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PA Well Pad Violations map

Well Pad Violations in Pennsylvania

Emerging Trends

We are always learning new things at FracTracker. While we have been analyzing and mapping oil and gas (O&G) violations issued by the Department of Environmental Protection (DEP) in Pennsylvania since 2010, we have apparently been under-representing the total amount of issues associated with unconventional drilling in the state.

The reason for the missing violations is that there are inconsistencies with how well pads are classified in the compliance report. Many of these well pads – full of unconventional permits and drilled wells – are indeed categorized as “unconventional” in the DEP compliance data. Others, equally full of unconventional permits and wells, simply leave that field blank.

Therefore, any analysis for unconventional violations is likely to miss some of the incidents that are attributed to the well pad itself, as opposed to any of the wells that are found upon that well pad.

Midas Well Pad unearths issue

While we have heard about missing violation data in the past, I discovered the nature of the issue while researching the Midas Well Pad in Plum Borough, Allegheny County on the DEP resource site eFACTS, noting the presence of multiple violations at the nascent well site. However, when attempting to download the relevant data on the compliance report, the results were missing. I had entered search parameters that made sense to me, limiting results to violations in the proper county and municipality, and including an inspection date range that was broader than what was showing up on eFACTS. I had also limited results to unconventional wells, because while this is Plum’s first unconventional well pad, the back roads are dotted with dozens – if not hundreds – of conventional O&G sites.

The Midas Well Pad, as seem from Coxcomb Hill Rd. in Plum, PA

After that attempt failed, I downloaded the entire state’s worth of data, whether conventional or not, and I was able to find the 31 violations associated with the well pad.

I contacted DEP about this, wondering whether there was some data irregularity that prevented my search in Plum from finding all of the incidents that occurred there. The reply was somewhat helpful, noting that there was no county, municipality, or unconventional value associated with that well pad in the compliance report, explaining why the search result came up negative.

It is worth noting that the separate well pad report does indeed have values for all of these fields for the Midas Well Pad, so there is a lack of consistency on this issue. Even more importantly, it is worth remembering that any compliance report search that limits results using county, municipality, or unconventional variables are likely to result in incomplete results.

The violations at the Midas Well Pad are focused around erosion and sedimentation issues, wetland impacts, failure to follow approved methodology, and failure to fix some of the problems on subsequent site inspections. The compliance report includes a narrative inspection comment, giving the public a glimpse through the inspector’s eyes. Here is one of several such comments at the site:

Follow up inspection related to wetland impact reported on 2/23/18 and 2/24/18. At the time of inspection, the Operator was actively conducting earth disturbance activity associated with the construction of well pad channel 6. The Department gave verbal permission on 2/27/2018 to deviate from the construction sequence and continue with the construction of PCSM wet pond 1. At the time of inspection wet pond 1 was partially constructed. The outlet structure and emergency spillway associated with wet pond 1. At the time of inspection wet pond 1 was holding water, however the slopes were not temporary stabilized. The Operator indicated that additional work was planned for the wet pond and would be temporary stabilized. The Operator indicated a previously unidentified seep located upgradient and outside of the LOD is contributing additional water to wet pond 1. The Department recommended the Operator identify wet weather springs upgradient from wet pond 1. Additionally, the Department recommends the Operator monitor all additional flow and submit a permit modification outlines changes made to the construction sequence and identifies the location of all toe drains to be constructed on site. The Department and Operator agreed to reschedule an onsite meeting to discuss the remediation of the wetland. Th Department recommends the Operator monitor the vegetative growth in the wetland. The Department recommends that the Operator add additional temporary mulch to the disturbed area and continue to perform routine maintenance to the temporary BMPs.

How pervasive is this problem?

The DEP well pad report contains data on 12,600 wells, situated on 3,715 wells pads. On the compliance side, there are 2,689 violations at 390 different sites that contain the words “Well Pad.” 739 of these violations do not have associated Well API Numbers, and are therefore not shown in our Pennsylvania Shale Viewer map. The number of sites with violations per operator is shown below in Figure 1 (click to expand).

Figure 1: Number of well pads appearing on compliance report by operator, through 5/15/2018. Click on the image to see the full-sized version.

There are four things to note about about Figure 1. 

First, this table is not the number of violations on well pads, but merely the count of well pads with violations appearing on the compliance report.

Second, this does not contain any data on wells on those pads that were issued violations – only instances where the well pads themselves were cited are shown.

PA Well Pad Violations: 

View map fullscreen

This map shows oil and gas (O&G) violations in Pennsylvania that are assessed to well pads, as opposed to individual wells. To access the map’s legend and other details, click the double-arrow icon at the top-left corner of the map.

The third thing to note about Figure 1 is that there are instances where the same pad falls into more than one category. Hilcorp Energy, for example, has 10 wells in the unconventional category, 11 wells that are not defined, but only 13 total wells, indicating significant overlap between the categories.

And fourth, there are 31 instances where the phrase “well pad” occurs in the compliance report where the unique Site ID# does not appear on the well pad report. In some cases, the name of the facility indicates that it might be for another facility that is related to the well pad, such as “Southwest System – Well Pad 36 to Bluestone Pipeline.” For other entries, such as “Yarasavage Well Pad”, it remains unclear why the Site ID# does not yield a matching entry from the well pad report.


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

 

Shell Pipeline - Not Quite the Good Neighbor

Shell Pipeline: Not Quite the “Good Neighbor”

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

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

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

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

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

The “Good Neighbor” Narrative

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

Figure 1. Shell flyer

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

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

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

U.S. Pipeline Incident Data

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

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

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

Shell’s Incident Record

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

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

View Map Fullscreen | How FracTracker Maps Work

Incidents Relative to Other Operators

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

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

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

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

Table 2: Shell incidents and maintained pipeline miles by year

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

Cause & Location of Failure

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

Table 3. Shell Pipeline incidents by cause of failure

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

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

Table 4. Shell Pipeline incidents by location of failure

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

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

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

Table 5. Shell Pipeline incidents by commodity spill volumes

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

Impacts & Costs

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

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

Table 6. Costs of damage from Shell Pipeline incidents

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

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

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

Conclusion

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

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

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

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

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

Header image credit: AFP Photo / Joe Raedle

By Kirk Jalbert, FracTracker Alliance

ME2 pipeline and spills map by Kirk Jalbert

Mariner East 2 Drilling Fluid Spills – Updated Map and Analysis

Updated 8/2/17: An analysis by FracTracker and the Clean Air Council finds that approximately 202,000 gallons of drilling fluids have been accidentally released in 90 different spill events while constructing the Mariner East 2 pipeline in Pennsylvania. In a more recent update, FracTracker estimates these occurred at 42 distinct locations. Explore the map of these incidents below, which we have updated to reflect this growing total.

