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

Fracking’s Freshwater Supply and Demand in Eastern Ohio

Mapping Hydraulic Fracturing Freshwater Supply and Demand in Ohio

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


View map fullscreen | How FracTracker maps work

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

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

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

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

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

Broader Implications

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

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

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

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

Figures 1-3

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

Total Water Used

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

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

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

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

Conclusions and Next Steps

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

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

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

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

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


Relevant Data

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

Endnotes

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

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

The Falcon: High Consequence Areas & Potential Impact Zones

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project we continue to explore the different ways that pipelines are assessed for potential risk – in this case, relative to population centers, drinking water systems, and sensitive habitats. We outline methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called “high consequence areas” (HCAs) and how they determine potential impact zones for highly volatile liquid (HVL) pipelines. These methods are then applied to the Falcon to understand its possible dangers.

Quick Falcon Facts

  • An estimated 940-foot potential impact radius (PIR)
  • 60 of 97 pipeline miles qualifying as High Consequence Areas (HCA)
  • More than 8,700 people living in the “vapor zone”
  • 5 schools, 6 daycare centers, and 16 emergency response centers in “vapor zone”
  • In proximity to 8 source-water (drinking water) protection areas
  • Affecting habitats populated by 11 endangered, protected, or threatened species

Map of Falcon High Consequence Areas

The following map will serve as our guide in breaking down the Falcon’s High Consequence Areas. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

High Consequence Areas

While Class Locations, discussed in a prior project article, dictate the construction and maintenance of a pipeline, high consequence areas (HCAs) designate when operators must implement integrity management programs (IMP) where pipeline failures could cause major impacts to populated areas, as well as drinking water systems and ecological resources — otherwise defined as unusually sensitive areas (USAs).

Populated Areas

Two considerations are used when determining pipeline proximity to population centers:

  1. High Population Areas – an urbanized area delineated by the Census Bureau as having 50,000 or more people and a population density of at least 1,000 people per square mile; and
  2. Other Populated Areas – a Census Bureau designated “place” that contains a concentrated population, such as an incorporated or unincorporated city, town, village, or other designated residential or commercial area – including work camps.

USAs: Drinking Water

PHMSA’s definition of drinking water sources include things such as:

  • Community Water Systems (CWS) – serving at least 15 service connections and at least 25 year-round residents
  • Non-transient Non-community Water Systems (NTNCWS) – schools, businesses, and hospitals with their own water supplies
  • Source Water Protection Areas (SWPA) for a CWS or a NTNCWS
  • Wellhead Protection Areas (WHPA)
  • Sole-source karst aquifer recharge areas

These locations are typically supplied by regulatory agencies in individual states.

With the exception of sole-source aquifers, drinking water sources are only considered if they lack an alternative water source. However, PHMSA is strict on what alternative source means, stating that they must be immediately usable, of minimal financial impact, with equal water quality, and capable of supporting communities for at least one month for a surface water sources of water and at least six months for a groundwater sources.

One very important note in all of these “drinking water” USA designations is that they do not include privately owned groundwater wells used by residences or businesses.

USAs: Ecological Resource

Ecological resource areas are established based on any number of qualities with different variations. In general terms, they contain imperiled, threatened, or endangered aquatic or terrestrial species; are known to have a concentration of migratory waterbirds; or are a “multi-species assemblage” area (where three or more of the above species can be found).

Calculating HCAs

Like Class locations, HCAs are calculated based on proximity. The first step in this process is to determine the pipeline’s Potential Impact Radius (PIR) — the distance beyond which a person standing outdoors in the vicinity of a pipeline rupture and fire would have a 99% chance of survival; or in which death, injury, or significant property damage could occur. PIR is calculated based on the pipeline’s maximum allowable operating pressure (MAOP), diameter, and the type of gas. An example of this calculation is demonstrated in FracTracker’s recent article on the Mariner East 2 pipeline’s PIR.

Once the PIR is known, operators then determine HCAs in one of two ways, illustrated in the image below:

  • Method 1: A Class 3 or Class 4 location, or a Class 1 or Class 2 location where “the potential impact radius is greater than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human occupancy”; or a Class 1 or Class 2 location where “the potential impact circle contains an “identified site.”
  • Method 2: An area within PIR containing an “identified site” or 20 or more buildings intended for human occupancy.

Calculating HCAs
(source: PHMSA)

In these definitions, “identified sites” include such things as playgrounds, recreational facilities, stadiums, churches, office buildings, community centers, hospitals, prisons, schools, and assisted-living facilities. However, there is a notable difference in how HCAs are calculated for natural gas pipelines vs. hazardous liquid pipelines.

Beyond just looking at what lies within the PIR, pipelines that contain gasses such as ethane potentially impact a much broader area as vapors flow over land or within a river, stream, lake, or other means. A truly accurate HCA analysis for an ethane pipeline leak requires extensive atmospheric modeling for likely vapor dispersions, such as seen in the example image below (part of a recent ESRI GIS conference presentation).

Vapor dispersion modelling
(source: TRC Solutions)

 

What HCAs Dictate

HCAs determine if a pipeline segment is included in an operator’s integrity management program (IMP) overseen by PHMSA or its state equivalent. IMPs must include risk assessments that identify the most likely impact scenarios in each HCA, enhanced management and repair schedules, as well as mitigation procedures in the event of an accident. Some IMPs also include the addition of automatic shut-off valves and leak detection systems, as well as coordination plans with local first responders.

The Falcon Risk Zones

Shell’s permit applications to the PA DEP state the pipeline:

…is not located in or within 100 feet of a national, state, or local park, forest, or recreation area. It is not located in or within 100 feet of a national natural landmark, national wildlife refuge, or federal, state, local or private wildlife or plant sanctuaries, state game lands. It is also not located in or within 100 feet of a national wild or scenic river, the Commonwealth’s Scenic Rivers System, or any areas designated as a Federal Wilderness Area. Additionally, there are no public water supplies located within the Project vicinity.

This is a partial truth, as “site” and “vicinity” are vague terms here. A number of these notable areas are within the PIR and HCA zones. Let’s take a closer look.

The PIR (or “Blast Zone”)

Shell’s permit applications state a number of different pipeline dimensions will be used throughout the project. Most of the Falcon will be built with 12-inch steel pipe, with two exceptions: 1) The segment running from the Cadiz, OH, separator facility to its junction with line running from Scio, OH, will be a 10-inch diameter pipe; 2) 16-inch diameter pipe will be used from the junction of the Falcon’s two main legs located four miles south of Monaca, PA, to its end destination at the ethane cracker. We also know from comments made by Shell in public presentations that the Falcon’s maximum allowable operating pressure (MOAP) will be 1,440 psi. These numbers allow us to calculate the Falcon’s PIR which, for a 16″ ethane pipeline at 1,440psi, is about 940 feet. We’ve termed this the “blast zone” on our maps.

The HCA (or “Vapor Zone”)

Shell’s analysis uses an HCA impact radius of 1.25 miles. This much larger buffer reflects the fact that vapors from hazardous liquid pipelines can travel unpredictably at high concentrations for long distances before ignition. This expanded buffer might be called the “vapor zone,” a term we used on our map. Within the HCA “vapor zone” we find that 60 of the Falcon’s 97 miles qualify as high consequence areas, with 35 miles triggered due to their proximity to drinking water sources, 25 miles trigger for proximity to populated areas, and 3 miles for proximity to ecological areas.

Populated Areas

Shell’s HCA buffer intersects 14 US Census-designated populated areas, shown in the table below. Falcon’s right-of-way directly intersects two of these areas: Cadiz Village in Harrison County, Ohio, and Southview CDP (Census Designated Place) in Washington County, PA. These areas are listed below. Additionally, we included on the FracTracker map the locations of public facilities that were found inside the HCA buffer. These include 5 public schools, 6 daycare centers, 10 fire stations, and 6 EMS stations.

Area Population State HCA
Pittsburgh Urbanized Area High PA Indirect
Weirton-Steubenville Urbanized Area High WV/OH/PA Indirect
Scio Village Other OH Indirect
Cadiz Village* Other OH Direct
Amsterdam Village Other OH Indirect
Shippingport Borough Other PA Indirect
Industry Borough Other PA Indirect
Hookstown Borough Other PA Indirect
Midway Borough Other PA Indirect
Clinton CDP Other PA Indirect
Imperial CDP Other PA Indirect
Southview CDP* Other PA Direct
Hickory CDP Other PA Indirect
Westland CDP Other PA Indirect
* Indicates an area the Falcon’s right-of-way will directly intersect

While it is difficult to determine the actual number of people living in the PIR and HCA vapor zone, there are ways one can estimate populations. In order to calculate the number of people who may live within the HCA and PIR zones, we first identified U.S. Census blocks that intersect each respective buffer. Second, we calculated the percentage of that census block’s area that lies within each buffer. Finally, we used the ratio of the two to determine the percentage of the block’s population that lies within the buffer.

Based on 2010 Census data, we estimate that 2,499 people live within a reasonable projection of the Falcon’s PIR blast zone. When expanded to the HCA vapor zone, this total increases to 8,738 people. These numbers are relatively small compared to some pipelines due to the fact that a significant portion of the Falcon runs through fairly rural areas in most places.

