, and of course, industry needs to rectify its toxic impacts. Eager to encourage these entities to take action, the FracTracker team is committed to doing our own part to solve this plastics problem, and we hope that it inspires individuals, companies, community leaders, and politicians to join in.

Here’s what we’re doing to help the world #BreakFreeFromPlastic:

1. Continue working towards a world free from oil and gas.

Since over 99% of plastic is made from oil and gas, keeping fossil fuels in the ground is the only way to eliminate all of plastic’s toxic impacts. Plastic & Climate found that extracting and transporting oil and gas for plastic production releases over 100 million metric tons of carbon dioxide equivalents per year. There are many opportunities for these releases to occur, including from methane leakage and flaring, the drilling process, deforestation of forests for pipelines and well pads, and emissions from truck traffic.

Pipeline construction causes deforestation, releasing carbon stored in trees and preventing further carbon sequestration

The FracTracker team will continue to study, map, and analyze the risks of this industry to encourage both a switch to renewable energy and a movement away from plastic production.

2. Expose the risks of the fracking-driven plastics boom in the Gulf Coast & Ohio River Valley

Unconventional technology has opened up access to large reserves of natural gas liquids, such as ethane, and plastic manufacturing is one way to increase demand for this glut. In fact, the oil and gas industry is hoping to increase demand for plastic worldwide by 40%! Two regions with access to natural gas liquids that are rapidly expanding plastics manufacturing capacity are the Gulf Coast and the Ohio River Valley.

Eager to justify this build-out, politicians and industries tout the ways plastic is part of a sustainable future. They say that without investing in plastic, we’re not taking full advantage of our resources, and that by using natural gas to make plastic instead of burning it, we’re keeping greenhouse gasses from entering the atmosphere. Speaking on manufacturing plastic from natural gas with public radio station WHYY, Pennsylvania’s Governor Wolf stated:

“I want to move to a point where what we’re using the gas for is for products that go into that sustainable energy future: lightweight products…so that we’re not burning this, we’re actually creating products that would make that energy future that we all want, that would address the issues of climate change in an effective way.”

The Shell Ethane Cracker in Pennsylvania is projected to produce 1.6 million tons of plastic per year, which Governor Wolf states is part of a “sustainable energy future.” Photo by Ted Auch, aerial assistance by LightHawk.

But the data say otherwise.

Plastic does not address the issues of climate change. In fact, using natural gas for plastic perpetuates climate change. Climate & Plastics found that this year, “the production and incineration of plastic will add more than 850 million metric tons of greenhouse gases to the atmosphere—equal to the emissions from 136 one-thousand-megawatt coal power plants.” If plastic production grows as currently predicted, by 2030, emissions could reach 1.34 gigatons per year, or 291 new coal plants.

The rate of plastic production is directly at odds with global carbon emissions targets.

While plastic can be used for lightweight parts of electric vehicles or reusable materials, the plastic being produced by the current build out is primarily polyethylene plastic, most commonly used for packaging and single use products- plastic bags, bottles, jugs, containers, and plastic films and linings; products that countries and cities are phasing out.

3. Encourage plastic alternatives

While renewable energy is becoming increasingly available, so too are plastic alternatives. Across the world, communities are rethinking the products we use everyday. Thanks to historic legislation, zero waste stores,  and towns, and plastic-free bloggers, it’s never been a better time to cut back on plastic – and the FracTracker team is doing our part.

Rebecca, our Administrative and Human Resources Specialist, has cut her plastic use by switching to toothpaste tablets and bars of soap. Karen, our Eastern Program Coordinator, makes her own reusable beeswax food wraps. And Erica Jackson and Isabelle Weber in the Pittsburgh office keep reusable utensils in their backpacks. The whole team is cutting back on single-use plastic products, and are always on the look-out for non oil and gas-based products.

We also realize that with companies like Coca Cola selling 3,000 plastic bottles every second, and Nestlé  producing 1.7 million tons of plastic packaging a year, corporations play a key role in this movement.

Through the Story of Stuff’s #Messageinabottle project and Greenpeace’s #Isthisyours campaign, we’re also encouraging corporations to reimagine how the package and transport products.

Now YOU know, what will you do to help your company, community, or yourself #BreakFreeFromPlastic?

The Falcon Public Monitoring Project

Part of the Falcon Public EIA Project

In March of 2019, two and a half years after Shell Pipeline Co. announced plans for the Falcon Ethane Pipeline System, the imported pipes arrived at the Port of Philadelphia. As tree clearing and construction begins, we share frustration with residents that the project is underway while many of our concerns remain unaddressed.

Between 2010 and 2018, over 280 pipeline incidents were reported in Ohio, West Virginia, and Pennsylvania (the three states the Falcon crosses). Of those incidents, 70 were fires and/or explosions. As regulatory agencies and operators fail to protect the public, communities are taking the reins.

Residents of southwest PA gather along the Falcon route

Environmental organizations are training the public to spot construction violations and appealing inadequate pipeline permits. Impacted residents are running for office, testifying in court, and even spending time in prison to protect their communities.

These grassroots efforts are contributing to a shift in public perception about the safety and need of pipelines. In some cases, including with the Northeast Energy Direct Pipeline and the Constitution Pipeline, organizing efforts are helping stop projects before they begin.

We invite all residents along the Falcon route to get involved in ongoing efforts to monitor construction. Below, you’ll find a guide to reporting violations as well as high-risk areas along the Falcon route that require close monitoring.

Be a citizen watchdog

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Taking photos of pipeline development and recording your observations is a great way to monitor impacts. One tool to use while monitoring is the FracTracker mobile app (search “FracTracker” in the App Store or Google Play to download for free). The app allows the public to submit geolocated photos and descriptions of development, such as pipelines and wells, and concerns, such as spills and noise pollution. These reports help FracTracker crowdsource data and alert us to concerns that need follow up action. The app also contains a map of wells, pipelines, and compressor stations, including the Falcon pipeline route for reference in the field.

Click on the images below to view app reports of Falcon construction.

Documenting violations

During the construction phase, incidents often occur when companies cause erosion of the ground and release sediment, equipment, or discharge into waterways. Mountain Watershed Association and Clean Air Council have provided the following information on the process of looking for and documenting violations.

Step 1) Document baseline conditions. Documenting the pre-construction status of an area is crucial for understanding how it’s been impacted down the road. Document baseline conditions by taking photos, videos, and notes at different sites, and include the location and date on these materials (the Fractracker app does this for you automatically). Observing sites at different times and in different weather (such as during or after a storm) will give you the best data.

Step 2) Know what to look for. Below are images and descriptions of common construction violations.

Filtration Failure

Drilling fluid spill

For more violations, checkout Pipeline CSI’s list of Top Ten Observable Non-Compliance Issues.

3) File a Report. File an official complaint to your state environmental regulatory agency.

Your concerns can be sent to regulatory agencies using the following contact information:

4) Contact support organizations. There are several organizations ready to take action once violations have been confirmed. For confirmed violations in Beaver County, PA, contact Alex Bomstein, at the Clean Air Council (215-567-4004 x118) and for confirmed violations in Allegheny or Washington Counties, PA, contact Melissa Marshall at the Mountain Watershed Association (724-455-4200 x7#). For violations in Ohio or West Virginia, reach out to FracTracker (412-802-0273).

Reports made on the FracTracker App are shared with any app user and the FracTracker team, who look through the reports and contact users for any required follow up. App reports can also be submitted to regulatory agencies electronically. Simply visit the web version of the app, click on your report, and copy the URL (web address) of your report. Then “paste” it into the body of an email or online complaint form. The receiver will see the exact location, date, and any notes or photos you included in the report.

Where should you be monitoring?

Monitoring efforts must be limited to publicly accessible land. In general, areas that are most at-risk for environmental impact include stream and wetland crossings, steep slopes (particularly those near water crossings), flood-prone zones, and areas where storm water runoff will reach waterways. View a map of the Falcon’s water crossings here, and continue reading for more vulnerable locations to monitor.

The information below identifies high-risk areas along the pipeline route where monitoring efforts are extra necessary due to their impacts on drinking water, wetlands, undermined areas, and vulnerable species.

Drinking Water

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We found 240 private water wells within 1/4 mile of the Falcon.

While all of these wells should be assessed for their level of risk with pipeline construction, the subset of wells nearest to horizontal directional drilling (HDD) sites deserve particular attention. HDD is a way of constructing a pipeline that doesn’t involve digging a trench. Instead, a directional drilling machine is used to drill horizontally underground and the pipe is pulled through.

While an HDD is designed to avoid surface impacts, if rushed or poorly executed, it can damage surface water, groundwater, and private property. The Mariner East 2 pipeline construction left several families without water after construction crews punctured an aquifer at an HDD site.

Shell’s data highlights 24 wells that are within 1,000 feet of a proposed HDD site.

We’ve isolated the groundwater wells and HDDs in a standalone map for closer inspection below. The 24 most at-risk wells are circled in blue.

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Testing your groundwater quality before construction begins is crucial for determining impacts later on. Two upcoming workshops in Washington County, PA and another in Beaver County, PA will discuss how to protect your water and property.

The Falcon’s HDD locations offer disturbing similarities to what caused the Mariner East pipeline spills. Many of Sunoco’s failures were due to inadequately conducted (or absent) geophysical surveys that failed to identify shallow groundwater tables, which then led to drilling mud entering streams and groundwater.

Figure 1 below shows Greene Township, Beaver County, just south of Hookstown, where the “water table depth” is shown. The groundwater at this HDD site averages 20ft on its western side and only 8ft deep on the eastern side.

Figure 1. Water table depth in Greene Township

Water Reservoirs

The Falcon also crosses the headwaters of two drinking water reservoirs: the Tappan Reservoir in Harrison County, OH (Figure 2) and the Ambridge Reservoir in Beaver County, PA (Figure 3).  The Falcon will also cross the raw water line leading out of the Ambridge Reservoir.

The Ambridge Reservoir supplies water to five townships in Beaver County (Ambridge, Baden, Economy, Harmony, and New Sewickley) and four townships in Allegheny County (Leet, Leetsdale, Bell Acres & Edgeworth). The Tappan Reservoir is the primary drinking water source for residents in Scio.

Figure 2. Tappan Reservoir and the Falcon route in Harrison County, Ohio

Figure 3. Ambridge Reservoir and the Falcon route in Beaver County, Pennsylvania

Wetlands

Wetlands that drain into Raccoon Creek in Beaver County, PA will be particularly vulnerable in 2 locations. The first is in Potter Township, off of Raccoon Creek Rd just south of Frankfort Rd, where the Falcon will run along a wooded ridge populated by half a dozen perennial and intermittent streams that lead directly to a wetland, seen in Figure 4. Complicating erosion control further, Shell’s survey data shows that this ridge is susceptible to landslides. This area is also characterized by the USGS as having a “high hazard” area for soil erosion.

Figure 4. Wetlands and streams in Potter Township, PA

The other wetland area of concern along Raccoon Creek is found in Independence Township at the Beaver County Conservation District (Figure 5). Here, the Falcon will go under the Creek using HDD (highlighted in bright green). Nevertheless, the workspace needed to execute the crossing is within the designated wetland itself. An additional 15 acres of wetland lie only 300ft east of the crossing but are not accounted for in Shell’s data. This unidentified wetland is called Independence Marsh, considered the crown jewel of the Independence Conservancy’s watershed stewardship program.

Figure 5. Wetlands and Raccoon Creek in Independence Township, PA

Subsurface concerns

Shell’s analysis shows that 16.8 miles of the Falcon pipeline travel through land that historically has or currently contains coal mines. Our analysis using the same dataset suggests the figure is closer to 20 miles. Construction through undermined areas poses a risk for ground and surface water contamination and subsidence. 

Of these 20 miles of undermined pipeline, 5.6 miles run through active coal mines and are located in Cadiz Township, OH (Harrison Mining Co. Nelms Mine, seen in Figure 6); Ross Township, OH (Rosebud Mining Co. Deep Mine 10); and in Greene Township, PA (Rosebud Mining Co. Beaver Valley Mine). 