Last week, a judge with the PA Environmental Hearing Board granted a two week halt to horizontal directional drilling (HDD) operations pertaining to the construction of Sunoco Logistics’ Mariner East 2 (ME2) pipeline. The temporary injunction responds to a petition from the Clean Air Council, Mountain Watershed Association, and the Delaware Riverkeeper Network. It remains in effect until a full hearing on the petition occurs on August 7-9, 2017.

ME2 is a 350-mile long pipeline that, when complete, will carry 275,000 barrels of propane, ethane, butane, and other hydrocarbons per day from the shale gas fields of Western Pennsylvania to a petrochemical export terminal located on the Delaware River.

The petition relates to a complaint filed by the three groups detailing as many as 90 “inadvertent returns” (IRs) of drilling fluids and other drilling related spills along ME2’s construction route. IRs refer to incidents that occur during HDD operations in which drilling fluids consisting of water, bentonite clay, and some chemical mixtures used to lubricate the drill bit, come to the surface in unintended places. This can occur due to misdirected drilling, unanticipated underground fissures, or equipment failure.

What is Horizontal Directional Drilling?

An illustration of an “ideal” horizontal directional drilling boring operation is seen in the first graphic below (image source). The second image shows what happens when HDDs go wrong (image source).

hdd_crossing_example

hdd_ir

Mapping Inadvertent Returns

me2_ir_legendThe Pennsylvania Department of Environmental Protection (DEP) posted information on potential regulatory violations associated with these IRs on the PA Pipeline Portal website on July 24, 2017. This original file listed 49 spill locations. Our original map was based on those locations. As part of their legal filing, volunteer at the Clean Air Council (CAC) have parsed through DEP documents to discover 90 unique spills at these and other locations. On July 31, 2017, the DEP posted a new file that now lists 61 spills, which account for some of these discrepancies but not all.

Working with the CAC, we have created a map, seen below, of the 90 known IRs listed in the DEP documents and from CAC’s findings. Also on the map are the locations of all of ME2’s HDD boring locations, pumping stations, and workspaces, as well as all the streams, ponds, and wetlands listed in Sunoco’s permits as implicated in the project’s construction (see our prior article on ME2’s watershed implications here). Open the map full-screen to see many of these features and their more detailed information.

View map fullscreen | How FracTracker maps work

Analysis Results for ME2

From our analysis, we find that, conservatively, more than 202,000 gallons of drilling fluids have been accidentally released while constructing the Mariner East 2 pipeline in Pennsylvania since the first documented incident on May 3rd. We say conservatively because a number of incidents are still under investigation. In a few instances we may never know the full volume of the spills as only a fraction of the total drilling muds lost were recovered.

We analyzed where these 90 spills occurred relative to known HDD sites and estimate that there are 38 HDDs implicated in these accidents. An additional 11 spills were found at sites where the DEP’s data shows no HDDs, so we calculate the total number of “spill locations” at 42. A full breakdown by county and known gallons spilled at these locations is seen below.

County Number of IRs/Spills Gallons Spilled
Allegheny 4 2,050
Berks 3 540
Blair 3 2,400
Chester 4 205
Cumberland 32 162,330
Delaware 8 2,380
Huntingdon 1 300
Lancaster 7 5945
Lebanon 1 300
Washington 9 4,255
Westmoreland 17 21,532
York 1 25
Total 90 202,262

 

A few important notes on our methods and the available data we have to work with:

  1. CAC obtained spills from DEP incident reports, inadvertent return reports, and other documents describing spills of drilling fluid that have occurred during Mariner East 2 construction.  Those documents reflected incidents occurring between April 25, 2017 and June 17, 2017. In reviewing these documents, volunteers identified 61 discrete spills of drilling fluid, many of which happened at  similar locations. Unfortunately, separate coordinates and volumes were not provided for each spill.
  2. When coordinates were not provided, approximate locations of spills were assigned where appropriate, based on descriptions in the documentation. Two IRs have no known location information whatsoever. As such, they are not represented on the map.
  3. Spill volumes were reported as ranges when there was inconsistency in documentation regarding the same spill. The map circles represent the high-end estimates within these ranges. Of the 90 known spills, 29 have no volume data. These are represented on the map, but with a volume estimate of zero until more information is available.
  4. All documentation available to CAC regarding these spills was filed with the Environmental Hearing Board on July 19, 2017. DEP subsequently posted a table of inadvertent returns on its website on July 24, 2017.  Some of those spills were the same as ones already identified in documents CAC had reviewed, but 29 of the spills described on the DEP website were ones for which CCAC had never received documentation, although a subset of these are now listed in brief in the DEP spreadsheet posted on July 31, 2017. In total then, the documentation provided to CAC from DEP and spreadsheets on the DEP website describe at least 90 spills.

HDD Implications

The DEP’s press release assures the public that the drilling fluids are non-toxic and the IRs are “not expected to have any lasting effects on impacted waters of the commonwealth.” But this is not entirely the case. While the fluids themselves are not necessarily a public health threat, the release of drilling fluids into aquifers and drinking wells can make water unusable. This occurred in June in Chester County, for example.

More commonly, drilling fluid sediment in waterways can kill aquatic life due to the fine particulates associated with bentonite clay. Given that HDD is primarily used to lay pipe under streams, rivers, and ponds (as well as roads, parks, and other sensitive areas), this latter risk is a real concern. Such incidents have occurred in many of the instances cited in the DEP documents, including a release of drilling muds into a creek in Delaware County in May.

We hope the above map and summaries provide insights into the current risks associated with the project and levels of appropriate regulatory oversight, as well as for understanding the impacts associated with HDD, as it is often considered a benign aspect of pipeline construction.


By Kirk Jalbert, Manager of Community Based Research and Engagement, FracTracker Alliance

If you have any questions about the map on this page or the data used to create it, please contact Kirk Jalbert at jalbert@fractracker.org.

Water supplies article

Risks to Water Supplies in PA’s Susquehanna Basin

In this series of articles on the Susquehanna River Basin, FracTracker has explored the relationship between oil and gas extraction and the overall health of the watershed relative to oil and gas extraction impacts. We began with a basic overview of likely relationships, followed by an analysis of oil and gas violations relative to resources available for monitoring water quality changes. In the most recent article we assessed the corresponding effects of extraction on deforestation and habitat loss. With the rapid expansion of oil and gas drilling over the past decade, many have also formed legitimate concerns about threats to public and private water supplies. In the final article of the series we look closely at this issue, at the complexities of assessing risks to water supplies, while also highlighting recent research shedding new light on the nature of these risks.

Pennsylvania’s Hydrological System

The Susquehanna River is home to more than 3.3 million people who depend on the river and its tributaries for drinking water. The basin also feeds thousands of businesses that require water for their operations, such as manufacturing facilities, farms, golf courses, and more. In some instances, water supplies are fed by groundwater wells, which are in turn fed by underground aquifers of different depths. In other cases, water supplies are drawn from intake points in nearby lakes, rivers, and streams.

Map of PA's groundwater aquifer system.

