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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.

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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.

Map of pipeline incidents across the US

Pipeline Incidents Continue to Impact Residents

Pipelines play a major role in the oil and gas extraction industry, allowing for the transport of hydrocarbons from well sites to a variety of infrastructure, including processing plants, petrochemical facilities, power generation plants, and ultimately consumers. There are more than 2.7 million miles of natural gas and hazardous liquid pipelines in the United States, or more than 11 times the distance from Earth to the moon.

With all of this infrastructure in place, pipelines are inevitably routed close to homes, schools, and other culturally or ecologically important locations. But how safe are pipelines, really? While they are typically buried underground and out of sight, many residents are concerned about the constant passage of volatile materials through these pipes in close proximity to these areas, with persistent but often unstated possibility that something might go wrong some day.

Safety talking points

In an attempt to assuage these fears, industry representatives and regulators tend to throw around variants of the word “safe” quite a bit:

Pipelines are the safest and most reliable means of transporting the nation’s energy products.
— Keith Coyle, Marcellus Shale Coalition

Although pipelines exist in all fifty states, most of us are unaware that this vast network even exists. This is due to the strong safety record of pipelines and the fact that most of them are located underground. Installing pipelines underground protects them from damage and helps protect our communities as well.
— Pipeline and Hazardous Materials Safety Administration (PHMSA)

Pipelines are an extremely safe way to transport energy across the country.
Pipeline 101

Knowing how important pipelines are to everyday living is a big reason why we as pipeline operators strive to keep them safe. Pipelines themselves are one of the safest ways to transport energy with a barrel of crude oil or petroleum product reaching its destination safely by pipeline 99.999% of the time.
American Petroleum Institute

But are pipelines really safe?

Given these talking points, the general public can be excused for being under the impression that pipelines are no big deal. However, PHMSA keeps records on pipeline incidents in the US, and the cumulative impact of these events is staggering. These incidents are broken into three separate reports:

  1. Gas Distribution (lines that take gas to residents and other consumers),
  2. Gas Transmission & Gathering (collectively bringing gas from well sites to processing facilities and distant markets), and
  3. Hazardous Liquids (including crude oil, refined petroleum products, and natural gas liquids).

Below in Table 1 is a summary of pipeline incident data from 2010 through mid-November of this year. Of note: Some details from recent events are still pending, and are therefore not yet reflected in these reports.

Table 1: Summary of pipeline incidents from 1/1/2010 through 11/14/2018

Report Incidents Injuries Fatalities Evacuees Fires Explosions Damages ($)
Gas Distribution 934 473 92 18,467 576 226 381,705,567
Gas Transmission & Gathering 1,069 99 24 8,614 121 51 1,107,988,837
Hazardous Liquids 3,509 24 10 2,471 111 14 2,606,014,109
Totals 5,512 596 126 29,552 808 291 4,095,708,513

Based on this data, on average each day in the US 1.7 pipeline incidents are reported (a number in line with our previous analyses), requiring 9 people to be evacuated, and causing almost $1.3 million in property damage. A pipeline catches fire every 4 days and results in an explosion every 11 days. These incidents result in an injury every 5 days, on average, and a fatality every 26 days.

Data shortcomings

While the PHMSA datasets are extremely thorough, they do have some limitations. Unfortunately, in some cases, these limitations tend to minimize our understanding of the true impacts. A notable recent example is a series of explosions and fires on September 13, 2018 in the towns of Lawrence, Andover, and North Andover, in the Merrimack Valley region of Massachusetts. Cumulatively, these incidents resulted in the death of a young man and the injuries to 25 other people. There were 60-80 structure fires, according to early reports, as gas distribution lines became over-pressurized.

The preliminary PHMSA report lists all of these Massachusetts fires as a single event, so it is counted as one fire and one explosion in Table 1. As of the November 14 download of the data, property damage has not been calculated, and is listed as $0. The number of evacuees in the report also stands at zero. This serves as a reminder that analysis of the oil and gas industry can only be as good as the available data, and relying on operators to accurately self-report the full extent of the impacts is a somewhat dubious practice.



View map fullscreen | How FracTracker maps work
This map shows pipeline incidents in the US from 1/1/2010 through 11/14/2018. Source: PHMSA. One record without coordinates was discarded, and 10 records had missing decimal points or negative (-) signs added to the longitude values. A few obvious errors remain, such as a 2012 incident near Winnipeg that should be in Texas, but we are not in a position to guess at the correct latitude and longitude values for each of the 5,512 incidents.

Another recent incident occurred in Center Township, a small community in Beaver County, Pennsylvania near Aliquippa on September 10, 2018. According to the PHMSA Gas Transmission & Gathering report, this incident on the brand new Revolution gathering line caused over $7 million in damage, destroying a house and multiple vehicles, and required 49 people to evacuate. The incident was indicated as a fire, but not an explosion. However, reporting by local media station WPXI quoted this description from a neighbor:

A major explosion, I thought it was a plane crash honestly. My wife and I jumped out of bed and it was just like a light. It looked like daylight. It was a ball of flame like I’ve never seen before.

From the standpoint of the data, this error is not particularly egregious. On the other hand, it does serve to falsely represent the overall safety of the system, at least if we consider explosions to be more hazardous than fires.

Big picture findings

Comparing the three reports against one another, we can see that the majority of incidents (64%) and damages (also 64%) are caused by hazardous liquids pipelines, even though the liquids account for less than 8% of the total mileage of the network. In all of the other categories, however, gas distribution lines account for more than half of the cumulative damage, including injuries (79%), deaths (73%), evacuees (62%), fires (71%), and explosions (78%). This is perhaps due to the vast network (more than 2.2 million miles) of gas distribution mains and service lines, as well as their nature of taking these hazardous products directly into populated areas. Comparatively, transmission and hazardous liquids lines ostensibly attempt to avoid those locations.

Is the age of the pipeline a factor in incidents?

Among the available attributes in the incident datasets is a field indicating the year the pipeline was installed. While this data point is not always completed, there is enough of a sample size to look for trends in the data. We determined the age of the pipe by subtracting the year the pipe was installed from the year of the incident, eliminating nonsensical values that were created when the pipeline age was not provided. In the following section, we will look at two tables for each of the three reports. The first table shows the cause of the failure compared to the average age, and the second breaks down results by the content that the pipe was carrying. We’ll also include a histogram of the pipe age, so we can get a sense of how representative the average age actually is within the sample.

A. Gas distribution

Each table shows some fluctuation in the average age of pipeline incidents depending on other variables, although the variation in the product contained in the pipe (Table 3) are minor, and may be due to relatively small sample sizes in some of the categories. When examining the nature of the failure in relation to the age of the pipe (Table 2), it does make sense that incidents involving corrosion would be more likely to afflict older pipelines, (although again, the number of incidents in this category is relatively small). On average, distribution pipeline incidents occur on pipes that are 33 years old.

When we look at the histogram (Figure 1) for the overall distribution of the age of the pipeline, we see that those in the first bin, representing routes under 10 years of age, are actually the most frequent. In fact, the overall trend, excepting those in the 40 t0 50 year old bin, is that the older the pipeline, the fewer the number of incidents. This may reflect the massive scale of pipeline construction in recent decades, or perhaps pipeline safety protocol has regressed over time.

Pipeline incidents charting

Figure 1. Age of pipeline histogram for gas distribution line incidents between 1/1/2010 and 11/14/2018. Incidents where the age of the pipe is unknown are excluded.

B. Gas Transmission & Gathering

Transmission & Gathering line incidents occur on pipelines routes that are, on average, five years older than their distribution counterparts. Corrosion, natural force damage, and material failures on pipes and welds occur on pipelines with an average age above the overall mean, while excavation and “other outside force” incidents tend to occur on newer pipes (Table 4). The latter category would include things like being struck by vehicles, damaged in wildfires, or vandalism. The contents of the pipe does not seem to have any significant correlation with the age of the pipe when we take sample size into consideration (Table 5).

The histogram (Figure 2) for the age of pipes on transmission & gathering line incidents below shows a more normal distribution, with the noticeable exception of the first bin (0 to 10 years old) ranking second in frequency to the fifth bin (40 to 50 years old).

It is worth mentioning that, “PHMSA estimates that only about 5% of gas gathering pipelines are currently subject to PHMSA pipeline safety regulations.” My correspondence with the agency verified that the remainder is not factored into their pipeline mileage or incident reports in any fashion. Therefore, we should not consider the PHMSA data to completely represent the extent of the gathering line network or incidents that occur on those routes.