PIR est. pop. HCA est. pop.
OHIO
Carroll County 11 47
Harrison County 274 915
Jefferson County 334 1,210
Total 619 2,172
WEST VIRGINIA
Hancock County 242 1,155
Total 242 1,155
PENNSYLVANIA
Allegheny County 186 969
Beaver County 990 3,023
Washington County 461 1,419
Total 1,637 5,410
Grand Total 2,499 8,738


Drinking Water Sources

Shell’s data identified a number of drinking water features considered in their HCA analysis. Metadata for this information show these sites were obtained from the Ohio Division of Drinking and Ground Waters, the West Virginia Source Water Assessment and Wellhead Protection Program, and the Pennsylvania DEP Wellhead Protection Program. The exact locations of public drinking water wells and intake points are generally protected by states for safety reasons. However, we duplicated the 5-mile buffer zones used on Shell’s map around these points, presumably denoting the boundaries of source water protection areas, wellhead protection areas, or intake points.

Drinking water buffers in Shell’s HCA analysis

As shown on FracTracker’s interactive map, five of these areas serve communities in the northern portions of Beaver County, shown in the image above, as well as the Cadiz and Weirton-Steubenville designated populated areas. Recall that HCA drinking water analysis only requires consideration of groundwater wells and not surface waters. This is an important distinction, as the Ambridge Reservoir is within the HCA zone but not part of Shell’s analysis — despite considerable risks outlined in our Falcon article on water body crossings.

Ecological Areas

Shell’s permits state that they consulted with the U.S. Fish and Wildlife Service (USFWS), Pennsylvania Game Commission (PGC), Pennsylvania Fish & Boat Commission (PFBC), and the Pennsylvania Department of Conservation and Natural Resources (DCNR) on their intended route in order to determine potential risks to protected species and ecologically sensitive areas.

DCNR responded that the pipeline had the potential to impact six sensitive plant species: Vase-vine Leather-Flower, Harbinger-of-spring, White Trout-Lily, Purple Rocket, Declined Trillium, and Snow Trillium. PFBC responded that the project may impact the Southern Redbelly Dace, a threatened temperate freshwater fish, within the Service Creek watershed. PGC responded that the pipeline had potential impact to habitats used by the Short-Eared Owl, Northern Harrier, and Silver-Haired Bat. Finally, the USFWS noted the presence of freshwater mussels in a number of water features crossed by the Falcon.

The presence of these species, as well as the proximity of protected lands illustrated on our map, factored into the Falcon’s HCA designations. A more detailed analysis of these issues is provided in the Falcon Public EIA Project article on Protected Habitats & Species of Concern.

* * *

Related Articles

By Kirk Jalbert, FracTracker Alliance

A Hazy Future Report Cover

A Hazy Future: Pennsylvania’s Energy Landscape in 2045

Report Calculates Impacts from PA’s Planned Natural Gas Infrastructure

FracTracker Alliance released the report: A Hazy Future: Pennsylvania’s Energy Landscape in 2045 today, which details the potential future impacts of a massive buildout of Marcellus Shale wells and associated natural gas infrastructure.

Industry analysts forecast 47,600 new unconventional oil and gas wells may be drilled in Pennsylvania by 2045, fueling new natural gas power plants and petrochemical facilities in PA and beyond. Based on industry projections and current rates of consumption, FracTracker – a national data-driven non-profit – estimates the buildout would require 583 billion gallons of fresh water, 386 million tons of sand, 798,000 acres of land, 131 billion gallons of liquid waste, 45 million tons of solid waste, and more than 323 million truck trips to drilling sites.

A Hazy Future - Impact Summary

“Only 1,801 of the 10,851 unconventional wells already drilled count as a part of this projection, meaning we could see an additional 45,799 such wells in the coming decades,” commented Matt Kelso, Manager of Data and Technology for FracTracker and lead author on the report.

Why the push for so much more drilling? Out of state – and out of country – transport is the outlet for surplus production.

“The oil and gas industry overstates the need for more hydrocarbons,” asserted FracTracker Alliance’s Executive Director, Brook Lenker. “While other countries and states are focusing more on renewables, PA seems resolute to increase its fossil fuel portfolio.”

The report determined that the projected cleared land for well pads and pipelines into the year 2045 could support solar power generation for 285 million homes, more than double the number that exist in the U.S.

A Hazy Future shows that a fossil fuel-based future for Pennsylvania would come at the expense of its communities’ health, clean air, water and land. It makes clear that a dirty energy future is unnecessary,” said Earthworks’ Pennsylvania Field Advocate, Leann Leiter. Earthworks endorsed FracTracker’s report. She continued, “I hope Governor Wolf reads this and makes the right choices for all Pennsylvanians present and future.”

A Hazy Future reviews the current state of energy demand and use in Pennsylvania, calculates the footprint of industry projections of the proposed buildout, and assesses what that would look like for residents of the Commonwealth.

About FracTracker Alliance

Started in 2010 as a southwestern Pennsylvania area website, FracTracker Alliance is a national organization with regional offices across the United States in Pennsylvania, the District of Columbia, New York, Ohio, and California. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Its goal is to support advocacy groups at the local, regional, and national level, informing their actions to positively shape our nation’s energy future.

Questions? Email us: info@fractracker.org.

Sandhill Crane

Giving Voice to the Sandhill Cranes: Place-based Arguments against Keystone XL

By Wrexie Bardaglio, guest commentator

When we hear his call, we hear no mere bird. We hear the trumpet in the orchestra of evolution. He is the symbol of our untamable past, of that incredible sweep of millennia which underlies and conditions the daily affairs of birds and men…” ~ Aldo Leopold, on the Sandhill Crane, in “Marshland Elegy”

Dilbit – or diluted bitumen – is refined from the naturally-occurring tar sands deposits in Alberta, Canada. In March 2017, I applied to the Nebraska Public Service Commission for standing as an intervenor in the Commission’s consideration of TransCanada’s request for a permit to construct a pipeline transporting dilbit – a project referred to as the Keystone XL pipeline. Below are my reflections on the battle against the permitting process, and how FracTracker’s maps ensured the Sandhill Crane’s voice made it into public record.

A Pipeline’s History

The Keystone 1 pipeline carries the dilbit from Alberta, to Steele City, Nebraska, and ultimately to Port Arthur, Texas and export refineries along the Gulf Coast. The state of Montana had already approved the Keystone XL project, as had the state of South Dakota. The decision of the South Dakota Public Utilities Commission was appealed, however, and has now worked its way to the South Dakota Supreme Court, where it is pending.

Resistance to TransCanada’s oil and gas infrastructure projects is not new. Beginning in 2010, some Nebraska farmers and ranchers joined forces with tribal nations in the Dakotas, who were also fighting TransCanada’s lack of proper tribal consultation regarding access through traditional treaty territory. The indigenous nations held certain retained rights as agreed in the 1868 Fort Laramie Treaty between the United States government and the nine tribes of the Great Sioux Nation. The tribes were also protesting TransCanada’s flaunting of the National Historic Preservation Act’s protections of Native American sacred sites and burial grounds. Further, although TransCanada was largely successful in securing the easements needed in Nebraska to construct the pipeline, there were local holdouts refusing to negotiate with the company. TransCanada’s subsequent attempts to exercise eminent domain resulted in a number of lawsuits.

In January of 2015, then-President Barack Obama denied the international permit TransCanada needed. While that denial was celebrated by many, everyone also understood that a new president could well restore the international permit. Indeed, as one of his first actions in January 2017, the new Republican president signed an executive order granting the permit, and the struggle in Nebraska was reignited.

“What Waters Run Through My Veins…”

While I am a long-time resident of New York, I grew up in the Platte River Valley of South Central Nebraska, in a town where my family had and continues to have roots – even before Nebraska became a state. There was never a question in my mind that in this particular permitting process I would request status as an intervenor; for me, the matter of the Keystone XL Pipeline went far beyond the legal and political and energy policy questions that were raised and were about to be considered. It was about who I am, how I was raised, what I was taught, what waters run through my veins as surely as blood, and who my own spirit animals are, the Sandhill Cranes.

wrexie_3yrs

Bardaglio (age 3) and her father, along the banks of the Platte River

When we were growing up, our father told us over and over and over about why Nebraska was so green. The Ogallala Aquifer, he said, was deep and vast, and while eight states partially sat atop this ancient natural cistern, nearly all of Nebraska floated on this body. Nebraska was green, its fields stretching to the horizon, because, as our father explained, the snow runoff from the Rockies that flowed into our state and was used eleven times over was cleansed in water-bearing sand and gravel on its way to the Missouri on our eastern boundary, thence to the Mississippi, and finally to the Gulf.

I grew up understanding that the Ogallala Aquifer was a unique treasure, the largest freshwater aquifer in the world, the lifeblood for Nebraska’s agriculture and U.S. agriculture generally, and worthy of protection. I thought about the peril to the aquifer because of TransCanada’s plans, should there be a spill, and the additional threats an accident would potentially pose to Nebraska’s rivers, waterways and private wells.

2000px-ogallala_saturated_thickness_1997-sattk97-v2-svg

The Ogallala Aquifer

Knowing that climate change is real, terrifying, and accelerating, I recognized that a warming world would increasingly depend on this aquifer in the nation’s midsection for life itself.

Migration of the Sandhill Cranes

As I thought about how I would fight the KXL, another narrative took shape rising out of my concern for the aquifer. Growing up in the South Central Platte River Valley, I – and I daresay most everyone who lives there – have been captivated by the annual migration of the Sandhill Cranes, plying the skies known as the Central Flyway. As sure as early spring comes, so do the birds. It may still be bitterly cold, but these birds know that it is time to fly. And so they do – the forward scouts appearing in winter grey skies, soon followed by some 500,000 – 600,000 thousand of them, darkening the skies, their cries deafening and their gorgeous archaeopteryx silhouettes coming in wave after wave like flying Roman Legions.

branch-bird-sky-sunrise-sunset-morning-dawn-flock-dusk-birds-cranes-water-bird-bird-migration-migratory-birds-atmospheric-phenomenon-animal-migration-crane-like-bird-529634

To this day, no matter where I am, the first thing in my sinews and bones when winter begins to give way is the certainty that the birds are coming, I feel them; they are back. They are roosting on the sandbars in the braided river that is the Platte and gleaning in the stubbled fields abutting it… they are home.

