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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.

View Map Fullscreen | How FracTracker Maps Work

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.

Leaking tank in Arvin

Arvin, CA Setback Ordinance Passes Unanimously!

The small city of Arvin, CA has succeeded in taking a brave step forward to protect the public health of its community.

On July 17, 2018 the Arvin City Council voted 3-0 (two members were absent) in support of a setback ordinance. This is the first California oil and gas ordinance that has an actual effect, as it is the first in a region where drilling and fracking are actively occurring. The Arvin, CA setback ordinance prevents wells from being drilled in residential or commercially-zoned spaces. Also, setback distances of 300 feet for new development and 600 feet for new drilling operations have been established for sensitive sites, such as parks, hospitals, and schools.

(To see where other local actions have been taken in California, check out our coverage of local actions and map, which was recently updated.)

More details and maps of the setback ordinance and its development can be found in the initial FracTracker coverage of the proposal, below:

The measure was supported by Arvin Mayor Jose Gurrola. He described the front-lines experience of Arvin citizens:

The road to the update has been difficult for this community. Eight Arvin families were evacuated after a toxic gas leak from an underground oilfield production pipeline located near their homes in 2014. Some have now been re-occupied by concerned residents with no other options; other homes still stand empty. Meanwhile, a short distance away an older pump jack labors day and night next to homes pumping oil mixed with water to a nearby tank. Despite multiple complaints to state agencies of odors and noise by the residents, they are told by the agencies that there is nothing that can be done under the current regulations. The pump jack continues to creak along as children walk nearby on their way to school, covering their faces as the smell occasionally drifts their direction. – Jose Gurrola, Mayor of the City of Arvin

Fugitive Emissions Monitoring

In anticipation of the city council’s vote, FracTracker collaborated with Earthworks and the grassroots organization Central California Environmental Justice Network to visit the urban well sites within the city limits. Using Infrared FLIR technology, the sites were assessed for fugitive emissions and leaks. Visualizing emissions of volatile organic compounds (VOCs) at these sites provides a glimpse to what the community living near these wells are continually exposed. The infrared cameras used in these videos are calibrated to the wavelengths of the infrared spectrum where VOC hydrocarbons of interest are visible.

The map below shows the locations that were visited, as indicated by the three stars. Videos of each site are shown below the map.

Map 1. Arvin Setback Ordinance and FLIR Videos

View map fullscreen | How FracTracker maps work

FLIR Videos and Findings

Sun Mountain Simpson-1 Lease

In this FLIR video of Sun Mountain Simpson-1, fugitive emissions are obvious. The emissions are coming from the PV vent at the top of the produced water tank. These emissions are a mixture of a variety of volatile organic compounds, such as BTEX compounds and methane. This well site is located between homes, a small apartment complex, and a playground. While on the ground operating the FLIR camera I felt light headed, dizzy, and developed a headache. The emissions were reported to the San Joaquin Valley Air District (SJVAD), who sampled and found VOC concentrations at dangerous levels. The well operator was notified but refused to respond. Unfortunately, because this particular well produces under 50 barrels of oil/day, the site is exempt from any health related emissions regulations.

Sun Mountain Jewett 1-23 Lease

This well site is located near a number of single family homes and next two a park. The well site is also on the future location of the Arvin Community College. The FLIR video below is particularly interesting because it shows fugitive emissions from four different locations. The leaks include one at the well head that is potentially underground, one on separator equipment, and leaks from each of the tank PV hatches. When regulators were notified, they visited the site and fixed two of the leaks immediately. Fugitive emissions from the PV hatches were not addressed because this site is also exempt from regulations.

ABA Energy Corporation Richards Facility Tank Farm

The Richards Facility Tank Farm is a well site located outside the city limits on farmland. The facility is regulated as a point source of air pollution, therefore enforcement action can require the operator to fix leaks even from PV hatches on tanks. This FLIR video shows leaks from PV hatches, and a major leak from a broken regulator valve. A complaint was submitted to the SJVAD, and the operator was required to replace the broken regulator valve.


By Kyle Ferrar, Western Program Coordinator

Feature Image: Leaking tank at the Simpson 1 well site, Photo by Kyle Ferrar | FracTracker Alliance, 2018.