Pipeline incidents chart

Figure 2. Age of pipeline histogram for transmission & gathering line incidents between 1/1/2010 and 11/14/2018. Incidents where the age of the pipe is unknown are excluded.

C. Hazardous Liquids

The average incident on hazardous liquid lines occurs on pipelines that are 27 years old, which is 6 years younger than for distribution incidents, and 11 years younger than their transmission & gathering counterparts. This appears to be heavily skewed by the equipment failure and incorrect operation categories, both of which occur on pipes averaging 15 years old, and both with substantial numbers of incidents. On the other hand, excavation damage, corrosion, and material/weld failures tend to occur on pipes that are at least 40 years old (Table 6).

In terms of content, pipelines carrying carbon dioxide happen on pipes that average just 11 years old, although there are not enough of these incidents to account for the overall departure from the other two datasets (Table 7).

The overall shape of the histogram (Figure 3) is similar to that of transmission & gathering line incidents, except that the first bin (0 to 10 years old) is by far the most frequent, with more than 3 and a half times as many incidents as the next closest bin (4o to 50 years old). Operators of new hazardous liquid routes are failing at an alarming rate. In descending order, these incidents are blamed on equipment failure (61%), incorrect operation (21%), and corrosion (7%), followed by smaller amounts in other categories. The data indicate that pipelines installed in previous decades were not subject to this degree of failure.

Pipeline incidents charting

Figure 3. Age of pipeline histogram for hazardous liquid line incidents between 1/1/2010 and 11/14/2018. Incidents where the age of the pipe is unknown are excluded.

Conclusions

When evaluating quotes, like those listed above, that portray pipelines as a safe way of transporting hydrocarbons, it’s worth taking a closer look at what they are saying.

Are pipelines the safest way of transporting our nation’s energy products? This presupposes that our energy must be met with liquid or gaseous fossil fuels. Certainly, crude shipments by rail and other modes of transport are also concerning, but movements of solar panels and wind turbines are far less risky.

Does the industry have the “strong safety record” that PHMSA proclaims? Here, we have to grapple with the fact that the word “safety” is inherently subjective, and the agency’s own data could certainly argue that the industry is falling short of reasonable safety benchmarks.

And what about the claim that barrels of oil or petroleum products reach their destination “99.999% of the time? First, it’s worth noting that this claim excludes gas pipelines, which account for 92% of the pipelines, even before considering that PHMSA only has records on about 5% of gas gathering lines in their pipeline mileage calculations. But more to the point, while a 99.999% success rate sounds fantastic, in this context, it isn’t good enough, as this means that one barrel in every 100,000 will spill.

For example, the Dakota Access Pipeline has a daily capacity of 470,000 barrels per day (bpd). In an average year, we can expect 1,715 barrels (72,030 gallons) to fail to reach its destination, and indeed, there are numerous spills reported in the course of routine operation on the route. The 590,000 bpd Keystone pipeline leaked 9,700 barrels (407,400 gallons) late last year in South Dakota, or what we might expect from four and a half years of normal operation, given the o.001% failure rate. In all, PHMSA’s hazardous liquid report lists 712,763 barrels (29.9 million gallons) were unintentionally released, while an additional 328,074 barrels (13.8 million gallons) were intentionally released in this time period. Of this, 284,887 barrels (12 million gallons) were recovered, meaning 755,950 barrels (31.7 million gallons) were not.

Beyond that, we must wonder whether the recent spate of pipeline incidents in new routes is a trend that can be corrected. Between the three reports, 1,283 out of the 3,853 (32%) incidents occurred in pipelines that were 10 years old or younger (where the year the pipeline’s age is known). A large number of these incidents are unforced errors, due to poor quality equipment or operator error.

One wonders why regulators are allowing such shoddy workmanship to repeatedly occur on their watch.


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

Virtual Pipelines - Potential Routes to Cayuga

Virtual pipelines: Convenient for Industry, a Burden on Communities

As the natural gas industry faces harsher and more widespread critiques from environmentalists and citizens, pipeline projects are facing delays, fines, and defeat. Aside from the questionable economics behind transporting gas and oil by pipeline, there are broad economic risks associated with pipeline accidents. With an increasing list of pipeline-related accidents in the public eye, including the two this past summer in Texas and Kansas, blasts this fall in Beaver County, PA, and in Boston, MA, scrutiny of new pipeline projects is on the uptick.

That being said, what is the alternative?

Virtual Pipelines?

Virtual Pipeline - Oil and gas truck

Loaded CNG transport vehicle

Industry, not deterred by resistance from regulators and environmentalists, has developed a new work-around method to get their product to market. Rather than build pipelines across rugged, remote, or highly-populated terrain, a new “solution” called “virtual pipelines” has come on the scene, with roots in New England in 2011.

The term “virtual pipeline,” itself, is so new that it is trademarked by Xpress Natural Gas (XNG), Boston, MA. XNG and other virtual pipeline companies use specially-designed tanker trucks to move compressed natural gas (CNG) or liquefied natural gas (LNG) via our public roads and highways. CNG in this system is under very high pressure — up to 3,600 psi when tank trailers are full. Rail and barge shipments are also considered part of the system, and trailers are designed to be easily loaded onto train cars or boats.

For the gas industry, virtual pipelines can be used in locales where gas is only needed for a limited time period, the pipeline network is not developed, or opposition by landowners is too contentious to make eminent domain an option, among other issues. These virtual pipeline trucks are identifiable by the hazard class 2.1 placard they carry: 1971, indicative of flammable, compressed natural gas or methane.

Restricted only by permissible weight limits on roads (up to 80,000 pounds or more), 5-axle trucks may make in excess of 100 round trips a day from the fueling location to their destination — sometimes hundreds of miles away. These trucks, which may travel alone or in caravans, are identifiable by the hazard class 2.1 placard they carry: 1971, indicative of flammable, compressed natural gas or methane. Manufacturers of these virtual pipeline rigs tout the safety considerations that go into their engineered design. These considerations include special pressure monitoring for the dozens of tanks and super-strength materials to protect against ruptures.

Specialized equipment has been created to load compressed gas tanks into the trailers that will carry them to their destinations. Here’s a promotional video from Quantum:

Loading CNG into specialized trailers for transport

Impacts on Communities

Following New York State’s rejection of the Constitution Pipeline in 2016 based on water quality concerns, industry has been looking for ways to move natural gas from Pennsylvania’s Marcellus gas fields to the Iroquois Pipeline. The current strategy is to load the gas in canisters from a special compressor facility, and re-inject the gas to a pipeline at the journey’s endpoint. The extent to which virtual pipelines may be utilized in New York State and New England is not well known, but the natural gas industry does speak in sanguine terms about this strategy as a solution to many of its transportation issues.

Citizen blogger/activist Bill Huston has compiled a list accidents that have occurred with CNG transport trucks along the virtual pipeline that runs from a “mother station” at Forest Lake, PA to Manheim, NY, near the Iroquois pipeline. While there have been no explosions or loss of life as a result of these accidents, there are a number of reported incidents of trucks tipping or rolling over, sliding off the road, or spontaneously venting.

To move CNG from “Point A” to “Point B,” truck traffic through populated areas is unavoidable. In central New York, public outcry about virtual pipelines is rising, due in large part to the safety issues associated with increased truck traffic on state highways. In rural New York, state highways run through towns, villages, and cities. They are not separated from population centers in the way that interstate highways typically are. Traffic from CNG transport trucks clogs roadways, in some cases burdening the pass-through communities with 100 or more tractor trailers a day. Routes pass directly in front of schools and health care facilities.

In short, virtual pipelines present a public safety hazard that has yet to be addressed.

Virtual Pipelines and the Cayuga Power Plant 

In Lansing, NY, there is an inefficient and economically-beleaguered power plant, currently run on coal, that the power utility would prefer to see shut down. The Cayuga Power Plant was cited in 2016 for exceeding mercury emissions by nearly 2000%. Its inherently inefficient design makes it a significant greenhouse gas contributor. Years ago, it provided considerable tax benefits to its host community of Lansing, and as such has some lingering support. After both a devastating fire in one stack and mechanical failure in another, the plant has been barely running for the past 3 or 4 years. It is currently used as a “peaker plant“, operating only during periods of excessive demand on the electric grid, during summer months.

New York State’s Governor, Andrew Cuomo, has stated that all coal-power plants will be shut down by 2020.

Cayuga Power Plant in Lansing, NY.