According to The Nature Conservancy:

Scientists estimate that at least one-third of the entire North American population of Sandhill Cranes breed in the boreal forest of Canada and Alaska…

Scientists estimate that approximately 80 percent of all Sandhill Cranes in North America use a 75-mile stretch of Nebraska’s Platte River during spring migration. From March to April, more than 500,000 birds spend time in the area preparing for the long journey north to their breeding grounds in Canada and Alaska. During migration, the birds may fly as much as 400 miles in one day.

Sandhill Cranes rely on open freshwater wetlands for most of their lifecycle. Degradation of these kinds of wetland habitats is among the most pressing threats to the survival of Sandhill Cranes. (Emphasis added)

Giving Sandhill Cranes a Voice

But how could I make the point about the threat TransCanada posed to the migratory habitat of the Sandhill Cranes (and endangered Whooping Cranes, pelicans, and hummingbirds among the other thermal riders who also migrate with them)? Books, scientific papers, lectures – all the words in the world – cannot describe this ancient rite, this mysterious primal navigation of the unique pathway focusing on this slim stretch of river, when viewed from a global perspective a fragile skein in a fragile web in a biosphere in peril.

In my head I called it a river of birds in the grassland of sky. And I am so grateful to my friend, Karen Edelstein at FracTracker Alliance, for her willingness to help map and illustrate the magnificence of the migration flyway in the context of the three proposed options for the KXL pipeline.

flyway_map

Karen prepared two maps for me, but my favorite is the one above.

It shows an ancient, near-primordial, near-mystical event. Guided by rudders and instinct we can barely comprehend, in concert with earth’s intrinsic and exquisitely-designed balance, and as certain as a sunrise, a sunset or a moon rise, these oldest of crane species find their ways through the heavens. They hew to certainties that eclipse the greed of multinational corporations like TransCanada, who barely even pay lip service to the integrity of anything over which they can’t exert dominion. To say they don’t respect the inherent rights of species other than our own, or to ecological communities that don’t directly include us, is an understatement, and a damning comment on their values.

I was prepared for pushback on these maps from TransCanada. And in truth, the company was successful in an in limine motion to have certain exhibits and parts of my testimony stricken from the official record of the proceedings.

But not the maps.

In fact, too many other intervenors to count, as well as several of the lawyers involved in the proceedings commented to me on the beauty and accuracy of the maps. And not only are they now a part of the permanent record of the Nebraska Public Service Commission, should there be an appeal (which all of us expect), on both sides of the issue, there is a very good possibility they will be incorporated into the formal testimonies by the lawyers as the matter moves through the appeals process.

Taking Action, Speaking Out

Ordinary citizens must figure out how to confront the near-impenetrable stranglehold of multi-national corporations whose wealth is predicated on the continuance of fossil fuels as the primary sources of energy. We have had to become more educated, more activist, and more determined to fight the destruction that is now assured if we fail to slow down the impacts of climate change and shift the aggregate will of nations towards renewable energy.

Many activists do not realize that they can formally intervene at the state level in pipeline and infrastructure permitting processes. In doing so, the voice of the educated citizen is amplified and becomes a threat to these corporations whose business models didn’t account for systematic and informed resistance in public agencies’ heretofore pro forma proceedings. The publicly-available documents and filings from corporations can be important tools for “speaking truth to power” when paired with the creative tools born of necessity by the environmental movement.

Technology is value-neutral, but as I learned – as did many others in the Keystone XL Pipeline fight – in skilled hands it becomes a weapon in the struggle for the greater good.

I will be forever grateful for FracTracker, and will be interested to see how others use this tool in the fights that are sure to come.

EXCELSIOR!

For more background on the natural history of Sandhill Cranes, please view this video produced by The Crane Trust.


Wrexie Bardaglio is a Nebraska native living in Covert, New York. She worked for ten years for a member of Congress as a legislative assistant with a focus on Indian affairs and for a DC law firm as legislative specialist in Indian affairs. She left politics to open a bookstore in suburban Baltimore. She has been active in the Keystone XL fights in Nebraska and South Dakota and in fracking and gas infrastructure fights in New York.

This article’s feature image of a Sandhill Crane is the work of a U.S. Fish and Wildlife Service employee, taken or made as part of that person’s official duties. As a work of the U.S. federal government, the image is in the public domain.

FracTracker Alliance makes hundreds of maps, analyses, and photos available for free to frontline communities, grassroots groups, NGO’s, and many other organizations concerned about the industry to use in their oil and gas campaigns. To address an issue, you need to be able to see it.

However, we rely on funders and donations – and couldn’t do all of this without your help!

JOSHUA DOUBEK / WIKIMEDIA COMMONS

Groundwater risks in Colorado due to Safe Drinking Water Act exemptions

Oil and gas operators are polluting groundwater in Colorado, and the state and U.S. EPA are granting them permission with exemptions from the Safe Drinking Water Act.

FracTracker Alliance’s newest analysis attempts to identify groundwater risks in Colorado groundwater from the injection of oil and gas waste. Specifically, we look at groundwater monitoring data near Class II underground injection control (UIC) disposal wells and in areas that have been granted aquifer exemptions from the underground source of drinking water rules of the Safe Drinking Water Act (SDWA). Momentum to remove amend the SDWA and remove these exemption.

Learn more about Class II injection wells.

Aquifer exemptions are granted to allow corporations to inject hazardous wastewater into groundwater aquifers. The majority, two-thirds, of these injection wells are Class II, specifically for oil and gas wastes.

What exactly are aquifer exemptions?

The results of this assessment provide insight into high-risk issues with aquifer exemptions and Class II UIC well permitting standards in Colorado. We identify areas where aquifer exemptions have been granted in high quality groundwater formations, and where deep underground aquifers are at risk or have become contaminated from Class II disposal wells that may have failed.

Of note: On March 23, 2016, NRDC submitted a formal petition urging the EPA to repeal or amend the aquifer exemption rules to protect drinking water sources and uphold the Safe Drinking Water Act. Learn more

Research shows injection wells do fail

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Class II injection well in Colorado explodes and catches fire. Photo by Kelsey Brunner for the Greeley Tribune.

Disposal of oil and gas wastewater by underground injection has not yet been specifically researched as a source of systemic groundwater contamination nationally or on a state level. Regardless, this issue is particularly pertinent to Colorado, since there are about 3,300 aquifer exemptions in the US (view map), and the majority of these are located in Montana, Wyoming, and Colorado. There is both a physical risk of danger as well as the risk of groundwater contamination. The picture to the right shows an explosion of a Class II injection well in Greeley, CO, for example.

Applicable and existing research on injection wells shows that a risk of groundwater contamination of – not wastewater – but migrated methane due to a leak from an injection well was estimated to be between 0.12 percent of all the water wells in the Colorado region, and was measured at 4.5 percent of the water wells that were tested in the study.

A recent article by ProPublica quoted Mario Salazar, an engineer who worked for 25 years as a technical expert with the EPA’s underground injection program in Washington:

In 10 to 100 years we are going to find out that most of our groundwater is polluted … A lot of people are going to get sick, and a lot of people may die.

Also in the ProPublic article was a study by Abrahm Lustgarten, wherein he reviewed well records and data from more than 220,000 oil and gas well inspections, and found:

  1. Structural failures inside injection wells are routine.
  2. Between 2007-2010, one in six injection wells received a well integrity violation.
  3. More than 7,000 production and injection wells showed signs of well casing failures and leakage.

This means disposal wells can and do fail regularly, putting groundwater at risk. According to Chester Rail, noted groundwater contamination textbook author:

…groundwater contamination problems related to the subsurface disposal of liquid wastes by deep-well injection have been reviewed in the literature since 1950 (Morganwalp, 1993) and groundwater contamination accordingly is a serious problem.

According to his textbook, a 1974 U.S. EPA report specifically warns of the risk of corrosion by oil and gas waste brines on handling equipment and within the wells. The potential effects of injection wells on groundwater can even be reviewed in the U.S. EPA publications (1976, 1996, 1997).

As early as 1969, researchers Evans and Bradford, who reported on the dangers that could occur from earthquakes on injection wells near Denver in 1966, had warned that deep well injection techniques offered temporary and not long-term safety from the permanent toxic wastes injected.

Will existing Class II wells fail?

For those that might consider data and literature on wells from the 1960’s as being unrepresentative of activities occurring today, of the 587 wells reported by the Colorado’s oil and gas regulatory body, COGCC, as “injecting,” 161 of those wells were drilled prior to 1980. And 104 were drilled prior to 1960!

Wells drilled prior to 1980 are most likely to use engineering standards that result in “single-point-of-failure” well casings. As outlined in the recent report from researchers at Harvard on underground natural gas storage wells, these single-point-of-failure wells are at a higher risk of leaking.

It is also important to note that the U.S. EPA reports only 569 injection wells for Colorado, 373 of which may be disposal wells. This is a discrepancy from the number of injection wells reported by the COGCC.

