Recent Changes to Pennsylvania Maps
June 28, 2017 /4 Comments/in Articles, Data and Analysis, Pennsylvania /by Matt Kelso, BA
Recently, the Pennsylvania Department of Environmental Protection (DEP) started to offer additional data resources with the introduction of the Open Data Portal. This development, along with the continued evolution of the ArcGIS Online mapping platform that we utilize has enabled some recent enhancements in our mapping of Pennsylvania oil and gas infrastructure. We’ve made changes to the existing Pennsylvania Shale Viewer for unconventional wells, and created a Conventional and Historical Wells in Pennsylvania map.
Unconventional Wells
Rather than defining the newer, industrial-scaled oil and gas wells by specific geological formations, configuration of the well, or the amount of fluid injected into the ground during the hydraulic fracturing process, Pennsylvania’s primary classification is based on whether or not they are considered to be unconventional.
Unconventional Wells – An unconventional gas well is a bore hole drilled or being drilled for the purpose of or to be used for the production of natural gas from an unconventional formation. An unconventional formation is defined as a geologic shale formation below the base of the Elk Sandstone or its geologic equivalent where natural gas generally cannot be produced except by horizontal or vertical well bores stimulated by hydraulic fracturing.
PA Shale Viewer (Unconventional Drilling)
View map fullscreen | How FracTracker maps work
The previous structure of the PA Shale Viewer had separate layers for permits, drilled wells, and violations. This version replaces the first two layers with a single layer of unconventional locations, which we have called “Unconventional Wells and Permits” for the sake of clarity. The violations layer appears in the same format as before. When users are zoomed out, they will see generalized layers showing the overall location of O&G infrastructure and violations in the state, which were formed by creating a one mile buffer around these features. As users zoom in, the generalized layers are then replaced with point data showing the specific wells and violations. At this point, users can click on individual points and learn more about the features they see on the map.
Figure 1. PA Shale Viewer zoomed in to see individual wells by status
O&G locations are displayed by their well status, as of the time that FracTracker processed the data, including: Abandoned, Active, Operator Reported Not Drilled, Plugged OG Well, Proposed but Never Materialized, and Regulatory Inactive Status. Note that just because a well is classified as Active does not mean that it has been drilled, or even necessarily permitted. These milestones, along with whether or not it has been plugged, can be determined by looking for entries in the permit issue date, spud date, and plug date entries in the well’s popup box.
Conventional and Historical Wells
The map below shows known conventional wells in Pennsylvania along with additional well locations that were digitized from historical mining maps.
Conventional Oil and Gas Wells Map
Although there are over 19,000 unconventional oil and gas locations in Pennsylvania, this figure amounts to just 11% of the total number of wells in the state that the DEP has location data for, the rest being classified as conventional wells. Furthermore, in a state that has been drilling for oil and gas since before the Civil War, there could be up to 750,000 abandoned wells statewide.
The DEP has been able to find the location of over 30,000 of these historical wells by digitizing records from old paper mining maps. This layer has records for 16 different counties, but well over half of these wells are in just three counties – Allegheny, Butler, and Washington. It looks like it would take a lot more work to digitize these historical wells throughout the rest of the state, but even when that happens, we will probably still not know where the majority of the old oil and gas wells in the state are located.
By Matt Kelso, Manager of Data & Technology
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/06/PA-Changes-Maps-Feature.jpg 400 900 Matt Kelso, BA https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg Matt Kelso, BA2017-06-28 13:44:592017-06-28 13:44:59Recent Changes to Pennsylvania Maps
Forest Fragmentation and O&G Development in PA’s Susquehanna Basin
June 6, 2017 /in Articles, Data and Analysis, Oil/Gas, Pennsylvania /by Matt Kelso, BA
In this forest fragmentation analysis, FracTracker looked at existing vegetation height in the northern portion of Pennsylvania’s Susquehanna River Basin. The vegetation height data is available from LANDFIRE, a resource used by multiple federal agencies to assess wildfire potential by categorizing the vegetation growth in 30 by 30 meter pixels into different categories. In the portion of Pennsylvania’s Susquehanna Basin where we looked, there were 29 total categories based on vegetation height. For ease of analysis, we have consolidated those into eight categories, including roads, developed land, forest, herbs, shrubs, crops, mines and quarries, and open water.
We compared the ratio of the total number of each pixel type to the type that was found at vertical and horizontal wells in the region. In this experiment, we hypothesized that we would see evidence of deforestation in the areas where oil and gas development is present. Per our correspondence with LANDFIRE staff, the vegetation height data represents a timeframe of about 2014, so in this analysis, we focused on active wells that were drilled prior to that date. We found that the pixels on which the horizontal wells were located had a significantly different profile type than the overall pixel distribution, whereas conventional wells had a more modest departure from the general characteristics of the region.
Figure 1 – Vegetation profile of the northern portion of Pennsylvania’s Susquehanna River Basin. The area is highly impacted by O&G development, a trend that is likely to continue in the coming years.
In Figure 1, we see that the land cover profile where vertical wells (n=6,198) are present is largely similar to the overall distribution of pixels for the entire study area (n=40,897,818). While these wells are more than six times more likely to be on areas classified as mines, quarries, or barren, it is surprising that the impact is not even more pronounced. In terms of forested land, there is essentially no change from the background, with both at about 73%. However, the profile for horizontal wells (n=3,787) is only 51% forested, as well as being four times more likely than the background to be categorized as herbs, which are defined in this dataset as having a vegetation height of around one meter.
Why Aren’t the Impacts Even More Pronounced?
While the impacts are significant, particularly for horizontal wells, it is a bit surprising that evidence of deforestation isn’t even more striking. We know, for example, that unconventional wells are usually drilled in multi-well pads that frequently exceed five acres of cleared land, so why aren’t these always classified as mines, quarries, and barren land, for example? There are several factors that can help to explain this discrepancy.
First, it must be noted that at 900 square meters, each pixel represents almost a quarter of acre, so the extent of these pixels will not always match with the area of disturbance. And in many cases, the infrastructure for older vertical wells is completely covered by the forest canopy, so that neither well pad nor access road is visible from satellite imagery.
The map above shows horizontal and vertical wells in a portion of Centre County, Pennsylvania, an area within our study region. Note that many of the vertical wells, represented by purple dots, appear to be in areas that are heavily forested, whereas all of the horizontal wells (yellow dots) are on a defined well pad in the lower right part of the frame. Panning around to other portions of Centre County, we find that vertical wells are often in a visible clearing, but are frequently near the edge, so that the chances of the 30 by 30 meter pixel that they fall into is much more likely to be whatever it would have been if the well pad were not there.
We must also consider that this dataset has some limitations. First of all, it was built to be a tool for wildfire management, not as a means to measure deforestation. Secondly, there are often impacts that are captured by the tool that were not exactly on the well site. For this reason, it would make sense to evaluate the area around the well pad in future versions of the analysis.
Figure 2 – A close up of a group of wells in the study area. Note that the disturbed land (light grey) does not always correspond exactly with the well locations.
In Figure 2, we see a number of light grey areas –representing quarries, strip mines, and gravel pits –with an O&G well just off to the side. Such wells did not get classified as being on deforested land in this analysis.