Nonetheless, the plant owners are pushing to re-power the Cayuga Power Plant with natural gas. Currently, however, there is no pipeline to deliver the gas to the plant.  Without support by the public nor the Public Service Commission for the construction of a supply pipeline, Cayuga Power Plant has revealed they plan to receive gas deliveries via truck.

Scenario Maps

FracTracker has modeled the five most likely scenarios that would take compressed natural gas from a loading station in northern Pennsylvania to the Cayuga Power Plant in Lansing. All of the scenarios bring the trucks through populated communities, in dangerous proximity to high-risk facilities where both human safety and evacuations are problematic. The routes also pass through intersections and road stretches that have some of the highest accident rates in the area.

Route 1: This route passes within a half mile of homes of 36,669 people in the Villages of Lansing, Candor, Spencer, Owego; Towns of Ithaca, Lansing, Newfield, Danby, Candor, Spencer, Tioga, Owego, Vestal; and the City of Ithaca. Within the half-mile evacuation zone of this route, should there be an accident, are:

  • 17 health care facilities
  • 20 day care centers
  • 4 private school
  • 21 public schools

Click on the tabs in the box above to explore the five potential truck routes with maps.

Interactive Map

For a full interactive map of the potential routes for CNG delivery to the Cayuga Power Plant, and the schools, health care facilities, etc. within a half-mile evacuation zone of the routes, view the interactive map below.

View map fullscreen | How FracTracker maps work

A Call for Alternative Energy

Despite the apparent convenience that virtual pipelines present for the fossil fuel industry, they are not the solution the future energy supply needs. Yes, they present an alternative to pipeline transportation — but they also play a disastrous role in continuing our descent into climate chaos caused by increasing greenhouse gas concentrations in the atmosphere.

Methane leakage is an unavoidable component of the entire life cycle of natural gas usage — from “cradle to grave” — or more precisely, from the moment a well is drilled to when the gas is combusted by its end-user. And methane, as a greenhouse gas, is up to 100 times more potent than carbon dioxide. The Intergovernmental Panel on Climate Change’s (IPCC) recent report (see summary here) is unflinching in its clarion call for immediate, and extreme, cut-backs in greenhouse gas production. If we choose not to heed this call, much of humanity’s future survival is called into question.


By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance

More of the details about the Cayuga Power Plant will be explained in the upcoming weeks in a related guest blog by environmental activist and organizer, Irene Weiser, of Tompkins County, NY.

 

 

Pipeline Regulations & Impact Assessments, a Primer

Part of the Falcon Public EIA Project

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

Regulating Pipelines

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

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

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

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

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

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

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

Regulating the Falcon

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

Questioning Impact Assessments

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

An excerpt from the Atlantic Sunrise EIS addressing environmental justice concerns

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

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

* * *

Related Articles

By Kirk Jalbert, FracTracker Alliance

Heavy equipment moves debris from the site of a house explosion April 17 in Firestone, Colo., which killed two people. (David Kelly / For The Times)

Risks from Colorado’s Natural Gas Storage and Transmission Systems

Given recent concerns about underground natural gas storage wells (UGS), FracTracker mapped UGS wells and fields in Colorado, as well as midstream transmission pipelines of natural gas that transport the gas from well sites to facilities for processing. Results show that 6,673 Colorado residents in 2,607 households live within a 2.5 mile evacuation radius of a UGS well. Additionally, the UGS fields with the largest number of “single-point-of-failure” high-risk storage wells are also the two fields in Colorado nearest communities.

Worst Case Scenario

A house exploding from a natural gas leak sounds straight out of a 19th century period drama, but this tragedy just recently occurred in Firestone, Colorado. How could this happen in 2017? We have seen pictures and read reports of blowouts and explosions at well sites, and know of the fight against big oil and natural gas pipelines across the country. At the same time we take for granted the natural gas range that heats our food to feed our families. The risk of harm is seemingly far removed from our stove tops, although it may be much closer to home than we think – There are documented occupational hazards and compartmentalized risks in moving natural gas off site.

Natural gas is an explosive substance, yet the collection of the gas from well sites remains largely industry-regulated. Unfortunately, it has become clear that production states like Colorado are not able to provide oversight, much less know where small pipelines are even located. This is particularly dangerous, since the natural gas in its native state is ordorless, colorless, and tasteless. Flowing in the pipelines between well sites and processing stations, natural gas does not contain the mercaptan that gives commercial natural gas its tell-tale odor. In fact, much of the natural gas or “product” is merely lost to the atmosphere, or much worse, can collect in closed spaces and reach explosive levels. This means that high, potentially explosive levels of methane may go undetected until far too late.

Mapping Flow Lines

As a result of the house explosion in Firestone on April 17th CO regulators are now requiring oil and gas operators to report the location of their collection flow pipelines, as shown in Figure 1.

Figure 1. Map of Gathering Pipeline “Flowlines”

View map fullscreen

The locations of the collection of pipeline “flowlines”, like the uncapped pipeline that caused the house explosion in Firestone, have been mapped by FracTracker Alliance (above). The dataset is not complete, as not all operators complied with the reporting deadline set by the COGCC. For residents living in the midst of Colorado’s oil and gas production zones, addresses can be typed into the search bar in the upper left corner of the map. Users can see if their homes are located near or on top of these pipelines. The original mapping was done by Inside Energy’s Jordan Wirfs-Brock.

Underground Storage

When natural gas is mixed with mercaptan and ready for market, operators and utility companies store the product in UGS fields. (EDIT – Research shows that in most cases natural gas in UGS fields is not yet mixed with mercaptan. Therefore leaks may go undetected more easily. Aliso Canyon was a unique case where the gas was being stored AFTER being mixed with mercaptan. Odorization is not legally required until gas moves across state lines in an interstate pipeline or is piped into transmission lines for commercial distribution.) In August 2016, a natural gas storage well at the SoCal Gas Aliso Canyon natural gas storage field failed causing the largest methane leak in U.S. history. The Porter Ranch community experienced health impacts including nosebleeds, migraines, respiratory and other such symptoms. Thousands of residents were evacuated. While Aliso Canyon was the largest leak, it was by no means a unique case.

FracTracker has mapped the underground natural gas storage facilities in Colorado, and the wells that service the facilities. As can be seen below, there are 10 storage fields in Colorado, and an 11th one is planned. All the fields used for storage in Colorado are previously depleted oil and gas production fields. The majority of storage wells used to be production wells. All sites are shown in the map below (Figure 2).

Figure 2. Map of Natural Gas Underground Storage Facilities

View map fullscreen | How FracTracker maps work

Impacted Populations

Our analysis of Colorado natural gas storage facilities shows that 6,673 Colorado residents living in 2,607 households live within a 2.5 mile evacuation radius of a UGS well. The majority of those Coloradans (5,422) live in Morgan County, with 2,438 in or near the city of Fort Morgan. The city of Fort Morgan is surrounded by the Young Gas Storage Facility with a working capacity of 5,790,049 MCF and Colorado Interstate Gas Company with a working capacity of 8,496,000 MCF.

By comparison, the failure in Aliso Canyon leaked up to 5,659,000 MCF. A leak at either of these facilities could, therefore, result in a similar or larger release.

UGS Well Risk Assessment

A FracTracker co-founder and colleague at Harvard University recently completed a risk assessment of underground natural gas storage wells across the U.S. The analysis identified the storage wells shown in the map above (Figure 1) and defined a number of “design deficiencies” in wells, including “single-point-of-failure” designs that make the wells vulnerable to leaks and failures. Results showed that 2,715 of the total 14,138 active UGS wells across the country were constructed using similar techniques as the Aliso Canyon failed well.

Applying this assessment to the wells in Colorado, FracTracker finds the following:

  • There are a total of 357 UGS wells in Colorado.
  • 220 of which are currently active.
  • Of those 220 UGS wells, they were all drilled between 1949 and 1970.
  • 43 of the UGS wells are repurposed production wells.
  • 40 of those repurposed wells are the highest risk single barrier wells.

Specifically focusing on the UGS fields surrounding the city of Fort Morgan:

  • 21 single barrier wells are located in the Flank field 2.5 miles North of the city.
  • 13 single barrier wells are located in the Fort Morgan field 2.5 miles South of the city.

We originally asked how something as terrible as Firestone could have occurred. Collectively we all want to believe this was an isolated incident. Sadly, the data suggest the risk is higher than originally thought: The fields with the largest number of “single-point-of-failure” high-risk UGS wells are also the two fields in Colorado nearest communities. While the incident in Firestone is certainly heartbreaking, we hope regulators and operators can use the information in this analysis to avoid future catastrophes.