LPA Pipeline protest - Crosshairs feature

In the Crosshairs

The Origins & Work of Lebanon Pipeline Awareness, Inc. in Lebanon County, PA
by Michael Schroeder, Lebanon Pipeline Awareness, Inc.
LPA Logo

Nestled in a mostly agricultural region blessed with some of the most fertile, non-irrigated farmland in the world, Lebanon County, Pennsylvania sits square in the crosshairs of a Pipeline Revolution – smack-dab in between the Marcellus Shale fracking zones in northern and western PA and the processing and export facilities of the Eastern seaboard. This Pipeline Revolution began in earnest more than four years ago, in spring 2014, when Williams/Transco announced plans to build a 200-mile, 42-inch diameter, high-pressure (1,480 p.s.i.) underground natural gas pipeline with the Orwellian-sounding name “Atlantic Sunrise” as a shortcut to whisk fracked natural gas to points south – mainly Cove Point just south of Baltimore – for export. See map below for more context.

That’s the north-south axis of the crosshairs. East-west, for starters, is the 8-inch diameter, cast-iron Mariner East pipeline, which has traversed the state since the late 1930s, carrying gasoline from the Philadelphia region to the Pittsburgh area. Also around spring 2014, Mariner East’s owner-operator, Sunoco Logistics, announced its Mariner East expansion project: to stop carrying gasoline, reverse the flow, and start streaming natural gas liquids (NGLs – mainly propane, ethane, and butane) from the fracking zones of western PA to the Marcus Hook export facility outside Philadelphia. Also planned were several new larger-volume pipelines to be laid in the same easement – Mariner East 2 and 2X – along with their corresponding pump stations.

The two major transmission pipeline projects cross on private land atop a forested hill in Lebanon County’s South Londonderry Township – making “in the crosshairs” an apt metaphor for where we stand in relation to the Pipeline Revolution.

In response to Williams/Transco’s announcement in spring 2014, activists in neighboring Lancaster County organized the grassroots citizens’ group Lancaster Against Pipelines. We soon followed suit, holding our first organizing meeting in April in humble surroundings, an artist’s loft in downtown Lebanon. After a democratic vote,we called ourselves Lebanon Against Pipelines and began meeting bi-weekly with a core group of 8-10 people.

LPA Organizing Meeting - Crosshairs

Initial organizing meeting of Lebanon Against Pipelines (soon changed to Lebanon Pipeline Awareness), downtown Lebanon, April 2014

By summer 2014, we adopted what we felt was a more positive and publicly acceptable name in our strongly conservative county, one more in keeping with our core mission of raising public awareness about the immensely destructive power of fracking and pipelines: Lebanon Pipeline Awareness.

Making Plans

Over the next year, a core leadership emerged. With the pro-bono help of a local attorney, we became a 501c(3) non-profit corporation with officers and a board of directors, making it possible to apply for much-needed grants after our meager, mostly self-funded beginnings.

Realizing the importance of strength in numbers, from the outset we reached out to collaborate with other groups. We’ve had many key allies in this fight, especially our sister organization, Concerned Citizens of Lebanon County (CCLC). Focused on Sunoco’s Mariner East projects, CCLC has focused mainly on the judicial system to challenge the absurd notion that this project merits status as a “public utility” – most notably by pursuing civil action against Sunoco for not obtaining the proper permits before building its new pump station in West Cornwall Township.

Bringing About Change

How have we worked to raise public awareness? In most every way we can think of, given our limited resources.

We still lack a website, but we have developed and curated a highly active Facebook presence (with nearly 800 “likes” at present). We’ve designed, printed, and distributed widely an attractive tri-fold brochure and our own eye-catching logo. We’ve set up tables at most every available community event (National Night Out in Campbelltown; Historic Old Annville Day; the Lebanon County Fair; and others). We’ve organized protests and demonstrations, often in tandem with Lancaster Against Pipelines and other allied groups. We have sponsored film screenings, public safety forums, speakers from allied organizations, and informational meetings for local landowners and other concerned citizens.

Public protest by LPA

Public protest with Lancaster Against Pipelines, Annville town square, December 2015

We’ve attended local municipal meetings to encourage local authorities to pass resolutions opposing the pipelines traversing their municipalities – in two cases successfully. We’ve filed dozens of Right-To-Know requests, developing a rich archive of construction violations and disseminating our findings publicly. We’ve brought our concerns to the county commissioners’ meetings, prompting them to write letters of concern to state and federal officials and add an informational “pipelines” tab to their website. We have developed a robust presence in local media outlets – issuing press releases and writing letters to the editor and op-ed pieces, and inviting reporters to the events we sponsor – including local newspapers (like the Lebanon Daily News), regional digital media platforms (like NPR’s StateImpact), local TV and radio stations, and more. We’ve even hosted a few tours for national photographers and reporters.