And finally, after clarifying the LANDFIRE metadata with US Forest Service personnel involved in the project, we learned that while the map does represent vegetation cover circa 2014, it is actually build on satellite data collected in 2001, which has subsequently been updated with a detailed algorithm. However, the project is just beginning a reboot of the project, using imagery from 2015 and 2016. This should lead to much more accurate analyses in the future.
Why Forest Fragmentation Matters
The clearing of forests for well pads, pipelines, access roads, and other O&G infrastructure that has happened to date in the Susquehanna Basin is only a small fraction of the planned development. The industry operates at full capacity, there could be tens of thousands of new unconventional wells drilled on thousands of well pads in the region through 2030, according to estimates by the Nature Conservancy. They have also calculated an average of 1.65 miles of gathering lines from the well pad to existing midstream infrastructure. With a typical right-of-way being 100 feet wide, these gathering lines would require clearing 20 acres. It isn’t unusual for the total disturbance for a single well pad and the associated access road to exceed ten acres, making the total disturbance about 30 acres per well pad. Based on the vegetation distribution of the region, we can expect that 22 of these acres, on average, are currently forested land. Taking all of these factors into consideration, a total disturbance of 100,000 to 200,000 acres in Pennsylvania’s Susquehanna River Basin due to oil and gas extraction, processing, and transmission may well be a conservative estimate, depending on energy choices we make in the coming years.
This forest fragmentation has a number of deleterious effects on the environment. First, many invasive plant species, such as bush honeysuckle and Japanese knotweed, tend to thrive in recently disturbed open areas, where competing native plants have been removed. The practice also threatens numerous animal species that thrive far from the forest’s edge, including a variety of native song birds. The disturbed lands create significant runoff into nearby rivers and streams, which can have an impact on aquatic life. And the cumulative release of carbon into the atmosphere is staggering – consider that the average acre of forest in the United States contains 158,000 pounds of organic carbon per acre. As the area is 73% forested, the total cumulative impact could result in taking 5.8 to 11.6 million tons of organic carbon out of forested storage. Much of this carbon will find its way into the atmosphere, along with the hydrocarbons that are purposefully being extracted from drilling operations.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/06/Forest-Fragmentation-Feature.jpg 400 900 Matt Kelso, BA https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg Matt Kelso, BA2017-06-06 10:09:452017-06-28 13:24:46Forest Fragmentation and O&G Development in PA's Susquehanna Basin
PA DEP Environmental Justice Listening Tour
April 10, 2017 /in Articles, Environmental Justice, Our Perspectives, Pennsylvania /by FracTracker Alliance
A Guide to Current EJ Rules and Potential Changes
by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance
and Veronica Coptis, Executive Director, Center for Coalfield Justice
The Pennsylvania Department of Environmental Protection (DEP) will be hosting a nine-stop “listening tour” to hear residents’ perspectives on environmental justice (EJ). These sessions begin in the western part of the state on April 12th and 13th. The complete list of dates and locations of these meetings can be found here. The DEP will also be accepting written comments, which can be either mailed or emailed to DEP-OEJ@pa.gov.
The EJ listening tour follows on the heels of events in May 2016, when environmental advocacy groups questioned the well pad siting practices of oil and gas drilling company Range Resources, causing the DEP to announce it would revisit its EJ policies. Such changes would include reassessing how EJ zones are designated and what kinds of development triggers additional scrutiny by the DEP’s Office of Environmental Justice. We wrote about this story, and detailed how present EJ rules fail to account for oil and gas development in June 2016.
The following guide is meant to provide helpful information to residents in preparing for the listening tour. We first offer a summary of PA’s present EJ policies, followed by a commentary on what gaps we believe exist in those policies, and conclude with some reflections on EJ policies in other U.S. states and what we might learn from them in reassessing our own state’s EJ laws.
Listening Sessions Format
Each environmental justice listening tour will include opening remarks from Acting Secretary McDonnell, followed by a brief presentation from the Office of Environmental Justice, and then will open to receive testimony from the public. Verbal testimony is limited to 3 minutes for each witness. Organizations are asked to designate one witness to present testimony on their behalf. Verbal comments will be recorded by a court stenographer, and transcripts will be made available to the public at a later date.
The DEP Office of Environmental Justice has offered a set of eight questions to guide comments in the listening tour sessions. They are as follows:
What environmental justice concerns are most pressing in your community?
Do you feel that the current definition of an environmental justice community (20% poverty and/or 30% minority) properly represents the needs of your community and the Commonwealth at large?
Do you feel the DEP is engaged with marginalized communities to ensure that they have a voice in the decision making process? How can the DEP be more engaged with these communities?
What tools have you used to find out information on DEP permitting/enforcement actions?
What ways can the DEP be more effective at sharing information with the public?
How can the DEP be more effective at receiving public input?
What resource(s) is your community lacking that the DEP can provide that would assist in efforts to ensure environmental equity?
What additional steps can be taken by the Department to effectively reach out to these vulnerable communities to ensure that their concerns are taken into consideration?
Summary of Existing EJ Policies
According to the U.S. Environmental Protection Agency, environmental justice is “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” This same definition is used by the DEP.
In 2004, the DEP codified this EJ definition in the Environmental Justice Public Participation Policy. EJ designations are defined by the DEP as any census tract where 20% or more of the population lives in poverty and/or 30% or more of the population identifies as a minority. Designations are based on the U.S. Census Bureau and by the federal poverty guidelines.
Below is a map of current EJ designated census tracts in PA that also shows the counties where listening tour sessions will be held. When zoomed in to regional scale, EJ areas can be clicked to see their current poverty and minority percentages. The locations of oil and gas wells and permits are also visible at the regional scale.
Map of current EJ areas (based on 2015 census data) shown in teal, with listening tour counties outlined in red
Of note in the 2004 policy are the kinds of permits that trigger a potential EJ review – specifically: industrial wastewater facilities, air permits for new major source of hazardous air pollution, waste permits for landfills and incinerators, coal mining permits and coal refuse facilities, and/or concentrated animal feeding operations. The policy also allows for review of “opt-in permits” the DEP believes warrant special consideration, but we have found no evidence to suggest that this option has been historically used.
When a project triggers EJ review, the DEP “strongly encourages” the applicant meets with community stakeholders prior to submitting their permit, with the idea that additional public outreach makes project details more apparent. The applicant is also encouraged to produce “plain language” information sheets, online and in print form, regarding the proposed activity.
Issues with Existing PA EJ Policies
A complete list of what may occur when a project triggers EJ review can be found here. The following table is a breakdown of where we see deficiencies in PA EJ policies that need to be addressed:
Existing Policy Issue Possible Solutions
EJ Definition
EJ areas defined by 20% poverty/30% minority indicators.EJ ensures meaningful involvement of all people regardless of race, color, national origin, or income. Many communities are just outside poverty/minority thresholds, or are spread across multiple census tracts experiencing concentrated industrial activities.
Disproportionate exist due to other factors besides poverty and race. DEP should go beyond the census tracts, as well as account for other factors such as the “working poor”, homeownership rates, assisted school lunches rate, disability and elderly populations, and language barriers.
Reviews should factor in “cumulative impacts” of more developing relative to existing industrial burdens.
Regardless of “age and gender” should be added to EJ protection language.