By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Feature Image: Heavy equipment moves debris from the site of a house explosion April 17, 2017 in Firestone, Colorado, which killed two people. (David Kelly / For The Times)

Porterville incident map

Mysterious leak near Porterville Compressor Station, NY

Last month, FracTracker Alliance featured a blog entry and map exploring the controversy around National Fuel’s proposed Northern Access Pipeline (NAPL) project, shown in the map below. The proposed project, which has already received approval from the Federal Energy Regulatory Commission (FERC), is still awaiting another decision by April 7, 2017 — Section 401 Water Quality Certification. By that date, the New York State Department of Environmental Conservation (NYS DEC) must give either final approval, or else deny the project.

Northern Access Pipeline Map

View map fullscreen | How FracTracker maps work

The NAPL project includes the construction of 97-mile-long pipeline to bring fracked Marcellus gas through New York State, and into Canada. The project also involves construction of a variety of related major infrastructure projects, including a gas dehydration facility, and a ten-fold expansion of the capacity of the Porterville Compressor Station located at the northern terminus of the proposed pipeline, in Erie County, NY.

On three consecutive days in early February, 2017, the New York State Department of Environmental Conservation (NYS DEC) held hearings in Western New York to gather input about the NAPL project. On February 7th, the day of the first meeting at Saint Bonaventure University in Allegany County, NY, an alarming — and yet to be fully reported — incident widely considered to be a gas leak, occurred at, or near, the Porterville Compressor Station (also known locally as the “Elma Compressor Station”). The incident is thought to be connected to the planned upgrades to the facility, but was not even mentioned as a concern during the public meetings relating to the Northern Access Pipeline in the subsequent hours and days.

What follows is a story of poor communication between the utility company, first responders, and local residents, resulting in confusion and even panic, and has yet to be conclusively explained to the general public.

Incident Description

 Area of incident

Area of incident in NY State

We know that a little past 10 AM on February 7th, people in the villages of Elma and East Aurora, within about a mile of the Porterville Compressor Station, reported strong odors of gas. They filed complaints with the local gas utility (National Fuel), and the local 911 center, which referred the calls to the local Elma Fire Department. The fire department went to the Porterville Compressor station to investigate, remembering a similar incident from a few years earlier. At the compressor station, representatives from National Fuel, the operator of the compressor station, assured the fire company that they were conducting a routine flushing of an odorant line, and the situation was under control, so the fire company departed.

Residents in the area became more alarmed when they noticed that the odor was stronger outside their buildings than inside them. National Fuel then ordered many residents to evacuate their homes. The East Aurora police facilitated the evacuation and instructed residents to gather in the East Aurora Library not far from those homes. Nearby businesses, such as Fisher Price, headquartered in East Aurora, chose to send their employees home for the day, due to the offensive odor and perceived risks.

Around 11:30 in the morning, up to 200 clients at Suburban Adult Services, Inc. (SASi), were evacuated to the Jamison Road Fire Station, where they remained until around 3 PM that afternoon. Over 200 reports were received, some from as far away as Orchard Park, eight miles down-wind of the compressor station.

After East Aurora elementary and middle schools placed complaints, National Fuel told them to evacuate students and staff from their buildings. Realizing that the smell was stronger outside than inside the building, school leaders revised their plans, and started to get buses ready to transport student to the high school, where there had not been reports of the odor. Before the buses could load, however, the police department notified the school that the gas leak had been repaired, and that there was no need to evacuate. School officials then activated the school’s air circulation system to rid the building of the fumes.

Perplexingly, according to one report, National Fuel’s Communications Manager Karen Merkel said “that the company did not reach out into the community to tell people what was going on because the company cannot discourage anyone from making an emergency gas call.”

Merkel noted further, “You never know if the smell being reported is related to work we are doing or another gas leak,” she said. “This wouldn’t be determined until we investigate it.”

That smell…

Some background on gas leaks & odorant additives

Ethyl mercaptan molecule

Ethyl mercaptan molecule

An odorant, such as ethyl mercaptan, is often added to natural gas in order to serve as an “early warning system” in the event of a leak from the system. Odorants like mercaptan are especially effective because the humans can smell very low concentrations of it in the air. According to the National Center for Biotechnology Information, “The level of distinct odor awareness (LOA) for ethyl mercaptan odorant is 1.4 x10-4 ppm,” or 0.00014 parts per million. That translates to 0.000000014 percent by volume.

Not all natural gas is odorized, however. According to Chevron Phillips, “mercaptans are required (by state and federal regulations) to be added to the gas stream near points of consumption as well as in pipelines that are near areas with certain population density requirements, per Department of Transportation regulations… Not all gas is odorized, though; large industrial users served by transmission lines away from everyday consumers might not be required to use odorized gas.” Also, because odorants tend to degrade or oxidize when gas is travelling a long distance through transmission lines, they are not always added to larger pipeline systems.

The explosion and flammability concentration limit for natural gas refers to the percentage range at which a gas will explode. At very low concentrations, the gas will not ignite. If the concentration is too high, not enough oxygen is present, and the gas is also stable. This is why gas in non-leaky pipelines does not explode, but when it mixes with air, and a spark is present, the result can be disastrous. Methane, the primary component of natural gas, has a lower explosive level (LEL) of 4.4% and an upper explosive limit (UEL) (above which it will not ignite) of 16.4%. Nonetheless, levels above 1% are still worrisome, and may still be good cause for evacuation.

Therefore, the margin of safety between when natural gas is detectable with an odorant present, and when it may explode, is very broad. This may help to explain why the smell of gas was detected over such a broad distance, but no explosion (very fortunately) took place.

Local memories of gas explosion in East Aurora

Many East Aurora residents have had first-hand experience with the dangers posed by gas lines in their community. Less than 25 years ago, in  September 1994, a high-pressure pipeline owned by National Fuel ruptured in an uninhabited area between East Aurora and South Wales along Olean Rd. The blast left a 10-foot-deep, 20-foot-wide crater, and tree limbs and vegetation were burned as far as 50 feet away.

Porterville first-hand accounts and inquiries

FracTracker spoke extensively with one resident of East Aurora, Jennifer Marmion, about her experiences, and efforts to understand what had actually happened the day of this incident.

When personnel from the Jamison Fire Company — who are assumed to be first responders to emergencies of this sort — arrived at the Porterville Compressor Station, they were told by National Fuel that there was no hazard and that their services were not needed. Consequently, these crews left the site. The East Aurora Police Department was given a different explanation by National Fuel; there was a valve malfunction somewhere along Two Rod Road in Marilla. Still later, National Fuel indicated that the pipeline changeover occurred closer to the compressor station itself. The closest distance between anywhere on Two Rod Road and the compressor station, itself, is a mile and a half. And Ms. Marmion was given a still different story by a National Fuel engineer: that the odor, indeed, resulted during the replacement of a 100-foot-long section of aging pipeline at the Porterville (“Elma”) Compressor Station.

Key locations in incident report

Key locations in incident report

Some reports indicated an alternate explanation: that the odor originated at the East Aurora Town Hall (J. Marmion, pers. comm., via Channel 7 News), or a leaky valve along a pipeline near Marilla (J. Marmion, pers. comm, via East Aurora Police Department dispatcher). A member of the East Aurora Fire Department surmised that the leak might have been closer to Olean Road, south of the village, where there was a history of other leaks. The day after the incident, National Fuel indicated that the odor originated from the compressor station, and was the result of a routine, scheduled “blowdown” by National Fuel — wherein gas lines at the compressor station are cleared as part of routine maintenance. However, when pressed for more details, they did not provide them.

In need of follow up

More than six weeks have passed since the incident, and there is still no definitive explanation available. Clearly, there was considerable confusion about what the correct, and safe, procedure needed to be, as well as how this information needed to flow to the public. Ultimately, a representative from National Fuel’s Government Affairs office agreed that he would alert the local towns and fire departments when maintenance activities would be occurring. It is surprising that this was not already standard practice.

Although Ms. Marmion is continuing to be a determined citizen activist, she has been met with a frustrating array of ambiguous and often conflicting descriptions, phone calls that go un-answered, voice mailboxes at offices that are either full or not set up to receive messages. Furthermore, although National Fuel has told Marmion that there is an Action Plan to be followed in the event of an emergency, they have been unable to provide her with a written or electronic version of this document, because “the action plan is just known.”