Figure 6. Coal mines and are located in Cadiz Township, OH

For a complete map of mined areas, click here.

More than 25 of the Falcon’s 97 pipeline miles will be laid within karst landscapes, including 9 HDD sites. Karst is characterized by soluble rocks such as limestone prone to sinkholes and underground caves. A cluster of these are located in Allegheny and Washington counties, PA, with extensive historical surface mining operations.

The combination of karst and coal mines along Potato Garden Run, in Figure 7, make this portion of the pipeline route particularly risky. At this HDD site, the Falcon will cross a coal waste site identified in the permits as “Imperial Land Coal Slurry” along with a large wetland.

Figure 7. Coal mines in Imperial, Pennsylvania

Vulnerable species

Southern Redbelly Dace

The Southern Redbelly Dace, a threatened species, is especially vulnerable to physical and chemical (turbidity, temperature) changes to their environment. PA Fish and Boat Commission explicitly notes in their correspondence with Shell that “we are concerned about potential impacts to the fish, eggs and the hatching fry from any in-stream work.” Of note is that these sites of concern are located in designated “High Quality/Cold Water Fishes” streams of the Service Creek watershed (Figure 8). PFBC stated that that no in-stream work in these locations should be done between May 1 and July 31.

Figure 8. “High Quality/Cold Water Fishes” streams identified as habitat for the Southern Redbelly Dace

Northern Harriers & Short-Eared Owls

Portions of the Falcon’s workspace are located near 6 areas with known occurrences of Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species). Pennsylvania Game Commission requested a study of these areas to identify breeding and nesting locations, which were executed from April-July 2016 within a 1,000-foot buffer of the pipeline’s workspace (limited to land cover areas consisting of meadows and pasture). One Short-eared Owl observation and 67 Northern Harrier observations were recorded during the study. PGC’s determined that, “based on the unusually high number of observations at these locations” work should not be done in these areas during harrier breeding season, April 15 through August 31.

Figure 9. Surveyed areas for Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species)

Bald Eagles

A known Bald Eagle nest is located in Beaver County. Two potential “alternate nests” are located where the Falcon crosses the Ohio River. National Bald Eagle Management Guidelines bar habitat disturbances that may interfere with the ability of eagles to breed, nest, roost, and forage. The 1 active nest in close proximity to the Falcon, called the Montgomery Dam Nest, is located just west of the pipeline’s terminus at Shell’s ethane cracker facility.

U.S. Fish and Wildlife Service requested that Shell only implement setback buffers for the one active nest at Montgomery Dam (Figure 10). These include no tree clearing within 330 feet, no visible disturbances with 660 feet, and no excessive noise with 1,000 feet of an active nest. Furthermore, Shell must avoid all activities within 660ft of the nest from January 1st to July 31st that may disturb the eagles, including but not limited to “construction, excavation, use of heavy equipment, use of loud equipment or machinery, vegetation clearing, earth disturbance, planting, and landscaping.

Figure 10. Bald Eagle nest in Potter Township, Pennsylvania

Bats

The Falcon is located within the range of federally protected Indiana Bats and Northern Long-eared Bats in Pennsylvania and West Virginia. In pre-construction surveys, 17 Northern Long-eared Bats were found at 13 of the survey sites, but no Indiana Bats were captured.

A total of 9 Northern Long-eared Bat roost trees were located, with the nearest roost tree located 318 feet from the pipeline’s workspace. Figure 11 below shows a cluster of roost trees in Raccoon Township, PA. For a map of all the roost trees, click here. The U.S. Fish and Wildlife Service stated that “Due to the presence of several Northern Long-eared Bat roost trees within the vicinity of the project footprint (although outside of the 150-foot buffer), we recommend the following voluntary conservation measure: No tree removal between June 1 and July 31.”

The Pennsylvania Game Commission noted in early correspondences that Silver-haired Bats may be in the region (a PA species of special concern). PGC did not require a further study for the species, but did request a more restrictive conservation of no tree clearing between April 1 and October 31.

Figure 11. Northern long-eared bat roost trees in Raccoon Township, Pennsylvania

For more information on the wildlife impacts of the Falcon Pipeline, click here.

***

To continue reading about this pipeline, visit the Falcon Public EIA Project. 

By documenting the impacts of the Falcon Pipeline, you’re contributing to a growing body of work that shows the risks of fossil fuel pipelines. Not only does this evidence protect drinking water and vulnerable species, it serves as evidence against an inherently dangerous project that will contribute to climate change and the global plastics crisis.

We hope you’re inspired to take action and add your voice to a growing team in the region committed to safer and healthier environments. Thank YOU for your dedication to the cause!

By Erica Jackson, Community Outreach and Communications Specialist, FracTracker Alliance.

Portions of this article were adapted from previous posts in the Falcon Public EIA Project, written by Kirk Jalbert.

Appalachia storage hub prospects map by FracTracker

Storing Natural Gas Liquids in Appalachia

Last month, the Department of Energy (DOE) submitted a report titled Ethane Storage and Distribution Hub in the United States to Congress. The report sums up several other recent geologic studies and economic analyses that evaluate the potential to create a large petrochemical hub in southwest Pennsylvania, Ohio, West Virginia, and northeastern Kentucky.

Most people call this region Appalachia because of the mountains, or the Ohio River Valley because of the namesake river. The petrochemical industry looks deeper: they’ve branded it Shale Crescent USA, after the shale gas thousands of feet underground. This article summarizes recent developments on storing natural gas liquids, including ethane, in this region – whatever you prefer to call it.

Background

The United States currently produces more natural gas than any other country in the world, with much of the fracked gas coming from the Marcellus and Utica shales in Appalachia. The DOE report predicts that production in this region will continue growing from an estimated at 8.19 trillion cubic feet (Tcf) in 2017, to 13.55 Tcf in 2025 and 19.5 Tcf in 2050.

Natural Gas Production Estimates:

8.19 Tcf in 2017
13.55 Tcf in 2025
19.5 Tcf in 2050

In addition to oil and gas, fracking produces natural gas liquids (NGLs), such as ethane, propane, and butane. NGLs are a key component of the petrochemical industry, which takes these resources and converts them into plastics and resins. As industry extracts more natural gas, it will also be left with more NGLs to manage.

Hoping to profit off NGLs, the oil and gas industry is investing in petrochemical production. In the Appalachian basin, the DOE predicts that production of ethylene from ethane will reach 640,000 barrels a day by 2025 (this is 20 times the amount the region produced in 2013). The Gulf Coast of the U.S., as well as countries in Asia and the Middle East, are also growing their production capacities. Globally, ethylene production is projected to grow 31% from 2017 to 2025.

The rise of the petrochemical industry is coming at a point when there’s an increasing global awareness of the disaster that is plastic pollution. As much as 12.7 million tons of plastic waste goes into the ocean each year, affecting over 700 species of marine animals. On land, plastic waste is often shipped to less developed nations, where it ends up polluting poor communities and contaminating their drinking water and air.

Nevertheless, politicians in PA, OH, and WV are working hard to attract petrochemical build-out in Appalachia. The region already houses much of the infrastructure needed for a petrochemical hub, such as fracked wells that pump out NGLs and processing plants to separate these liquids from the rest of the natural gas stream. One thing it’s missing, however, is significant capacity to store natural gas liquids – particularly ethane.

Why does industry need storage?

Ethane storage offers several benefits to the petrochemical industry. For one, it would serve as a steady supply of ethane for plants like ethane crackers, which “crack” ethane into ethylene to make polyethylene plastic. With this constant supply (transported to crackers via pipeline), plants can operate 24 hours a day, year round, and avoid using energy to shutdown and restart. Storage also allows industry to adapt to fluctuations in demand. If demand decreases, ethane can be set aside instead of being burned off when a natural gas stream is processed.

Another argument for expanding petrochemical activity in Appalachia is to diversify the industry’s geography. The current petrochemical hub in Texas and Louisiana (where over 95% of the country’s ethylene production takes place) is subject to extreme weather events. In 2017, Hurricane Harvey caused over half of the nation’s polyethylene production capacity to shut down. The report mentions “extreme weather events” multiple times as justification for building a petrochemical hub in Appalachia. This stance strongly suggests that the DOE is preparing for increased hurricanes and flooding from climate change, although this is never explicitly stated. Unsurprisingly, the industry’s role in causing climate change is left out from the report as well.

What does storage look like?

While the term ‘natural gas liquid’ may seem like an oxymoron, it refers to the different forms the substances take depending on temperature and pressure. At normal conditions, NGLs are a gas, but when pressurized or exposed to extremely cold temperatures,  they act as a liquid. NGLs occupy significantly less space as a liquid, and are therefore moved and stored as a pressurized or refrigerated liquid.

Storage can be in above ground tanks, but is often underground in gas fields or underground caverns. NGLs are highly volatile, and storing them above ground puts workers and surrounding communities at risk. For example – last week, an above ground storage tank exploded at a natural gas processing plant in Washington County, PA, sending four people to the hospital. While underground storage is often perceived as “safer,” it still poses significant risks, particularly in a geography like Appalachia full of wells, coal mines, and pipelines. This underground infrastructure can cause NGLs to leak during storage or the land above them to collapse.

A study out of West Virginia University, titled “A Geologic Study to Determine the Potential to Create an Appalachian Storage Hub For Natural Gas Liquids,” identified three different types of storage opportunities along the Ohio and Kanawha river valleys:

Underground storage options

  1. Mined-rock cavern: Companies can mine caverns in formations of limestone, dolomite, or sandstone. The formation must be at least 40 feet thick to hold NGLs. This study focused on formations of the Greenbrier Limestone, which occurs throughout southwestern Pennsylvania, West Virginia, and Kentucky.
  2. Salt cavern: Developing salt caverns involves injecting water underground to create a void, and then pumping NGLs into the cavern. Suitable salt caverns have “walls” at least 100 feet thick above and below the cavern. The study recommended salt caverns 1,500 to 3,000 feet deep, but considered those as deep as 6,700 feet.
  3. Gas field: NGLs can also be stored in natural gas fields or depleted gas fields in underground sandstone reservoirs. Suitable gas fields are 2,000 feet deep or more according to the WVU study.

Where could storage sites be located?

The West Virginia University study identified and ranked thousands of gas fields, several salt caverns, and many regions in the Greenbrier Limestone that could serve as NGL storage. Most of the top-ranked opportunities are in West Virginia, near the state’s borders with Ohio and Pennsylvania, and several cross beneath the Ohio or Kanawha rivers. The researchers conclude with three “prospects,” which are circled in Figure 1.

A map of storing natural gas liquids opportunities in the Ohio River Valley

Figure 1. NGL storage opportunities identified by the Appalachian Oil and Natural Gas Consortium at West Virginia University

The table below lists the specific storage opportunities in each prospect, as well as the available data on depth, thickness, and acreage of the formations. Also listed are the counties that the storage facility would cross into.

Name Type Depth (feet) Thickness (feet) Counties Land Size (acres)
Salina F4 Salt cavern Salt cavern >100 to 150 Primarily Columbiana, OH, also Hancock, WV & Beaver, PA 83,775
Salina F4 salt cavern Salt cavern 100 to 150 Primarily Jefferson, OH, also Brooke & Hancock WV, & Washington, PA 129,017
Ravenna-Best Consolidated Field Depleted gas field 4,107 to 6,497 25 to 156 Mahoning, OH 69,000
No specific field was ranked Gas field in Oriskany sandstone 3,000 to 7,000 0 to 70+ Throughout the prospect

Existing NGL Storage

Storage in the United States

Currently, the U.S. has two major NGL storage hubs (both in salt caverns): One is in Mont Belvieu, Texas and the other in Conway, Kansas. These facilities are strategically located near the petrochemical industry’s hub along the Gulf Coast. There is also underground storage in Sarnia, Ontario.