Trigger Permits
Limited kinds of “trigger” permit types are listed in the Public Participation Policy as eligible for EJ review. Permits outside of these categories are also degrading the communities and being targeted to environmental justice communities. Oil and gas extractions, pipelines, and other infrastructure are not currently considered trigger permits but are impacting many environmental justice areas. DEP should oil and gas permits to the trigger list. All permits, even of seemingly lesser severity, should trigger review to see if they contribute to cumulative impacts to already burdened community.
Permit Notifications
DEP program staff must notify the Office of EJ when a permit “trigger” EJ review and report the details of the proposed activity. Currently not all DEP program staff are alerting the EJ office of trigger permits, and many are not education on EJ policies. More training and funding needs to be allocated to make sure that trigger permits are not overlooked or mishandled.
Requiring the distribution of “plain language” information sheets regarding the proposed activity and permit conditions. Public notices are to be placed in widely read publications in print and online. Does not always happen or the information produced is inadequately written or poorly distributed. Public notices are put in the legal sections of paper, often initial meetings are not even publicly noticed if the company is the only one organizing the meeting. Enforce this requirement and include real infographics as much as possible. Consult with local community groups to determine what communication tools work best.
Publish additional notice outside of newspaper in widely read publications, flyers in local businesses, community centers, and church bulletins. Require applicants to do direct mailing.
Updated the “eFacts notification system to include more information and send email notices to interested parties when updates in non-technical language.
Applicant Public Meetings
DEP “strongly suggests” applicants meet with all stakeholders, before applying for permit, as well as throughout the permitting process. Not all stakeholders are being brought into conversations and often DEP allows the applicant to decide who these people should be. Applicants are often not transparent about their plans. Meetings do not occur at all stages of the process. It should not be up to the applicant to control the process and do outreach. DEP should ensure that all interested parties are engaged in the permitting process.
Meeting should be held during the entire permitting process. This should be required, not “strongly suggested.” A meeting should occur after a permit is administratively complete and again after technical review is done but before a decision is made. Many changes happened during technical review and this gives communities the opportunity to weigh in on the final project and understand its timeline.
DEP should always participate in these meetings and make themselves available to answer questions from the community.
DEP Public Meetings
DEP holds an informal public conference within 30 days of receiving the application to inform residents of EJ area designation and the nature of project. These meetings frequently are not able to answer people questions and residents are told to wait for additional information. The format of these meetings do not allow for dialogue, which prevents the community from learning from each other. The DEP needs to hold the informal public conferences in discussion formats so residents can ask questions together and receive answers in person, not just take notes and tell residents they will receive a written response. DEP staff responsible for reviewing the proposal must be present at the meetings to answer questions.
DEP accepts comments from EJ communities. These comments are often not taken into consideration, or given very little weight during the permitting process. Instead, the comments are merely noted for the record. Create a formal process for integrating comments from community experts who are often best able to provide information about how a project will impact their community.
DEP Availability
DEP will maintain presence and be availability to residents throughout permitting process. DEP staff are available during public meetings but are otherwise unavailable until there is a permit decision.
Inadequate continuing public oversight of how EJ policies are administered across the state. Actively provide updates on the permitting process and changes to the application. The burden should not be on an EJ community to stay up date on the permit, but should be the DEP and applicant’s responsibility.
DEP staff responsible for reviewing the proposal must be available to the community to answer questions. DEP should also prioritize filling its regional Environmental Advocate staff positions currently vacant in many of its districts.
Convert the DEP Citizen Environmental Justice Advisory Board (EJAB) to a full committee, with the power to oversee EJ permits under review and influence state EJ policies. Hold quarterly EJAB meetings in different DEP regions on a rotating basis.
Reflections on other states’ EJ policies
States that use poverty and race indicators differently:
Connecticut: Uses income below 200% of the federal poverty level (“working poor”).
Illinois: indicates low-income and/or minority population as being “greater than twice the statewide average.”
Massachusetts: Defines by census “block group” rather than census tract, which can identify pocket EJ areas that might be lost in larger census tracts.
Texas: For income indicator, uses census block group and income below 200% of the federal poverty level.
States that go beyond poverty and race indicators:
California: Considers existing disproportionate environmental burden. Also, demographics include “low levels of homeownership, high rent burden…or low levels of educational attainment.”
Connecticut: includes a “distressed community” indicator, defined as whether it is eligible for HUD grants, or experienced layoffs/tax loss due to a major plant closing.
Georgia: includes language for elderly and disabled populations “The Americans with Disabilities Act (ADA) encourages the involvement of people with disabilities in the development and improvement of transportation and paratransit plans and services.”
Massachusetts: Uses linguistic isolation, defined as “25% or more of households having no one over the age of 14 who speaks English only, or very well.”
New Jersey: Communities can file a petition to be recognized as a vulnerable.
Example of better public participation affordances:
New Jersey: When a community is designated EJ, a task force is formed to develop a unique “Action Plan” after consultation with residents, local, and county government, that will address environmental, social and economic factors affecting their health or environment. This task force monitors Action Plan implementation, and advises development projects to reduce impacts.
Environmental justice rules came into existence in order to deal with the burdens of large polluting facilities like landfills, incinerators, and coal mines. Race and poverty measures are, without question, two very important indicators that have provided for the fair treatment of people of all races, income, and cultures in these instances. However, if we are to properly assess how residents are disproportionately impacted across a range of environmental burdens in the state, other indicators of marginalization should be included. The Center for Coalfield Justice suggests a few in a report titled Community Indicators of Environmental Justice: A Baseline Report Focusing on Greene and Washington Counties, Pennsylvania.
Fair treatment in EJ communities should also mean offering mechanisms for meaningful input that allow residents to shape the ultimate direction of proposed projects, as well. Finally, current EJ policies are very limited in only addressing future projects, whereas issues such as how disadvantaged communities, struggling with legacy problems such water, air, and soil pollution, are left to other agencies to deal with.
We encourage residents of Pennsylvania to attend an environmental justice listening tour session to share their perspectives, and how the DEP can better fulfill its mandates to protect vulnerable communities.
Photo: Clairton Coke Works, by Mark Dixon, Blue Lens, LLC.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/04/EJ_tour_header.jpg 400 900 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg FracTracker Alliance2017-04-10 11:06:352018-05-08 15:28:38PA DEP Environmental Justice Listening Tour
Remaining Questions on Mariner East Technical Deficiencies
February 9, 2017 /1 Comment/in Articles, Data and Analysis, Pennsylvania, Pipelines /by FracTracker Alliance
In the summer of 2015, Sunoco Logistics submitted applications to the Pennsylvania Department of Environmental Protection (DEP) to build its massive Mariner East 2 pipeline. The ME 2 pipeline would have the capacity to transport 275,000 barrels a day of propane, ethane, butane, and other hydrocarbons from the shale fields of Western Pennsylvania to the Marcus Hook export terminal, located on the Delaware River.
Sunoco’s applications were to satisfy the state’s Chapter 105 (water obstruction and encroachment) and Chapter 102 (erosion/sediment control and earth disturbance) permitting requirements. The DEP responded to Sunoco’s application, issuing 20 deficiency letters totaling more than 550 pages. Sunoco resubmitted their application in the summer of 2016 and the DEP again rejected many of its plans to disturb streams, ponds, and wetlands. In December, Sunoco resubmitted its revised application for a third time, hoping for final approval.