Working with Others

In our interactions with local governmental authorities, we consistently act respectfully and courteously and try hard not to blindside anyone. Before attending a public meeting, we’ll send a courtesy note to the relevant authority, detailing our concerns and summarizing what we’ll be saying and asking for. When speaking at public meetings, we’re civil, crisp, and respectful – though, when necessary, we have engaged in peaceful acts of public protest (like duct-taping our mouths shut when prevented from speaking at a township meeting because we’re not township residents).

We’ve also met with all of our state representatives, either in individual meetings or during town hall-style meetings with constituents. We’ve expressed our concerns to members of Governor Tom Wolf’s staff, his Pipeline Infrastructure Task Force and other Department of Environmental Protection officials, the Susquehanna River Basin Commission, the Federal Energy Regulatory Commission, and other public bodies.

Innovative Pipeline Monitoring Program

Pipeline monitor badge

Citizen pipeline monitoring badge

More recently, with pipeline construction well underway, we’ve developed a pipeline construction monitoring program, undergoing rigorous training and developing official badges to identify ourselves and our organization. We also register all of our monitors with the county commissioners’ office (to prevent imposters from engaging in nefarious acts in our name). (See badge, right)

And it’s made a difference.

I remember well our first outreach efforts in summer 2014 at events like National Night Out in Campbelltown, where we were met with a fair amount of open hostility. “Why do you oppose American energy independence?” people would ask.  “What about all the jobs the pipelines will bring to local workers?” After four years of respectfully but insistently hammering on these issues, the public tenor has shifted. Very rarely do we encounter outright hostility anymore. The public has grown increasingly receptive to our message – especially now that construction has begun and folks can see that what we’ve predicted is now coming to pass.

Respect and Reciprocity

We’ve worked very hard to cultivate a respectable public persona and reputation, and we’ve largely succeeded. As best as we can tell, the predominant public perception is that Lebanon Pipeline Awareness is run by a group of dedicated and well-informed volunteers with an important message to share. In fact, two of our leaders were singled out last year by the local newspaper for recognition as providing a positive impact for our community. Our core group, which generally meets twice a month, has expanded to include upwards of 15 committed local activists.

We’ve also worked hard to always couple our anti-pipeline message with a positive message about renewable energy – repeatedly emphasizing that wind, solar, geothermal, and other green energies represent an increasingly viable alternative for energy and for jobs.

In It for the Long Haul

So that’s where we in Lebanon Pipeline Awareness stand at the beginning of our fifth year. Because we have every reason to expect this insane pipeline buildout to intensify, we know we’re in it for the long haul. Our goals for the coming year are to expand our membership; build on and extend our alliances even further; intensify our outreach efforts and our pipeline construction monitoring program; and continue to host public meetings for concerned property owners and citizens.

CHISPA Flyer

CHISPA Flyer – Click to enlarge

We also plan to expand our activities to include direct action campaigns like CHISPA – “Challenge in the Streets to Pipelines in PA” – where every Friday afternoon from 4-6 p.m. we’ll be lining five miles of westbound Route 422 from Lebanon to Annville with volunteers bearing provocative protest signs that challenge the thousands of passing motorists to think in fresh ways about issues like climate change, jobs, eminent domain, property rights, renewable energies, and more.

Lebanon Pipeline Awareness is but one of dozens of grassroots citizens’ organizations that have emerged across Pennsylvania over the past decade to resist the Fracking and Pipeline revolutions and insist that we follow “a better path” (the name of an emergent coalition of anti-fracking and anti-pipeline groups from across Pennsylvania). We have lost many battles against our vastly more deep-pocketed and powerful adversaries, but we’ve also made a substantial and positive difference.

Will we win the war? Yes, eventually, as global climate disruption makes increasingly clear that our most pressing need as a species is to leave the remaining stocks of fossil fuels in the ground. In the meantime, win or lose, our efforts continue – and will continue as long as these insane Fracking and Pipeline revolutions continue to imperil humankind and the web of life that sustains us all.


by Michael Schroeder, Vice President, Lebanon Pipeline Awareness, Annville, Pennsylvania

Susquehanna River Basin map article #2

Violations and Monitoring in Pennsylvania’s Susquehanna River Basin

The Susquehanna River is a 444-mile long waterway extending from the area around Cooperstown, New York to the Chesapeake Bay. In Pennsylvania, the basin includes more than 37,000 miles of streams that feed into the river, which capture the precipitation of more than 20,000 square miles of land, and is home to over 3.3 million people.