Figure 1: Map of PA’s groundwater aquifer system.

While many believe underground and surface water systems are somehow discrete, this is far from the case. Groundwater is a major contributor to rivers, lakes, and wetlands – as they are all connected through the hydrological cycle. Some precipitation runs directly into streams. But much of it filters through soil and rock into shallow and deep aquifers. Aquifers then carry water over the course of months, years, and even centuries, into larger water bodies. The most common discharge points are from springs and from low-lying wetlands. The figures above (figure 1) and below (figure 2) illustrate Pennsylvania’s four major aquifer types, compiled by Penn State Extension.

Figure 3: Types of groundwater aquifers in PA.

Figure 2: Types of groundwater aquifers in PA.

Assessing Groundwater Supply Risks

Managing the overall health of the hydrological cycle is of critical importance to the 3.3 million people who live in the Susquehanna River Basin. However, oil and gas extraction poses significant risks to the state’s water sources. As we have detailed in prior articles in this series, accidents and spills can cause chemicals and hydraulic fracturing fluids to run off into nearby watersheds. Growing evidence also suggests that groundwater can be contaminated by migrating hydraulic fracturing fluids.

Figure 4: Number of household and public water supply groundwater wells by state (DCNR).

Figure 3: Number of household and public water supply groundwater wells by state (DCNR).

In one study, conducted by Columbia University in 2016, researchers found elevated levels of dissolved calcium, chlorine, sulfates and iron in lowland drinking wells within one kilometer of a drilling site compared to baseline averages. In lowland wells more than a kilometer away, they found elevated levels of methane, sodium, and manganese. Elevated levels dropped off in wells on higher ground, which suggests the hydraulic fracturing process affects shallow and deep groundwater sources along different timelines.

According to the PA Department of Conservation and Natural Resources (DCNR), Pennsylvania ranks second in the nation for total number of groundwater wells, second for number of private drinking wells, and third for number of public water supplies dependent on groundwater wells (figure 4). However, determining how many groundwater wells may be at risk to oil and gas extraction is complicated for a variety of reasons. First, DCNR acknowledges that only about half (480,000) of the 1 million groundwater wells in the state are documented. Registration of groundwater wells only began in 1955, and detailed information including latitude and longitudinal coordinates only came into being in the 1980s. These records are now maintained in the PA Groundwater Inventory System (PAGWIS). It is worth noting that the PA Department of Environmental Protection (DEP) does not regulate private drinking water wells. They are only required to respond to pollution complaints.

Correlating O&G Wells to Complaints Data

Despite these data gaps, we can still learn a lot from the wells that are documented in PAGWIS. For instance, we compared the location of groundwater wells to oil and gas related complaints and found some interesting correlations. The below map can be used to explore these relationships.

Map of at-risk groundwater wells, public water supplies, and citizen complaints


View Map Fullscreen | How FracTracker Maps Work

The first stage our analysis involved narrowing the PGWIS registered groundwater wells in the Susquehanna Basin to those that are actively used for drinking water, agriculture, and irrigation (66,306 total). We then limited to those within 1 kilometer of an oil and gas well, essentially mirroring the distances used by the Columbia University study. We found 2,551 groundwater wells within this “risk zone” of 1 kilometer.

For our second stage, we utilized research conducted by Public Herald, an investigative reporting team that spent three years reviewing oil and gas related complaints submitted to the DEP from 2004-2016. They found 9,442 total complaints, of which 43% were water related (surface and groundwater), and that the frequency of complaints track with the rise and fall of unconventional oil and gas development (figure 5).

Figure 5: Relationship of complaints to O&G development (Public Herald).

Figure 4: Relationship of complaints to O&G development (Public Herald).

From the Public Herald dataset, we found 1,573 total complaints were in the Susquehanna River Basin, of which 65% were water related complaints — a much higher percentage than the larger dataset’s average. We then compare the location of these complaints to our “risk zone” groundwater wells and found a statistically significant correlation between the number of groundwater wells within 1km of oil and gas activity and higher numbers of complaints by residents. What do these findings tell us?

In short, where we see more groundwater wells in proximity to an oil and gas well, we also see more water related complaints to the DEP.

The below graph illustrates this relationship (figure 6).

Figure 6: Relationship of complaints to at-risk groundwater wells.

Figure 5: Relationship of complaints to at-risk groundwater wells.

Groundwater to Surface Water Risks

DCNR estimates that Pennsylvania’s streams and wetlands get about 2/3 of their flow from groundwater sources. Meanwhile, there are 786 public water suppliers in the Susquehanna River Basin that are fed by different arrangements of groundwater and surface water sources. These suppliers are included in the interactive map for reference.

Assessing risks to public water supply systems is equally complicated to that of groundwater wells. The DEP regulates public water suppliers under the Safe Drinking Water Act, but the general public is not permitted to know the location of actual water sources or intake points due to security risks. This restriction poses a problem for nongovernmental organizations when doing analyses that would benefit from knowing the locations of these source points. Nevertheless, like our breakdown of risk zone groundwater wells, we can still learn a great deal from what we do know of public water supplies.

Figure 6: Wellsboro, PA, public water supply along with O&G wells and water-related citizen complaints in the supply watershed.

Figure 6: Wellsboro, PA, public water supply with O&G wells and citizen complaints in the supply’s watershed.

For instance, the town of Wellsboro, in Tioga County, is home to an estimated 3,300 people. The Wellsboro Municipal Authority supplies water to Wellsboro residents as well as to 1,000 people in surrounding Charleston and Delmar Townships. According to DEP records, groundwater and surface water sources for this system come from Hamilton Lake and tributaries of the Charleston Creek Watershed, much of which is designated as high-quality coldwater fisheries. Nevertheless, there are seven unconventional oil and gas wells in this watershed, one of which is only 400ft from Charleston Creek, just upstream from Hamilton Lake.

The area is also one of the brightest hot-spots for complaints to the DEP in the Public Herald dataset, with 40 water related complaints in Charleston and Delmar townships.

These relationships should be of particular concern to residents who believe their water is protected from extraction industry activities. In addition, while recent research suggests homes values can be negatively affected in neighborhoods dependent on private well water near drilling activity, correlations between potential groundwater and surface water pollution suggest that any changes in home value are more a matter of perceived rather than actual risk—homes on public water supplies should also be considered at risk in communities experiencing extraction.

Conclusion

Returning to the hydrological cycle, we can assume that pollutants from oil and gas extraction, like precipitation, will eventually find their way into larger water bodies, either directly through runoff into watershed tributaries or through groundwater migrations. While this article has primarily focused on the Pennsylvania headwaters of the Susquehanna, home to 570,000 residents, and risks to their water sources, groundwater complaints are not the exclusive problem of residents who are dependent on private drinking water wells. “We all live downstream” as the saying goes, and those who rely on the watershed for their drinking water and other water resource needs throughout the watershed should be concerned by the correlations illustrated in our analysis.