FracTracker Alliance first wrote about ME 2’s risks to watershed in August 2016, following Sunoco’s second application. Readers who want a general overview of the issues may find that article worth reading. In this new article, we dig deeper into the subject. Along with its December application, Sunoco also supplied the DEP with revised GIS files illustrating ME 2’s new route and documents summarizing its impacts to nearby water bodies. We have created a new map utilizing newly available data and provide contextual analysis valuable in determining how Sunoco responds to the DEP’s review of its prior rejected applications.
Detailed Mapping of Water Body Impacts
At the end of December, the DEP finally released Sunoco’s GIS files detailing water bodies that will be impacted by ME 2, as well as Sunoco’s data tables outlining alternative methods that might mitigate certain impacts. Our map (below) combines these new datasets to show the locations where ME 2’s route has changed since Sunoco’s initial application, presumably in response to the DEP’s technical deficiency letter.
Also on this map are water bodies: 1) implicated in ME 2’s environmental impact assessment, 2) determined by the DEP as likely impacted by construction, and 3) identified by Sunoco as having viable construction alternatives to mitigate impacts.
Mariner East 2 Technical Deficiencies Map
By viewing the map fullscreen and zooming in, one can click on a water feature to reveal its data tables (see below example). These tables contain information on the water body’s flow regime, the extent of permanent and temporary impacts, alternative crossing methods that could be used, and what benefits might come from those alternate methods. Also in the tables are a number of designations such as:
USGS Fish and Wildlife wetland classification (see guide). Most common are PEM (palustrine emergent wetland), PSS (palustrine scrub-shrub wetland), PFO (palustrine forested wetland), and PuB (palustrine unconsolidated bottom – i.e. ponds).
PA DEP stream designation (see guide). Most common are WWF (warm water fishes), CWF (cold water fishes), HQ (high quality), and EV (exceptional value).
PA Fish and Boat Commission classifications (see guide). Most common are ATW (approved trout water), STS (stocked trout stream), Class A (class A water), and WTS (wilderness trout stream).
An example water body data table that can be found on the map:
Our analysis of this new data reveals the number of water crossings in question is significantly higher than what we estimated in August: now totaling 1,222 streams, 34 ponds, and 708 wetlands crossings. This increase is primarily due to Sunoco’s data also containing information on ephemeral and intermittent waters that are not typically accounted for in USGS data (all that was available at the time of our prior analysis).
Defining Impacts
The DEP’s Chapter 105 Joint Permit Application Instructions break down “impacts” into two broad categories: permanent and temporary. These are primarily used to assess environmental impact fees, but are also valuable in determining what parameters Sunoco will be held to during and after ME 2’s construction.
Permanent impacts: are “areas affected by a water obstruction or encroachment that consist of both direct and indirect impacts that result from the placement or construction of a water obstruction or encroachment and include areas necessary for the operation and maintenance of the water obstruction or encroachment located in, along or across, or projecting into a watercourse, floodway or body of water.”
Permanent impacts are calculated using the pipeline’s 50-foot permanent right-of-way. For streams, all bed and banks are to be restored to pre-construction conditions. For ponds and wetlands, permanent impacts are assumed to remain even if the area is considered restored.
Temporary impacts: are “areas affected during the construction of a water obstruction or encroachment that consists of both direct and indirect impacts located in, along or across, or projecting into a watercourse, floodway or body of water that are restored upon completion of construction.” Temporary impacts consist of areas such as temporary workspaces and access roads.
The below table lists the total impacted acres broken down by county. Of interest here is that more than 175 acres would be permanently impacted — equivalent to 134 football fields — with an additional 82 acres temporarily impacted.
Table 1. Impacted Acres by County
County Permanent Impacts (acres) Temporary Impacts (acre)
Allegheny 1.85 0.39
Berks 11.14 4.88
Blair 11.70 6.72
Cambria 20.21 8.48
Chester 10.30 3.92
Cumberland 24.06 7.61
Dauphin 8.12 6.55
Delaware 5.05 3.33
Huntingdon 18.75 8.04
Indiana 11.42 4.73
Juniata 5.25 3.02
Lancaster 4.65 1.66
Lebanon 6.48 2.53
Perry 5.58 2.63
Washington 9.37 2.94
Westmoreland 17.72 12.36
York 3.46 2.16
Total 175.12 81.93
Viable Options to Reduce Impacts
An open cut wet crossing (image source)
Pipeline companies cross water bodies using a variety of methods depending on their classification. The DEP maintains three general categories for water crossings: minor (in streams less than or equal to 10 feet wide at the water’s edge at the time of construction), intermediate (perennial stream crossings greater than 10 feet wide but less than 100 feet wide at the water’s edge at the time of construction), and major (crossings of more than 100 feet at the water’s edge at the time of construction).
Minor and intermediate crossings often employ rudimentary trenching along “open cut” crossings where the water is either temporarily diverted (wet crossing) or allowed to flow during construction (wet crossing). After the cuts, the company attempts to repair damage done in the process of trenching.
In more sensitive places, such as in exceptional value streams, wetlands, and always in major crossings, a company uses conventional boring to tunnel under a water feature. When boring over long distances, such as under a lake or river, a company turns to Horizontal Directional Drilling (HDD), a more engineered form of boring. An example of HDD boring is seen below (image source):
We were surprised by the number of water crossings identified by Sunoco as having options to minimize impact. As the table below shows, more than 44% (869) of Sunoco’s crossings have an alternate method identified in the resubmitted applications. In most of these instances, the intended crossing method is either trenching through open cuts or dry crossings. The majority of identified alternatives would reduce impacts simply by altering the trenching route. 53 of the 869 were shown to have feasible conditions for conventional or HDD boring, but Sunoco categorized all of these as impracticable options despite their environmental benefits.
Table 2. Number of Crossings With and Without Viable Alternate Methods
Crossings Assessed but Unimpacted Impacted with No Alternative Impacted with Alternatives Total
Streams 313 925 297 1,535
Ponds 66 3 31 100
Wetlands 963 167 541 1,671
1,342 1,095 869 3,306
Absorbing the Costs of Environmental Impacts
If executed, these alternative methods would decrease the length of crossings, limit right-of-way encroachments, prevent land fragmentation, and significantly reduce risks to larger water bodies. More likely, Sunoco will pay the impact fees associated with the less complicated crossing methods. We’ve summarized these fees (found in Sunoco’s resubmitted application) in the table below. In total, Sunoco would pay roughly $1.8 million in exchange for nearly 2,000 water body crossings – a fraction of the project’s $2.5 billion estimated cost:
Table 3. Impact Fees for Sunoco’s Preferred Crossings
County Permanent Impacts area (fees) Temporary Impact area (fees) Admin Fees Total Fees
Allegheny $15,200 $1,600 $1,750 $18,550
Berks $89,600 $19,600 $1,750 $110,950
Blair $94,400 $27,200 $1,750 $123,350
Cambria $162,400 $34,000 $1,750 $198,150
Chester $83,200 $16,000 $1,750 $100,950
Cumberland $192,800 $30,800 $1,750 $225,350
Dauphin $65,600 $26,400 $1,750 $93,750
Delaware $40,800 $13,600 $1,750 $56,150
Huntingdon $150,400 $32,400 $1,750 $184,550
Indiana $92,000 $19,200 $1,750 $112,950
Juniata $42,400 $12,400 $1,750 $56,550
Lancaster $37,600 $6,800 $1,750 $46,150
Lebanon $52,000 $10,400 $1,750 $64,150
Perry $44,800 $10,800 $1,750 $57,350
Washington $75,200 $12,000 $1,750 $88,950
Westmoreland $142,400 $50,000 $1,750 $194,150
York $28,000 $8,800 $1,750 $38,550
$1,408,800 $332,000 $29,750 $1,770,550
This week, acting DEP Secretary Patrick McDonnell met with residents who voiced frustration that the agency failed to provide an additional public comment period following Sunoco’s application resubmission. Nevertheless, the DEP is expected to greenlight Sunoco’s plans any day now, adding another to the list of recent pipeline approvals in the region. Sunoco needs its permits now in order to begin clearing trees prior to endangered species bat nesting season, which begins in April.