The region has been heavily impacted by oil and natural gas extraction in recent years; more than 5,500 unconventional wells and roughly 13,500 conventional wells have been drilled in the PA segment of the basin since 2000. Unconventional wells, in particular, have brought industrial-scaled activity, pollution, and waste products to a wide area of the basin, with especially heavy development occurring in three counties along Pennsylvania’s northern tier – Bradford, Susquehanna, and Tioga.

Several governmental agencies are involved with monitoring impacts to this massive watershed. This article focuses on the Pennsylvania portion of the basin, and examines how capable agency-run monitoring efforts are in capturing oil and gas (O&G) related pollution events. The Pennsylvania Department of Environmental Protection (DEP), the US Geological Survey (USGS), and the Susquehanna River Basin Commission (SRBC) maintain a combined network of 274 monthly “grab sample” monitoring sites and 58 continuous data loggers in the Pennsylvania portion of the river basin. Meanwhile, between January 1, 2000 and February 7, 2017, the DEP logged 6,522 on the O&G violations compliance report within the same region. More than three out of every four of these violations have been assessed to unconventional wells, even though only one out of every four active wells in the basin is categorized as such.

Map of O&G Monitoring & Violations in PA’s Susquehanna River Basin


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Limitations of Monitoring Efforts

Grab samples obtained from official monitoring locations are the preferred method for regulatory purposes in understanding the long-term health of the river system. Researchers can test for any number of analytes from samples that are collected in-stream, but analyzed in certified laboratories. However, samples from these locations are collected periodically – usually once per month – and therefore are very likely to miss the effects of a significant spill or issue that may impact surface water chemistry for a number of hours or days before being diluted and washing downstream.

Continuous data loggers give regulators a near real-time assessment of what is happening in selected points in the basin, usually at 15-minute intervals. While there are numerous events that contribute to fluctuations in these measurements, these data loggers would be the most likely instruments available to register an event impacting the surface water within the basin. However, there are unique issues with data loggers. For instance, available data from these data loggers are much more limited in scope, as temperature, pH, and conductivity are typically the only available analytes. In addition, because the analysis occurs on site, the results carry less weight than laboratory results would. Finally, even though data loggers collect data at rapid intervals, only some are equipped to send data real-time to agency offices. Some data loggers must be manually collected on a periodic basis by program managers.

Perhaps the greatest challenge for monitoring in the Susquehanna River Basin is that it is simply not practical to monitor in all places likely to be impacted by oil and gas operations. Testing within the jurisdiction of the Susquehanna River Basin is actually fairly extensive when compared to other regions, such as the Ohio River Basin. The Ohio River Valley Water Sanitation Commission – the equivalent of the SRBC for the Ohio River Basin – only monitors basic analytes like total dissolved solids at 29 locations, all at or near the main stem of the river. However, none of the agencies monitoring water quality in the Susquehanna River Basin have capacity to test everywhere. On average, there is one testing location for every 111 miles of rivers and streams within the basin.

Case Studies

If agency-based monitoring is so limited, then the important question is: How well do these efforts capture oil and gas-related impacts? Some violations are more likely to impact surface water quality than others. This article takes a closer look at some of the bigger problem areas within the basin, including the Dimock region in Susquehanna County, Leroy Township in Bradford County, and Bell Township in Clearfield County.

Dimock

Map of O&G violations and water monitoring near Dimock, PA

O&G violations and water monitoring near Dimock, PA. Note that multiple violations can occur at the same location. Click to expand map.

The highest concentration of oil and gas violations in the Susquehanna Basin is located in the townships of Dimock and Springville, in Susquehanna County, PA, with a total of 591 incidents reported on the compliance report. This makes the region the highest concentration of O&G violations in the entire state. Many of these violations are related to the systemic failure of well integrity, resulting in the contamination of numerous groundwater supplies. In terms of how these might affect surface water, 443 of the violations are in areas that drain into the Thomas Creek-Meshoppen Creek subwatershed by the southern edge of Springville Township, while most of the rest of the violations drain into the parallel West Branch of Meshoppen Creek.