By Kirk Jalbert, Manager of Community based Research & Engagement, FracTracker Alliance

Feature image: Hydrologic cycle graphic by Watershed-Watch.org

Susquehanna River Basin map article #2

Violations and Monitoring in Pennsylvania’s Susquehanna River Basin

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

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

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

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

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Limitations of Monitoring Efforts

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

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

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

Case Studies

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

Dimock

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

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

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

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

Leroy Township

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

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

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

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

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

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

Bell Township

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

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

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

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

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

Conclusions

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

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

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

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

PA Oil & Gas Fines feature image

Pennsylvania Oil & Gas Fines Analysis

In March 2017, FracTracker Alliance conducted a review of the available Pennsylvania oil and gas fine data released publicly by the PA Department of Environmental Protection (DEP) to identify trends in industry-related fines over time and by particular operators. In total, the DEP has assessed nearly $36 million in fines to oil and gas extraction and pipeline operators since January 1, 2000. Such fines are associated with over 42,000 violations issued1 by DEP in that time frame, covering 204,000 known oil and gas locations,2 as well as 91,000 miles of pipelines3 within the Commonwealth.

Understanding the Data Structure

The amount of money that the Pennsylvania Department of Environmental Protection (DEP) fines oil and gas (O&G) operations is included in the DEP’s compliance report published on their website. Even though fines data are made available, they are not necessarily straight-forward, and caution must be taken not to over-estimate the total number of assessed fines.

Records of fines are associated with enforcement identification codes on the compliance report. A single fine is often applied to numerous violations, and the full amount of the fine is listed on every record in this subset. Therefore, the total dollar amount of fines assessed to O&G companies appears overstated. For example, if a $400,000 fine were assessed to settle a group of 10 violations, that figure will appear on the report 10 times, for an apparent aggregate of $4,000,000 in fines. To get an accurate representation of fines assessed, we need to isolate fines associated with particular enforcement ID numbers, which are used administratively to resolve the fines.

This process is further complicated by the fact that, on occasion, such enforcement ID numbers are associated with more than one operator. This issue could result from a change in the well’s operator (or a change of the operator’s name), a group of wells in close proximity that are run by different operators, or it might point to an energy extraction company and a midstream company sharing responsibility for an incident. Sometimes, the second operator listed under an enforcement ID is in fact “not assigned.” The result is that we cannot first summarize by operator and then aggregate those subtotals without overstating the total amount of the assessed fines. In all, 62 of the enforcement ID numbers apply to more than one operator, but this figure amounts to less than one percent of the nearly 15,000 distinct enforcement ID numbers issued by DEP.

Conventional & Unconventional Violations & Fines

Oil and gas wells in Pennsylvania are categorized as either conventional or unconventional, with the latter category intended to represent the modern, industrial-scaled operations that are commonly referred to as “fracking wells.” Contrastingly, conventional wells are supposed to be the more traditional O&G wells that have been present in Pennsylvania since 1859. The actual definition of these wells leaves some blurring of this distinction, however, as almost all O&G wells now drilled in Pennsylvania are stimulated with hydraulic fracturing to some degree, and some of the conventional wells are even drilled horizontally – just not into formations that are technically defined as unconventional. For the most part, however, unconventional remains a useful distinction indicating the significant scale of operations.

Table 1. Summary of oil and gas wells, violations, and fines in Pennsylvania

Category Conventional Unconventional (blank) Total
Wells 193,655 10,291 0 203,946
Violations 27,223 6,126 9,026 42,375
Fines $7,000,203 $13,689,032 $21,563,722 $35,949,495*
Fines per Violation 257 2,235 2,389 848
Fines per Well 36 1330  – 176.27
Violations per Well 0.14 0.60  – 0.21
Wells per Violation 7.11 1.68  – 4.81
* The total fine amount issued is not a summary of the three preceding categories, as some of the fines appear in multiple categories

Ninety-five (95)% of the state’s 204,000 O&G wells are classified as conventional, so it should not be surprising to see that this category of wells accounts for a majority of violations issued by the department. However, fines associated with these violations are less frequent, and often less harsh; the $7 million in fines for this category accounts for only 19% of the total assessed penalties. In contrast, the total penalties that have been assessed to unconventional wells in the state are nearly twice that of conventional wells, despite accounting for just 5% of the state’s well inventory

On the 54,412 records on the compliance report, 10,518 (19%) do not indicate whether or not it is an unconventional well. The list of operators includes some well-known conventional and unconventional drilling operators, and hundreds of names of individuals or organizations where O&G drilling is not their primary mode of business (such as municipal authorities and funeral homes). This category also contains violations for midstream operations, such as pipelines and compressor stations. Altogether, 3,795 operators have entries that were not categorized as either conventional or unconventional on the compliance report, and 124 of these operators were issued fines. One additional complication is that some of the violations and fines that fall into this category are cross-referenced in the conventional and unconventional categories, as well.

The resulting impact of these factors is that the blank category obscures the trends for violations and fines in the other two categories. While tempting to reclassify well data in this category as either conventional or unconventional, this would be a tall task due to the sheer number of records involved, and would likely result in a significant amount of errors. Therefore, the FracTracker Alliance has decided to present the data as is, along with an understanding of the complexities involved.

Most Heavily Fined Operators

Despite the numerous caveats listed above, we can get a clear look at the aggregated fines issued to the various O&G operators in the state by constructing our queries carefully. Table 2 shows the top 12 recipients of O&G-related fines assessed by DEP since 2000. Ten of these companies are on the extraction side of the business, and the total number of well permits issued4 to these companies since 2000 are included on the table. By looking at the permits instead of the drilled wells, we discover the operator that was originally associated with the drilling location, whereas the report of drilled wells associates the current operator associated with the site, or most recent operator in the event that the location is plugged and abandoned.

Stonehenge Appalachia and Williams Field Services operate in the midstream sector. Combining the various business name iterations and subsidiaries would be an enormous task, which we did not undertake here, with the exception of those near the top of the list. This includes Vantage Energy Appalachia, which was combined with records from Vantage Energy Appalachia II, and the compliance history of Rice Energy is the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.

Table 2. Top 12 operators that have been assessed oil and gas-related fines by DEP since 2000

Operator Total Fines Conventional Permits Unconventional Permits Violations Fines / Violation Fines / Permit
Range Resources Appalachia LLC $5,717,994 2,104 2,206 819 $6,982 $1,327
Chesapeake Appalachia LLC $3,120,123 18 3,072 754 $4,138 $1,010
Rice Energy* $2,336,552 442 165 $14,161 $5,286
Alpha Shale Res LP $1,681,725 3 62 31 $54,249 $25,873
Stonehenge Appalachia LLC $1,500,000  – 294 $5,102
Cabot Oil & Gas Corp $1,407,275 19 902 726 $1,938 $1,528
CNX Gas Co LLC $1,274,330 1,613 677 387 $3,293 $556
WPX Energy Appalachia LLC $1,232,500 347 159 $7,752 $3,552
Chevron Appalachia LLC $1,077,553 2 604 113 $9,536 $1,778
Vantage Energy Appalachia LLC** $1,059,766 3 300 35 $30,279 $3,498
Williams Field Services Co, LLC $872,404  – 158 $5,522
XTO Energy Inc $739,712 1,962 461 383 $1,931 305
* Fines for Rice Energy here represent the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.