Meanwhile, communities along the pipeline’s path are preparing for the sudden wave of disruption that may ensue. Some have threatened lawsuits, arguing that the resubmitted application still contains many deficiencies including missing wetlands and private drinking wells that must be accounted for. Indeed, the map and data presented in this article confirms that there is still a lot that the general public does not know about ME 2 – in particular, the extent of water impacts the DEP seems willing to accept and the range of options at Sunoco’s disposal that might mitigate those impacts if it were forced to do so.
Finally, it is encouraging to see that the DEP is becoming more transparent in sharing datasets, compared to other pipeline projects. However, this data is complex and not easily understood without sufficient technical expertise. We are discouraged to think that it is unlikely the public will learn about additional changes to the construction plan until after permits are issued. In order for data to be useful, it must be made available throughout the process, not at the end stages of planning, and done so in a way that it becomes integrated into the agency’s public participation responsibilities.
by Kirk Jalbert, Manager of Community-Based Research & Engagement
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/02/ME2_technical_def_header.jpg 400 900 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg FracTracker Alliance2017-02-09 11:47:092018-05-08 15:28:38Remaining Questions on Mariner East Technical Deficiencies
A Formula for Disaster: Calculating Risk at the Ethane Cracker
February 8, 2017 /3 Comments/in Articles, Companies, Data and Analysis, Facilities, Health/Community, Pennsylvania /by FracTracker Alliance
by Leann Leiter, Environmental Health Fellow
map & analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement
in partnership with the Environmental Integrity Project
On January 18, 2016, Potter Township Supervisors approved conditional use permits for Shell Chemical Appalachia’s proposed ethane cracker facility in Beaver County, PA. A type of petrochemical facility, an ethane cracker uses energy and the by-products of so-called natural gas to make ethylene, a building block of plastics. FracTracker Alliance has produced informative articles on the jobs numbers touted by the industry, and the considerable negative air impacts of the proposed facility. In the first in a series of new articles, we look at the potential hazards of ethane cracker plants in order to begin calculating the risk of a disaster in Beaver County.
As those who stand to be affected by — or make crucial decisions on — the ethane cracker contemplate the potential risks and promised rewards of this massive project, they should also carefully consider what could go wrong. In addition to the serious environmental and human health effects, which might only reveal themselves over time, what acute events, emergencies, and disasters could potentially occur? What is the disaster risk, the potential for “losses, in lives, health status, livelihoods, assets and services,” of this massive petrochemical facility?
Known Ethane Cracker Risks
A well-accepted formula in disaster studies for determining risk, cited by, among others, the United Nations International Strategy for Disaster Reduction (UNISDR), is Disaster Risk = (Hazard x Vulnerability)/Capacity, as defined in the diagram below. In this article, we consider the first of these factors: hazard. Future articles will examine the remaining factors of vulnerability and capacity that are specific to this location and its population.
Applied to Shell’s self-described “world-scale petrochemical project,” it is challenging to quantify the first of these inputs, hazard. Not only would a facility of this size be unprecedented in this region, but Shell has closely controlled the “public” information on the proposed facility. What compounds the uncertainty much further is the fact that the proposed massive cracker plant is a welcome mat for further development in the area—for a complex network of pipelines and infrastructure to support the plant and its related facilities, and for a long-term commitment to continued gas extraction in the Marcellus and Utica shale plays.
U.S. Chemical Safety and Hazard Investigation Board, Williams Geismar Case Study, No. 2013-03-I-LA, October 2016.
We can use what we do know about the hazards presented by ethane crackers and nearby existing vulnerabilities to establish some lower limit of risk. Large petrochemical facilities of this type are known to produce sizable unplanned releases of carcinogenic benzene and other toxic pollutants during “plant upsets,” a term that refers to a “shut down because of a mechanical problem, power outage or some other unplanned event.” A sampling of actual emergency events at other ethane crackers also includes fires and explosions, evacuations, injuries, and deaths.
For instance, a ruptured boiler at the Williams Company ethane cracker plant in Geismar, Louisiana, led to an explosion and fire in 2013. The event resulted in the unplanned and unpermitted release of at least 30,000 lbs. of flammable hydrocarbons into the air, including ethylene, propylene, benzene, 1-3 butadiene, and other volatile organic chemicals, as well as the release of pollutants through the discharge of untreated fire waters, according to the Louisiana Department of Environmental Quality. According to the Times-Picayune, “workers scrambl(ed) over gates to get out of the plant.” The event required the evacuation of 300 workers, injured 167, and resulted in two deaths.
The community’s emergency response involved deployment of hundreds of personnel and extensive resources, including 20 ambulances, four rescue helicopters, and buses to move the injured to multiple area hospitals. The U.S. Chemical Safety and Hazard Investigation Board chalked up the incident to poor “process safety culture” at the plant and “gaps in a key industry standard by the American Petroleum Institute (API).” The accident shut the plant down for a year and a half.
Potential Risks & Shell’s Mixed Messages
Shell has done little to define the potential for emergencies at the proposed Beaver County ethane cracker plant, at least in materials made available to the public. Shell has revealed that general hazards include “fire, explosion, traffic accidents, leaks and equipment failures.”
However, we located numerous versions of Shell’s handout and found one notable difference among them—the brochure distributed to community members at a December 2016 public hearing held by the Pennsylvania Department of Environmental Protection (PA DEP) excluded the word “explosion” from the list of “potential safety concerns.” The difference is seen in comparing the two documents.
Figure #1 below: Excerpt of online version of a handout for Beaver County, dated May 2015, with “explosion” included in list of “potential safety concerns.” (Other Shell-produced safety documents, like the one included as an exhibit in the conditional use permit application on file with the township, and Shell’s webpage for the project, also include “explosion” in the list of hazards.)
Figure #2 below: Excerpt of handout, dated November 2016 and provided to the community at December 15, 2016 meeting, with the word “explosion” no longer included.
Additional hints about risks are peppered throughout the voluminous permit applications submitted by Shell to the PA DEP and Potter Township, such as references to mitigating acts of terror against the plant, strategies for reducing water contamination, and the possibility of unplanned upsets. But the sheer volume of these documents, coupled with their limited accessibility challenge the public’s ability to digest this information. The conditional use permit application submitted by Shell indicates the existence of an Emergency Response Plan for the construction phase, but the submission is marked as confidential.