Aquifer Exemptions in Colorado

According to COGCC, prior to granting a permit for a Class II injection well, an aquifer exemption is required if the aquifer’s groundwater test shows total dissolved solids (TDS) is between 3,000 and 10,000 milligrams per liter (mg/l). For those aquifer exemptions that are simply deeper than the majority of current groundwater wells, the right conditions, such as drought, or the needs of the future may require drilling deeper or treating high TDS waters for drinking and irrigation. How the state of Colorado or the U.S. EPA accounts for economic viability is therefore ill-conceived.

Data Note: The data for the following analysis came by way of FOIA request by Clean Water Action focused on the aquifer exemption permitting process. The FOIA returned additional data not reported by the US EPA in the public dataset. That dataset contained target formation sampling data that included TDS values. The FOIA documents were attached to the EPA dataset using GIS techniques. These GIS files can be found for download in the link at the bottom of this page.

Map 1. Aquifer exemptions in Colorado


View map fullscreen | How FracTracker maps work

Map 1 above shows the locations of aquifer exemptions in Colorado, as well as the locations of Class II injection wells. These sites are overlaid on a spatial assessment of groundwater quality (a map of the groundwater’s quality), which was generated for the entire state. The changing colors on the map’s background show spatial trends of TDS values, a general indicator of overall groundwater quality.

In Map 1 above, we see that the majority of Class II injection wells and aquifer exemptions are located in regions with higher quality water. This is a common trend across the state, and needs to be addressed.

Our review of aquifer exemption data in Colorado shows that aquifer exemption applications were granted for areas reporting TDS values less than 3,000 mg/l, which contradicts the information reported by the COGCC as permitting guidelines. Additionally, of the 175 granted aquifer exemptions for which the FOIA returned data, 141 were formations with groundwater samples reported at less than 10,000 mg/l TDS. This is half of the total number (283) of aquifer exemptions in the state of Colorado.

When we mapped where class II injection wells are permitted, a total of 587 class II wells were identified in Colorado, outside of an aquifer exemption area. Of the UIC-approved injection wells identified specifically as disposal wells, at least 21 were permitted outside aquifer exemptions and were drilled into formations that were not hydrocarbon producing. Why these injection wells are allowed to operate outside of an aquifer exemption is unknown – a question for regulators.

You can see in the map that most of the aquifer exemptions and injection wells in Colorado are located in areas with lower TDS values. We then used GIS to conduct a spatial analysis that selected groundwater wells within five miles of the 21 that were permitted outside aquifer exemptions. Results show that groundwater wells near these sites had consistently low-TDS values, meaning good water quality. In Colorado, where groundwater is an important commodity for a booming agricultural industry and growing cities that need to prioritize municipal sources, permitting a Class II disposal well in areas with high quality groundwater is irresponsible.

Groundwater Monitoring Data Maps

Map 2. Water quality and depths of groundwater wells in Colorado
Groundwater risks in Colorado - Map 2
View live map | How FracTracker maps work

In Map 2, above, the locations of groundwater wells in Colorado are shown. The colors of the dots represent the concentration of TDS on the right and well depth on the left side of the screen. By sliding the bar on the map, users can visualize both. This feature allows people to explore where deep wells also are characterized by high levels of TDS. Users can also see that areas with high quality low TDS groundwater are the same areas that are the most developed with oil and gas production wells and Class II injection wells, shown in gradients of purple.

Statistical analysis of this spatial data gives a clearer picture of which regions are of particular concern; see below in Map 3.

Map 3. Spatial “hot-spot” analysis of groundwater quality and depth of groundwater wells in Colorado
Groundwater risks in Colorado - Map 3
View live map | How FracTracker maps work

In Map 3, above, the data visualized in Map 2 were input into a hot-spots analysis, highlighting where high and low values of TDS and depth differ significantly from the rest of the data. The region of the Front Range near Denver has significantly deeper wells, as a result of population density and the need to drill municipal groundwater wells.

The Front Range is, therefore, a high-risk region for the development of oil and gas, particularly from Class II injection wells that are necessary to support development.

Methods Notes: The COGCC publishes groundwater monitoring data for the state of Colorado, and groundwater data is also compiled nationally by the Advisory Committee on Water Information (ACWI). (Data from the National Groundwater Monitoring Network is sponsored by the ACWI Subcommittee on Ground Water.) These datasets were cleaned, combined, revised, and queried to develop FracTracker’s dataset of Colorado groundwater wells. We cleaned the data by removing sites without coordinates. Duplicates in the data set were removed by selecting for the deepest well sample. Our dataset of water wells consisted of 5,620 wells. Depth data was reported for 3,925 wells. We combined this dataset with groundwater data exported from ACWI. Final count for total wells with TDS data was 11,754 wells. Depth data was reported for 7,984 wells. The GIS files can be downloaded in the compressed folder at the bottom of this page.

Site Assessments – Exploring Specific Regions

Particular regions were further investigated for impacts to groundwater, and to identify areas that may be at a high risk of contamination. There are numerous ways that groundwater wells can be contaminated from other underground activity, such as hydrocarbon exploration and production or waste injection and disposal. Contamination could be from hydraulic fracturing fluids, methane, other hydrocarbons, or from formation brines.

From the literature, brines and methane are the most common contaminants. This analysis focuses on potential contamination events from brines, which can be detected by measuring TDS, a general measure for the mixture of minerals, salts, metals and other ions dissolved in waters. Brines from hydrocarbon-producing formations may include heavy metals, radionuclides, and small amounts of organic matter.

Wells with high or increasing levels of TDS are a red flag for potential contamination events.

Methods

Groundwater wells at deep depths with high TDS readings are, therefore, the focus of this assessment. Using GIS methods we screened our dataset of groundwater wells to only identify those located within a buffer zone of five miles from Class II injection wells. This distance was chosen based on a conservative model for groundwater contamination events, as well as the number of returned sample groundwater wells and the time and resources necessary for analysis. We then filtered the groundwater wells dataset for high TDS values and deep well depths to assess for potential impacts that already exist. We, of course, explored the data as we explored the spatial relationships. We prioritized areas that suggested trends in high TDS readings, and then identified individual wells in these areas. The data initially visualized were the most recent sampling events. For the wells prioritized, prior sampling events were pulled from the data. The results were graphed to see how the groundwater quality has changed over time.

Case of Increasing TDS Readings

If you zoom to the southwest section of Colorado in Map 2, you can see that groundwater wells located near the injection well 1 Fasset SWD (EPA) (05-067-08397) by Operator Elm Ridge Exploration Company LLC were disproportionately high (common). Groundwater wells located near this injection well were selected for, and longitudinal TDS readings were plotted to look for trends in time. (Figure 1.)

The graphs in Figure 1, below, show a consistent increase of TDS values in wells near the injection activity. While the trends are apparent, the data is limited by low numbers of repeated samples at each well, and the majority of these groundwater wells have not been sampled in the last 10 years. With the increased use of well stimulation and enhanced oil recovery techniques over the course of the last 10 years, the volumes of injected wastewater has also increased. The impacts may, therefore, be greater than documented here.

This area deserves additional sampling and monitoring to assess whether contamination has occurred.


Figures 1a and 1b. The graphs above show increasing TDS values in samples from groundwater wells in close proximity to the 1 Fassett SWD wellsite, between the years 2004-2015. Each well is labeled with a different color. The data for the USGS well in the graph on the right was not included with the other groundwater wells due to the difference in magnitude of TDS values (it would have been off the chart).

Groundwater Contamination Case in 2007

We also uncovered a situation where a disposal well caused groundwater contamination. Well records for Class II injection wells in the southeast corner of Colorado were reviewed in response to significantly high readings of TDS values in groundwater wells surrounding the Mckinley #1-20-WD disposal well.

When the disposal well was first permitted, farmers and ranchers neighboring the well site petitioned to block the permit. Language in the grant application is shown below in Figure 2. The petitioners identified the target formation as their source of water for drinking, watering livestock, and irrigation. Regardless of this petition, the injection well was approved. Figure 3 shows the language used by the operator Energy Alliance Company (EAC) for the permit approval, which directly contradicts the information provided by the community surrounding the wellsite. Nevertheless, the Class II disposal well was approved, and failed and leaked in 2007, leading to the high TDS readings in the groundwater in this region.

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Figure 2. Petition by local landowners opposing the use of their drinking water source formation for the site of a Class II injection disposal well.

 

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Figure 3. The oil and gas operation EAC claims the Glorietta formation is not a viable fresh water source, directly contradicting the neighboring farmers and ranchers who rely on it.

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Figure 4. The COGCC well log report shows a casing failure, and as a result a leak that contaminated groundwater in the region.

Areas where lack of data restricted analyses

In other areas of Colorado, the lack of recent sampling data and longitudinal sampling schemes made it even more difficult to track potential contamination events. For these regions, FracTracker recommends more thorough sampling by the regulatory agencies COGCC and USGS. This includes much of the state, as described below.

Southeastern Colorado

Our review of the groundwater data in southeastern Colorado showed a risk of contamination considering the overlap of injection well depths with the depths of drinking water wells. Oil and gas extraction and Class II injections are permitted where the aquifers include the Raton formation, Vermejo Formation, Poison Canyon Formation and Trinidad Sandstone. Groundwater samples were taken at depths up to 2,200 ft with a TDS value of 385 mg/l. At shallower depths, TDS values in these formations reached as high as 6,000 mg/l, and 15 disposal wells are permitted in aquifer exemptions in this region. Injections in this area start at around 4,200 ft.

In Southwestern Colorado, groundwater wells in the San Jose Formation are drilled to documented depths of up to 6,000 feet with TDS values near 2,000 mg/l. Injection wells in this region begin at 565 feet, and those used specifically for disposal begin at below 5,000 feet in areas with aquifer exemptions. There are also four disposal wells outside of aquifer exemptions injecting at 5,844 feet, two of which are not injecting into active production zones at depths of 7,600 and 9,100 feet.