** Fines for Vantage Energy Appalachia were combined with records from Vantage Energy Appalachia II.

Predictably, many of the entries on this list are among the most active drillers in the state, including Range Resources and Chesapeake Appalachia. However, Alpha Shale Resources has the dubious distinction of leading the pack with the highest amount of fines per violation, as well as the highest amount of fines per permit. Fitting in with the theme, the story here is complicated by the fact that Alpha had a joint venture with Rice, before selling them their stake in a group of wells and midstream operations that were fined $3.5 million by DEP.5 On this compliance report, the fines from this incident are split between the two companies.

Fines Issued Over Time

It is worth taking a look at how O&G related fines have varied over time, as well (Figure 1, shown in millions of dollars). Numerous factors could contribute to changes in trends, such as the number of available DEP inspectors,6 the amount of attention being paid to the industry in the media, differing compliance strategies employed by various political administrations, or changes in practices in the field, which could in turn be impacted by significant fines issued in the past.

PA Oil & Gas Fines Analysis chart

Figure 1. O&G Fines Issued by DEP, 2000 through 2016

The notable spike in fines issued from 2010 to 2012 corresponds with the peak of unconventional drilling in the state – 4,908 of these industrial scaled wells were drilled during those three years, amounting to 48% of all unconventional wells in PA. In contrast, only 504 unconventional wells were drilled in 2016, or around a quarter of the total for 2011. In this context, the reduction in fines since the early part of the decade seems reasonable.

The association with the number of unconventional wells falls apart a bit in the years 2013 to 2014, however. These two years saw an average of 1,293 unconventional wells drilled, but the fines issued amounted to only 35% of the 2011 total.

Considerable strides have been made in the public accessibility of oil and gas data available from the PA DEP since FracTracker started requesting and reviewing this information in 2009. Still, there are many gaps in the datasets, such as geolocation details for 10 of the 20 largest fines issued by the department. FracTracker hopes external analyses like this one will help to close such gaps and identify operators who, too, need to improve their compliance records.

References & Footnotes

  1. Pennsylvania Department of Environmental Protection (PA DEP) Oil and Gas (O&G) Compliance Database.
  2. PA DEP O&G Spud Database. Note: Starting date 1/1/1800 captures unknown spud (wells drilled) dates.
  3. Pipeline Hazardous Materials and Safety Administration (PHMSA) Pipeline Data Mart Reports.
  4. PA DEP Permits Issued Database.
  5. State Impact PA. (2016). Rice Energy fined $3.5 million for wellsite and pipeline violations.
  6. PennEnvironment Research & Policy Center. (2017). Fracking Failures 2017, Oil and Gas Industry Environmental Violations in Pennsylvania.

Oil & Gas Fines White Paper

This analysis is also available for download in a printer-friendly, white paper format:


Cover Photo by Pete Stern, Loyalsock, PA

South Belridge field by Sarah Leen, National Geographic

Trends in California’s Oil and Gas Development

By Kyle Ferrar, Western Program Coordinator

Over 38,000 oil and gas wells have likely been hydraulically fractured in California. The last permitted hydraulic fracturing operation in CA was approved in June 2015. Additionally, new aquifer exemption proposals will make it easier for operators to obtain hydraulic fracturing permits. One of the most interesting and troubling issues we found when analyzing the data on violations is that operators with the highest number of new well permits are also responsible for the majority of violations. In this article, we provide a look at these and other the trends of unconventional drilling in CA.

Updated CA Shale Viewer

First of all, the CA Shale Viewer has been updated! New data has been uploaded into the map about unconventional drilling in California, and new data resources have been used to identify shale gas activity (Fig. 1). Recent reports in CA have exposed what many researchers expected – hydraulic fracturing has been occurring in the state without any oversight or documentation for a long time.

In this presentation of the Updated CA Shale Viewer we showcase an analysis of these new data sources that better describe unconventional drilling in CA. We then look to new well permitting data to see what current spatial trends may mean for future oil and gas development. We also look at a sample of operator violations issued by the state regulatory agency to tell us a bit about who the bad actors may be.

Figure 1. CA Shale Viewer – Location of well stimulation & other unconventional oil & gas activity


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Current Fracking Activity

Fracking in California has been put on hold at the moment as a result of low oil prices combined with the new permitting requirements for groundwater monitoring. In 2015, the CA Council on Science and Technology (CCST) released a report on hydraulic fracturing, as required by State Bill 4, proposed by Senator Pavley. The legislation required the Division of Oil, Gas and Geothermal Resources to create regulations for hydraulic fracturing and other stimulation activities such as acidizing. The report highlighted the necessity of protecting California’s groundwater resources. As another requirement of SB4, the state water resources control board adopted Model Criteria for Groundwater Monitoring in areas of Oil and Gas Well Stimulation, which includes three main components:

  1. Area-specific required groundwater monitoring near stimulation wells by operators
  2. Requirements for designated contractor sampling and testing
  3. Regional scale groundwater monitoring to be implemented by the State Water Board

With these requirements in place to protect groundwater, using hydraulic fracturing and other “extreme” high energy input techniques to extract oil is not currently economical in California. Operators have not submitted a permit application for hydraulic fracturing in CA since June 2015.

This status may change in the near future, though, as DOGGR has proposed groundwater monitoring exemptions for 3 large aquifer systems in Kern and Arroyo Grande counties. Such a proposal would mean that operators would not have to monitor for groundwater contamination in these areas when using hydraulic fracturing or other stimulation technologies like acidizing.

Previous Fracking Activity

One outcome of the aforementioned CCST report on hydraulic fracturing was a review of stimulation activity that has occurred in CA but went undocumented. Researchers at Lawrence Berkeley National Laboratory (LBNL) screened thousands of oil and gas well logs and records to calculate the extent to which hydraulic fracturing was actually being used in California’s oil fields. LBNL derived “Well Stimulation Treatment” probabilities based on the number of well records that reported utilizing hydraulic fracturing.

Probabilities were then derived for each pool, which is a geographically isolated formation within an oil field. Using these probabilities, FracTracker calculated a conservative estimate for the number of stimulated wells in the state at over 38,000. There are 228,010 unique Well ID’s listed in the DOGGR database. This puts the proportion of hydraulically fractured wells in California at 16.7% of the total 228,090 wells known.