Per Pennsylvania law, and as set forth in PA DEP guidelines, Shell must submit a Preparedness, Prevention, and Contingency Plan (PPC Plan) at an unspecified point prior to operation. But at that likely too-late stage, who would hear objections to the identified hazards, when construction of the plant is already a done deal? Even then, can we trust that the plan outlined by that document is a solid and executable one?
Shell’s defense of the Beaver County plant is quick to point out differences between other plants and the one to come, making the case that technical advances will result in safety improvements. But it is noteworthy that the U.S. Chemical Safety and Hazard Investigation Board attributes failures at the Williams Geismar plant, in part, to “the ineffective implementation of…process safety management programs… as well as weaknesses in Williams’ written programs themselves.” The Geismar explosion demonstrates some of the tangible hazards that communities experience in living near ethane cracker plants. It is worth noting that the proposed Beaver County facility will have about 2½ times more ethylene processing capacity than the Geismar plant had at the time of the 2013 explosion.
Opening the Floodgates
In an effort to expand our understanding of risk associated with the proposed Beaver County ethane cracker and the extent of related developments promised by industry leaders, FracTracker Alliance has constructed the below map. It shows the site of the Shell facility and nearby land marked by Beaver County as “abandoned” or “unused.” These land parcels are potential targets for future build-out of associated facilities. Two “emergency planning zones” are indicated—a radius of 2 miles and a radius of 5 miles from the perimeter of Shell’s site. These projections are based upon FracTracker’s discussions with officials at the Saint Charles Parish Department of Homeland Security and Emergency Preparedness, who are responsible for emergency planning procedures in Norco, Louisiana, the site of another Shell ethane cracker facility. The emergency zones are also noted in the 2015 Saint Charles Hazard Mitigation Plan.
Also shown on the map is an estimated route of the Falcon pipeline system Shell intends to build, which will bring ethane from the shale gas fields of Ohio and Pennsylvania. Note that this is an estimated route based on images shown in Shell’s announcement of the project. Finally, our map includes resources and sites of vulnerability, including schools, fire stations, and hospitals. The importance of these sites will be discussed in the next article of this series.
Ethane Cracker Hazards Map
While the site of the Shell cracker is worth attending to, it would be a mistake to limit assessments of disaster risk to the site of the facility alone. Shell’s proposed plant is but one component in a larger plan to expand ethane-based processing and use in the region, with the potential to rival the Gulf Coast as a major U.S. petrochemical hub. An upcoming conference on petrochemical construction in the region, scheduled for June 2017 in Pittsburgh, shows the industry’s commitment to further development. These associated facilities (from plants producing fertilizers to plastics) would utilize their own mix of chemicals, and their potential interactions would produce additional, unforeseen hazards. Ultimately, a cumulative impact assessment is needed, and should take into account these promised facilities as well as existing resources and vulnerabilities. The below Google Earth window gives a sense of what this regional build-out might look like.
What might an ethane cracker and related petrochemical facilities look like in Beaver County? For an idea of the potential build-out, take a tour of Norco, Louisiana, which includes Shell-owned petrochemical facilities.
Final Calculations
As discussed in the introduction, “hazard,” “vulnerability,” and “capacity” are the elements of the formula that, in turn, exacerbate or mitigate disaster risk. While much of this article has focused on drastic “hazards,” such as disastrous explosions or unplanned chemical releases, these should not overshadow the more commonplace public health threats associated with petrochemical facilities, such as detrimental impact on air quality and the psychological harm of living under the looming threat of something going wrong.
The second and third articles in this series will dig deeper into “vulnerability” and “capacity.” These terms remind us of the needs and strengths of the community in question, but also that there is a community in question.
Formulas, terminology, and calculations should not obscure the fact that people’s lives are in the balance. The public should not be satisfied with preliminary and incomplete risk assessments when major documents that should detail the disaster implications of the ethane cracker are not yet available, as well as when the full scale of future build-out in the area remains an unknown.
Much gratitude to Lisa Graves-Marcucci and Lisa Hallowell of the Environmental Integrity Project for their expertise and feedback on this article.
The Environmental Integrity Project is a nonpartisan, nonprofit watchdog organization that advocates for effective enforcement of environmental laws.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/02/ethane-cracker-hazards-1-header.jpg 400 900 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg FracTracker Alliance2017-02-08 13:30:042019-07-22 11:53:45A Formula for Disaster: Calculating Risk at the Ethane Cracker
Revolving Doors & the PA Natural Gas Industry
January 24, 2017 /in Articles, Data and Analysis, Guest Commentaries, Pennsylvania, People, Politics /by FracTracker Alliance
By Susan Volz, FracTracker Alliance Intern
The result of this year’s presidential election has sent shock waves through all levels of government. Many are now wondering what the next four years will look like in terms of funding and policy decisions. Just a few days after the inauguration, the next administration’s cabinet choices have many worried. For example, the person President-Elect Trump has selected to lead the transition at the Environmental Protection Agency (EPA), Myron Ebell, has connections to the fossil fuel industry, suggesting national energy policy may embrace fossil fuel development. Of equal concern are the industry connections of former ExxonMobil CEO Rex Tillerson as Secretary of State and former Texas governor Rick Perry as Secretary of Energy.
While these transformations are happening at the federal level, Pennsylvania has its own long history of revolving doors between government and industry that deserve attention. Examination of data collected by citizen advocate, Dorina Hippauf, as well as my own independent research, shows a state government with extensive ties to the oil and gas industry. This relationship is a concern given that state responses to national energy policy and climate change will become particularly important in coming years.
The Governor’s Office
Former Governor Ed Rendell, who served from 2003-2011, has multiple ties to the natural gas industry and was governor during the initial stages of the shale gas boom in PA. During this time, Governor Rendell leased 130,000 acres of state land to gas extraction companies (he later imposed a ban on leasing state lands). After leaving office, Rendell joined Element Partners, an equity firm with investments in the gas industry. Currently, Rendell is Co-chair of Building America’s Future, a bipartisan coalition of elected officials advocating for investment in the nation’s infrastructure. As recently as August 2016, Rendell has said he makes no apologies and remains a “strong advocate” of unconventional gas extraction, also stating that weaknesses in regulation were “cured” in 2010.
Pennsylvania’s shale gas industry saw its beginnings under Governor Rendell, but the industry truly boomed under Governor Tom Corbett. Corbett, a Republican, served a single term from 2011 to 2015. One of Corbett’s first acts as governor was to sign Act 13, which revised oil and gas laws and implemented the controversial impact fee in lieu of a severance tax. Corbett overturned Rendell’s ban on leasing public lands to gas companies. Corbett accepted $1.8 million in campaign contributions from gas companies. These contributions came not only from the companies themselves but also individual contributions from industry executives. Many of the companies that donated to Corbett’s campaign also found themselves appointed to the Marcellus Shale Advisory Commission.
Pennsylvania’s current Governor, Democrat Tom Wolf, campaigned on a platform of tougher restrictions on natural gas companies, as well as a 5% severance tax. However, the severance tax has failed to be implemented due to contentious budget negotiations with the Republican-held General Assembly. There were also concerns during Wolf’s campaign when it was revealed he had received $273,000 in donations from members of the gas industry. Many environmental advocates called on Wolf to return the funds.
Another important point to consider in these transitions is that, as elected officials move through various offices, their staffers often move with them or are appointed to influential positions. For example, K. Scott Roy served as Rendell’s chief of staff while in Harrisburg. After leaving politics, Roy joined Range Resources, one of the largest gas extraction companies in Pennsylvania. In the past he has also served as Treasurer for the Marcellus Shale Coalition.