National Fuel points to the weather

National Fuel maintains that the only factor that was out of the ordinary was that during the event, a combination of unusual weather factors caused the released gas to travel in an unusual manner and also not dissipate as quickly as expected. National Fuel also indicated that the strong odor (created by the additive mercaptan) was a benefit to the local community, added to natural gas so that residents would be alerted to problems. It’s important to note that the largest gas transmissions pipelines, like the nearby 26” diameter Tennessee Gas Pipeline to the east of Elma and East Aurora, as well other pipelines that will run to the greatly expanded Porterville Compressor Station as part of the Northern Access Pipeline project, will be without the odorant.

Here’s what FracTracker could verify, based on National Weather Service, and Weather Underground historical data. In the morning and afternoon of February 7th, the wind was uncharacteristically blowing from the east/northeast — atypical for western New York, when winds normally come from the west. Wind speeds were recorded between 10-15 mph. Humidity was also uncharacteristically high for February — topping out at 93% that day. Warm air aloft, combined with freezing rain, created a temperature inversion. The moist air then trapped the odor, which lingered across the region.

weather_feb72017

feb72017_wind-data

Screen captures of weather statistics on February 7, 2017 (Source: wunderground.com). Note dominant wind direction from ENE, as well as high humidity, during morning and early afternoon, when incident took place.

Who monitors air quality in Western New York?

Calls by FracTracker for clarification from the New York State DEC’s Division of Air Resources have gone unanswered. The only station at which the DEC monitors methane is located more than 275 miles away to the southeast, in the Bronx. In Erie County, where the incident took place, there are only four permanent ambient air pollution monitoring stations. These include stations in:

  • Amherst: Continuous monitoring of ozone, NO2. Manual monitoring of PM5, acid deposition.
  • Buffalo: Continuous monitoring of SO2, NOx, NO, NO2, NOy, CO, CPM5. Manual monitoring of PM2.5, PM10, toxics
  • Brookside Terrace/Tonawanda: Continuous monitoring of SO2, CPM5. Manual monitoring of toxics and carbonyls
  • Grand Island (special purpose only): Continuous monitoring of CPM5. Manual monitoring of toxics and carbonyls

PM” refers to particulate matter diameter. PM5, for example, denotes particulate matter 5 microns in diameter, and smaller.

The East Aurora and Elma fire departments lack the appropriate air quality detection instruments to make their own judgements on the explosive nature of these gas plumes. Instead, small towns rely on the expertise of National Fuel to arrive on the scene after a call has been made, so that National Fuel can take measurements and then respond to the community. Some residents waited over three hours for an assessment, but by this time the plume had drifted away two hours ago.

National Fuel, however, has not disclosed any of the air quality data measurements they made on February 7th when they responded to this complicated incident. Ms. Marmion and others still want to know what levels of methane were measured in the communities involved in this incident, or the specific quantity of gas that entered the air that day.

What’s next?

While National Fuel did not notify the residents or the school district administration in advance of the scheduled “blowdown,” their Government Affairs Representative indicated that in the future, town governments, community leaders, and the local fire companies would be alerted to the upcoming releases and maintenance work. Nonetheless, weeks after the odor incident, National Fuel has neither contacted the local community leaders, nor local law enforcement, to provide complete and detailed answers as to what actually happened on February 7th.


By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance. Special thanks to East Aurora resident Jennifer Marmion, for her insights and comments. 

Colorado Setbacks, One Step Forward?

By Sierra Shamer, Visiting Scholar, FracTracker Alliance

longmont

OurLongmont.org sign supporting the city’s ban on fracking

In 2012, citizens of Longmont, Colorado voted to increase setback distances of oil and gas infrastructure from occupied buildings. As well pads and storage facilities crept closer to homes, schools, and playgrounds, concerns of air, water, and noise pollution steadily grew. These regulations to protect public health and safety in Longmont culminated in an outright ban of hydraulic fracturing / directional drilling within their boundary. This prompted the state regulatory agency, the Colorado Oil and Gas Conservation Commission (COGCC) to sue the town, arguing that only the state has the power to regulate energy development. While the suit was dropped, the ban was overruled in 2014 in the Boulder District Court, determining that the city did not have the authority to prohibit what is permitted throughout the state. The city motioned for a Stay Pending Appeal and it was granted by the court – the ban on fracking in Longmont will stay in effect until the case is settled.

In response to these local challenges of oil and gas expansion, the COGCC passed new setback rules. However, with loopholes, exceptions, and an increasing awareness of public health and safety threats, Coloradans have continued to demand increased and enforced setback distances. This article highlights the issue of setback regulations in Colorado, featuring a map of Weld County that exemplifies the statewide expansion of fracking wells into communities.

Colorado Setbacks Regulation

The COGCC passed new setback rules for oil and gas facilities in February of 2013 with a stated purpose of decreasing the “potential adverse health and safety risks to the public and the environment, including spills, odors, noise, dust, and lighting.” Prior rules permitted drilling within 150 feet of occupied buildings in a rural area and within 350 feet in an urban area. A COGCC report in October 2013 stated that 600 oil and gas locations were located within 500 feet of occupied buildings, 26% of the total. The new regulations increased the minimum setback distance to 500 feet, adding a 350-foot setback from outdoor recreational areas such as playgrounds or sports fields, and a 1,000-foot setback from high occupancy building such as schools or hospitals. It also included 1,000-foot buffer distances from these outdoor areas and buildings within which facilities are permitted but require increased on-site mitigation to prevent air, noise, and water pollution. These rules took effect on August 1, 2013.

Setback Success?

Colorado’s setback rules have been criticized by organizations, activists, landowners, and researchers who argue that the loopholes and exemptions allowed by the COGCC make the rules ineffective, and even if they were enforced, the modest increase in setback distance would not adequately protect citizens from negative impacts. Exceptions to the rules, shown in the table below, are included the regulations and are available for the majority of setback distances identified, allowing oil and gas facilities to continue development in close proximity to communities. The Western Resource Advocates, a conservation organization in Colorado, identifies two commonplace built-in exceptions to the 500-foot minimum setback rule: the “Beware Thy Neighbor” exception, allows surface landowners the ability to allow wells within setback distances, and the “Expansion Exception,” which allows active well pads the ability to expand even if they are within the new setback distances. If exceptions are granted, the facility must include additional mitigation measures to lessen air and noise pollution and safeguard against potential spills due to the proximity of communities.

Exceptions to Setback Rules CO

Source: COGCC

In 2015, the University of Denver and the Sierra Club conducted a review of compliance with these setback regulations, finding that 181 permits approved after the rules were enacted lacked legally required information. These permits will result in 951 wells, 1221 oil and condensate tanks, and 932 separators throughout the state, concentrated in counties like Garfield, La Plata, and Weld that have the most widespread oil and gas development. This review identified that in Weld County, permits for 798 wells, 1140 tanks, and 800 separators lacked critical information the COGCC required.

In February of this year, a study published in Environmental Health Perspectives evaluated the adequacy of setbacks in Pennsylvania, Texas, and Colorado. The researchers concluded that the current s setbacks are insufficient to protect public health and safety, leaving communities vulnerable. Further, they claim while that there is no defined setback that will ensure the safety of a population, all three states should adopt larger setbacks distances and increased mitigation measures.

Continued Demands

Armed with health and safety information, evidence of COGCC lack of enforcement, and the lived experiences of Coloradans, communities and groups are organizing around ballot initiatives. These initiatives would become part of the state constitution, and would to increase setback distances and secure the ability of local governments to determine where development occurs within their boundaries. Unlike the internal rules and regulations determined by the COGCC, these additions to the state constitution would offer no exceptions.

The Western Colorado Congress (WCC) a group that organizes communities around threats to environmental and public health, advocated in 2013 for 1,000-foot setbacks from homes and 1,500-foot setbacks from schools. They continue to push for increased distances and support ballot initiatives that allow local governmental control of oil and gas development. Current ballot initiatives, created by Coloradans Resisting Extreme Energy Development (CREED) demand local government control of oil and gas infrastructure and 2,500-foot setbacks from homes, schools, outdoor recreation areas, and sources of drinking water. This setback distance is based on a Colorado health study, concluding that people living with a half-mile of wells had an increased risk of illness than those further away.

Weld County: A Closer Look

Weld County has experienced dramatic oil and gas development, with increasing infrastructure permitted closer and closer to residents’ homes and communities. Currently, there are over 12,200 directional wells in Weld County and over 35,300 wells in total. The map below uses data accessed from the COGGC on April 7th, 2016 and address points data from Weld County. The address points are located within the center of homes, and while setbacks distances are measured from the center of the well pad to the nearest wall of the building, the address points still demonstrate the proximity and danger of encroaching infrastructure. The map identifies directional wells permitted within the designated setback of 500 feet and the buffer zone of 1,000 feet and pending directional wells within proposed 1,000 and 2,500-foot setbacks. Address points within these setbacks are identified, and if you select the Directional Lines layer, the underground directional well lines become visible.