The USGS operates a monthly monitoring location in the middle of the cluster of violations, at the confluence of Burdick and Meshoppen creeks, just north of the Dimock’s southern border. While this location might seem ideal at first, only 180 of the 443 violations in the subwatershed are upstream of the grab sample site. There is another water monitoring location that captures all of these violations in the Meshoppen subwatershed, but it is more than 15 miles downstream. (link to EJ article about Dimock)

Leroy Township

Map of O&G Violations and monitoring near Leroy Township, PA

O&G Violations and monitoring near Leroy Township, PA. Click to expand map.

Compared to the huge amount of oil and gas violations throughout the Dimock area, Leroy Township in Bradford County looks relatively quiet. It also appears to be well covered by monitoring locations, including a data logger site near the western edge of the township, a centrally located monthly monitoring location, as well as another monthly grab sample site upstream on Towanda Creek, just beyond the eastern boundary in Franklin Township.

And yet, this area was hit hard in the early part of the decade by two significant spills. On April 19, 2011, Chesapeake Appalachia lost control of the Atlas 2H well, with thousands of gallons of flowback fluid spilling onto the countryside and into the nearby Towanda Creek.

A little over a year later on July 4, 2012, a second major spill in the township saw 4,700 gallons of hydrochloric acid hit the ground. According to the DEP compliance report, this did not make it into the waterways, despite the gas well being located only about 550 feet from Towanda Creek, and less than 300 feet from another unnamed tributary.

Both incidents were within a reasonable distance of downstream monitoring locations. However, as these are grab sample sites that collect data once per month, they can only offer a limited insight into how Towanda Creek and its tributaries were impacted by these notable O&G related spills.

Bell Township

Map of O&G violations and monitoring near Bell Township, PA. Susquehanna River Basin project

O&G violations and monitoring near Bell Township, PA. Click to expand map.

Bell Township is a small community in Clearfield County along the banks of the West Branch Susquehanna River. The northwestern portion of the township ultimately drains to the Ohio River, but all of the violations in Bell Township are within the Susquehanna River Basin.

Two significant incidents occurred in the township in 2016. On February 18, 2016, Alliance Petroleum Corp lost control of the McGee 11 OG Well, located less than 250 feet from Deer Run. According to the oil and gas compliance report, control of the well was regained five days later, after releasing unspecified quantities of gas, produced fluid, and crude oil. On December 5th of the same year, Exco Resources was cited for allowing 30 barrels (1,260 gallons) of produced fluid to spill at the Clyde Muth M-631 Wellpad in Bell Township.

A United States Geological Survey monthly monitoring location along the West Branch Susquehanna in nearby Greenwood Township is upstream, and could capture the effects of spills throughout much of Bell Township. However, the incident at the Clyde Muth well pad occurred in the Curry Run subwatershed, which meets up with the West Branch Susquehanna downstream of the monitoring location, so any pollution events in that area will not be reflected by monitoring efforts.

Conclusions

In the case of Dimock and Springville townships, we see how official water monitoring efforts capture only a fraction of the notorious cluster of wells that have resulted in hundreds of violations over the past decade. There could scarcely be a better candidate for systematic observation, and yet only a single grab sample site covers the immediate vicinity. Leroy Township does not have the same quantity of impacts as Dimock, but it did see one the worst blowouts in the recent history of O&G operations in Pennsylvania. The area is relatively well covered by grab samples sites, but due to the monthly sampling schedule, these locations would still be unlikely to capture significant changes in water quality. In Bell Township, much of the area is upstream of a monthly grab sample site, but the nearest downstream monitoring location to a major spill of produced fluid that occurred here is more than 17 miles away from the incident as the crow flies.

It should be noted that there are a number of industries and activities that contribute to water pollution in Pennsylvania, and as a result, the monitoring efforts are not specifically designed to capture oil and gas impacts. However, the compliance record shows heavy impacts from oil and gas wells in the basin, particularly from modern unconventional wells.