Industry in Appalachia is connected to these storage facilities via pipelines, including Sunoco’s Mariner West that transports ethane to Sarnia, and the Appalachia-Texas-Express (ATEX) pipeline that takes ethane to Mont Belvieu. However, as suggested above, NGL storage in Appalachia is also under development.

Appalachia Storage & Trading Hub

Appalachia Development Group LLC is heading the development of the Appalachia Storage & Trading Hub initiative. The company has not announced the specific location for underground storage, but has been working hard to secure the funds  for this development.

In September of 2017, Appalachia Development Group submitted part 1 of a 2-part application for a $1.9 billion loan to the US DOE Loan Program Office. The DOE approved the application the following January, inviting the company to submit the second part, which is currently pending. This second part goes through the DOE’s Title XVII innovative clean energy projects loan program.

According to the DOE, this program “provides loan guarantees to accelerate the deployment of innovative clean energy technology.” Paradoxically, this means the DOE may give clean energy funds to the petrochemical industry, which is fueled by fossil fuels and does not provide energy but rather plastic and resins.

Steven Hedrick, the CEO of Appalachia Development Group, was part of a West Virginia trade delegation that traveled to China in 2017 to meet with China’s largest energy company. This meeting, which included President Trump and China’s President Xi Jinping, resulted in China Energy agreeing to invest $83.7 billion to support natural gas and petrochemical development in West Virginia. (Of note: This agreement has faced uncertainty following Trump’s tariffs on Chinese goods). West Virginia Governor Jim Justice later criticized Hedrick’s involvement in the meeting, where he promoted the interests of his private company.

Mountaineer NGL Storage Project

Another company, Energy Storage Ventures LLC, has plans to construct NGL storage near Clarington, Ohio. This facility would be on land formerly belonging to Quarto Mining Company’s Powhatan Mine No. 4. Called “Mountaineer NGL Storage,” the project would develop salt caverns to store propane, ethane, and butane. Each cavern could store 500,000 barrels (21 million gallons) of NGLs.

The video below, made by the Energy Storage Ventures, describes the process of developing salt caverns for storage.

The Mountaineer NGL Storage Project location is about 12 miles south of the PTTGC ethane cracker (if built), in Dilles Bottom Ohio. It’s also roughly 60 miles south of the Shell ethane cracker (under construction) in Potter Township, PA. If developed, the project could supply these plants with ethane and allow them to continuously operate. According to Energy Storage Ventures President, David Hooker, the project would also trigger $500 million in new pipelines in the region and $1 billion in fractionation facilities to separate NGLs.

Energy Storage Ventures wants to build three pipelines beneath the Ohio River. Two pipelines (one for ethane and one for propane and butane) would deliver NGLs to the storage site from Blue Racer Natrium, a fractionation plant that separates dry natural gas from NGLs. A third pipeline would take salt brine water from the caverns to the Marshall County chlorine plant (currently owned by Westlake Chemical Corp). These facilities, as well as the locations of the two ethane crackers storage could serve, are in the map below. This map also includes the potential storage opportunities the researchers at West Virginia University identified.



View map full screen | How FracTracker maps work

Referring to concerns about building pipelines and caverns near the Ohio River, a drinking water source for 5 million people, the company’s president David Hooker stated, “This is not rocket science. These things have operated safely for years… Salt, at depth, is impermeable. You won’t see any migration out of the salt.”

This video is a rendering of what the 200-acre site will look like, including the salt water impoundment structure (capable of holding 3.25 million barrels), and the infrastructure needed to deliver products and equipment by rail and truck:

The company has stated that it owns both the land and mineral rights it needs to develop the caverns, but the project has also faced delays.

Where is this plastic going?

One common argument for a petrochemical hub in Appalachia is the region’s proximity to the downstream sector of petrochemical industry. Manufacturers such as PPG Industries, Dow Chemical Inc., and BASF are all based in the area and could make use of the feedstock from an Appalachian hub.

However, the report doesn’t make it clear where the plastic and resin end products will land. It does state that the demand in the United States isn’t enough to swallow up two major petrochemical hubs worth of plastic.

Export markets

The DOE report states that, “the development of new petrochemical capacity in Appalachia is not necessarily in conflict with Gulf Coast expansion.” Since the Gulf Coast already has the infrastructure for export, it could focus on international markets while Appalachia meets domestic demand. Alternatively, the Appalachian hub could serve European destinations while the Gulf Coast hub delivers to Pacific Basin and South American destinations. Plastic consumption is highly correlated with population, so countries with large, growing populations such as India and China are likely markets.

It’s important to note that the U.S. isn’t the only country increasing its production of petrochemical derivatives, and as the report notes, exports from the US “may face a challenge from global capacity surplus.” Figure 2 shows that global production of ethylene is expected to surpass global consumption, shown in Figure 3. The graph of consumption likely ignores the impact of plastic-reducing policies that hundreds of countries and cities are implementing. As such, it may be an over-estimation.

Historical and Projected Ethylene Production Capacity by Global Area

Figure 2. Historical and future ethylene production by global region. Source

Graph of ethylene consumption by global area.

Figure 3. Ethylene consumption by global region. Source

In the end, it appears that the industry’s plan is to build first, and worry about markets later, hoping that a growing supply of affordable plastic will increase consumption.

Perhaps the reason industry is so eager to forge a market is because oil and gas is struggling with a lot of debt. A study out of the Sightline Institute found that as of the first half of 2018, “US fracking-focused oil and gas companies continued their eight-year cash flow losing streak.”  The Center for International Environmental Law found that petrochemicals generally have a larger profit margin than oil and gas: “In 2015, ExxonMobil’s Chemicals segment accounted for roughly 10% of its revenues but more than 25% of its overall profits.”

Plastic is one way to subsidize this dying industry…

Beyond Storing Natural Gas Liquids

The motive behind developing storage is to catalyze and support a major industry. The DOE report states that the new infrastructure required “would include gathering lines, processing plants, fractionation facilities, NGLs storage facilities, ethane crackers, and then…plants for polyethylene, ethylene dichloride, ethylene oxide, and other infrastructure.” A hub would require more fracking and wastewater injection wells, cause even more heavy truck traffic that adds stress to roadways, and require additional power plant capacity to serve its electricity demand.

In other words, an Appalachia petrochemical hub would profoundly impact the region. The report contains an in-depth analysis of the economic impacts, but fails to mention any environmental concerns, social impacts on communities, or health effects. The other major studies on this buildout,  mentioned above, follow a similar pattern.

A quick look at industry along the Gulf Coast tells you that environmental, social, and health concerns are very real and produce their own economic debts. The petrochemical industry has created a “cancer alley” in Texas and Louisiana, disproportionately impacting low-income and minority communities. Yet, industry is preparing another hub without a single comprehensive environmental impact assessment or health assessment for the region. As each pipeline, fracked well, and plant is permitted separately, we can’t properly assess the cumulative negative impacts this development will have on our waterways, forests, soil, or air quality. Therefore, we also won’t know how it will affect our health.

Looking into the future

The report analyzes the industry through 2050. It states that NGL output in Appalachia:

… will continue to grow throughout the forecast period. As natural gas production gradually migrates away from liquids-rich gas areas, which are expected to slowly deplete, to dryer areas, the rate of growth in NGPL production will slow relative to the rate of natural gas production growth.

In 31 years, the kids growing up in Appalachia right now could be left with brownfields, dried-up wells, and abandoned ethane crackers. But it doesn’t have to be this way. Last year, the DOE reported that there are more jobs in clean energy, energy efficiency, and alternative vehicles than in fossil fuels. By using funds such as the DOE’s Title XVII innovative clean energy loan – for actual clean energy – we can bring economic development to the region that will be relevant past 2050 and that won’t sacrifice our health and natural resources for short-term private gains.

By Erica Jackson, Community Outreach and Communications Specialist

A map of deficiencies along the Falcon Pipeline Route

The Falcon Pipeline: Technical Deficiencies

Part of the Falcon Public EIA Project

In August 2016, Shell announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. In response to available data, FracTracker launched the Falcon Public EIA Project in January of 2018 to unearth the environmental and public health impacts of the proposed pipeline. As part of that project, today we explore Shell’s Chapter 105 application and the deficiencies the Pennsylvania Department of Environmental Protection (DEP) cited after reviewing Shell’s application.

Just a heads up… there are a lot.

Shell originally submitted a Chapter 105 application to the DEP to receive a permit for water obstruction and encroachment. The DEP began reviewing the application in January of 2018. On June 1st, they sent Shell technical deficiency letters listing several issues with the application. Shell responded to these deficiencies on August 1st.

Now, it’s up to the DEP to decide if Shell’s response is adequate, and if the department should go ahead and approve the application or require more work from Shell. Explore the technical deficiencies below for more information.

Technical Deficiencies

Below is a map that highlights several of the deficiencies the DEP found with Shell’s application and a brief explanation of each one. Expand the map full-screen to explore more layers – Some layers only become visible when you zoom in due to the level of detail they display.

View Map Full Screen | How Our Maps Work

Next, we’ll walk you through the technical deficiencies, which we have broken down into the following categories:

  1. Wetlands, rivers, streams
  2. Stormwater control
  3. Public health and safety (drinking water & trails)
  4. Conservation areas
  5. Alternative routes
  6. Geological concerns (including mining issues)
  7. Documentation issues
Legend

A = Allegheny County, B = Beaver County, W = Washington County. The numbers reference the number listed in the deficiencies letter.

1. Wetlands, Rivers, & Streams

Water withdrawal from rivers and discharge

  • B2 A2 W2 The project will discharge waste water from an industrial activity to a dry swale, surface water, ground water, or an existing sanitary sewer system or separate storm water system. The DEP requested that Shell identify and describe this discharge, as the DEP’s Clean Water Program must authorize discharges. Shell stated that water will be discharged from hydrostatic testing, (which ensures a pipeline can withstand high pressure by pumping water through it to test for leaks), and a PAG-10 permit (needed for hydrostatic test water discharge) was submitted to the DEP July 27, 2018 with the locations of discharge. Drawings of the discharges are in Attachment O. (The locations of the discharges were not included in Shell’s public response to this deficiency.)
  • B33 A31 W31 Shell will be withdrawing water for hydrostatic testing. The DEP asked Shell to explain the intake and discharge methods so the DEP can decide if these should be included as impacts. The DEP also asked Shell to provide the location of intake and discharge. The DEP’s Clean Water Program must authorize discharges. In response, Shell stated that water will be withdrawn from Raccoon Creek and the Ohio River in West Virginia. The specific locations are listed in the PAG-10 permit, submitted to the DEP in July. Drawings of the discharges are included in Attachment O.