The DEP: Regulating in the Public Interest?
The Department of Environmental Protection (DEP) is the state agency responsible for enforcing and regulating the natural gas industry in PA. However, research shows a consistent thread of secretaries with ties to the oil and gas industry dating as far back as secretaries James Seif (1995-2001) and David Hess (2001-2003). Both joined lobbying firms after leaving government. Seif joined Ridge Global, LLC, a lobbying firm founded by former governor Tom Ridge, which has had contracts with the Marcellus Shale Coalition, and where Seif currently serves as Principal of Energy and Environment. Hess joined Crisci, a lobbying firm with many gas companies as clients, where he is currently the Director of Policy and Communication at Crisci.
Katie McGinty was appointed by Governor Rendell and served from 2003 to 2008. Since leaving the agency she has worked for a number of energy-related companies including NRG Energy (operator of natural gas plants), Element Partners (the same firm Ed Rendell joined), and has been senior vice-president at Westen Solutions (a consulting firm with several natural gas companies as clients). During her Senate campaign, McGinty faced criticism for the significant campaign donations she received from the natural gas industry, as well as her employment past. McGinty was succeeded by John Hanger, who served from 2008 to 2011. Hanger left the DEP to join the law and lobbying firm Eckert Seamans Cherin and Mellott, LLC, which is a member of the Marcellus Shale Coalition. One of their clients is the Pennsylvania Independent Oil and Gas Association (PIOGA).
Perhaps the most infamous DEP secretary was Michael Krancer (2011-2013), who once notoriously said, “At the end of the day, my job is to get gas done.” Prior to joining the DEP, Krancer worked for Blank Rome, a law and lobbying firm that represents gas companies and is also a member of the Marcellus Shale Coalition, where he now currently works once again. Krancer also served as a member of the Marcellus Shale Advisory Commission, the panel that advised Governor Corbett on unconventional gas drilling regulations. Krancer’s father, Ronald, was also a significant contributor to Corbett’s 2010 gubernatorial campaign. After Krancer left the DEP, Corbett appointed Christopher Abruzzo, who served for about a year, followed by Dana Ankust, who also served a single year.
When Tom Wolf took office in 2015, he appointed John Quigley to head the DEP. Due to his past working with environmental advocacy group PennFuture, there was optimism that Quigley’s appointment would take the DEP in a different direction. Quigley had also previously served as secretary of the Department of Conservation and Natural Resources. In 2014, the Pennsylvania Environmental Defense Council sued the Commonwealth to try and stop the leasing of state lands to gas companies. Quigley testified that he had felt pressure to allow the lease of public land. Quigley dramatically resigned as secretary of the DEP in May, 2016, as a result of a leaked email voicing frustration with environmental advocacy groups and gridlock in the General Assembly. Quigley is an interesting counterpoint to the trend of DEP secretaries being influenced by the shale gas industry — an environmental advocate entering a political arena hostile to the DEP’s mission.
If one looks deeper at the DEP, there is further evidence of the revolving door between the oil and gas industry and the agency. For example, Barbara Sexton served as executive deputy secretary before leaving to join Chesapeake Energy, where she is currently Director of Government Relations. Another former deputy secretary, John Hines, left the agency to work for Shell. Michael Arch, who was an inspection supervisor, left to work for PIOGA. And finally, L. Richard Adams was formerly the DEP watershed manager before joining Chief Oil and Gas.
These findings suggest that multiple aspects of the Pennsylvania state government have historical and presently revolving-door relationships with the oil and gas industry. In a sense, this situation is not entirely surprising. PA is one of the largest natural gas producing states in the country, and the rhetoric of energy policy sells natural gas as a cleaner, cheaper, domestically-produced alternative to coal or oil. Historically, states have acted as “laboratories of policy,” as the federal government has been slow to pass legislation addressing energy and climate change. The incoming Trump administration has shown itself to be enthusiastic about expanding the fossil fuel market. However, it’s impossible to predict what changes will happen to the EPA and federal regulations. Such unpredictability makes states all the more important in shaping environmental protection policy in the next few years. We need to be aware of these revolving doors so we can be prepared for what’s coming in the future.
Click here to download the infographic as a PDF
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/01/PA_Capitol_header.jpg 400 900 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg FracTracker Alliance2017-01-24 01:22:562019-07-19 06:43:55Revolving Doors & the PA Natural Gas Industry
Hypothetical Impacts of Unconventional Drilling In Allegheny County
December 30, 2016 /in Articles, Data and Analysis, Leases, Pennsylvania, Permits, Waste /by Matt Kelso, BA
With tens of thousands of wells scattered across the countryside, Southwestern Pennsylvania is no stranger to oil and gas development. New, industrial scale extraction methods are already well entrenched, with over 3,600 of these unconventional wells drilled so far in that part of the state, mostly from the well known Marcellus Shale formation.
Southwestern Pennsylvania is also home to the Pittsburgh Metropolitan Area, a seven county region with over 2.3 million people. Just over half of this population is in Allegheny County, where unconventional drilling has become more common in recent years, along with all of its associated impacts. In the following interactive story map, the FracTracker Alliance takes a look at current impacts in more urban and suburban environments, plus projects what future impacts could look like, based on leasing activity.
Click to Enter the Hypothetical Impacts Interactive Story Map
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/12/AC_hypothetical_drilling_header.jpg 400 900 Matt Kelso, BA https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg Matt Kelso, BA2016-12-30 10:03:102019-07-19 06:43:57Hypothetical Impacts of Unconventional Drilling In Allegheny County
“Taking” Wildlife in PA, OH, WV
December 12, 2016 /1 Comment/in Articles, Ecology, Geopolitics, Ohio, Pennsylvania, Permits, West Virginia /by Karen Edelstein
By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance
In an apparent move to step around compliance with comprehensive regulations outlined in the Endangered Species Act (ESA), a coalition of nine oil and gas corporations has filed a draft plan entitled the Oil & Gas Coalition Multi-State Habitat Conservation Plan (O&G HCP). The proposed plan, which would relax regulations on five species of bats, is unprecedented in scope in the eastern United States, both temporally and spatially. If approved, it would be in effect for 50 years, and cover oil and gas operations throughout the states of Ohio, Pennsylvania, and West Virginia—covering over 110,000 square miles. The oil and gas companies see the plan as a means of “streamlining” the permit processes associated with oil and gas exploration, production, and maintenance activities. Others outside of industry may wonder whether the requested permit is a broad over-reach of an existing loophole in the ESA.
Habitat fragmentation, air, and noise pollution that comes with oil and gas extraction and fossil fuel delivery activities have the potential to incidentally injure or kill bat species in the three-State plan area that are currently protected by the Endangered Species Act (ESA) of 1973. In essence, the requested “incidental take permit”, or ITP, would acknowledge that these companies would not be held to the same comprehensive regulations that are designed to safeguard the environment, particularly the flora and fauna at most risk to extirpation. Rather, they would simply be asked to insure that their impacts are “minimized and mitigated to the maximum extent practicable.”