Western Colorado

In western Colorado well Number 1-32D VANETA (05-057-06467) by Operator Sandridge Exploration and Production LLC’s North Park Horizontal Niobara Field in the Dakota-Lokota Formation has an aquifer exemption. The sampling data from two groundwater wells to the southeast, near Coalmont, CO, were reviewed, but we can’t get a good picture due to the lack of repeat sampling.

Northwestern Colorado

http://digital.denverlibrary.org/cdm/ref/collection/p16079coll32/id/346073

A crew from Bonanza Creek repairs an existing well in the McCallum oil field. Photo by Ken Papaleo / Rocky Mountain News

In Northwestern Colorado near Walden, CO and the McCallum oil field, two groundwater wells with TDS above 10,000 ppm were selected for review. There are 21 injection wells in the McCallum field to the northwest. Beyond the McCallum field is the Battleship field with two wastewater disposal wells with an aquifer exemption. West of Grover, Colorado, there are several wells with high TDS values reported for shallow wells. Similar trends can be seen near Vernon. The data on these wells and wells from along the northern section of the Front Range, which includes the communities of Fort Collins, Greeley, and Longmont, suffered from the same issue. Lack of deep groundwater well data coupled with the lack of repeat samples, as well as recent sampling inhibited the ability to thoroughly investigate the threat of contamination.

Trends and Future Development

Current trends in exploration and development of unconventional resources show the industry branching southwest of Weld County towards Fort Collins, Longmont, Broomfield and Boulder, CO.

These regions are more densely populated than the Front Range county of Weld, and as can be seen in the maps, the drinking water wells that access groundwaters in these regions are some of the deepest in the state.

This analysis shows where Class II injection has already contaminated groundwater resources in Colorado. The region where the contamination has occurred is not unique; the drinking water wells are not particularly deep, and the density of Class II wells is far from the highest in the state.

Well casing failures and other injection issues are not exactly predictable due to the variety of conditions that can lead to a well casing failure or blow-out scenario, but they are systemic. The result is a hazardous scenario where it is currently difficult to mitigate risk after the injection wells are drilled.

Allowing Class II wells to expand into Front Range communities that rely on deep wells for municipal supplies is irresponsible and dangerous.

The encroachment of extraction into these regions, coupled with the support of Class II injection wells to handle the wastewater, would put these groundwater wells at particular risk of contamination. Based on this analysis, we recommend that regulators take extra care to avoid permitting Class II wells in these regions as the oil and gas industry expands into new areas of the Front Range, particularly in areas with dense populations.


Feature Image: Joshua Doubek / WIKIMEDIA COMMONS

Article by: Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

 

October 31, 2017 Edit: This post originally cited the Clean Water Act instead of the Safe Drinking Water Act as the source that EPA uses to grant aquifer exemptions.

Northeast Ohio Class II injection wells taken via FracTracker's mobile app, May 2015

What are aquifer exemptions? Permitted exemptions from the Safe Drinking Water Act

We’d like to give our readers a bit of background on aquifer exemptions, because we’re going to be covering this topic in a few upcoming blog posts. Stay tuned!

Liquid Waste Disposal

Drilling for oil and gas produces both liquid and solid waste that must be disposed of. The liquid waste from this industry is considered a “Class II waste” according to the US EPA. Aquifers are places underground capable of holding or transmitting groundwater. To dispose of Class II waste, operators are granted aquifer exemptions, by the EPA based on the state’s recommendations. The term “exemption,” specifically, refers to the Safe Drinking Water Act, which protects underground sources of drinking water (USDWs).

Therefore, these exemptions grant oil and gas operators the right to contaminate groundwaters, albeit many of the groundwater formations used for disposal in Class II wells are very deep.

Learn more about disposal well classes and aquifer exemptions on this story map by the US EPA

Aquifer Exemption Criteria

There are several qualifiers for a USDW to be granted exempt from the Safe Drinking Water Act. Aquifer exemptions are granted for underground formations that are not currently used as a source of drinking water and meet one of the following criteria:

  • The formation contains commercially producible minerals or hydrocarbons;
  • The formation is so deep that recovery of water for drinking water purposes is economically or technologically impractical; or,
  • The formation is so contaminated that it would be economically or technologically impractical to render the water fit for human consumption.
  • In some states, aquifer exemptions are not approved for formations with Total Dissolved Solids (TDS*) equal to or less than 3,000 mg/l TDS.

If an underground formation qualifies for an exemption, it does not mean that groundwater cannot be used for drinking water, just that it is not currently a source of drinking water. The most precarious criteria requirement, therefore, is the determination that a USDW is simply not “economically viable” or it is “technologically impractical,” meaning that the cost of drilling a groundwater well to the depth of the aquifer (under the condition of the current need for water) may make the investment impractical. In the near future, this water may be needed and highly valued, however.

TDS = Total dissolved solids are inorganic salts (e.g. calcium, magnesium, potassium, sodium, bicarbonates, chlorides, and sulfates), as well as some organic matter, dissolved in water.

The Lay of the Land

Below, we have put together a map of aquifer exemptions in the U.S. Click on the dots and shaded areas to learn more about a particular aquifer.

Map of all aquifer exemptions in the U.S.

View map fullscreen | How FracTracker maps work


By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Brine or water roadspreading in WV

Does roadspreading of brine equate to oil and gas waste dumping?

air quality impact, which is why roadspreading of brine occurs

This 2015 photo from West Virginia illustrates that large trucks on dirt roads create a legitimate dust problem, which impacts both air and water quality.

The application of liquid oil and gas waste from conventional wells onto roadways for dust control and road stabilization is permitted in Pennsylvania, provided that operators adhere to plans approved by the Department of Environmental Protection (DEP). There are brine spreading guidelines that operators are required to follow, but overall, DEP considers roadspreading to be a beneficial use of the liquid oil and gas waste products.

Dust suppression is a legitimate concern, particularly in areas that see a lot of heavy truck traffic on dirt roads, such rural oil and gas fields. Prolonged exposure to airborne dust contributes to a number of different health problems, ranging from temporary irritation to debilitating diseases of the heart, lungs, and kidneys. This road dust can also impact aquatic life, from plants to aquatic insects to fish.

While applying liquid waste from the oil and gas industry undoubtedly seems like a convenient solution to dusty roads, is roadspreading really advisable?

PA Oil and Gas Liquid Waste Road Applications


View map fullscreen | How FracTracker maps work

In the map above, the areas in green are municipalities where liquid waste from Pennsylvania’s conventional wells were applied to roadways in 2016. The purple areas are counties where additional quantities of the liquid waste were applied in cases where the exact municipality was not specified on the 2016 waste report. The majority of the state’s oil and gas roadspreading remains in Pennsylvania, but some of the brine is spread on roads in New York, as well.

What’s in the brine?

In Pennsylvania, the large-scale extraction efforts from deep carbon-rich shales like the Marcellus and Utica formations are classified as unconventional oil and gas, whereas the shallower formations requiring smaller amounts of hydraulic fracturing stimulation to bring the wells into production are considered to be conventional.

While the chemical components of these brines vary from formation to formation, in general they are known for containing high-salinity toxic metals, such as barium and strontium, as well as volatile organic compounds including benzene. Bromide in the brine can interact with purification processes at treatment plants to create carcinogenic compounds called trihalomethanes. These compounds actually created a problem in the early parts of the Marcellus boom in Western Pennsylvania, when large enough quantities of bromide were added to the region’s rivers and streams. And of particular concern is naturally occurring radioactive materials (NORMs), which sometimes occur at very high concentrations, even in brines from conventional wells.

The Pennsylvania Geological Survey commissioned Evan Dresel and Arthur Rose from Penn State to investigate oil and gas brine from a sample of 40 wells in 1985, although the accompanying paper wasn’t published until 2010.  Their samples included dissolved solids of 343,000 milligrams per liter, and radium occurring at up to 5,300 picocuries per liter. As a point of comparison, the US Environmental Protection Agency mandates that drinking water not exceed 5 picocuries per liter, and the authors of this report express concern about the high levels shown in these brines.

Based on the six samples analyzed, radium shows a general correlation with barium and strontium and an inverse correlation with [sulfate], though the correlation is not perfect. The radium values are high enough that a possible radiation hazard exists, especially where radium could be adsorbed on iron oxides and accumulate in brine tanks.

The article’s preface, written in 2010, echoes the concern, stating, ” the very high radium contents indicate that caution should be used in handling these brines.” One imagines that the radium content might also be a concern for people walking their dogs along dirt roads where these brines are spread.

Testing for radiological contamination appears to be insufficient for liquid oil and gas waste. Ben Stout, PhD, a professor of Biology at Wheeling Jesuit University (and a FracTracker Alliance board member) sampled liquid waste from Marcellus Shale wells in 2009. Here is what he found:

In terms of radiation, 9 of the 13 samples exceeded the drinking water standard for radium. Furthermore, 7 of the 13 samples exceeded the drinking water standard for gross alpha particles, which are a strong indicator of radioactivity. Most notably, one sample from a frac pit at the Phillips #20 site in Westmoreland County, PA yielded a gross alpha reading of 4846 +/‐ 994 picocuries per liter (pCi/L), though the drinking water standard is 15 pCi/L. In fact, the same sample had combined radium readings well over 1,000 pCi/L, a multiple in excess of 200 times the (5 pCi/L) standard. It should be noted that none of the samples triggered a response from radiation meters.

What to do?