Map of wells and setbacks in Weld County, CO

View map full screen | How FracTracker maps work

The state, the COGCC, and the industry oppose these initiatives, arguing that it will hinder the economic development of Colorado and threaten state control of regulation. Industry advocates have claimed that a 2,500-foot setback would eliminate 87% of new operations in Weld County. This strong opposition often results in such initiatives being dropped or voted out, a reality that occurred earlier this month when two of three initiatives relating to oil and gas were voted down the state house of representatives.

Currently, 48% of addresses (around 53,700) in Weld County are within 2,500 feet of at least one directional well, and 9% are within 1,000 feet. Since August 2013, 16 directional wells have been permitted within 500 feet of buildings, and 207 have been permitted within 1,000 feet. Regarding new operations in Weld County, of the 379 pending directional wells, 319 of them are within 2,500 feet of homes – around 84% – slightly less than the industry claimed, but close. However, is important to note that many pending wells are planned on existing well pads, constructed prior to the new rules, and can be given exceptions. Additionally, the technology of directional drilling allows greater flexibility. When viewing the directional lines on the map, it is clear that wells can be drilled in any direction from a well pad, suggesting that companies could place surface wells further away from homes and still access the underground resource.

Moving Forward With Setbacks

Demands for protection from oil and gas encroachment are steadily increasing. The group, Coloradans Against Fracking, a large coalition of organizations, has endorsed the 2016 ballot initiatives put forward by CREED. It is clear that the state can accept continuous challenges to oil and gas development, particularly if rules and regulations are neglected at the expense of public health and safety.

Feature image by Western Colorado Congress (WCC).

Clearing land for shale gas pipeline in PA

A Push For Pipelines

By Bill Hughes, WV Community Liaison

For anyone who even casually follows Marcellus and Utica shale gas exploration and production, such as in the active gas fields of West Virginia or Southwestern PA or Ohio, we know there are many concerns surrounding the natural gas production process. These issues range from air pollution, water consumption and contamination, to waste disposal. We know that, after all well the pad drilling and construction traffic are done, we must also have pipelines to get the gas to compressor stations, processing plants, and to markets in the Eastern United States (and likely Europe and Asia in the near future). Gas companies in Wetzel County, WV, and in neighboring tri-state counties, are convinced that building pipelines – really big pipelines – will be the silver bullet to achieving some semblance of stability and profitability.

Problems With Proposed Pipelines

One of the new, very large diameter (42”) proposed gas pipelines getting attention in the press is the Mountain Valley Pipeline, which will originate in the village of Mobley in eastern Wetzel County, WV and extend Southeast, through national forests and over the Appalachian Mountains into the state of Virginia. Even if the residents of Wetzel County and other natural gas fields are guinea pigs for experiments with hydraulic fracturing, we know how to build pipelines, don’t we? The equipment, knowledge, and skill sets needed for pipeline construction is readily available and commonly understood compared to high pressure horizontal drilling with large volumes of slick water. So, what could go wrong?

I can answer that question first hand from my hayfield in Wetzel County. Almost two years ago, EQT wanted to survey my property for a similar proposed pipeline – this one 30” in diameter, called the Ohio Valley Connector (OVC). The application for this project has now been filed with the Federal Energy Regulatory Commission (FERC). The below map shows a section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land. Multiple routes were being explored at first. Were this version approved, it would have gone right through my hayfield and under our stream.

A section of the OVC as proposed almost two years ago.

A section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land.

Pipeline opponents express concern about habitat fragmentation, the crossing of pristine streams and rivers, erosion and sedimentation issues, spills, gas leaks, and possible explosions. These are all very valid concerns. But the potential for other logistical errors in the building process – from very simple to potentially serious ones – are also worth consideration. In this article I will use my recent personal experience as a detailed and documented example of how a professionally surveyed location on my property contained an error of almost one mile – over 4,000 feet – as part of a pipeline construction planning project. Yes, you read that right.

Part I: How Did We Get To This Point

Before we get to my story, I should review my first contact with EQT on this issue. In February of 2014, an EQT land agent asked me for permission to walk my property for preliminary evaluation of a route that would send their 30” high-pressure pipe through our land, from south to north.

It is important to keep in mind that almost every landowner in Wetzel County has been contacted by mail, phone or in person, by land agents promising cash with a verbal assurance that all will be well. The goal is to get a landowner’s signature on a loosely worded “right of way” (RoW) lease contract, with terms favorable to the gas company, and move on. Unfortunately, pipeline lease offers cannot be ignored. Not objecting or not questioning can sometime leave the landowner with fewer choices later. This is because many of the bigger interstate transmission lines are being proposed as FERC lines. When final approval is granted by FERC, these pipelines will have the legal power of eminent domain, where the property owner is forced to comply. Just filing a FERC application does not grant eminent domain in West Virginia, as it seems to in Virginia, but the potential for eminent domain gives land agents power over landowners.

I was not ready to give them surveying permission (to drive stakes or other permanent markers). Since a natural gas pipeline would affect all my neighbors, however, I agreed to allow a preliminary walk through my property and to hang surveyor ribbons in exchange for answering my questions about the project. For instance, one of my biggest concerns was the potential for significant habitat fragmentation, splitting up the forest and endangering wildlife habitat.

[av_font_icon icon=’ue836′ font=’entypo-fontello’ style=” caption=” link=” linktarget=” size=’40px’ position=’left’ color=”][/av_font_icon] There are many questions residents should consider when approached by land agent. A list of these questions can be found in the appendix below.

I never did get answers to most of my questions in the few e-mail exchanges and phone conversations with EQT. I never saw the surveyors either. They simply came and left their telltale colored ribbons. Later, at a public meeting an EQT representative said the closest they would run the pipe to any residence would be 37.5 feet. That number is correct. I asked twice. They said they had the right to run a pipeline that close to a residence but would do their best not to. The 37.5 feet is just one half of the permanent RoW of 75 feet, which was also only part of a 125 foot RoW requested for construction. A few months later, a very short e-mail said that the final pipeline route had changed and they would not be on my property. For a time we would enjoy some peace and quiet.

A Word On Surveyors

Most folks can relate to the work and responsibility of bookkeepers or Certified Public Accountants (CPAs). They measure and keep track of money. And their balance sheets and ledgers actually have to, well, BALANCE. Think of Surveyors as the CPAs of the land world. When they go up a big hill and down the other side, the keep track of every inch — they will not tolerate losing a few inches here and there. They truly are professionals, measuring and documenting everything with precision. Most of the surveyors I have spoken with are courteous and respectful. They are a credit to their profession. They are aware of the eminent domain threat and their surveying success depends on treating landowners with respect. They are good at what they do. However, as this article will show, their professional success and precision depends on whether or not they are given the correct route to survey.

Part II: Surveyor Stakes and Flags

Over the next year we enjoyed peace and quiet with no more surveyors’ intrusions. However, in my regular travels throughout the natural gas fields here, countless signs of surveyor activity were visible. Even with the temporary slowdown in drilling, the proposed pipeline installations kept these surveyors busy. Assorted types of stakes and ribbons and markings are impossible to miss along our roads. I usually notice many of the newer surveyor’s flags and the normal wooden stakes used to mark out future well pads, access roads, compressor stations, and more recently pipelines. Given that survey markings are never taken down when no longer needed, the old ones sometimes hide the new ones.

It can be difficult keeping track of all of them and hard at first to identify why they are there. Even if sometimes I am not sure what a stake and flag might indicate, when one shows up very unexpectedly in what is essentially my front yard, it is impossible to not see it. That is what happened in August of 2015. Despite being unable to get our hay cut due to excessive rain the previous month, the colored flags were highly visible. Below shows one of the stakes with surveyor’s tape, and the hay driven down where the surveyors had parked their trucks in my field alongside my access road.

A surveyor stake alongside my access road.

A surveyor stake alongside my access road.

To call it trespassing might not be legally defensible yet. The stakes were, after all, near a public roadway – but the pins and stakes and flags were on my property. Incidents like this, whether intentional or accidental, are what have given the natural gas companies a reputation as bad neighbors. There were surveyors’ stakes and flags at two different locations, my hay was driven down, and I had no idea what all this meant given that I had no communication from anyone at EQT in over 18 months. I consider myself fortunate that the surveyors did not stray into wooded areas where trees might have been cut. It’s been known to happen.