New Wells

Whereas many other states break down their oil and gas data to show in what phase of development a well may be, CA identifies all wells between the permitted and producing/injecting phase as “new.” In Figure 2 below you can see the wells identified in 2016 as “new.” The DOGGR dataset shows there are currently 6,561 new wells in California as of July 2016. Counts of new well permits were calculated for individual operators and are listed below in Table 1.

Table 1. Top 10 operators according to new well permit counts in California, along with the number of new well permits currently active, the percent those permits represent of total new well permits in the state, and the percentage of violations the operator is responsible in the DOGGR dataset provided to FracTracker Alliance.

Order Operator Permit Count Permit % Violations %
1 Aera Energy LLC 2012 30.67% 22.34%
2 Chevron U.S.A. Inc. 968 14.75% 20.35%
3 California Resources Production Corporation 768 11.70% 5.89%
4 Linn Operating, Inc. 574 8.75% 12.04%
5 E & B Natural Resources Management Corporation 572 8.71% 1%
6 California Resources Elk Hills, LLC 374 5.70% 5.52%
7 Seneca Resources Corporation 185 2.82% 2.83%
8 Freeport-McMoRan Oil & Gas LLC 164 2.50% 15.22%
9 Vaquero Energy, Inc. 154 2.35% 0.22%
10 Macpherson Oil Company 116 1.77% 2.09%

There are 68 fields in CA that have added new wells in the new DOGGR dataset published in July 2016. The top 10 fields are listed in Table 2 below.

Table 2. Top 10 Oil Fields by Permit (New Well) Count

Order Oil Field Well Count
1 Belridge, South 1518
2 Midway-Sunset 903
3 Poso Creek 553
4 Lost Hills 488
5 Cymric 336
6 Kern River 294
7 Elk Hills 276
8 Kern Front 233
9 McKittrick 186
10 Belridge, North 174

In Figure 2 below, the counts of new wells in fields are shown in shades of yellow/red. The fields with the highest number of new wells are located in the Central Valley. The top 10 operators’ wells are also identified. The majority of new well permits are located in the South Belridge oil field, and the majority of those wells are operated by Aera Energy. As can be seen in the map, most new wells are located in fields in Kern county, but Santa Barbara and Fresno, and even Salinas counties have fields with 40 or more new well permits.

Figure 2. New Well Permitting Map of Unconventional Drilling in California


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Violations

Who collects violations data?

In most states with heavy oil and gas drilling, data on violations is collected by the state regulatory agency, aggregated in datasets and spreadsheets, and made available to the public. FracTracker has done analyses with such data in the past.

In Pennsylvania for instance, a 2011 look at the data showed us that as the number of inspectors on the ground in the Marcellus Shale fields increases, the number of violations/well actually decrease. This was important information that challenged the cynical hypothesis: that more inspectors mean additional eyes on the ground to identify more violations during inspections. In reality, more inspectors actually mean that operators are held to higher standards, and further best management practices (BMPs) are employed. This trend at least seemed to be the case in Pennsylvania. As a regulatory agency, such knowledge is incredibly important, and even validates increased spending and budgets for more personnel.

In California, the issue of publishing violations data is again met with a similar response from the Division of Oil Gas and Geothermal Resources (DOGGR), specifically the “Oh, is that my job?” question.

How is it shared?

At FracTracker, we spent time working with regulatory officials at DOGGR to get some data on violations. We were informed that at some point in the future, the data may be aggregated and available digitally. Until then, however, a request for the data would have to be made to each of the six district offices individually and would take approximately a year to pull together scanned copies of violations notices in PDF format. Unfortunately, we at FracTracker do not have the capacity to process such files. Instead we asked for anything DOGGR had digitally available, and we were provided with a sample subset of 2,825 violations dating mostly from 2013 and 2014 and only in District 2, the Los Angeles Basin.

What does CA violations data look like?

Looking at the sample of data in Table 2, we see that the majority of violations are caused by the operators that also have the most new well permits. Aera Energy, in particular, is responsible for over 1/5 of all violations in our sample set. Limiting factors and sampling bias of the sample set of violations may impact this analysis, though, as all violations are limited to Los Angeles County.  Operators that mostly operate in the Central Valley will be under represented in the violations count. When more violations data becomes available we will be sure to expand this analysis.

Bans and Regulations on Unconventional Drilling in California

Although every state regulatory agency lambasts that they have the most comprehensive and conservative set of oil and gas extraction regulations, California regulators may actually be right. That is, save for New York which has banned hydraulic fracturing outright.

Regardless of the policy decisions made at the state-level, multiple local municipalities in CA have attempted to or succeeded in passing local bans. Six counties have passed outright bans on unconventional drilling in California, as can be seen in the FracTracker Local Actions map below (Fig. 3). Most recently the county of Alameda, home to the cities of Berkeley and Oakland, has passed a ban. The county of Monterey is also considering a ban on all oil and gas extraction, which has been approved as a local ballot initiative for November 2016.

Figure 3. Local Actions, Bans and Regulations Map


View map fullscreen | How FracTracker maps work

As the price of oil rebounds closer to $100/barrel, there will be more interest by operators to increase unconventional drilling in California. The addition of new aquifer exemptions will make it all the more appealing. These local movements are therefore incredibly important to ensure that “extreme” extraction methods like fracking don’t expand in the future.

Feature Photo: South Belridge field by Sarah Leen, National Geographic

Approaching 10K Unconventional Wells in PA

Approaching 10K Unconventional Wells in PA

By Matt Kelso, Manager of Data & Technology

Each state has its own definition of what it means for an oil or gas well to be “fracked.” In Pennsylvania, these wells are known as “unconventional,” a definition mostly based on the depth of the target formation:

An unconventional gas well is a well that is drilled into an unconventional formation, which is defined as a geologic shale formation below the base of the Elk Sandstone or its geologic equivalent where natural gas generally cannot be produced except by horizontal or vertical well bores stimulated by hydraulic fracturing.

The count of these unconventional wells in PA stands at 9,760 as of June 14, 2016. Their distribution is widespread across the state, but is particularly focused in the northeast and southwest corners of Pennsylvania.

Unconventional oil and gas wells in Pennsylvania:

View map full screen | How FracTracker maps work

Wells Drilled

The industry is not drilling at the same torrid pace as it was between 2010 and 2012, however. The busiest month for drill rigs in the Keystone State was August 2011, with 210 unconventional wells drilled. Last month, there were just 32 such wells.

Unconventional wells in PA: Unconventional oil and gas permits, wells, and violations in Pennsylvania by quarter. Data source: Pennsylvania DEP

Figure 1. Unconventional oil and gas permits, wells, and violations in Pennsylvania by quarter. Data source: Pennsylvania DEP

Permits

As Figure 1 captures, the number of permits issued per quarter is always greater than the number of wells drilled during the same time period. Even when drilling activity seems to be entering a bust phase, oil and gas operators continue to plan for future development. Altogether, there are 17,492 permitted locations, meaning there are about 7,700 permitted locations where drilling has not yet commenced.