While the network of government-operated manual monitoring locations and data logger sites are fairly extensive in Susquehanna River Basin, these efforts are not sufficient to capture the full extent of oil and gas impacts in the region. Finding evidence of a small to medium sized spill at a site with monthly testing is unlikely, as contaminated water doesn’t stay in place in a dynamic river system. Data loggers also have a limited capacity, but are a useful tool for identifying substantial changes in water chemistry, and could therefore be employed to identify the presence of substantial spills. As such, it might be beneficial for additional data loggers to be distributed throughout the basin, particularly in areas that are heavily affected by the oil and gas industry. Furthermore, given resource gaps and staff cuts within agencies tasked with protecting the river basin, agencies should strongly consider utilizing networks of volunteers to augment their limited monitoring networks.

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

For the Susquehanna River Basin Impacts Project

An Introduction to the Susquehanna River Basin Impacts Project

By the FracTracker Alliance
In partnership with the Pennsylvania Chapter of the Sierra Club
and Clean Water Action 

Looking at a map of Pennsylvania, three major rivers span the Commonwealth — the Ohio River in the West, the Susquehanna River in the middle of PA, and the Delaware River in the East. The Delaware River Watershed benefits from the active oversight and management of the Delaware River Basin Commission (DRBC) and the Ohio is managed by Ohio River Valley Water Sanitation Commission (ORSANCO). The multi-state effort to protect the Susquehanna River is known as the Susquehanna River Basin Commission (SRBC).

These agencies differ greatly in how they oversee protections of their respective watersheds, particularly in the context of oil and gas development. For instance, the DRBC engages in a range of activities related to water quantity protection (like water supply allocation and water conservation), water quality, regulatory review and permitting, watershed-wide planning, flood mitigation and drought management, and recreational activities. Meanwhile, ORSANCO and the SRBC interpret their responsibilities very narrowly, primarily focusing on managing issues related to discharge standards in the case of ORSANCO, and water quantity in the case of the SRBC.

Major watershed boundaries in PA, with the Susquehanna River Basin shown in pale green. Source DCNR

In this new series of articles, FracTracker Alliance, in partnership with the Sierra Club Pennsylvania Chapter and Clean Water Action, takes a closer look at the Susquehanna River Watershed and its many challenges related to industrial development, including deforestation and sedimentation issues, nutrient loading from poor agricultural practices, sewer and stormwater runoff. A significant component of Susquehanna River Basin impacts can be attributed to expanding oil and gas development. How will the Susquehanna River Watershed withstand future impacts from the oil and gas industry given the SRBC’s limited oversight? A first step in understanding the problem is to look at the state of the watershed today.

Oil & Gas in the Susquehanna River Watershed

As part of the ongoing Marcellus Shale oil and gas boom, nearly 5,500 unconventional wells on roughly 2,000 well pads have been drilled in the Susquehanna River Watershed since 2007. According to the Nature Conservancy, shale gas companies could drill 27,600 additional wells in the Susquehanna River basin by 2030, which would result in approximately 6,900 well pads (assuming four wells per pad, a relatively conservative number given recent trends where up to a dozen wells are being drilled on a single pad). These additional 4,900 well pads represent 31,850 acres of disturbed lands for the pads and access roads alone. Overall, the Nature Conservancy believes that up to 110,000 acres of forested land could be cleared in the Susquehanna River Watershed by 2030. In addition to well pads and access roads, one must also account for the impacts of associated pipelines. Estimates suggest that 12-15 acres of gathering line are installed per acre of well pad.

This explosive growth of the shale drilling industry, combined with declining resources for regulatory oversight, would complicate regional watershed management strategies. A growing body of evidence suggests that watersheds near hydraulic fracturing operations can be impacted by improper waste disposal, trucking accidents, migration of drilling fluids, as well as problems related to land disturbance such as pipeline and access road stream crossings, sedimentation and runoff (needs a reference). And while there are two major water monitoring programs operating in the Susquehanna River, one run by the Pennsylvania Department of Environmental Protection (PA DEP) and the other operated by the SRBC, significant questions remain about their ability to assess the Susquehanna River’s water quality. These concerns primarily stem from the infrequent and patchwork-like coverage of their sampling regimes, as well as inconsistencies in indicators measured at different sites.

Existing Water Monitoring Efforts

Watershed testing is key to understanding how industrial development affects water quality. It also significantly informs mitigation strategies. In this first map of the series (below), we have put together several layers to help illustrate the state of water testing in the Susquehanna River Basin. This map can be used to obtain summary information about unconventional oil and gas activity and monitoring efforts at the watershed level by clicking on individual features.