Wetlands and Streams

  • B5 A3 W4 The DEP asked Shell to identify the presence of wetlands within the project area that are identified by the US Fish & Wildlife Service’s National Wetlands Inventory (NWI) data system, and provide data on how they may be impacted by the proposed pipeline.  Shell identified one NWI wetland in Beaver County, but did not delineate or provide information on it, due to safety concerns (it’s on a steep cliff). This wetland will be crossed via HDD (horizontal directional drill). In Allegheny County, there is an NWI wetland that Shell also did not provide data on. This wetland was not initially evident, and when staff returned to survey it, the property owner did not let them access the site because they did not want a pipeline on their property. According to Shell, this NWI wetland is not within the “Project’s Limit of Disturbance.” In Washington County, Shell stated that “all of the NWI-mapped wetlands that were determined not to be wetlands have been accounted for in Washington County. These NWI wetlands were all located in an area that had been previously strip-mined and due to mining activities, those wetlands are no longer there. Data were taken for these areas and included… separately as Attachment D.” Also in Washington County is an NWI wetland located above the Panhandle Trail, which Shell determined to be outside of the study area and therefore did not collect data on it. This wetland is not on the map, but Shell did provide this image of it.
  • B6 A4 W5 The DEP requested that Shell match off-line wetland data with sampling point locations from study area maps. In response, Shell placed offline data sheets in the order that they are in Table 3 in the Wetlands Delineation Report and in Table 4 in the Watercourse Delineation Report.
  • B7 A5 W6 Shell needed to discuss the types and conditions of riverine resources that the project impacts. Specifically, how the conditions of these resources relate to their hydrological functions, biogeochemical functions, and habitat attributes. These are discussed under question 7 for Beaver County, question 5 for Allegheny County, and question 6 for Washington County.
  • B8 A6 W7 Shell needed to discuss the types and conditions of wetlands that the project impacts. Specifically, how the conditions of these wetlands contribute to their hydrological functions, biogeochemical functions, and habitat attributes. Shell also needed to discuss impacts to wetlands that will be temporarily impacted, as it previously only discussed wetlands facing permanent impacts. These are discussed under question 8 for Beaver County, question 6 for Allegheny County, and question 7 for Washington County.
  • B9 A7 W8 The DEP asked Shell to evaluate the impact of open cut installation on wetlands with perched water tables and/or confining layers. Perched water tables have an impermeable confining layer (such as clay) between them and the main water table below. If open cut methods are used, the confining layer is destroyed and this water table will be lost. In Beaver County, Shell identified one wetland (W-PA-170222-MRK-002) will be open cut. If it is perched, Shell states it will replace the confining layer “along the same horizon during pipeline backfilling, and then [compact the layer] so that hydrology may be maintained.” Shell will also put trench plugs “on either side of the wetland on the ROW to prevent water from migrating out on the sides.” In Allegheny County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160401-MRK-006, W-PA-161220-MRK-001, and W-PA-161220-MRK-002.In Washington County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160407-JLK-002, W-PA-151203-MRK-005, and W-PA-151203-MRK-006.
  • A11 The DEP asked Shell to evaluate if any wetlands can be classified as “exceptional value” due to their proximity to nesting areas of the northern harrier (a threatened species in Pennsylvania). Wetlands are exceptional value if they serve as habitat for threatened or endangered species, or if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain habitat for the species in the wetland. Shell determined that there are six wetlands that could be nesting areas for northern harriers, and therefore are exceptional value (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003, W-PA-170207-MRK-001, W-PA-170113-MRK-008, W-PA-170113-MRK-001). Three of these wetlands are within the project’s LOD (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003).
  • B13 A10 W11 The DEP asked Shell to evaluate whether the proposed Falcon Pipeline will impact wetlands that are of “exceptional value” based on their proximity to public water systems. Wetlands can be considered “exceptional value” if they are located along public or private drinking water supplies (surface or ground water), and help maintain the quality or quantity of the supply. Shell stated that the (potentially man made) ponds near public water supply A could be considered exceptional value, however, they are located outside of the project’s study area and were not delineated, therefore Shell does not have information on them or their impact to this well. There were no other wetlands Shell considered to be exceptional value based on their proximity to public water systems.
  • B21 There were two protected plant species- harbinger of spring (PA threatened) and purple rocket (PA endangered)- located within the Raccoon Creek floodplain. The DEP asked Shell to evaluate whether there are wetlands in the project area that should be considered “exceptional value” due to their proximity to these species. Wetlands are considered “exceptional value” if they serve as habitat for a threatened or endangered plant or animal species. They are also exceptional value if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain the habitat of the species. There are six wetlands near populations of these plant populations: W-PA-151014-MRK-001, W-PA-151013-MRK-002, -003, and -004, W-PA-170407-JLK-001, W-PA151013-MRK-001. However, Shell stated that the harbinger of spring is not dependent on wetland habitat for survival and the species is considered an upland plant species (because it is not listed on Eastern Mountains and Piedmont List or on the National Wetland Plant List).  Purple rocket is listed as a “Facultative Wetland Plant” (FACW) on both lists. However, Shell stated that, “although it is a FACW, this plant is not one that occurs in wetlands,” and the population of purple rocket was found in an upland, disturbed area. Therefore, Shell determined that none of these wetlands are considered exceptional value.
  • B23 A21 W21 Shell needs to assess cumulative impacts to wetlands from the proposed pipeline and other existing projects and potential future projects. These are discussed in the Cumulative Impact Assessment document, Sections 4.1 and 4.2, and Tables B1 and B2.
  • B24 A22 W22 Shell needed to provide an explanation of how it will restore wetlands and streams disturbed during construction. The explanation needed to include information on seed mixes, shrubs, and trees that will restore stream banks and riparian areas.
  • B26 A24 W24 Shell needed to provide a table that lists, describes, and quantifies permanent impacts to wetlands and watercourses. Shell stated that there are no permanent fills associated with the project, but there will be permanent conversion impacts to the following wetlands. They total 10,862 ft2 or 0.25 acres in Beaver County, 5,166 ft2 (0.12 acres) in Allegheny County, and 4971 ft2 (0.11 acres) in Washington County. (W-PA-151013-JLK-005, W-PA-161202-MRK-001, W-PA-160404-MRK-001, W-PA-160412-CBA-004, W-PA-160412-CBA-001, W-PA-161205-WRA-003, W-PA-160401-MRK-005, W-PA-170213-JLK-003, W-PA-160406-MRK-001, W-PA-170413-RCL-005, W-PA-170214-CBA-005.)
  • B27 A25 W25 Shell needed to provide more information on the Neshannock Creek Restoration site, including a master restoration plan for the entire site. This mitigation is required to offset conversion impacts to wetlands along the pipeline route. The plan for the site is documented here.
  • B28 A26 W26 Shell needed to provide the location and resource crossing number for the HDDs in PA. They are listed in these tables:

Allegheny County:Table of Resources Falcon Pipeline Crosses by HDD in Allegheny County

Washington County:

Beaver County:

Table of water resources the Falcon pipeline crosses by HDD

2. Stormwater control

  • B3 A1 W1 Shell indicated that the project was in a floodplain project by the Commonwealth, a political subdivision of the commonwealth or a public utility. The DEP asked for an identification of this floodplain project, to which Shell responded that it misunderstood the question and the pipeline will not go through a floodplain project by one of these entities, but rather a floodway. The pipeline will pass many floodways, which are listed in Table 1 in separate documents for Beaver County, Allegheny County, and Washington County.
  • W3 The DEP requested that Shell provide an analysis of impact to Act 167 plans. Act 167 requires counties to create stormwater management plans and municipalities to adopt ordinances to regulate development in accordance with these plans. The pipeline route occurs in areas with Act 167 plans in Chartiers Township, Mount Pleasant Township, and Robinson Township.

3. Public health and safety

  • B1 The proposed pipeline does not meet the provisions of a zoning ordinance or have zoning approval in a particular area. Specifically, in Independence Township, the pipeline is within setback distances of places of congregation and/or of residences. One example is the Beaver County Conservation District, considered a place of congregation. Shell responded to this deficiency, saying it is working with Independence Township to obtain necessary approvals, and the township will “officially remove the pipeline ordinance from their records and no variances or permits will be required.”
  • B10 A8 W9 The DEP requested that Shell evaluate and discuss how the pipeline may impact public water systems that are within 1 mile of the pipeline route. Shell located 12 sites within a mile, most of which are ground water wells. One site is the Ambridge Water Authority, which provides drinking water for an estimated 30,000 people. Shell stated that impacts “might include an Inadvertent Return (IR) causing a bentonite slurry mix to enter the supply, which might contaminate the supply for any wells that are located near an HDD site or construction equipment.” Shell stated that all wells are a minimum of 1000 feet outside construction zones and built in thick bedrock which will minimize threat on contamination. The sites within 1 mile include:
    • Youthtowne Barn
    • Beaver County Conservation District
    • Independence Elementary School
    • Independence Volunteer Fire Department
    • McConnell’s Farm and Market, Inc
    • Ambridge Water Authority- Independence Township
    • Ambridge Water Authority- Raccoon Township
    • Hookstown Free Methodist Church
    • Hookstown Fair
    • Hookstown Grange
    • South Side Memorial Post 952
    • Jack’s Diner
    • NOVA Chemical, Inc
  • B11 A9 W10 The DEP asked Shell to discuss efforts to avoid/minimize impacts to the above public water systems, and suggested that efforts “might include, but are not limited to, considering alternative locations, routings or design for the proposed pipeline; providing provisions for shut-off in the event of break or rupture; etc.” Shell stated that the route avoids direct impacts to groundwater wells and surface water intake. Shell will provide water buffalos if wells are contaminated, and drill new wells if necessary. There are mainline valves approximately 7 to 7.5 miles apart that can automatically shut off the flow of ethane. There will also be staff living within the project area that can quickly respond to issues.
  • B12 The pipeline crosses headwaters of the Ambridge Reservoir and the Reservoir’s raw water service pipeline, which supplies water to 30,000 residents. The DEP noted significant public concern regarding this crossing, and asked Shell to evaluate and discuss the pipeline’s potential to affect the Reservoir and public water supply service. The DEP also asked Shell to elaborate on efforts to avoid/minimize impacts, and what measures will be implemented to mitigate any unavoidable impacts. In response, Shell stated the pipeline will cross the raw water line via an HDD  31 feet below the line. Shell explained that the water service line is made of pre-stressed concrete, which cannot be retrofitted in the field if a break occurs. It can take six weeks for pipe joints to be made and delivered from Ohio if there is a rupture. Shell stated it will supply extra pipe joints so the Ambridge Water Authority can have pieces on deck in case of a break. Shell also outlined the protective coatings and design of the HDD portion of the pipeline that will cross the water line, and said valves that can shut off the pipeline are located 2.4 miles from one side of the water line and 3.5 on the other.
  • A17 W17 The DEP asked Shell to consider the proposed pipeline’s effect on the Montour Trail, a multi-use, recreational trail, and to consider re-routes that would avoid impacts to the Trail. Shell determined that routing around the trail is not feasible. Shell will use conventional bore or HDD methods. If the trail needs to be temporarily closed during construction, operation, or maintenance, Shell will notify the trail owner and provide alternate temporary access for trail users. Shell will also cross the Panhandle Trail by HDD. The entrance and exit sights of the bore will not be on the trail’s property. Shell has “unlimited ingress and egress over Owners property” for inspections, repair and maintenance of the pipeline, and in case of emergency situations.
  • B29 A27 W27 Shell needed to revise the “Shell Pipeline HDD Procedure” to include HDD site feasibility analysis, inadvertent return risk assessment, water supply protection, agency contact information, etc. Shell’s response is included in the document, Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan.
  • B30 A28 W28 Shell needed to include a preboring geologic evaluation to determine if drinking water supplies will be impacted around boring locations. Shell also needed to discuss how it will verify that drinking water sources and aquifers are protected and what measures will be taken in the event that they are impacted. Shell’s response is included as Appendix C to this document.

4. Conservation

  • B19 A18 W18 19A 19W – There are many areas important for the region’s biodiversity and natural heritage that the proposed pipeline passes near or through. The DEP asked Shell to evaluate impacts to these areas. Information on them is available from the Pennsylvania Natural Heritage Program. They include:
    • Ambridge Reservoir Valleys Natural Heritage Area
    • Lower Raccoon Creek Natural Heritage Area
    • Raccoon Creek Valley and Wildflower Reserve Natural Heritage Area
    • Raccoon Creek Floodplain Biologically Diverse Area
    • Raccoon Creek Landscape Conservation Area
    • Clinton Wetlands Biologically Diverse Area
    • Raccoon Creek Landscape Conservation Area
    • Raccoon Creek Valley & State Park Important Bird Area – Regarding the Important Bird Area, Shell stated that 23 miles of the pipeline is located within this area. Shell has not been able to get in contact with the National Audobon SW PA office. Shell added that the only waterbody large enough in the project area to support the documented waterfowl is the open water at Beaver County Conservation District. Shell stated that “an outlet has been installed at the far end of the lake to restore it to more of a wetland and less of a lake, as it was originally designed.Raccoon Creek Valley is also a passageway for migratory birds, which are protected under the Migratory Bird Treaty Act. Shell stated that less than 2% of this Important Bird Area will be permanently impacted by pipeline construction and installation.