Violations

The number of violations issued by DEP is generally follows the same trends as permits and wells. It is usually the smallest of the three numbers. In the first quarter of 2016, however, is one of a few instances on the chart above where the number of violations issued outpaced wells drilled. There could be any number of reasons for this anomaly; it could have been due to to unusual compliance issued in the field or aggressive regulatory blitzes. It could also be due to some other factor that can’t be determined by the available published data source.

Interestingly, this phenomenon has not occurred since the first quarter of 2010, when the industry was in full swing.

About VpW

One of the best ways to understand the impact of the industry is to look at violations per well (VpW). Unfortunately, there are a number of important caveats to that discussion. First of all, not all items that appear on the compliance report receive their own Violation ID number. It is clear from the DEP workload report that violations are tallied internally by the number of Violation ID numbers. This is as opposed to the number of items on the compliance report. As of June 14, 2016, there were 6,706 rows of data and 5,755 distinct Violation ID numbers that were issued to 2,080 different oil and gas wells. This discrepancy means that about 21% of unconventional wells are issued violations in Pennsylvania. Those that are cited receive an average of 2.8 to 3.2 violations per well, depending on how you count them.

Unconventional Wells in PA: Violations per well (VpW) of the 20 companies with the most unconventional wells in PA.

Table 1. Violations per well (VpW) of the 20 companies with the most unconventional wells in PA.

Determining the violations per well by operator comes with additional caveats. The drilled wells data comes from the spud report, which lists the current operator of each of the wells. The compliance report, however, lists the operator that was in charge of the well at the time of the infraction. This poses a problem for analysis, however. The ownership of the wells is quite fluid when taken in aggregate, as companies fold, are bought out, or change their names to something else.

VpW Results

We calculated VpW figures for the 20 operators with the largest inventory of drilled wells wells in Pennsylvania, found in Table 1. In some instances, we were able to reunite operators with violations that were issued under a different name but are in fact the same company. Specifically, we combined Rex Energy’s violations with RE Gas Dev, CONSOL violations with CNX, and Southwestern with SWN Productions, as the company is now known.

SWN’s violation-per-well score appears to be quite low. Their statistic, however, does not take into account wells that it purchased from Chesapeake in 2014, for example. In this transaction, 435 wells changed hands, with an unknown number of those in Pennsylvania. Any violations on these wells that Chesapeake had would stay with that company even as their well count was reduced. Such a change would thereby artificially inflate Chesapeake’s VpW score. On the other hand, SWN is now in possession of a number of wells which might have been problematic during the early stages of operation. Those violations, alternatively, are not associated with SWN, making their inventory of wells appear to be less problematic.

Data Caveats and Takeaways

Alas, we do not live in a world of perfect data. As such, these results must be taken with a grain of salt. Still, we can see that there are some trends that persist among operators that have been active in Pennsylvania for many years. Chief, Cabon, and EXCO, for example, all average more than one violation per well drilled. Chevron, CNX, and RE Gas Development, on the other hand, have much better rates of compliance, on the order of one violation per every five wells drilled.

Defining Environmental Justice in Pennsylvania

By Kirk Jalbert, Manager of Community-Based
Research & Engagement, FracTracker Alliance

Missing the Mark in Oil & Gas Communities

Conventional oil and gas drilling for commercial purposes has existed in Pennsylvania for over 150 years. In the past decade, drilling operations have turned to extract these resources from unconventional reservoirs, such as the deep underground Marcellus Shale formation. Proponents of the oil and gas industry’s expansion promise jobs and tax revenue for regions seeking economic revitalization. However, a growing body of research suggests that these processes also negatively impact the environment and pose significant public health risks.

According to the U.S. Environmental Protection Agency, environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. How this definition applies to residents of Pennsylvania has become a hotly contested issue as regulatory agencies have begun to investigate whether or not the oil and gas industry targets marginalized communities.

PA Environmental Justice Map

The following interactive article and map illustrates how race and poverty, the two key indicators for determining environmental justice eligibility, fail to capture the nature of the industry. It also suggests that there are other ways we might assess unfair development practices. In doing so, the goal of the article is to shed light on the complexity of environmental justice issues and to offer guidance as PA’s Department of Environmental Protection (DEP) assesses its policies in coming days.

environmental justice map

Feature image photo credit: Drilling rig and farm in PA by Schmerling (photodocmark@gmail.com)

Aliso Canyon natural gas leak - Photo by Environmental Defense Fund

A Climate Disaster – California in state of emergency as a result of massive natural gas leak

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

A natural gas well equipment failure in southern California has resulted in the largest point release of methane to the atmosphere in U.S. history. California Governor Jerry Brown has declared a California state of emergency for the incident, and the California Air Resources Board (CARB) has identified the site as the single largest source point of global warming.1 Since October 23, 2015 the failure has been reported to be releasing 62 million cubic feet of methane per day – 110,000 pounds per hour – for a total of about 80 million metric tons thus far. (A running counter for the natural gas leak can be found here, on Mother Jones).2,3 This quantity amounts to a quarter of California’s total methane emissions, and the impact to the climate is calculated to be the equivalent of the operation of 7 million cars.

SoCalGas (a subsidiary of Sempra Energy) reports that nothing can be done to stop or reduce the leak until February or March of 2016. As a result, the nearby community of Porter Ranch has been largely evacuated (30,000 people) due to health complaints and the rotten egg smell of tertbutyl mercaptan and tetradydrothiophen. Air quality sampling, being assessed by the Office of Environmental Health Hazard and Assessment (OEHHA), measured volatile organic compounds, specifically the carcinogen benzene, at concentrations below acute toxicity health standards.4 Exposure to benzene even at low levels presents a risk of cancer and other health hazards. Locals have complained of headaches, sore throats, nosebleeds and nausea. The LA County Department of Public Health has ordered SoCalGas to offer free temporary relocation to any area residents affected. About 1,000 people are suing the company.5 A fly over of the site has been posted to youtube by the Environmental Defense Fund, and can be seen here. The video uses a FLIR camera to take infrared video that shows the leak.

Site Description

CA gas storage and Aliso Canyon natural gas leak

Figure 1. California active natural gas storage fields most active in 2014

The source of the leak is a natural gas storage well operated by SoCalGas in the Aliso Canyon oil field – a drained oil field now used to store natural gas. SoCalGas is the largest natural gas utility in the U.S., distributing natural gas to 20.9 million.4 Aliso Canyon is the largest gas storage field in the state, but there are numerous other gas storage fields in the state that could present similar risks. In Figure 1, to the right, California’s other currently active gas storage fields are shown. Injection volumes of natural gas are summed and averaged over the area of the field, and the Aliso Canyon is shown to have injected over 1,000,000 cubic feet per km2 of natural gas since the beginning of 2014. Other high volume fields include Honor Rancho, McDonald Island Gas, and Wild Goose Gas.