Note that there are two separate layers on this map depicting summary data — one outlined in dark green and one in light green, both at HUC-08 level. The dark green outlines are in PA only and contain oil and gas summaries of wells and violations. The light green outlines show agency-based monitoring activity, and are not restricted to PA boundaries. The reason for the two layers is that states classify oil and gas wells differently and so cannot be combined easily.

View map fullscreenHow FracTracker maps work

The Susquehanna River Basin has over 49,000 miles of waterways, according to the SRBC. While it may not be possible to fully document the impacts that the oil and gas industry has on the basin, there are some efforts underway to chronicle changes to the river system. In this map, we look at the efforts of governmental and quasi-governmental agencies to test the waters throughout the region, which range from periodic grab samples to automated data loggers that constantly evaluate several measures of water quality. There are advantages to both methods, as data loggers can capture short term spikes in conductivity, for example, that monthly sampling would likely miss altogether. However, grab sampling allows for a more in-depth analysis of the water in a laboratory than what the data loggers can provide.

While oil and gas is the focus of the map, it is not the only concern of the SRBC. Thus, considerable testing occurs in areas that are not seeing drilling activity. The drilling regions are shown on the map as a great orange arc, extending from Indiana County in the west-central part of Pennsylvania all the way to Susquehanna county in the Northern Tier. If you zoom in on this region, data for individual unconventional wells will become visible, along with permits for wells that have yet to be been drilled, and violations that have been issued by DEP.

Clusters of Development and Oversight

In some regions of the Susquehanna basin, there are significant clusters of oil and gas activity without a corresponding governmental monitoring regimen. Other areas have significant monitoring coverage. In many cases, periodic grab samples are taken from the same sites as data loggers – and may therefore appear twice on our map – to capture both aspects of monitoring activity. Our map can be used to find quick summary data for a given watershed.  For example, the Upper Susquehanna-Tunkhannock watershed is being monitored with 53 testing sites and nine data loggers. The same region has 2,178 wells, and 2,347 violations associated with these wells.

We can also use the map to focus on concerns at different scales. The cluster of drilling activity in Ulysses Township, seen below, resulted in a number of violations (shown in yellow). Due to historical impact of the oil and gas industry in this sub-watershed, additional monitoring locations might be called for.

While we think that it is important to protect all the Susquehanna’s waters, certain areas are more fragile than others. For instance, headwater streams that are designated as high quality (HQ) or exceptional value (EV) are vital to the overall health of the river system and their protection is required by Pennsylvania law. However, many headwaters streams have no monitoring despite heavy oil and gas drilling, as can be seen in the below map. We have included HQ/EV designated streams on the map, although due to the large amount of data these streams are not displayed by default. They can be seen by activating the layer.

Broader Implications

The Susquehanna River provides drinking water to 4.1 million people, including residents in New York, Pennsylvania, and Maryland. In addition, through water that is diverted to areas outside the watershed, it is estimated that the Susquehanna also serves as a drinking water supply for 2 million people in more populated areas such as Baltimore, MD and Chester County, PA. With clean drinking water hanging in the balance, and the potential build-out of thousands more natural gas well pads in the watershed, it is more important than ever to understand how oil and gas activity could affect the watershed.

The Pennsylvania Constitution reminds us of our right to clean air, pure water, and the preservation of the environment. Prior to the adoption of the Environmental Rights Amendment — 80 years ago this year — and long before the federal Clean Water Act, the Pennsylvania legislature passed the state level Clean Streams Law in recognition of the need to protect the integrity of our valuable aquatic resources. In the spirit of this tradition to lead on clean water issues, the SRBC, Pennsylvania, and surrounding states must commit to putting the protection and preservation of the Susquehanna River watershed at the forefront of decision-making within the basin.

In future installments of this series, we seek to reveal gaps in watershed and land management plans in order to evaluate what these risks mean for the people and environments of the Susquehanna River Basin. The mapping and analysis provided in this series will be used to frame a series of conversations throughout the Basin with the goal of encouraging concerned residents to become more involved in public discussions about watershed management planning. Further, this project will result in recommendations for tangible solutions to filling oversight and management gaps and communicate these findings to relevant agencies. Only with adequate information can the public ensure strong protections for this life-sustaining waterway. Recognizing the important work that the SRBC has done in recent years, we also hope to identify areas where the Commission can direct additional resources to analyzing the cumulative impacts of shale gas development and expand their oversight strategies.

Top: fair use image by Nicholas A. Tonelli

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