5. Alternative locations

  • B17 A15 W15 The DEP asked Shell to revise its current alternatives and provide a more detailed “analysis of the alternative locations and routes that were considered to avoid or minimize adverse environmental impacts.” The alternatives are discussed in Section 9 of Shell’s Comprehensive Environmental Assessment.
  • B18 16A 16W According to the DEP, “18.5 of the 45 miles (41%) of the proposed pipeline are parallel to or adjacent to existing right-of-ways (ROWs).” The DEP asked Shell to see if there are additional opportunities to build the pipeline within existing ROWs, with the hope of reducing environmental impacts. In response, Shell discussed the additional ROWs that were considered (along Mariner West) but ultimately rejected. Shell discusses these routes more in Section 9.1 of the Comprehensive Environmental Assessment.
  • B32 A30 W30 The DEP asked Shell to discuss the feasibility of several changes to the proposed pipeline’s route, including avoiding impacts to wetlands, relocating resource crossings, moving valve sites outside of wetlands, moving HDD locations, and evaluating the impact to a coal refuse pile (the pipeline crosses underneath at least one pile via HDD). These reroutes are discussed under question 32 for Beaver County, question 30 for Allegheny County, and question 30 for Washington County.

6. Geological concerns

  • B14 12A 12W The pipeline is located in previously coal mined areas. The DEP asked Shell to provide a map of the pipeline that showed these mining areas, and GIS shape files with this information. Shell’s response is included in the HDD Subsurface Investigation Reports, which includes the following table of the extent of mined areas along the pipeline route:
  • B15 A13 W13 The pipeline is located in coal mined areas, which could be susceptible to subsidence and/or mine water discharge. The DEP requested that Shell revise drawings to show the limits of previously mined areas, depth of cover over the mine workings in areas the proposed pipeline crosses through, and the distance between mine workings and the proposed pipeline. Furthermore, the DEP asked Shell to “evaluate and discuss the potential for a subsidence event compromising the utility line, and the potential to create a mine water discharge.” Shell discusses this in Appendix B of this this document and in the Mining Summary Report. Shell also identifies the following areas as being at risk for coal mine discharge: HOU MM 1.2, HOU MM 8.9 (proposed HDD), HOU MM 12.1, HOU MM 12.95, HOU MM 13.1, HOU MM 13.6, HOU MM 17.4, and HOU MM 17.65 (proposed HDD).
  • B16 A14 14W The DEP requested that Shell include areas where the pipeline will cross active mining permit boundaries. There is one active mining permit boundary that intersects the proposed pipeline, the Rosebud Mine in Beaver County.
  • B31 A29 W29 Shell needed to evaluate the potential for the project to encounter areas underlain by carbonate bedrock and landslide prone areas. Carbonate bedrock is indicative of a karst landscape, meaning an area likely to have underground sinkholes and caves. The DEP also asked Shell to discuss precautionary methods taken during construction in these areas. Shell’s response is included in the Carbonate Rock Analysis and Slope Stability and Investigation Report. The Carbonate Rock Analysis report shows that carbonate bedrock was encountered in 20 out of 40 of the borings taken during the analysis.

7. Documentation

  • B4 The PA DEP asked Shell to describe the structures and activities that occur within junction sites. Shell responded that there will be a Junction Custody Transfer Meter Station at the site, and provided maps of the site.
  • B22 20A 20w The DEP requested that Shell revise their Comprehensive Environmental Assessment to include alternatives, impacts, and mitigation items that were previously included in other sections of their environmental assessment.
  • B25 A23 W23 The DEP asked Shell to provide a copy of the Mitigation Bank Credit Availability Letter from First Pennsylvania Resource, LLC. In response, Shell stated the Letter is no longer needed because “the permanent stream and wetland fills have been removed from this project.”
  • B34 A32 W32 The DEP asked Shell to include a copy of the Preparedness, Prevention, and Contingency Plan.
  • B35 A33 W33 Shell needs to include all of the above modifications to the application in the Chapter 103 permit application.

Conclusion

As evidenced by the list above, the proposed Falcon Pipeline poses a variety of threats to Pennsylvania’s natural resources, wildlife, and public health – but this deficiencies list is likely not complete. The pipeline also passes through West Virginia and Ohio, and if completed, will likely attract more pipelines to the area. As it feeds Shell’s ethane cracker plant in Beaver County, it is a major step towards the region becoming a hub for plastic manufacturing. Therefore, the public response to the above deficiencies and the decision the DEP makes regarding them will have major implications for the Ohio River Valley’s future.

Of note: The DEP’s letters and Shell’s response to them are available to the public in separate documents for  Allegheny, Beaver, and Washington Counties. 


By Erica Jackson, Community Outreach and Communications Specialist

The Falcon: Methods, Mapping, & Analysis

Part of the Falcon Public EIA Project

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

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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

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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

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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

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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.

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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.

* * *

Related Articles

Piecing together the ethane cracker - Graphic by Sophie Riedel

Piecing Together an Ethane Cracker

How fragmented approvals and infrastructure favor petrochemical development

By Leann Leiter and Lisa Graves-Marcucci

Let’s think back to 2009, when oil and gas companies like Range Resources began drilling the northeast shale plays in earnest. Picture the various stages involved in drilling – such as leasing of land, clearing of trees, boring of wells, siting of compressor stations, and construction of pipelines to gather the gas. Envision the geographic scope of the gas infrastructure, with thousands of wells in Pennsylvania alone, and thousands of miles of pipelines stretching as far as Louisiana.

Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter.

Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter

Now, picture the present, where a homeowner looks out over her yard and wonders how a lease she signed with Shell several years prior made it possible for the company to run an ethane pipeline across her property and between her house and her garage.

Think forward in time, to 2022, the year when a world-scale ethane cracker is set to go online in Beaver County, Pennsylvania, to begin churning through natural gas liquids from wells in PA and others, producing a variety of disposable plastic products.

At each of these moments in gas development, which of the many stakeholders – industry leaders, local governments, state regulatory agencies, or landowners and residents – were granted a view of the full picture?

The proposed Shell ethane cracker in Beaver County is an illustration of the fragmented nature of gas development. From the extensive web of drilling infrastructure required to supply this massive facility, to several years of construction, this project is a case-study in piecemeal permitting. Such fragmentation creates a serious barrier to transparency and to the informed decision-making that relies upon it.

In the first two articles in this series on the petrochemical development in Beaver County, we focused on ethane cracker emergency scenarios and how the area might prepare. In this article, we draw the lens back to take in the larger picture of this region-altering project and highlight the effects of limited transparency.

The “Piecemeal” Nature of Gas Development

All across the Pennsylvania, proposed industrial development – even coal operations – have historically provided to the public, elected officials, and regulatory agencies the extent or footprint of their planned operations. Nonetheless, the oil and gas industry has in several instances undertaken a practice of developing its extensive infrastructure piece-by-piece. Operators of these facilities first acquire a GP-5 General Permit, which is only available to certain oil and gas operations with “minor” emissions and which allows them to avoid having the permit undergo public notice or comment. These operators then add emissions sources and increases through a series of minor amendments. While they are required to obtain a “major” source permit once their modifications result in major emissions, they avoid the scrutiny required for a major source by this fragmented process.

Unlike most other industrial permitting, the gas industry has enjoyed a much less transparent process. Instead of presenting their entire planned operation at the time of initial permit application, gas operators having been seeking – and receiving – incremental permits in a piecemeal fashion. This process puts local decision makers and the women, men, and children who live, work, and go to school near gas development at a severe disadvantage in the following ways:

  • Without full disclosure of the entirety of the planned project, neither regulatory bodies nor the public can conduct a full and factual assessment of land use impacts;
  • Incremental approvals allow for ever-expanding operations, including issuance of permits without additional public notification and participation;
  • Piecemeal approvals allow operations to continuously alter a community and its landscape;
  • The fragmented approval process prevents consideration of cumulative impacts; and
  • Without full transparency of key components of the proposed operations, emergency planning is hampered or non-existent.

From the Well to the Ethane Cracker

In the fragmented approval process of gas development, the proposed ethane cracker in Beaver County represents a pertinent example. Developers of this massive, multi-year, and many-stage project have only revealed the size and scope in a piecemeal fashion, quietly making inroads on the project (like securing land leases along the route of the pipeline required for the cracker, years in advance of permit approvals for the facility itself). By rolling out each piece over several years, the entirety of the petrochemical project only becomes clear in retrospect.

A World-Scale Petrochemical Hub

While Shell is still pursuing key approval from the PA Department of Environmental Protection, industry leaders treat the ethane cracker as a foregone conclusion, promising that this facility is but one step in turning the area into a “petrochemical hub.”

The cracker facility, alone, will push existing air pollution levels further beyond their already health-threatening state. Abundant vacant parcels around Shell’s cracker site are attractive sites for additional spin-off petrochemical facilities in the coming “new industry cluster.” These facilities would add their own risks to the equation, including yet-unknown chemical outputs emitted into the air and their resulting cumulative impacts. Likewise, disaster risks associated with the ethane cracker remain unclear, because in the piecemeal permitting process, the industry is not required to submit Preparedness, Prevention, and Contingency (PPC) Plans until after receiving approval to build.

Figure 2: Visualization shows a portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh's Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 "Annual Report of Natural Gas and Supplemental Gas Supply and Disposition," 2007.

Figure 2. A portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh’s Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.

92.3 Miles of Explosive Pipeline

More than just a major local expansion, communities downriver and downwind will be susceptible to the impacts, including major land disturbance, emissions, and the potential for “incidents,” including explosion. The pipeline required to feed the cracker with highly flammable, explosive ethane would tie the tri-state region into the equation, expanding the zone of risk into Ohio and crossing through West Virginia.

Figure 3: The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP.

Figure 3. The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP

Renewed Demand at the Wellhead

No one piece of the gas infrastructure stands alone; all work in tandem. According to the  Energy Information Administration (EIA), the new US ethane crackers will drive consumption of ethane up by a 26% by the end of 2018. Gas wells in the northeast already supply ethane; new ethane crackers in the region introduce a way to profit from this by-product of harvesting methane without piping it to the Gulf Coast. How this renewed demand for ethane will play out at fracked wells will be the result of complex variables, but it will undoubtedly continue to drive demand at Pennsylvania’s 10,000 existing unconventional oil and gas wells and those of other states, and may promote bringing new ones online.

quote-from-petchem-report

Figure 4. Excerpt from Executive Summary of IHS Markit Report, “Prospects to Enhance Pennsylvania’s Opportunities in Petrochemical Manufacturing.”

Along with drilling comes a growing network of gathering and transmission lines, which add to the existing 88,000 miles of natural gas pipeline in Pennsylvania alone, fragment wildlife habitat, and put people at risk from leaks and explosions. Facilities along the supply stream that add their own pollution and risks include pump stations along the route and the three cryogenic facilities at the starting points of the Falcon Pipeline (see Fig. 6).

Figure 4: Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter.

Figure 5. Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter

The infrastructure investment required for ethane crackers in this region could reach $3.7 billion in processing facilities, pipelines for transmitting natural gas liquids including ethane, and storage facilities. A report commissioned by Team Pennsylvania and the PA Department of Community and Economic Development asserts that “the significant feedstock and transportation infrastructure required” will “exceed what is typically required for a similar facility” in the Gulf Coast petrochemical hub, indicating a scale of petrochemical development that rivals that of the southern states. This begs the question of how the health impacts in Pennsylvania will compare to those in the Gulf Coast’s “Cancer Alley.”

Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP.

Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP

Water Impacts, from the Ohio River to the Arctic Ocean

Shell’s facility is only one of the ethane crackers proposed for the region that, once operational, would be permitted to discharge waste into the already-beleaguered Ohio River. This waterway, which traverses six separate states, supplies the drinking water for over 3 million people. Extending the potential water impact even further, the primary product of the Shell facility is plastics, whose inevitable disposal would unnecessarily add to the glut of plastic waste entering our oceans. Plastic is accumulating at the alarming rate of 3,500 pieces a day on one island in the South Pacific and as far away as the waters of the Arctic.