From environmental concerns of high salinity to health concerns about the toxic and radiological content of oil and gas brines, intentionally introducing this waste product to public spaces is a dubious practice. It is understandable that township supervisors would want to use readily available materials for dealing with dust control on dirt roads, but if you are concerned about the practice and your area is indicated on the map above, you may wish to contact them to find out where this waste is being spread in greater detail.

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

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

Wayne National Forest map and drilling

Wayne National Forest Could Be Deforested – Again

Guest article by Becca Pollard

Eighty years ago, Southeastern Ohio was a wasteland of barren, eroding hills. During the 18th and 19th centuries this once heavily forested area in the Appalachian foothills had been clear cut and mined beyond recognition. When the Great Depression struck, lowering crop prices made farming unprofitable in the area, and 40% of the population moved away.

In 1933, President Franklin Delano Roosevelt established the Civilian Conservation Corps (CCC), a public work relief program that employed men aged 18-25 to do manual labor related to conservation and development of natural resources such as planting trees, constructing trails, roads, and lodges, fighting wildfires, and controlling erosion. The following year, Ohio’s legislature agreed to allow the federal government to purchase land in the state for the purpose of establishing a national forest. The Forest Service was tasked with restoring the land for what is now called Wayne National Forest (WNF). A tree nursery was established near Chillicothe, and with the help of the CCC and volunteers, including members of the Daughters of the American Revolution, garden clubs, and school children, reforestation began.

Photos Credit: US Forest Service

An Area on the Mend

Today, WNF comprises three units that span 12 Ohio counties in the Unglaciated Allegheny Plateau. The hills are covered in biologically diverse mixed mesophytic forest, which includes approximately 120 species of trees and provides habitat for at least 45 species of mammals, 158 species of birds, 28 species of reptiles, 29 species of amphibians, and 87 species of fish. The US Forest Service estimates that 240,000 people visit this ecological wonder annually, according to Forest Recreation Program Manager, Chad Wilberger, in Nelsonville, Ohio. The restoration of barren public land to its current state is a great achievement. If it continues to be protected, Wayne could one day resemble the old growth forest that thrived here before the arrival of European settlers.

The Bureau of Land Management (BLM), however, has recently decided to lease up to 40,000 acres of Wayne to gas and oil companies for horizontal hydraulic fracturing, or fracking. The first auction took place last December resulting in the lease of 700 acres. A second auction this March leased another 1,200 acres. Nearly all of this land lies within the 60,000 acre Marietta Unit of the forest. This brings Oil & Gas Expressions of Interest (EOI) acreage to roughly 7.5% of all WNF owned parcels in this unit.

Wayne National Forest and Adjacent Existing Oil and Gas Infrastructure
Below is a map of the Wayne National Forest, along with parcels owned by WNF (shown in gray) and those that might be subject to unconventional oil and gas development (gray parcels outlined with dashes). We also include existing unconventional oil and gas infrastructure near the park. Explore the map below, or click here to view the map fullscreen.


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Not new, not old

Gas and oil development is not new to the Wayne. Since the passage of The Federal Land Policy and Management Act of 1976, the US Forest Service’s land management plan for WNF has included conventional drilling, and derricks are a common sight on both public and private land in southeastern Ohio.

Fracking (unconventional drilling), however, has a far greater impact, requiring clear cutting of large areas of land for the construction of concrete well pads, and the use of millions of gallons of water that will become contaminated during the process and then transported by truck to injection wells. Accidents can be catastrophic for workers and nearby residents, and fracking and waste water disposal have been linked to earthquakes in Ohio.

In 2012, BLM updated its WNF Land and Resource Management Plan to allow fracking in the forest without conducting new impact studies.

What is at risk?

The Marietta Unit of the WNF is located in Monroe, Perry, and Washington counties in Southeastern Ohio along the Ohio River. Within its boundary are a wealth of trails used for hiking, backpacking, horseback riding, and mountain biking, campgrounds, and waterways ideal for kayaking and fishing. Both the highest and lowest points in the Wayne lie in this unit, as does the Irish Run Natural Bridge. The area is also known for its exceptional wildflowers, as shown in the photos below.

One popular recreation area, Lamping Homestead, lies directly within an oil and gas Expression Of Interest (EOI) parcel #3040602400 (See Map Above), one of the areas under consideration for lease. In the 1800s, it was the site of the Lamping family’s farm, but today all that remains of the settlers is a small cemetery with an iron gate atop a hill overlooking a small lake. Six campsites are situated around the western side of the lake, and two intersecting hiking loops rise into the wooded hills to the east. On the western side of the parking lot is a covered picnic area. A creek flows out of the lake and into Clear Fork, a tributary of the Little Muskingum River, across the road from the parking lot.

Both the lake and stream are popular boating and fishing areas. Lamping is an excellent spot for wildlife viewing. The lake, the creeks that flow in and out of it, and the surrounding wooded hills support an impressive variety of plant and animal species. During the day, visitors might spot ducks, geese, great blue herons, red-winged blackbirds, summer tanagers, red spotted newts, box turtles, northern water snakes, garter snakes, deer, rabbits, and muskrats. At night, they could be greeted by a cacophony of voices from frogs, owls, and coyotes.

Species of trees, plants, and fungus are also numerous. In winter, stands of white pine pop out against the bare branches of oak, hickory, maple, buckeye, and other deciduous trees. In spring, eye-catching splotches of blooming dogwood and redbud contrast against the many shades of green. But hikers who pull their gaze away from the brightly colored canopy and look down are rewarded with an abundance of wildflowers and the butterflies they attract, as well as many varieties of mushrooms and fungus, including such edible varieties as morels, wood ear, and dryad’s saddle.

Estimating Disturbances

It is unclear how much surface disturbance would occur on public land if this parcel were to be fracked, but even if the well pad and pipelines were constructed on private land adjacent to the forest, in order to drill under the forest, the public land and its inhabitants and visitors would certainly be impacted.

There is no question that noise and air pollution from traffic and construction would be disruptive both to wildlife and to human visitors. Explore various photos of the oil and gas industry in the gallery below:

The extraction process requires 2 million to 6 million gallons of fresh water each time a well is fracked. The rate at which hydraulic fracturing’s water demand is increasing on a per-well basis here in Ohio reached an exponential state around Q4-2013 and Q1-2014 and continues to rise at a rate of 3.1 million gallons per well per year (Figure 1).

Ohio Hydraulic Fracturing Total and Per Well Freshwater Demand between Q3-2010 and Q3-2016.

Ohio Hydraulic Fracturing Total and Per Well Freshwater Demand between Q3-2010 and Q3-2016.

In Ohio, oil and gas companies are allowed to pull this water directly from streams and rivers at no cost. All this is possible, despite the fact that after its use it is so contaminated that it must be disposed of via injection wells and is permanently removed from the water cycle. The industry is already pulling water from streams in the Marietta Unit of the WNF for use in fracking on private land. Fracking public land simply means water withdrawals will occur on a much larger scale.

Ohio and West Virginia Shale Water Demand and Injection Waste Disposal
This map shows Utica wells weighted by water demand and disposal (and/or production). It also depicts water, sand, and chemical usage as well as injection waste and oil production. Explore the map below, or click here to view map fullscreen.


View map fullscreen | How FracTracker maps work

Inevitable methane leaks, in addition to contributing to climate change, affect humans and wildlife in their immediate vicinity, causing headaches and nausea and even killing trees and plants.

In addition to the anticipated harm that fracking inflicts upon a natural area, there is also a risk of accidents with potentially devastating consequences. Residents of Monroe County have already seen a few in recent years from fracking on private land. In 2014, a well pad fire in the village of Clarington resulted in a chemical spill that contaminated nearby Opossum Creek, killing 70,000 fish. The same year a large gas leak 15 miles south in the village of Sardis resulted in the evacuation of all homes within half mile radius.

Recent studies have shown that extraction wells, in addition to injection wells, can cause earthquakes. Unsurprisingly, Monroe County has seen a spike in seismic activity with the increase in fracking activity in the area. The most recent incident was a 3.0 magnitude earthquake in the forest less than five miles from Lamping Homestead in April of this year.

Supporters of Wayne National Forest

Many people have repeatedly spoken out against BLM’s plan, submitting a petition with more than 100,000 signatures, and protesting outside Wayne National Forest Headquarters and Athens Ranger Station in Nelsonville. They have even organized voters to call and write letters to Regional Forester Kathleen Atkinson and legislators, including Senators Sherrod Brown and Rob Portman, and Governor John Kasich. BLM has not budged on its decision, unfortunately, insisting that leasing this land for fracking, and associated infrastructure buildout, will have “no significant impact.”

This May, the Center for Biological Diversity, Ohio Environmental Council, Ohio Sierra Club, and Heartwood, a regional organization focused on protecting forests, filed a lawsuit against BLM, aiming to void BLM leases and halt all fracking operations within the national forest.

Concerned citizens continue to organize raise awareness as they await the outcome of the suit.

Becca Pollard is Freelance Journalist and Co-founder of Keep Wayne Wild


Data Downloads

Click on the links below to download the data used to create this article’s maps:

Ethanol and fracking

North American Ethanol’s Land, Water, Nutrient, and Waste Impact

Corn Ethanol and Fracking – Similarities Abound

Even though it is a biofuel and not a fossil fuel, in this post we discuss the ways in which the corn ethanol production industry is similar to the fracking industry. For those who may not be familiar, biofuel refers to a category of fuels derived directly from living matter. These may include:

  1. Direct combustion of woody biomass and crop residues, which we recently mapped and outlined,
  2. Ethanol1 produced directly from the fermentation of sugarcanes or indirectly by way of the intermediate step of producing sugars from corn or switchgrass cellulose,
  3. Biodiesel from oil crops such as soybeans, oil palm, jatropha, and canola or cooking oil waste,2 and
  4. Anaerobic methane digestion of natural gas from manures or human waste.