Below shows the two sets of wooden stakes, roughly 70-80 feet apart, with flags and capped steel rebar pins. Both stakes were near the road’s gravel lane, which is a public right of way. Nevertheless, the stakes were clearly on my property. The markings on one side of the stake identify the latitude, longitude, and the elevation above sea level of the point. The other side of the stake identified it as locating the OVC pipeline (seen here as “OVC 6C):

These identifying numbers are unique to this pin which is used to denote a specific type of location called a “control point.” Control points are usually located off to the side of the center-line of the pipeline:

A control point, located off to the side of the center-line of the pipeline.

A control point, located off to the side of the center-line of the pipeline.

It seemed that somehow, without informing me or asking permission to be on my land, EQT had changed their mind on the OVC route and were again planning to run a pipeline through my property. If this was intentional, both EQT and I had a problem. If this was some kind of mistake, then only EQT would have a problem. Either way I could not fathom how this happened. Trespassing, real or perceived, is always a sensitive topic. This is especially true since, when I had initially allowed the surveyor to be on my property, I had not given permission for surveying. Given concerns about eminent domain, I wanted answers quickly. I documented all this with detailed pictures in preparation for contacting EQT representatives in Pittsburgh, PA, with my complaints.

Part III: What Happened & How?

I think it is safe to say that, in light of my well-known activism in documenting all things Marcellus, I am not your average surface owner. I have over 10,000 photographs of Marcellus operations in Wetzel County and I document every aspect of it. Frequently this leads to contacting many state agencies and gas operators directly about problems. I knew which gas company was responsible and I also knew exactly who in Pittsburgh to contact. To their credit, the person I contacted at EQT, immediately responded and it took most of the day to track down what had happen. The short story was that it was all a simple mistake—a 4,300 foot long mistake—but still just a mistake. The long story follows.

The EQT representative assured me that someone would be out to remove their stakes, flags and the steel pins. I told them that they needed to be prompt and that I would not alter or move their property and locating points. The next day, when I got home, the stakes with flags were gone. Just a small bare patch of dirt remained near the white plastic fencepost I had placed to mark the location. However, since I am a cultivated skeptic—adhering to the old Russian proverb made famous by President Reagan, “Trust but Verify”—I grabbed a garden trowel, dug around a bit, and clink, clink. The steel pin had just been driven deeper to look good, just waiting for my tiller to locate someday. I profusely re-painted the pin, photographed it, and proceeded to send another somewhat harsh e-mail to EQT. The pin was removed the next day.

After all the stakes, ribbons, and steel pins were removed, EQT provided further insights into what had transpired. Multiple pipeline routes were being evaluated by EQT in the area. Gas companies always consider a wide range of constraints to pipeline construction such as road and stream crossings, available access roads, permission and cooperation of the many landowners, steepness of terrain, etc. At a certain point in their evaluation, a final route was chosen. But for unknown reasons the surveyor crew was given the old, now abanoned, route on which to establish their control points. The magnitiude of the error can be seen on the map below. The bright blue line is the original path of the OVC pipeline through my property and the red line shows where the FERC filed pipeline route will go. A new control point has now been established near the highway where the pipeline was meant to cross.

The FERC filed OVC pipeline route vs. the accidentally surveyed route.

The FERC filed OVC pipeline route vs. the accidentally surveyed route.

 

Part IV: Lessons To Be Learned

Given the likely impact of many proposed large-diameter, very long, pipelines being planned, it seems useful to examine how these errors can happen. What can we learn from my personal experience with the hundreds of miles of new pipelines constructed in Wetzel County over the past eight years? First, it is important to ask whether or not similar problems are likely to happen elsewhere, or if this was this just an isolated incident. Can we realistically expect better planning on the proposed Mountain Valley Pipeline, which will run for over 300 miles? Can the residents and landowners living along these pipeline RoWs expect more responsible construction and management practices?

In general, many of the pipeline projects with which landowners, such as those in Wetzel County, are familiar with fall into the unregulated, gathering line category. They might be anywhere from six inches in diameter up to sixteen inches. As we review their track record, we have seen every imaginable problem, both during construction and after they were put into operation. We have had gas leaks and condensate spills, hillside mud slips, broken pipes, erosion and sedimentation both during construction and afterwards.

Now for some apparently contradictory assumptions—I am convinced that, for the most part, truck drivers, pipeliners, equipment operators, drilling and fracturing crews, well tenders and service personnel at well sites, all do the best job they can. If they are given the proper tools and materials, accurate directions with trained and experienced supervision, the support resources and the time to do a good job, then they will complete their tasks consistently and proudly. A majority of employees in these positions are dedicated, trained, competent, and hard working. Of course, there are no perfect contractors out there. These guys are human too. And on the midnight shift, we all get tired. In the context of this story, some pipeline contractors are better and more professional than others, some are more experienced, and some have done the larger pipelines. Therefore, despite best intentions, significant errors and accidents will still occur.

The Inherent Contradictions

It seems to me that the fragile link in natural gas production and pipeline projects is simply the weakness of any large organization’s inherent business model. Every organization needs to constantly focus on what I refer to as the “four C’s—Command and Control, then Coordination and Communication—if they are to be at all successful. It is a challenge to manage these on a daily basis even when everyone is in the same big building, working for the same company, speaking the same language. This might be in a university, or a large medical complex, or an industrial manufacturing plant.

But the four C’s are nearly impossible to manage due to the simple fact that the organizational structure of the natural gas industry depends completely on hundreds of sub-contractors. And those companies, in turn, depend on a sprawling and transient, expanding and collapsing, network of hundreds of other diverse and divergent independent contractors. For example, on any given well pad, during the drilling or fracturing process, there might be a few “company” men on site. Those few guys actually work for the gas company in whose name the operating permit is drawn. Everyone else is working for another company, on site temporarily until they are ready to move on, and their loyalty is elsewhere.

In the best of situations, it is next to impossible to get the right piece of information to the right person at just the right time. Effective coordination among company men and contractors is also next to impossible. I have seen this, and listened in, when the drilling company is using one CB radio channel and the nearby pipeline company is using some private business band radio to talk to “their people.” In that case, the pipeline contractors could not talk to the well pad—and it did not matter to them. In other cases, the pilot vehicle drivers will unilaterally decide to use another CB radio channel and not tell everyone. I have also watched while a massive drill rig relocation was significantly delayed simply because a nearby new gas processing plant was simultaneously running at least a hundred dump trucks with gravel on the same narrow roadway. Constant communication is a basic requirement for traffic coordination, but next to impossible to do properly and consistently when these practices are so prevalent.

These examples illustrate how companies are often unable to coordinate their operations. Now, if you can, just try to picture this abysmal lack of command and control, and minimal communication and coordination, in the context of building a 300-mile length of pipeline. The larger the pipeline diameter, and the greater the overall length of the pipeline, the more contractors will be needed. With more contractors and sub-contractors, the more coordination and communication are essential. A FERC permit cannot fix this, nor would having a dozen FERC permits. Unfortunately, I do not envision the four Cs improving anytime soon in the natural gas industry. It seems to be the nature of the beast. If, as I know from personal experience, a major gas company can arrange to locate a surveyed control point 4,300 feet from where it should have been, then good luck with a 300 mile pipeline. Even with well-intentioned, trained employees, massive problems are still sure to come.

The FERC approvals for these pipelines might not be a done deal, but I would not bet against them. So vigilance and preparation will still be of the essence. Citizen groups must be prepared to observe, monitor, and document these projects as they unfold. If massive pipelines like the MVP and OVC are ever built, they should become the most photographed, measured, scrutinized, and documented public works projects since the aqueducts first delivered water to ancient Rome. For the sake of protecting the people and environment of Wetzel County and similar communities, I hope this is the case.

By Bill Hughes, WV Community Liaison, FracTracker Alliance
Read more Field Diary articles.

Appendix: Questions to Ask When Approached by a Land Agent (Landsman)

These questions can be modified to suit your location. The abbreviation “Gas Corp.” is used below to reference a typical natural gas company or a pipeline subsidiary to a natural gas company.  These subsidiaries are frequently called Midstream Companies. Midstream companies build and manage the pipelines, gas processing, and some compressor stations on behalf of natural gas companies.