Figure 7: View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.

Figure 7. View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.

How does fragmentation favor industry?

The gas and petrochemical industry would likely defend the logistical flexibility the piecemeal process affords them, allowing them to tackle projects, make investments, and involve new players as needed overtime. But in what other ways do the incredibly fragmented approval processes, and the limited requirements on transparency, favor companies like Shell and their region-changing petrochemical projects? And what effect does the absence of full transparency have on local communities like those in Beaver County? We conclude that it:

  • “Divides and conquers” the region. The piecemeal approach to gas development, and major projects like the Shell ethane cracker, deny any sense of solidarity between the people along the pipeline route resisting these potentially explosive channels cutting through their yards, and residents of Beaver County who fear the cracker’s emissions that will surround their homes.
  • Makes the project seem a foregone conclusion, putting pressure on others to approve. For example, before Shell formally announced its intention to build the facility in Potter Township, it rerouted a state-owned road to facilitate construction and increased traffic flow. Likewise, though a key permit is still outstanding with the PA DEP, first responders, including local volunteer firefighters, have already begun dedicating their uncompensated time to training with Shell. While this is a positive step from a preparedness standpoint, it is one of many displays of confidence by Shell that the cracker is a done deal.
  • Puts major decisions in the hands of those with limited resources to carry them out and who do not represent the region to be affected. In the case of the Shell ethane cracker, three township supervisors in Potter Township granted approvals for the project. The impacts, however, extend well beyond Potter or even Beaver county and include major air impacts for Allegheny County and the Pittsburgh area. Effects will also be felt by landowners and residents in numerous counties and two states along the pipeline route, those near cryogenic facilities in Ohio and Pennsylvania, plus those living on the Marcellus and Utica shale plays who will see gas well production continue and potentially increase.


Figures 8a and 8b. Potter Township Supervisors give the go-ahead to draft approval of Shell’s proposed ethane cracker at a January meeting, while confronted with public concern about deficiencies in Shell’s permit applications. Photos courtesy of the Air Quality Collaborative.

Fragmented Transparency, Compromised Decision-making

The piecemeal, incremental, and fragmented approval processes for the ethane cracker – and other gas-related facilities in the making – create one major problem. They make it nearly impossible for locals, elected officials, and regulatory agencies to see the whole picture as they make decisions. The bit-by-bit approach to gas development amounts to far-reaching development with irreversible impacts to environmental and human health.

We ask readers, as they contemplate the impacts closest to them – be it a fracked well, a hazardous cryogenic facility, the heavily polluted Ohio River, a swath of land taken up for the pipeline’s right-of-way, or Shell’s ethane cracker itself – to insist that they, their elected officials, and regulators have access to the whole picture before approvals are granted. It’s hard to do with a project so enormous and far-reaching, but essential because the picture includes so many of us.

Sincere Appreciation

To The International League of Conservation Photographers, The Ohio Environmental Council, and The Air Quality Collaborative for sharing photographs.

To Sophie Riedel for sharing her visualizations of natural gas interstate pipelines.

To Lisa Hallowell at the Environmental Integrity Project, and Samantha Rubright and Kirk Jalbert at FracTracker, for their review of and and invaluable contributions to this series.

Photo by Garth Lenz, iLCP - for Ethane Cracker article about risk and disclosure

Understanding in Order to Prepare: Ethane Cracker Risk and Disclosure

By Leann Leiter and Lisa Graves Marcucci
Maps and data analysis by Kirk Jalbert

Highly industrialized operations like petrochemical plants inherently carry risks, including the possibility of large-scale disasters. In an effort to prepare, it is incumbent upon all stakeholders to fully understand the risk potential. Yet, the planned Shell ethane cracker and additional petrochemical operations being proposed for Western Pennsylvania are the first of their kind in our region. This means that residents and elected officials are without a frame of reference as they consider approving these operations. Officials find themselves tasked with reviewing and approving highly complicated permit applications, and the public remains uncertain of what questions to ask and scenarios to consider. Often overlooked in the decision-making process is valuable expertise from local first responders like police, fire and emergency crew members, HAZMAT teams, and those who protect vulnerable populations, like emergency room personnel, nursing home staff, and school officials.

Steam cracker at BASF's Ludwigshafen site. Photo credit: BASF - for risk and disclosure article

Example of cracker producing ethylene, located at BASF’s Ludwigshafen site. Photo credit: BASF

In the first article in this series , we tried to identify the known hazards associated with ethane crackers. In this article, we look more closely at how that risk could play out in Beaver County, PA and strive to initiate an important dialogue that invites valuable, local expertise.

In keeping with the first article in this series, we use the terms vulnerability and capacity. Vulnerability refers to the conditions and factors that increase the disaster impact that a community might experience, and capacity consists of the strengths that mitigate those impacts. Importantly, vulnerability and capacity frequently intertwine and overlap. We might, for example, consider a fire station to be a site of “capacity,” but if it lies within an Emergency Planning Zone (discussed more below), an explosion at the plant could render it a vulnerability. Likewise, “vulnerable” populations such as the elderly may have special skills and local knowledge, making them a source of capacity.

Emergency Planning: Learning from Louisiana

FracTracker got in touch with the Emergency Operations Center (EOC) in St. Charles Parish, Louisiana, to learn how a community already living with Shell-owned and other petrochemical facilities manages risk and disclosure. The Emergency Manager we spoke with explained that they designate a two- and a five-mile area around each new facility in their jurisdiction, like ethane crackers, during their emergency planning process. They call these areas “ emergency planning zones ” or EPZs, and they maintain records of the vulnerabilities and sites of capacity within each zone. In case of a fire, explosion, or other unplanned event at any facility, having the EPZs designated in advance allows them to mobilize first responders, and notify and evacuate everyone living, working, and attending school within the zone. Whether they activate a two- or a five-mile EPZ depends on the type of incident, and factors like wind speed and direction.

Based on those procedures, the map below shows similar likely zones for the proposed plant in Beaver County, along with sites of vulnerability and capacity.

Ethane Cracker Hazard Map

View Map Fullscreen | How FracTracker Maps Work

The map helps us visualize the vulnerability and capacity of this area, relative to the proposed ethane cracker. It includes three main elements: the Shell site and parcels likely to be targeted for buildout of related facilities, two Emergency Planning Zones (EPZs) around the Shell facility, and infrastructure and facilities of the area that represent vulnerability and capacity.

vacant-parcels

Vacant parcels near the site

It is important to note that the proposed ethane cracker in Beaver County is merely the first of an influx of petrochemical spin-off facilities promised for the area, potentially occupying the various empty parcels indicated on the map above as “vacant properties” and presented in light gray in the screenshot left.

Each new facility would add its own risks and cumulative impacts to the equation. It would be impossible to project these additional risks without knowing what facilities will be built here, so in this article, we stick to what we do know – the risks already articulated by Shell, lessons learned from other communities hosting petrochemical industry in other parts of the country, and past disasters at similar facilities.

Vulnerability and Capacity in Beaver County

Red, blue, and green points on the map above and in the screenshot below stand in for hospitals like Heritage Valley Beaver; fire and emergency medical services like Vanport Volunteer Fire Company; police stations like the Beaver County Sheriff’s office; and daycares and schools like Center Grange Primary School.

Transportation routes, if impacted, could challenge evacuation. Potter Township Fire Chief Vicki Carlton pointed out that evacuations due to an event at this facility could also be complicated by the need to stay upwind, when evacuations would likely move in a downwind direction. This map lacks drinking water intakes and other essential features upon which lives depend, but which nonetheless also sit within this zone of vulnerability.

points-within-epzs

Points within EPZS

Vulnerability/capacity within 2-mile zone:

  • 1 hospital
  • 5 police stations
  • 10 fire/EMS stations
  • 23 schools/daycare facilities
  • 47,717 residents*

When expanded to 5-mile zone:

  • 2 hospitals
  • 9 police stations
  • 23 fire/EMS stations
  • 40 schools/daycare facilities
  • 120,849 residents*

*Note: For census tracts that are partly within a zone, a ratio is determined based on the percentage of land area in the tract within the zone. This ratio is then used to estimate the fraction of the population likely within the zone.

Stakeholders’ Right to Know

No person or community should be subjected to risk without the opportunity to be fully informed and to give meaningful input. Likewise, no group of people should have to bear a disproportionate share of environmental risks, particularly stakeholders who are already frequently disenfranchised in environmental decision-making. “Environmental justice” (EJ) refers to those simple principles, and DEP designates environmental justice areas based on communities of color and poverty indicators.

Presented as blue fields on the map and shown in the screenshot below, several state-designated EJ areas fall partially or entirely within the 2- and 5-mile EPZs (a portion of two EJ areas home to 2,851 people, and when expanded to five miles, two entire EJ areas and a portion of seven more, home to 18,679 people, respectively).

EJ Areas and Emergency Planning Zones around the Site

EJ Areas and Emergency Planning Zones around the Site

The basic ideas behind environmental justice have major bearing in emergency scenarios. For example, those living below the poverty line tend to have less access to information and news sources, meaning they might not learn of dangerous unexpected emissions plumes coming their way. They also may not have access to a personal vehicle, rendering them dependent upon a functioning public transportation system to evacuate in an emergency. Living below poverty level may also mean fewer resources at home for sheltering-in-place during a disaster, and having less financial resources, like personal savings, may lead to more difficult post-disaster recovery.

Local expertise

FracTracker recently consulted with the Emergency Management Director for Beaver County, Eric Brewer, and with Potter Township Fire Chief Vicki Carlton. Both indicated that their staff have already begun training exercises with Shell -including a live drill on site that simulated a fire in a work trailer. But when asked, neither reported that they had been consulted in the permit approval process. Neither had been informed of the chemicals to be held on site, and both referred to emergency planning considerations as something to come in the future, after the plant was built.

Unfortunately, the lack of input from public safety professionals during the permit approval stage isn’t unique to Beaver County. Our emergency management contact in Louisiana pointed to the same disturbing reality: Those who best understand the disaster implications of these dangerous developments and who would be mobilized to respond in the case of a disaster are not given a say in their approval or denial. This valuable local expertise – in Louisiana and in Beaver County – is being overlooked.

All Beaver County first responders who spoke with FracTracker clearly showed their willingness to perform their duties in any way that Shell’s new facility might demand, hopefulness about its safety, and a generally positive relationship with the company so far. Chief Carlton believes that the ethane cracker will be an improvement over the previous facility on the same site, the Horsehead zinc smelter, though a regional air pollution report characterizes this as a trade off of one type of dangerous pollution for another. Director Brewer pointed to the existing emergency plans for the county’s nuclear facility as giving Beaver County an important leg-up on preparedness.

But the conversations also raised concern about what the future relationship between the community and the industry will look like. Will funds be allocated to these first responders for the additional burdens brought on by new, unprecedented facilities, in what amount, and for how long into the future? Chief Carlton pointed out that until Shell’s on-site fire brigade is in place two or three years from now, her all-volunteer department would be the first line of defense in case of a fire or other incident. In the meantime, her fire company has ordered a much-needed equipment upgrade to replace a 30-year old, outdated tanker at a cost of $400,000. They are formally requesting all corporate businesses in the township, including Shell, to share the cost. Hopefully, the fire company will see this cost covered by their corporate neighbors who use their services. But further down the road? Once all is said and done, and Shell has what they need to operate unfettered, Chief Carlton wonders, “where do we stand with them?”

Waiting for disclosure of the risks

Emergency preparedness and planning should be a process characterized by transparency and inclusion of all stakeholders. However, when it comes to the Shell ethane cracker, those who will share a fence line with such operations have not yet been granted access to the full picture. Currently, the DEP allows industrial operations like the proposed ethane cracker to wait until immediately before operations begin to disclose emergency planning information, in the form of Preparedness, Prevention, and Contingency (PPC) plans. In other words, when permits are up for approval or denial prior to construction, permit applicants are not currently required to provide PPC plans, and the public and emergency managers cannot weigh the risks or provide crucial input.