Speaking about biofuels in 2006, J. Hill et al. said:

To be a viable substitute for a fossil fuel, an alternative fuel should not only have superior environmental benefits over the fossil fuel it displaces, be economically competitive with it, and be producible in sufficient quantities to make a meaningful impact on energy demands, but it should also provide a net energy gain over the energy sources used to produce it.

Out of all available biofuels it is ethanol that accounts for a lion’s share of North American biofuel production (See US Renewables Map Below). This trend is largely because most Americans put the E-10 blends in their tanks (10% ethanol).3 Additionally, the Energy Independence and Security Act of 2007 calls for ethanol production to reach 36 billion gallons by 2022, which would essentially double the current capacity (17.9 billion gallons) and require the equivalent of an additional 260 refineries to come online by then (Table 1, bottom).

US Facilities Generating Energy from Biomass and Waste along with Ethanol Refineries and Wind Farms


View map fullscreen | How FracTracker maps work

But more to the point… the language, tax regimes, and potential costs of both ethanol production and fracking are remarkably similar. (As evidenced by the quotes scattered throughout this piece.) Interestingly, some of the similarities are due to the fact that “Big Ag” and “Big Oil” are coupled, growing more so every year:

The shale revolution has resulted in declining natural gas and oil prices, which benefit farms with the greatest diesel, gasoline, and natural gas shares of total expenses, such as rice, cotton, and wheat farms. However, domestic fertilizer prices have not substantially fallen despite the large decrease in the U.S. natural gas price (natural gas accounts for about 75-85 percent of fertilizer production costs). This is due to the relatively high cost of shipping natural gas, which has resulted in regionalized natural gas markets, as compared with the more globalized fertilizer market. (USDA, 2016)

Ethanol’s Recent History

For background, below is a timeline of important events and publications related to ethanol regulation in the U.S. in the last four decades: 

Benefits of Biofuels

[Bill] Clinton justified the ethanol mandate by declaring that it would provide “thousands of new jobs for the future” and that “this policy is good for our environment, our public health, and our nation’s farmers—and that’s good for America.” EPA administrator Carol Browner claimed that “it is important to our efforts to diversify energy resources and promote energy independence.” – James Bovard citing Peter Stone’s “The Big Harvest,” National Journal, July 30, 1994.

Of the 270 ethanol refineries we had sufficient data for, we estimate these facilities employ 235,624 people or 873 per facility and payout roughly $6.18-6.80 billion in wages each year, at an average of $22.9-25.2 million per refinery. These employees spend roughly 423,000 hours at the plant or at associated operations earning between $14.63 and $16.10 per hour including benefits. Those figures amount to 74-83% of the average US income. In all fairness, these wages are 13-26% times higher than the farming, fishing, and forestry sectors in states like Minnesota, Nebraska, and Iowa, which alone account for 33% of US ethanol refining.

Additional benefits of ethanol refineries include the nearly 179 million tons of CO2 left in the field as stover each year, which amounts to 654,532 tons per refinery. Put another way – these amounts are equivalent to the annual emissions of 10.7 million and 39,194 Americans, respectively.

Finally, what would a discussion of ethanol refineries be without an estimate of how much gasoline is produced? It turns out that the 280 refineries (for which we have accurate estimates of capacity) produce an average of 71.93 million gallons per year and 20.1 billion gallons in total. That figure represents 14.3% of US gasoline demand.

Costs of Biofuels

Direct Costs

Biofuel expansions such as those listed in the timeline above and those eluded to by the likes of the IPCC have several issues associated with them. One of which is what Pimentel et al. considered an insufficient – and to those of us in the fracking NGO community, familiar sounding – “breadth of relevant expertise and perspectives… to pronounce fairly and roundely on this many-sided issue.”

The above acts and reports in the timeline prompted many American farmers to double down on corn at the expense of soybeans, which caused Indirect Land Use Change (ILUC); the global soy market skyrocketed. This, in turn, prompted the clearing and/or burning of large swaths of the Amazonian rainforests and tropical savannas in Brazil, the world’s second-leading soy producer. More recently, large swaths of Indonesia and Malaysia’s equally biodiverse peatland forests have been replaced by palm oil plantations (Table 2 and Figure 3, bottom). In the latter countries, forest displacement is increasing by 2.7-5.3% per year, which is roughly equal to the the rate of land-use change associated with hydraulic fracturing here in the US4 (Figure 1).


Figures 1A and 1B. Palm Oil Production in A) Indonesia and B) Malaysia between 1960 and 2016.

There is an increasing amount of connectivity between disparate regions of the world with respect to energy consumption, extraction, and generation. These connections also affect how we define renewable or sustainable:

In a globalized world, the impacts of local decisions about crop preferences can have far reaching implications. As illustrated by an apparent “corn connection” to Amazonian deforestation, the environmental benefits of corn-based biofuel might be considerably reduced when its full and indirect costs are considered. (Science, 2007)

These authors pointed to the fact that biofuel expectations and/or mandates fail to account for costs associated with atmospheric – and leaching – emissions of carbon, nitrogen, phophorus, etc. during the conversion of lands, including diverse rainforests, peatlands, savannas, and grasslands, to monocultures. Also overlooked were:

  • The ethical concerns associated with growing malnourishment from India to the United States,
  • The fact that 10-60%5 more fossil fuel derived energy is required to produce a unit of corn ethanol than is actually contained within this very biofuel, and
  • The tremendous “Global land and water grabbing” occuring in the name of natural resource security, commodification, and biofuel generation.

Sacrificing long-term ecological/food security in the name of short-term energy security has caused individuals and governments to focus on taking land out of food production and putting it into biofuels.

The rationale for ethanol subsidies has continually changed to meet shifting political winds. In the late 1970s ethanol was championed as a way to achieve energy independence. In the early 1980s ethanol was portrayed as salvation for struggling corn farmers. From the mid and late 1980s onward, ethanol has been justified as saving the environment. However, none of those claims can withstand serious examination. (James Bovard, 1995)

This is instead of going the more environmentally friendly route of growing biofuel feedstocks on degraded or abandoned lands. An example of such an endeavor is the voluntary US Conservation Reserve Program (CRP), which has stabilized at roughly 45-57 thousand square miles of enrolled land since 1990, even though the average payout per acre has continued to climb (Figure 2).

The Average Subsidy to Farmers Per Acre of Conservation Reserve Program (CRP) between 1986 and 2015.

Figure 2. The Average Subsidy to Farmers Per Acre of Conservation Reserve Program (CRP) between 1986 and 2015.

The primary goals of the CRP program are to provide an acceptable “floor” for commodity prices, reduce soil erosion, enhance wildlife habitat, ecosystem services, biodiversity, and improve water quality on highly erodible, degraded, or flood proned croplands. Interestingly CRP acreage has declined by 27% since a high of 56 thousand square miles prior to the Energy Independence and Security Act of 2007 being passed. Researchers have pointed to the fact that corn ethanol production on CRP lands would create a carbon debt that would take 48 years to repay vs. a 93 year payback period for ethanol on Central US Grasslands.

To quote Fred Magdoff in The Political Economy and Ecology of Biofuels:

Alternative fuel sources are attractive because they can be developed and used without questioning the very workings of the economic system — just substitute a more “sustainable,” “ecologically sound,” and “renewable” energy for the more polluting, expensive, and finite amounts of oil. People are hoping for magic bullets to “solve” the problem so that capitalist societies can continue along their wasteful growth and consumption patterns with the least disruption. Although prices of fuels may come down somewhat — with dips in the business cycle, higher rates of production, or a burst in the speculative bubble in the futures market for oil — they will most likely remain at historically high levels as the reserves of easily recovered fuel relative to annual usage continues to decline.

Indirect Costs: Ethanol, Fertilizers, and the Gulf of Mexico Dead Zone

This is the Midwest vs. the Middle East. It’s corn farmers vs. the oil companies. – Dwaney Andreas in Big Stink on the Farm by David Greising

Sixty-nine percent6 of North America’s ethanol refineries are within the Mississippi River Basin (MRB). These refineries collectively rely on corn that receives 1.9-5.1 million tons of nitrogen each year, with a current value of $1.06-2.91 billion dollars or 9,570-26,161 tons of nitrogen per refinery per year (i.e. $5.42-14.81 million per refinery per year). These figures account for 27-73% of all nitrogen fertilizer used in the MRB each year. More importantly, the corn acreage receiving this nitrogen leaches roughly 0.81-657 thousand tons of it directly into the MRB. Such a process amounts to 5-44% of all nitrogen discharged into the Gulf of Mexico each year and 1.7-13.8 million tons of algae responsible for the Gulf’s growing Dead Zone.

Midwest/Great Plains US Ethanol Refineries and Crop Residue Production

Leaching of this nitrogen is analogous to flushing $45.7-371.6 million dollars worth of precious capital down the drain. Put another way, these dollar figures translate into anywhere between 55% and an astonishing 4.53 times Direct Costs to the Gulf’s seafood and tourism industries of the Dead Zone itself.

These same refineries rely on corn acreage that also receives 0.53-2.61 million tons of phosphorus each year with a current value of 0.34-1.66 billion dollars. Each refinery has a phosphrous footprint in the range of 2,700 to 13,334 tons per year (i.e., $1.72-8.47 million). We estimate that 25,399-185,201 tons of this fertilizer phosphorus is leached into the the MRB, which is equivalent to 19% or as much as 1.42 times all the phosphorous dischared into the Gulf of Mexico per year. Such a process means $16.13-117.60 million is lost per year.