  1. Please provide a Plain English translation of your landowner initial contract.
  2. What will Gas Corp. be allowed to do, and not allowed to do, short term and long term?
  3. What will Gas Corp. be required to do, and not required to do?
  4. What is the absolute minimum distance this pipeline will be placed away from any dwelling anywhere along its entire length?
  5. What restrictions will there be on the my land after you put in the pipelines?
  6. Who will be overseeing and enforcing any environmental restrictions (erosion and sedimentation, slips, stream crossings, etc.)?
  7.  Who will be responsible for my access road upkeep?
  8. Who will be responsible for long term slips and settlements of surface?
  9. When would this construction begin?
  10. When would all work be completed?
  11. Who would be responsible for long term stability of my land?
  12. Will the pipeline contractor(s) be bound to any of our agreements?
  13. Who are the pipeline contractor(s)?
  14. What will be transported in the pipeline?
  15. Will there be more than one pipe buried?
  16. How wide is the temporary work RoW?
  17. How wide is the permanent RoW?
  18. How deep will the pipeline(s) be buried?
  19. What size pipe will it be; what wall  thickness?
  20. How often will the welds on the individual pipe segments be inspected?
  21. Will there be any above ground pipeline components left visible?
  22. Where will the pipe(s) originate and where will they be going to?
  23. What will the average operating pressure be?
  24. What will the absolute maximum pressure ever be?
  25. At this pressure and diameter, what is the PIR—Potential Impact Radius?
  26. Will all pipeline and excavating and laying equipment be brought in clean and totally free from any invasive species?
  27. How will the disturbed soil be reclaimed?
  28. Will all top soil be kept separate and replaced after pipeline is buried?
  29. Also, After all the above is settled, how much will I be paid per linear foot of pipeline?
Oil train decoupled, January 2016, Pittsburgh PA

Oil Train Decoupled in Pittsburgh, No Injuries

Dangerously Close Call

Today a train carrying oil products decoupled, or separated, in the City of Pittsburgh. Collaborators at CMU report that this morning an oil train decoupled along the tracks that run past the Bellefield boiler and under Forbes Avenue in Oakland, a very populated section of the city. While no spills, explosions, or injuries were reported, concerns remain.

This train was carrying a significant number of cars either marked with 1075 or 3295 hazard placards – flammable liquids and gases produced during oil and gas drilling. We’ve discussed the risks associated with oil trains on several occasions on FracTracker. We have not previously mentioned the 3295 hazmat placard, however, which is apparently used to identify condensate. More and more train cars hosting 3295 placards have been passing through Pittsburgh in recent months, observers report.

The cars on this train were likely full, based on the train’s direction (bound for refineries on the East Coast). While it is difficult to tell given available data, these kinds of trains generally originate from Western PA, Ohio, as well as the Bakken shale formation in North Dakota.

Fortunately, the coupling broke while the train was headed uphill. For residents living in Junction Hollow, the brakes on the disconnected part of the train worked properly. If the brakes had failed, this portion of the train could have rolled downhill and derailed at the first turn in the hollow. A similar situation – with much more disastrous results – occurred in 2013 in Lac-Mégantic, Quebec.

Train Incident Photos (Submitted by CMU)

This video taken of the train passing once it was reconnected with the engine shows the sheer quantity of hydrocarbons being hauled through the city. (Randy Sargent of CMU’s CREATE Lab, identifies each of the car’s hazard placards as the train passes his office).

Drilling, Emergency Preparedness, & Public Engagement

By Danny Kallich, Southwest Pennsylvania Environmental Health Project

This article examines whether emergency responders are prepared in rural areas for oil and gas drilling emergencies, how people may be put at risk if the proper procedures aren’t in place, and other critical safety questions that citizens in Southwest Pennsylvania should be asking.
Drilling and populations as they relate to emergency preparedness in SW PA

Maps of wells per sq. mile and people per well in Washington County, PA

The rapid spread of unconventional natural gas development (UNGD) across Pennsylvania has highlighted the need for state, county, and municipal agencies to regulate industry activity and protect the public on several fronts. In particular, comprehensive emergency preparedness and response specific to natural gas development is an obvious necessity for residents living within close proximity of wells, compressor stations, and other stages of UNGD.

While experts in the field of emergency planning are rightfully responsible for creating and executing emergency plans, the Federal Emergency Planning and Community Right to Know Act of 1986 (EPCRA) defines citizens’ rights to engage in the process, both through open records requests and public meetings with local emergency planners. EPCRA establishes roles and requirements for emergency planners while clarifying the rights of citizens to engage in dialogue with those responsible for safety about potentially harmful industrial activity in their community.

Unique Emergency Preparedness Challenges

UNGD presents a unique set of challenges for residents and emergency planners. The high likelihood that UNGD will be located in a rural area not typically supporting industrial use argues for the need for special treatment by emergency planners. Furthermore, responding to a UNGD emergency requires specialized training that is not mandated for local first responders, often volunteer fire fighters. While local first responders cannot be expected to specialize in UNGD related emergencies, it takes many hours for the contracted well-fire specialists, Texas-based Wild Well Control, to arrive and mitigate an emergency situation. The interim period between the arrival of local and county first responders and the arrival of Wild Well Control is, nonetheless, a critical time during which a system for consistent updates to nearby residents should be a priority. An emergency situation, as demonstrated by the February 11, 2014 Chevron Appalachia well fire, discussed below, can affect a community in a variety of ways, even if evacuation is not necessary.

Chevron Appalachia Incident, Greene County, PA

Testing The System:

Using Right-To-Know requests to gauge transparency & citizen awareness

The opportunities for citizen comment and engagement with emergency planners are limited and not well publicized. The dearth of clear and consistent means of communication between residents and those responsible for emergency planning provides a noteworthy opportunity to test the provisions of EPCRA as they relate to UNGD.

In this regard, testing the emergency response system related to oil and gas drilling emergencies is intended to analyze existent emergency plans, municipal preparedness, communication between county, municipal, and industry emergency planners, and perhaps most importantly, how much of this information is available to citizens.

The transparency of the system was tested by filing Right-To-Know requests. These public information requests were filed with nine municipalities in various counties across the state of Pennsylvania. All filed requests specifically asked for “all available county, municipal, and company generated emergency plans” in relation to specific well sites. One request asked for emergency plans generated by an elementary school in relation to a well site within approximately a half-mile.

Of these nine requests, three were fulfilled with returned emergency plans. Of the remaining six requests, five were not fulfilled because no emergency plan existed on record in the municipality. Initially, the request for the elementary school emergency plan was unable to be met by the municipal open records officer because no plan existed. Two months after that request, an unsolicited response from the same individual was received stating that the now-existent plan could not be shared because of security issues. A final question posed to the open records officer asked what concerned parents might be able to do to prepare themselves for emergency situations. This question, too, was deemed unanswerable due to security reasons. Another unmet municipal request was redirected to a county emergency planner who stated that the company generated plan was not theirs to distribute. Of the three emergency plans received, only one made any specific mention of residents living within close proximity; this response merely stated the number of nearby houses. Excluding GPS coordinates, no plan addressed any other infrastructure specific to the surrounding area, indicating a broad generality to their application.

The fact that six out of nine queried communities in PA were unable or unwilling to provide emergency response plans is highly concerning. These findings, when considered in the broader national context, indicate a significant chance that UNGD specific emergency planning and necessary communication with the public is deficient, particularly on the municipal level.

What Communities Need

Lack of specificity, inter-agency communication, and transparency indicate that the potential of EPCRA to benefit citizens has been largely untapped during the Marcellus Shale boom relative to emergency planning. Residents living within close proximity to UNGD should not only be apprised of emergency risk and strategy before an emergency arises, they should have a clearly accessible venue through which to voice concerns, needs, and recommendations. Furthermore, residents have valid reason to demand greater public oversight of current emergency planning efforts when the overwhelming majority of publicly available emergency plans fail to provide any information useful to a layperson.

Currently, there are communities in which the questionable practice of locating UNGD within a half-mile of elementary schools and other sensitive areas continues. In such areas, every effort must be made to develop, institute, and practice emergency plans prioritizing the concerns, safety, and coordination of local residents. Recommendations for improved transparency include:

  1. Make publicly available site-specific plans,
  2. Hold regular public meetings, and
  3. Prioritize communication between emergency responders and residents during emergency events

We encourage residents who are concerned about what their community is doing for UNGD-specific emergency planning to contact their local emergency responders and attend Local Emergency Planning Committee meetings in their county to advocate for such measures.

About EHP

The Southwest Pennsylvania Environmental Health Project (EHP) is a nonprofit environmental health organization created to assist and support Washington County residents who believe their health has been, or could be, impacted by natural gas drilling activities. Their Mission is to respond to individuals’ and communities’ need for access to accurate, timely and trusted public health information and health services associated with natural gas extraction.