Shell’s Acknowledged Risks
According to public information provided by Shell

Sampling of Shell’s Disastrous
Petrochemical Precedents

Fire and Explosions

Shell’s Deer Park, Texas, 1997:
Blast at chemical plant

Leaks

Shell’s Deer Park, Texas refinery and chemical plant, 2013:
Harmful air pollution and benzene leak

Equipment Failures

Shell’s Martinez Refinery in California, 2016:
Equipment failure event; Shell’s refusal to reveal gases emitted

According to Shell, possible risks of the proposed Beaver County petrochemical facility include fire, explosion, leaks, and equipment failures. More than mere potentialities, examples of each are already on the books. The above table presents a sampling. Shell also points out the increased risk of traffic accidents, not explored in this chart. It is worth noting, however, that the proposed facility, and likely spin-off facilities, would greatly increase vehicular and rail traffic.

The ethane cracker in Beaver County plant has not yet been constructed. However, Shell operates similar operations with documented risks and their own histories of emergency events. Going forward, the various governmental agencies tasked with reviewing permit applications should require industrial operations like Shell, to make this information public as part of the review and planning process. Currently they can relegate safety information to a few vague references and get a free pass to mark it as “confidential” in permit applications. Strengthening risk disclosure requirements would be a logical and basic step toward ensuring that all stakeholders – including those with special emergency planning expertise – can have input on whether those risks are acceptable before permits are approved and site prep begins.

Until regulations are tightened, we invite Shell to fulfill its own stated objective of being a “good neighbor” by being forthcoming about what risks will be moving in next door. Shell can and should take the initiative to share information about its existing facilities, as well as lessons learned from past emergencies at those sites. Instead of waiting for the post-construction, or the “implementation” stage, all stakeholders deserve disclosure of Shell’s plans to prevent and respond to emergencies now.

In our next article, we will explore the infrastructure for the proposed Shell facility, which spans multiple states, and sort out the piecemeal approval processes of building an ethane cracker in Pennsylvania.


Sincere Appreciation

Emergency Managers and First Responders in St. Charles Parish, Louisiana and Potter Township and Center Township, PA.

Lisa Hallowell, Senior Attorney at the Environmental Integrity Project, for her review of this article series and contributions to our understanding of relevant regulations.

Kirk Jalbert, in addition to maps and analysis, for contributing key points of consideration for and expertise on environmental justice.

The International League of Conservation Photographers for sharing the feature image used in this article.

The image used on our homepage of the steam cracker at BASF’s Ludwigshafen site was taken by BASF.


By Leann Leiter, Environmental Health Fellow for FracTracker Alliance and the Southwest PA Environmental Health Project and Lisa Graves Marcucci, PA Coordinator, Community Outreach of Environmental Integrity Project

With maps and analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance

Shell Ethane Cracker

A Formula for Disaster: Calculating Risk at the Ethane Cracker

by Leann Leiter, Environmental Health Fellow
map & analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement
in partnership with the Environmental Integrity Project

On January 18, 2016, Potter Township Supervisors approved conditional use permits for Shell Chemical Appalachia’s proposed ethane cracker facility in Beaver County, PA. A type of petrochemical facility, an ethane cracker uses energy and the by-products of so-called natural gas to make ethylene, a building block of plastics. FracTracker Alliance has produced informative articles on the jobs numbers touted by the industry, and the considerable negative air impacts of the proposed facility. In the first in a series of new articles, we look at the potential hazards of ethane cracker plants in order to begin calculating the risk of a disaster in Beaver County.

As those who stand to be affected by — or make crucial decisions on — the ethane cracker contemplate the potential risks and promised rewards of this massive project, they should also carefully consider what could go wrong. In addition to the serious environmental and human health effects, which might only reveal themselves over time, what acute events, emergencies, and disasters could potentially occur? What is the disaster risk, the potential for “losses, in lives, health status, livelihoods, assets and services,” of this massive petrochemical facility?

Known Ethane Cracker Risks

A well-accepted formula in disaster studies for determining risk, cited by, among others, the United Nations International Strategy for Disaster Reduction (UNISDR), is Disaster Risk = (Hazard x Vulnerability)/Capacity, as defined in the diagram below. In this article, we consider the first of these factors: hazard. Future articles will examine the remaining factors of vulnerability and capacity that are specific to this location and its population.

disaster-risk-infographic-websize

Applied to Shell’s self-described “world-scale petrochemical project,” it is challenging to quantify the first of these inputs, hazard. Not only would a facility of this size be unprecedented in this region, but Shell has closely controlled the “public” information on the proposed facility. What compounds the uncertainty much further is the fact that the proposed massive cracker plant is a welcome mat for further development in the area—for a complex network of pipelines and infrastructure to support the plant and its related facilities, and for a long-term commitment to continued gas extraction in the Marcellus and Utica shale plays.

williams-geismar-explosion-websize

U.S. Chemical Safety and Hazard Investigation Board, Williams Geismar Case Study, No. 2013-03-I-LA, October 2016.

We can use what we do know about the hazards presented by ethane crackers and nearby existing vulnerabilities to establish some lower limit of risk. Large petrochemical facilities of this type are known to produce sizable unplanned releases of carcinogenic benzene and other toxic pollutants during “plant upsets,” a term that refers to a “shut down because of a mechanical problem, power outage or some other unplanned event.” A sampling of actual emergency events at other ethane crackers also includes fires and explosions, evacuations, injuries, and deaths.

For instance, a ruptured boiler at the Williams Company ethane cracker plant in Geismar, Louisiana, led to an explosion and fire in 2013. The event resulted in the unplanned and unpermitted release of at least 30,000 lbs. of flammable hydrocarbons into the air, including ethylene, propylene, benzene, 1-3 butadiene, and other volatile organic chemicals, as well as the release of pollutants through the discharge of untreated fire waters, according to the Louisiana Department of Environmental Quality. According to the Times-Picayune, “workers scrambl(ed) over gates to get out of the plant.” The event required the evacuation of 300 workers, injured 167, and resulted in two deaths.

The community’s emergency response involved deployment of hundreds of personnel and extensive resources, including 20 ambulances, four rescue helicopters, and buses to move the injured to multiple area hospitals. The U.S. Chemical Safety and Hazard Investigation Board chalked up the incident to poor “process safety culture” at the plant and “gaps in a key industry standard by the American Petroleum Institute (API).” The accident shut the plant down for a year and a half.

Potential Risks & Shell’s Mixed Messages

Shell has done little to define the potential for emergencies at the proposed Beaver County ethane cracker plant, at least in materials made available to the public. Shell has revealed that general hazards include “fire, explosion, traffic accidents, leaks and equipment failures.”

However, we located numerous versions of Shell’s handout and found one notable difference among them—the brochure distributed to community members at a December 2016 public hearing held by the Pennsylvania Department of Environmental Protection (PA DEP) excluded the word “explosion” from the list of “potential safety concerns.” The difference is seen in comparing the two documents.

Figure #1 below: Excerpt of online version of a handout for Beaver County, dated May 2015, with “explosion” included in list of “potential safety concerns.” (Other Shell-produced safety documents, like the one included as an exhibit in the conditional use permit application on file with the township, and Shell’s webpage for the project, also include “explosion” in the list of hazards.)

Figure #2 below: Excerpt of handout, dated November 2016 and provided to the community at December 15, 2016 meeting, with the word “explosion” no longer included.

 

Additional hints about risks are peppered throughout the voluminous permit applications submitted by Shell to the PA DEP and Potter Township, such as references to mitigating acts of terror against the plant, strategies for reducing water contamination, and the possibility of unplanned upsets. But the sheer volume of these documents, coupled with their limited accessibility challenge the public’s ability to digest this information. The conditional use permit application submitted by Shell indicates the existence of an Emergency Response Plan for the construction phase, but the submission is marked as confidential.

Per Pennsylvania law, and as set forth in PA DEP guidelines, Shell must submit a Preparedness, Prevention, and Contingency Plan (PPC Plan) at an unspecified point prior to operation. But at that likely too-late stage, who would hear objections to the identified hazards, when construction of the plant is already a done deal? Even then, can we trust that the plan outlined by that document is a solid and executable one?

Shell’s defense of the Beaver County plant is quick to point out differences between other plants and the one to come, making the case that technical advances will result in safety improvements. But it is noteworthy that the U.S. Chemical Safety and Hazard Investigation Board attributes failures at the Williams Geismar plant, in part, to “the ineffective implementation of…process safety management programs… as well as weaknesses in Williams’ written programs themselves.” The Geismar explosion demonstrates some of the tangible hazards that communities experience in living near ethane cracker plants. It is worth noting that the proposed Beaver County facility will have about 2½ times more ethylene processing capacity than the Geismar plant had at the time of the 2013 explosion.

Opening the Floodgates

In an effort to expand our understanding of risk associated with the proposed Beaver County ethane cracker and the extent of related developments promised by industry leaders, FracTracker Alliance has constructed the below map. It shows the site of the Shell facility and nearby land marked by Beaver County as “abandoned” or “unused.” These land parcels are potential targets for future build-out of associated facilities. Two “emergency planning zones” are indicated—a radius of 2 miles and a radius of 5 miles from the perimeter of Shell’s site. These projections are based upon FracTracker’s discussions with officials at the Saint Charles Parish Department of Homeland Security and Emergency Preparedness, who are responsible for emergency planning procedures in Norco, Louisiana, the site of another Shell ethane cracker facility. The emergency zones are also noted in the 2015 Saint Charles Hazard Mitigation Plan.

Also shown on the map is an estimated route of the Falcon pipeline system Shell intends to build, which will bring ethane from the shale gas fields of Ohio and Pennsylvania. Note that this is an estimated route based on images shown in Shell’s announcement of the project. Finally, our map includes resources and sites of vulnerability, including schools, fire stations, and hospitals. The importance of these sites will be discussed in the next article of this series.

Ethane Cracker Hazards Map

View map fullscreenHow FracTracker maps work

While the site of the Shell cracker is worth attending to, it would be a mistake to limit assessments of disaster risk to the site of the facility alone. Shell’s proposed plant is but one component in a larger plan to expand ethane-based processing and use in the region, with the potential to rival the Gulf Coast as a major U.S. petrochemical hub. An upcoming conference on petrochemical construction in the region, scheduled for June 2017 in Pittsburgh, shows the industry’s commitment to further development. These associated facilities (from plants producing fertilizers to plastics) would utilize their own mix of chemicals, and their potential interactions would produce additional, unforeseen hazards. Ultimately, a cumulative impact assessment is needed, and should take into account these promised facilities as well as existing resources and vulnerabilities. The below Google Earth window gives a sense of what this regional build-out might look like.

What might an ethane cracker and related petrochemical facilities look like in Beaver County? For an idea of the potential build-out, take a tour of Norco, Louisiana, which includes Shell-owned petrochemical facilities.

Final Calculations

As discussed in the introduction, “hazard,” “vulnerability,” and “capacity” are the elements of the formula that, in turn, exacerbate or mitigate disaster risk. While much of this article has focused on drastic “hazards,” such as disastrous explosions or unplanned chemical releases, these should not overshadow the more commonplace public health threats associated with petrochemical facilities, such as detrimental impact on air quality and the psychological harm of living under the looming threat of something going wrong.

The second and third articles in this series will dig deeper into “vulnerability” and “capacity.” These terms remind us of the needs and strengths of the community in question, but also that there is a community in question.

Formulas, terminology, and calculations should not obscure the fact that people’s lives are in the balance. The public should not be satisfied with preliminary and incomplete risk assessments when major documents that should detail the disaster implications of the ethane cracker are not yet available, as well as when the full scale of future build-out in the area remains an unknown.

Much gratitude to Lisa Graves-Marcucci and Lisa Hallowell of the Environmental Integrity Project for their expertise and feedback on this article.