The failed well, known as Standard Sesnon 25, is marked with a red star in the map of gas storage wells shown below (Figure 2). The well was drilled in October of 1953. Reports show that pressures in the well bored reached 2,516 PSI in 2015. If you use the map to navigate around the state of California, it is clear that there are numerous other natural gas storage facilities in California, with wellbore pressures similar to or higher than the reported pressure of Standard Sesnon 25 and other wells in the Aliso Canyon Field. Beyond California, the state of Michigan is reported to have the most natural gas storage by volume, at 1.1 trillion cubic feet.6 The incident that caused the leak was a well casing failure, although the cause of the well casing failure has not yet been identified. There have been numerous editorials written that have painted SoCalGas as a model for contemporary corporate greed and corruption for several reasons, including the removal of safety valves, reports of corrosion, and lack of resources for inspections and repairs.7 Rather than this being a unique case of criminal neglect, casing failures are a statistical likelihood for wells of this age. Well casing failures are a systemic issue of all oil and gas development. Every well casing has a shelf life and will fail eventually.8 Additionally, leaks from gas storage wells have occurred at other SoCalGas natural gas storage facilities in California, such as Montebello and Playa Del Rey.

Figure 2. California’s gas storage wells. The size of orange markers indicates wellhead pressure, as reported in 2015. Blue markers show the volume of gas injected in 2014/2015. The Aliso Canyon leak at ‘Standard Sesnon 25’ natural gas storage well is marked with a red star. Click here to manipulate the map. After expanded, use the “Layers” menu to visualize the data with colored markers rather than size. 

Response

Fixing the problem is therefore much more complicated, overall, in this specific case. Since the well casing has ruptured deep underground, natural gas is leaking in the annular space outside the borehole and spewing from the topsoil surrounding the well head. To stop the leak the production pipe must be plugged below the rupture. All attempts to plug the well from the surface have failed due to the high pressure within the borehole, a 7” inner diameter of the production pipe. Therefore, a relief well is being drilled to intersect the well casing, to inject a mud-chemical cocktail intended to plug the well far below the casing failure. Updates on the response, claims information, and the location of the Community Resource Center can be found here. Additionally, Governor Jerry Brown has declared a state of emergency, which means federal support and a requirement of the state of California to cover the costs.9

The state response to the natural gas leak has included numerous agencies. According to documents from California Public Utilities Commission (CPUC), the agencies leading the response are the California Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR), the Office of Emergency Services (CalOES), California Air Resources Board (ARB), California Division of Occupational Safety and Health (CalOSHA), the California Energy Commission (CEC), and the CPUC. DOGGR is conducting an independent investigation of the incident. The investigation will include a third party analysis for root-cause issues. CARB is monitoring total methane emissions while the Office of Environmental Health Hazard Assessment with CalEPA are collecting and reviewing air quality data. Coordinated response information can be found on the CalOES site. SoCalGas has submitted a proposal to regulators to raise customer rates in order to raise $30 million for a more proactive approach to inspections and repairs.10

This event is the largest, but is not the first major methane/natural gas leak to occur at a wellsite. Leaks can result from a number of natural and anthropogenic (man made) causes. Besides the natural degradation of well integrity with age, acute events can also cause casing failures. There are documented cases where seismic activity has caused casing failures.

As a result of an earthquake natural fractures in the region can grow and disrupt well bores. In areas of dense drilling, fracture stimulations that propagate improperly or intersect unknown faults. When two wells become interconnected, known as “downhole communication” or a “frack hit” when it occurs due to hydraulic fracturing, spills and leaks can occur due to over-pressurization. In many states, these risks are mitigated by having setbacks between wells. California, the most seismically active state, has minimal setbacks for drilling or fracking oil and gas wells. In previous research, FracTracker found that over 96% of new hydraulic fractures in 2013 were drilled within 1,200 feet of another well, which would even violate setback rules in Texas!

Climate Impacts

Natural gas is hailed by the fossil fuel industry as the bridge fuel that will allow the world to transition to renewables. The main argument claims natural gas is necessary to replace coal as our main source of generating electricity. Burning both coal and natural gas produce carbon dioxide, but natural gas is more efficient. For the same amount of energy production, natural gas produces half as much carbon dioxide emissions. The legitimate threat of climate impacts comes from fugitive (leaked) emissions of methane, before the natural gas can be burned. Since methane is a gas, it is much harder to contain than oil or coal. Methane is also more insulating than carbon dioxide in the atmosphere (34-86 times more insulating), making it a more potent greenhouse gas. The leaked natural gas from the Aliso Canyon well is currently equivalent to 7,000,000 tons of CO2 (Updated here, on Mother Jones).

Current estimates show methane is responsible for 25% of the world’s anthropogenic warming to date. Proponents of the bridge fuel theorize that if methane leakage can be kept under 4% of total production, natural gas power generation will provide a climate-positive alternative to coal. EPA estimates set the leakage rate at 2.4%, but independent research estimates actual rates up to 7.9%.11 The EDF has been conducting an $18 million project focused on quantifying methane leaks from the natural gas industry. A team of 20 researchers from 13 institutions conducted the 2 year study measuring emissions from the Barnett Shale. Details can be found on the Environmental Defense Fund’s Page.12

Natural Gas Leak References

  1. Goldenberg, S. (2016). A single gas well leak is California’s biggest contributor to climate change. The Guardian. Accessed 1/6/16.
  2. Environmental Defense Fund. (2015). Aerial Footage of Aliso Canyon Natural Gas Leak. via YouTube. Accessed 1/5/16.
  3. Lurie, J. (2016). Thousands of Californians are Fleeing an Enormous Methane Leak. Here are 8 Things You Need to Know. Mother Jones. Accessed 1/6/16.
  4. CalOES. (2015). Aliso Canyon Natural Gas Leak. Accessed 1/8/15.
  5. BBC. (2015). California state of emergency over methane leak. Accessed 1/8/15
  6. Ellison, G. (2015). Michigan has most underground natural gas storage in U.S. MLive. Accessed 1/8/15.
  7. Reicher, M. (2015). SocalGas knew of corrosion at Porter Ranch gas facility, doc shows. LA Daily News. Accessed 1/5/16.
  8. Ingraffea et al. (2013). Assessment and risk analysis of casing and cement impairment in oil and gas wells in Pennsylvania, 2000-2012. PNAS. Vol.111 no.30.
  9. Cronin, M. (2015). Why Engineers Can’t Stop Los Angeles’ Enormous Methane Leak. Accessed 1/4/16.
  10. CUUC. (2015). Appendix A. Accessed 1/5/15. [please note that some CPUC files are being taken offline for unknown reasons]
  11. Howarth et al. (2011). Methane and the greenhouse-gas footprint of natural gas from shale formations. Climatic Change. 106:679-690.
  12. Song, L. (2015). Texas Fracking Zone Emits 90% More Methane Than EPA Estimated. InsideClimate News.

Feature Image: Aliso Canyon natural gas leak – Photo by Environmental Defense Fund