Together, the nitrogen and phosphorus leached from acreage allocated to corn ethanol have a current value that is between 75% and nearly 6 times the value lost every year to the Gulf’s seafood and tourism industries.

Indirect Costs: Fertilizer and Herbicide Costs and Leaching

The 270 ethanol refineries we have quality production data for are relying on corn that receives 367,772 tons of herbicide and insecticide each year, with a current value of $6.67 billion dollars or 1,362 tons of chemical preventitive per refinery per year (i.e. $24.7 million per refinery per year). More importantly the corn acreage receiving these inputs leaches roughly 15.8-128.7 thousand tons of it directly into surrounding watersheds and underlying aquifers. Leaching of these inputs is analogous to flushing $287 million to $2.3 billion dollars down the drain.

What’s Next?

During the recent Trump administration EPA, USDA, DOE administrator hearings, the Renewable Fuel Standard (RFS) was cited as critical to American energy independence by a bipartisan group of 23 senators. Among these were Democratic senator Amy Klobuchar and Republican Chuck Grassley, who co-wrote a letter to new EPA administrator Scott Pruitt demanding that the RFS remains robust and expands when possible. In the words of Democratic Senator Heidi Heitkamp – and long-time ethanol supporter – straight from the heart of the Bakken Shale Revolution in North Dakota:

The RFS has worked well for North Dakota farmers, and I’m fighting to defend it. As we’re doing today in this letter, I’ll keep pushing in the U.S. Senate for the robust RFS [and Renewable Volume Obligations (RVOs)] we need to support a thriving biofuels industry and stand up for biofuels workers. Biofuels create good-paying jobs in North Dakota and help support our state’s farmers, who rely on this important market – particularly when commodity prices are challenging.

Furthermore, the entire Iowa congressional delegation including the aforementioned Sen. Grassley joined newly minted USDA Secretary Sonny Perdue when he told the Iowa Renewable Fuels Association:

You have nothing to worry about. Did you hear what he said during the campaign? Renewable energy, ethanol, is here to stay, and we’re going to work for new technologies to be more efficient.

How this advocacy will play out and how the ethanol industry will respond (i.e., increase productivity per refinery or expand the number of refineries) is anybody’s guess. However, it sounds like the same language, lobbying, and advertising will continue to be used by the Ethanol and Unconventional Oil and Gas industries. Additional parallels are sure to follow with specific respect to water, waste, and land-use.

Furthermore, as both industries continue their ramp up in research and development, we can expect to see productivity per laborer to continue on an exponential path. The response in DC – and statehouses across the upper Midwest and Great Plains – will likely be further deregulation, as well.

From a societal perspective, an increase in ethanol production/grain diversion away from people’s plates has lead to a chicken-and-egg positive feedback loop, whereby our farmers continue to increase total and per-acre corn production with less and less people. In rural areas, mining and agriculture have been the primary employment sectors. A further mechanization of both will likely amplify issues related to education, drug dependence, and flight to urban centers (Figures 4A and B).

We still don’t know exactly how efficient ethanol refineries are relative to Greenhouse Gas Emissions per barrel of oil. By merging the above data with facility-level CO2 emissions from the EPA Facility Level Information on Greenhouse gases Tool (FLIGHT) database we were able to match nearly 200 of the US ethanol refineries with their respective GHG emissions levels back to 2010. These facilities emit roughly:

  • 195,116 tons of CO2 per year, per facility,
  • A total of 36.97 million tons per year (i.e., 2.11 million Americans worth of emissions), and
  • 22,265 tons of CO2 per barrel of ethanol produced.

Emissions from ethanol will increase to 74.35 million tons in 2022 if the Energy Independence and Security Act of 2007’s prescriptions run their course. Such an upward trend would be equivalent to the GHG emissions of somewhere between that of Seattle and Detroit.

What was once a singles match between Frackers and Sheikhs may turn into an Australian Doubles match with the Ethanol Lobby and Farm Bureau joining the fray. This ‘game’ will only further stress the food, energy, and water (FEW) nexus from California to the Great Lakes and northern Appalachia.

We are on a thinner margin of food security, just as we are on a thinner margin of oil security… The [World] Bank implicitly questions whether it is wise to divert half of the world’s increased output of maize and wheat over the next decade into biofuels to meet government “mandates.” – Ambrose Evans-Pritchard in The Telegraph

Will long-term agricultural security be sacrificed in the name of short-term energy independence?

US and Global Corn Production and Acreage between 1866 and 2015.

Figure 3. US and Global Corn Production and Acreage between 1866 and 2015.

Figures 4A and 4B. A) Number of Laborers in the US Mining, Oil and Gas, Agriculture, Forestry, Fishing, and Hunting sector and B) US Corn Production Metrics Per Farm Laborer between 1947 and 2015.

Ethanol Tables

Table 1. Summary of our Corn Ethanol Production, Land-Use, and Water Demand analysis

Gallons of Corn Ethanol Produced Per Year 17,847,616,000
Bushels of Corn Needed 6,374,148,571
Percent of US Production 44.73%
Land Needed 104,372,023 acres
“” 163,081 square miles
Percent of Contiguous US Land 5.51%
Percent of US Agricultural Land 11.28%
Gallons of Water Needed 49.76 trillion (i.e. 3.55 million swimming pools)
Gallons of Water Per Gallon of Oil 2,788
Average and Total Site/Industry Capacity
Average Corn Ethanol Production Per Existing or Under Construction Facility (n = 257) 69,717,250
Gallons of Corn Ethanol Produced Per Year 17,847,616,000
Difference Between 2022 Energy Independence and Security Act of 2007 36 Billion Gallon Mandate 18,152,384,000
# of New Refineries Necessary to Get to 2022 Levels 260
Percent Increase Over Current Facility Inventory 1.7
IEA 2009 World Energy Outlook 250-620% Increase Predictions for 2030
250% 44,619,040,000
# of New Refineries Necessary 640
Percent Increase Over Current Facility Inventory 150.00
620% 110,655,219,200
# of New Refineries Necessary 1,587
Percent Increase Over Current Facility Inventory 520.00

Table 2. Global Population Growth and Corn and Soybean Productivity Trends.

Percent Change Metric
+1.13% Global Population Growth Trend
Corn (Bushels Per Acre)
+1.15% Per Year United States
+1.20% Per Year Global
Soybean (Tons Per Acre)
+0.9% Per Year United States
+1.5% Per Year Brazil
Palm Oil (Tons)
+5.1% Per Year Indonesia
+2.7% Per Year Malaysia

References and Footnotes

  1. Ethanol as defined in the Ohio Revised Code (ORC) Corporation Franchise Tax 5733.46 means “fermentation ethyl alcohol derived from agricultural products, including potatoes, cereal, grains, cheese whey, and sugar beets; forest products; or other renewable resources, including residue and waste generated from the production, processing, and marketing of agricultural products, forest products, and other renewable resources that meet all of the specifications in the American society for testing and materials (ASTM) specification D 4806-88 and is denatured as specified in Parts 20 and 21 of Title 27 of the Code of Federal Regulations.”
  2. A) Pyrolysis is included in the biofuel category and involves the anaerobic decay of cellulose rich feedstocks such as switchgrass at high temperatures producing synthetic diesel or syngas, and
    B) According to many researchers biofuels made from waste biomass or crops grown on degraded and abandoned lands with warm-season prairie grasses and legumes incur little or no carbon debt and provide “immediate and sustained Greenhouse Gas (GHG) advantages” by rehabilitating soil health and capturing, rather than emitting by way of increased fertilizer use, various forms of nitrogen including N2O, NO3, and NO2.
  3. According to Fred Magdoff, the ethanol complex is lobbying for “more automobile engines capable of using E-85 (85 percent ethanol, 15 percent gasoline) for which there are currently 2,710 fueling stations across the country although 56% of them are in just nine states: 1) Wisconsin (117), 2) Missouri (107), 3) Minnesota (335), 4) Michigan (174), 5) Indiana (172), 6) Illinois (221),  7) Iowa (193), 8) Texas (99), and 9) Ohio (97). Some states are mandating a mixture greater than 10 percent. Ethanol can’t be shipped together with gasoline in pipelines because it separates from the mixture when moisture is present, so it must be trucked to where it will be mixed with gasoline.” The E-85 blend comes with its own costs including higher emissions of CO, VOC, PM10, SOx, and NOx than gasoline.
  4. McClaugherty, C., Auch, W. Genshock, E. and H. Buzulencia. (2017). Landscape impacts of infrastructure associated with Utica shale oil and gas extraction in eastern Ohio, Ecological Society of America, 100th Annual Meeting, Baltimore, MD, August, 2015.
  5. Hill et al. recently indicated “Ethanol yields 25% more energy than the energy invested in its production, whereas biodiesel yields 93% more.”
  6. An additional 9-10 refineries or 73% of all ethanol refineries are within 25 miles of the Mississippi River Basin.

By Ted Auch, PhD, Great Lakes Program Coordinator, FracTracker Alliance

Cover photo, left: Oil and gas well pad, Ohio. Photo by Ted Auch.
Cover photo, right: A typical ethanol plant in West Burlington, Iowa. Photo by Steven Vaughn.


Data Downloads

Click on the links below to download the datasets used to create the maps in this article.

  1. Detailed US Ethanol water, land, chemical fertilizer, and herbicide demand
  2. Estimates of North American Ethanol Refinery’s water and land-use demand

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