The Environmental Integrity Project is a nonpartisan, nonprofit watchdog organization that advocates for effective enforcement of environmental laws. 

Ethane Cracker Discussion in Regional Air Pollution Report

Pittsburgh Regional Environmental Threats Analysis (PRETA) Air: Hazardous Air Pollutants

Although now we are an independent non-profit, FracTracker.org actually started as a project of CHEC at the University of Pittsburgh Graduate School of Public Health. At that time, Matt, Kyle, and I worked with researchers such as Drew Michanowicz and Jim Fabisiak of Pitt, as well as Jill Kriesky now of the Southwest PA Environmental Health Project, on a data mapping and analysis project called PRETA. The Pittsburgh Regional Environmental Threats Analysis (PRETA) is intended to inform stakeholders about Southwest Pennsylvania’s major environmental health risks and provide ways to manage them. CHEC worked with key decision makers and other academics to identify, prioritize, and assess these risks. The top three risks identified were ozone, particulate matter (PM), and hazardous air pollutants (HAPs). Due to the extensive time that research like this takes, the final report about hazardous air pollutants was just recently released.

Relevant to our oil and gas readers, the HAPs report included a piece about the proposed ethane cracker slated to be built in Beaver County, PA. Below is an excerpt of PRETA HAPs that discusses how the air quality in our region may change as a result of the removal of the present zinc smelter on that site, in place of the new cracker facility.

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Excerpt: The Proposed Monaca, PA Ethane Cracker

Future Trends: New Sources of HAPs in Western Pennsylvania?

All of the previous risk analyses and data discussed [earlier in the report] were drawn using historical data collected in previous years. There is considerable delay around emissions inventory collection, air monitoring data collection, atmospheric modeling, and the calculated risk estimates’ being made public. Hence, these analyses speak best toward past and present trends. They often are less useful in predicting future risks, especially when sources and technologies are constantly changing. For example, better pollution mitigation and retrofitting processes should curtail future emissions from present levels. In addition, changing the profile of various industries within a region also will alter atmospheric chemistry and subsequent risks in future scenarios.

In recent years, there has been an unprecedented expansion of unconventional natural gas development (UNGD) in Western Pennsylvania, Ohio, and West Virginia driven in part by the recent feasibility of hydraulic fracturing, which is part of a drilling procedure that allows for the tapping of the vast methane deposits contained in the Marcellus and Utica shales beneath Pennsylvania and surrounding states. Primarily, drillers are seeking to extract methane (CH4), the primary component of natural gas. However, a portion of the natural gas present in our area is considered “wet gas,” which includes heavier hydrocarbons like ethane, propane, and butane that are typically dissolved in a liquid phase or condensate. These compounds are separated from the methane to be marketed as such products as liquid propane or used as feedstock in numerous other chemical processes. Therefore, a high demand remains for wet gas deposits regardless of fluctuating natural gas (methane) market prices. Thus, a large-scale expansion in other industries (e.g., chemical manufacturing) is anticipated to follow UNGD; new industrial facilities are needed to support the refining of wet gas condensates. For example, an ethane cracker converts or “cracks” ethane, a by-product of natural gas, into ethylene so that it can be used in the production of plastics.

Located in Monaca, Pa. (Beaver County), about 12 miles east of the West Virginia border, is an aging zinc smelter owned by the Horsehead Corporation. The present Horsehead facility is currently the largest zinc refining site in the United States, producing metallic zinc and zinc oxide from recycled material and steelmaking waste. The plant opened in the 1920s to take advantage of the by-products of steel manufacturing and has expanded and modernized over time. It employed about 600 workers until recently, when the company announced its relocation to a new state-of-the-art facility in North Carolina in the near future. The scope of this metal-refining operation was such that it was a significant source of metals and criteria air pollutants.

Recently, Shell Chemical, U.S. subsidiary of Royal Dutch Shell PLC, announced plans to build an ethane cracker in the northeast to take advantage of UNGD. Lured by substantial tax benefits and other economic incentives, Shell chose the former zinc smelting site in Monaca as its proposed new location for such a facility and, in March 2012, received the approval from Pennsylvania officials to build this petrochemical complex. The cracker, according to industry representatives, will be a multibillion-dollar structure and provide thousands of jobs for Pennsylvanians 43, 44. However, many of these jobs depend on the influx of concurrent industries and technologies, which are projected to follow in the wake of sufficient petrochemical refining facilities like the ethane cracker. Thus, it is not likely to be the sole source of pollutants in the area once constructed. Though plant construction remains years away, regional air pollutant composition and chemistry are poised to change as well. Adding to the issue is the fact that the zinc smelter, ranked as one of the worst air polluters in the country in 2002 45, will be decommissioned and have its operations moved to North Carolina.

Here, we will attempt to compare the pollutant profiles of the old and new air pollution sources in order to deduce potential air pollutant changes to existing air quality in the region. Previous emission inventories are available for the Horsehead zinc smelter (EPA Toxic Release Inventory for 2008) 46. Although the proposed cracker facility’s engineering specifics are not available yet, using the records of a similar existing wet gas processing plant, we can approximate the proposed cracker’s yearly emissions. In this case, we have chosen the similarly sized Williams Olefins Cracker Facility currently operating in Geismar, La., whose emissions profiles for 2008 also were available 46. This plant, owned by Williams Partners, L.P., processes approximately 37,000 barrels of ethane and 3,000 barrels of propane per day and annually produces 1.35 billion pounds of ethylene.

Table 5 from PRETA HAPs report

In assessing the emission inventories at the two sites, we first sought to compare those pollutants that were common to both facilities. Table 5 (above) compares the annual release of criteria pollutants for which National Ambient Air Quality Standards (NAAQS) exist. These include ozone, sulfur dioxide, nitrogen oxides, particulate matter (PM10, PM2.5), lead, and carbon monoxide, for which health-based regulatory standards exist for their concentration in ambient air1. Not surprisingly, the zinc smelter released large amounts of lead into the air (five tons per year). The proposed ethane cracker, on the other hand, would release only trace amounts of lead into the air and about 0.1 percent of the sulfur dioxide, 3 percent of the carbon monoxide, and 50 percent of the nitrogen oxides of the zinc smelter. Overall, release of PM would be of a similar order of magnitude at the two sites. Thus, the representative cracker facility by itself emits less NAAQS criteria pollutants than the smelter facility.

Table 6 from PRETA HAPs report

Similarly, Table 6 (above) examines similarly reported HAPs released from both of the facilities in question. A comparison of available emissions inventories of HAPs reveals a list of common pollutants, including acrolein, benzene, ethylbenzene, xylene, and volatile organic compounds (VOCs). Note the projected increase in release of acrolein and VOCs by the proposed ethane cracker. The latter are a rather broad class of organic chemicals that have high vapor pressure (low boiling point), allowing appreciable concentrations in the air as a gaseous phase 47, 48. Examples of VOCs include formaldehyde, d-limonene, toluene, acetone, ethanol (ethyl alcohol), 2-propanol (isopropyl alcohol), and hexanal, among others. They are common components of paints, paint strippers, and other solvents; wood preservatives; aerosol sprays; cleansers and disinfectants; moth repellents and air fresheners; stored fuels and automotive products; hobby supplies; and dry-cleaned clothing. They also possess a diverse range of health effects, including, but not limited to, eye and throat irritation, nausea, headaches, nosebleeds, and skin rashes at low doses, and kidney, liver, and central nervous system damage at high doses. Some are known or suspected carcinogens. These chemicals are more often known for their role in indoor air pollution and have been linked to allergies and asthma 49. Recall that acrolein is already the primary driver of noncancer respiratory risk in the PRETA area, and releases from the proposed cracker would theoretically add to that burden.

Table 7 from PRETA HAPs Report 2013

Table 7 shows a compiled list of HAPs that were released from the Geismar plant in 2008 but not from the zinc smelter, highlighting the potential change in the pollutant mixture. For comparison, the pollutants highlighted in yellow represent those that are several orders of magnitude greater than those emitted by the Clairton Coke Works in 2008. Note the rather large emissions of formaldehyde and acetaldehyde that were discussed above as the number one and number five existing cancer drivers in the area.

Other VOCs of note include ethylene glycol, ethylene oxide, methyl-tert-butyl ether and propionaldehyde. While all these pollutants may have toxic effects on their own, one of the primary concerns, especially in outdoor air, should be their ability to form secondary pollutants. For example, we have noted previously that both acetaldehyde and formaldehyde can be formed via photo-oxidation reactions of other hydrocarbons and VOCs. Thus, the direct emissions reported in the table are likely to be significant underestimations of the true burden of acetaldehyde and formaldehyde in the area near the cracker. It also should be mentioned that a complex nonlinear sensitivity exists among VOCs, NOX, and the production rate of ozone (O3). Most urban areas are considered NOX saturated or VOC sensitive and therefore have low VOC/NOX ratios. In these environments, ozone actually decreases with increasing NOX and increases with increasing VOCs—a potentially likely situation within the urban areas of Southwestern Pennsylvania.

In conclusion, it would appear that the replacement of the existing zinc smelter with the proposed ethane cracker has the potential to significantly transform the current pollutant mixture in the region. The elimination of lead and other heavy metal emissions would be replaced by increases in formaldehyde and acetaldehyde. In addition, it does not appear that the proposed ethane cracker alone would increase any of the NAAQS criteria air pollutants, with the possible exception of ozone. On the other hand, the rather large releases of several known cancer drivers, such as formaldehyde and acetaldehyde, from the proposed cracker could increase cancer risk in the immediate proximity. In addition, the large influx of VOCs and fugitive emissions from these operations warrants further predictive analysis, especially with regard to current pollution-mitigating strategies that may not be anticipating a transforming pollutant mix.

Introduction of the ethane cracker & its effect on regional air quality in SW PA

Authors and Credits

University of Pittsburgh Graduate School of Public Health
Center for Healthy Environments and Communities
Pittsburgh, PA | August 2013

Authors

Drew Michanowicz, MPH, CPH
Kyle Ferrar, MPH
Samantha Malone, MPH, CPH
Matt Kelso, BA
Jill Kriesky, PhD
James P. Fabisiak, PhD

Technical Support

Department of Communications Services
Marygrace Reder, BA
Alison Butler, BA

Full HAPs Report (PDF) | Ozone (PDF) | Particulate Matter (PDF)
For questions related to the full report, please contact CHEC.

References Mentioned in Excerpt

43. Detrow , S. (2012). What’s an ethane cracker? StateImpact – Pennsylvania. Accessed 12-18-12: http://stateimpact.npr.org/pennsylvania/tag/ethane-cracker.

44. Kelso, M. (2012). Jobs impact of cracker facility likely exaggerated. FracTracker Alliance. Accessed 12-18-12: www.fractracker.org/2012/06/jobs-impact-of-cracker-facility-likely-exaggerated.

45. SCORECARD: The Pollution Information Site. (2002). Environmental Release Report: Zinc Corp. of America Monaca Smelter. Accessed 12-18-12: http://scorecard.goodguide.com/envreleases/facility.tcl?tri_id=15061ZNCCR300FR#major_chemical_releases.

46. U.S. EPA. (2008). Technology Transfer Network, Clearinghouse for Inventories and Emissions Factors The National Emissions Inventory. The National Emissions Inventory. Accessed 1-25-13: www.epa.gov/ttn/chief/net/2008inventory.html.

47. U.S. EPA. (2012). An Introduction to Indoor Air Quality (IAQ). Volatile Organic Compounds. Accessed 12-18-12: www.epa.gov/iaq/voc.html.

48. U.S. EPA. (2012). Volatile Organic Compounds (VOCs). Accessed 12-18-12: www.epa.gov/iaq/voc2.html.

49. Nielsen, G.D., S.T. Larsen, O. Olsen, M. Lovik , L.K. Poulsen, C. Glue , and P. Wolkoff. (2007). Do indoor chemicals promote development of airway allergy? Indoor Air 17: pp. 236–255.

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