Section 10(a)(2)(B) of the ESA contains provisions for issuing an ITP to a non-Federal entity for the take of endangered and threatened species, provided the following criteria are met:
The taking will be incidental
The applicant will, to the maximum extent practicable, minimize and mitigate the impact of such taking
The applicant will develop an HCP and ensure that adequate funding for the plan will be provided
The taking will not appreciably reduce the likelihood of survival and recovery of the species in the wild
The applicant will carry out any other measures that the Secretary may require as being necessary or appropriate for the purposes of the HCP
What activities would be involved?
The Northern Long-eared Bat is a federally-listed threatened species, also included in the ITP
The proposed plan, which would seek to exempt both upstream development activities (oil & gas wells) and midstream development activities (pipelines). Upstream activities include the creation of access roads, staging areas, seismic operations, land clearing, explosives; the development and construction of well fields, including drilling, well pad construction, disposal wells, water impoundments, communication towers; and other operations, including gas flaring and soil disturbance; and decommissioning and reclamation activities, including more land moving and excavation.
Midstream activities include the construction of gathering, transmission, and distribution pipeline, including land grading and stream construction, construction of compressor stations, meter stations, electric substations, storage facilities, and processing plants, and installation of roads, culverts, and ditches, to name just a few.
Companies involved in the proposed “Conservation Plan” represent the major players in fossil fuel extraction, refinement, and delivery in the region, and include:
Antero Resources Corporation
Ascent Resources, LLC
Chesapeake Energy Corporation
EnLink Midstream L.P.
EQT Corporation
MarkWest Energy Partners, L.P., MPLX L.P., and Marathon Petroleum Corporation (all part of same corporate enterprise)
Rice Energy, Inc.
Southwestern Energy Company
The Williams Companies, Inc.
Focal species of the request
Populations of federally-endangered Indiana Bats could be impacted by the proposed Incidental Take Permit (ITP)
The five species listed in the ITP include the Indiana Bat (a federally-listed endangered species) and Northern Long-eared Bat (a federally-listed threatened species), the Eastern Small-footed Bat (a threatened species protected under Pennsylvania’s Game and Wildlife Code), as well as the Little Brown Bat and Tri-colored Bat. Populations of all five species are already under dire threats due to white-nose syndrome, a devastating disease that, since 2008, has killed an estimated 5.7 million bats in North America. In some cases, entire local populations have succumbed to this deadly disease. Because bats already have a naturally low birthrate, bat populations that do survive this epidemic will be slow to rebound. Only recently, wildlife biologists have begun to see hope for a treatment in a beneficial bacterium that may save affected bats. However, production and deployment details of this treatment are still under development. Best summarized in a recent article in the Pittsburgh Post-Gazette:
This [ITP] would be a huge deal because we are dealing with species in a precipitous decline,” said Jared Margolis, an attorney with the Center for Biological Diversity, a national nonprofit conservation organization headquartered in Tucson, Ariz. “I don’t see how it could be biologically defensible. Even without the drilling and energy development we don’t know if these species will survive.
In 2012, Bat Conservation International produced a report for Delaware Riverkeeper, entitled Impacts of Shale Gas Development on Bat Populations in the Northeastern United States. The report focuses on landscape scale impacts that range from water quality threats, to disruption of winter hibernacula, the locations where bats hibernate during the winter, en masse. In addition, because bats have strong site fidelity to roosting trees or groups of trees, forest clearing for pipelines, well pads or other facilities may disproportionately impact local populations.
The below map, developed by FracTracker Alliance, shows the population ranges of all five bat species, as well as the current areas impacted by existing development by the oil and gas industry through well sites, pipelines, and other facilities.
To learn more details about the extensive oil and gas development in each of the impacted states, follow these links:
Oil and gas threat map for Pennsylvania. Currently, there are ~104,000 oil and gas wells, compressors, and other related facilities here.
Oil and gas threat map for Ohio. Currently, there are ~90,000 oil and gas wells, compressors, and other related facilities here.
Oil and gas threat map for West Virginia. Currently, there are ~16,000 oil and gas wells, compressors, and other related facilities here.
Public input options
The U.S. Fish and Wildlife Service (USFWS) announced in the Federal Register in late November 2016 its intent to prepare an environmental impact statement (EIS) and hold five public scoping sessions about the permit, as well as an informational webinar. In keeping with the parameters of an environmental impact statement, USFWS is particularly interested in input and information about:
Aspects of the human environment that warrant examination such as baseline information that could inform the analyses.
Information concerning the range, distribution, population size, and population trends concerning the covered species in the plan area.
Additional biological information concerning the covered species or other federally listed species that occur in the plan area.
Direct, indirect, and/or cumulative impacts that implementation of the proposed action (i.e., covered activities) will have on the covered species or other federally listed species.
Information about measures that can be implemented to avoid, minimize, and mitigate impacts to the covered species.
Other possible alternatives to the proposed action that the Service should consider.
Whether there are connected, similar, or reasonably foreseeable cumulative actions (i.e., current or planned activities) and their potential impacts on covered species or other federally listed species in the plan area.
The presence of archaeological sites, buildings and structures, historic events, sacred and traditional areas, and other historic preservation concerns within the plan area that are required to be considered in project planning by the National Historic Preservation Act.
Any other environmental issues that should be considered with regard to the proposed HCP and potential permit issuance.
The public comment period ends on December 27, 2016. Links to more information about locations of the public hearings, as well as instructions about how to sign up for the December 20, 2016 informational webinar can be found at this website. In addition, you can electronically submit comments about the “conservation plan” by following this link.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/12/Eastern-small-footed-bat-header.jpg 430 1500 Karen Edelstein https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg Karen Edelstein2016-12-12 14:22:072019-07-19 06:43:58"Taking" Wildlife in PA, OH, WV
The Dakota Access Pipeline: An Uncertain Future
December 10, 2016 /2 Comments/in Articles, Environmental Justice, Geopolitics, North Dakota, Pipelines, Water /by Kyle Ferrar, MPH
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
Eliza Czolowski, Program Associate, PSE Healthy Energy
Since April 2016, demonstrators in North Dakota have been protesting a section of the Dakota Access Pipeline (DAPL) being built by Dakota Access LLC, a construction subsidiary of Energy Transfer Partners LP. The proposed pipeline passes just 1.5 miles north of the Standing Rock Sioux Tribal Lands, where it is planned to cross Lake Oahe, the largest Army Corps of Engineers reservoir created on the Missouri River. The tribe argues that the project will not only threaten their environmental and economic well-being, but will also cut through land that is sacred.
Given how quickly circumstances have changed on the ground, we have received numerous requests to post an overview on the issue. This article examines the technical aspects of the DAPL proposal and details the current status of protests at Standing Rock. It includes a discussion of what the Army Corps’ recent denial of DAPL’s permits means for the project as well as looks towards the impacts of incoming Trump administration. We have also created the below map to contextualize DAPL and protest activities that have occurred at Standing Rock.
Standing Rock Protest Map
DAPL is a $3.78 billion dollar project that was initially slated for completion on January 1, 2017. The DAPL is a joint venture of Phillips 66, Sunoco Logistics, and other smaller fossil fuel companies including Marathon Petroleum Corporation, and Enbridge Energy Partners. Numerous banks and investment firms are supporting the project and financing the related infrastructure growth, including Citi Bank, JP Morgan Chase, HSBC, PNC, Community Trust, Bank of America, Morgan Stanley, ING, Tokyo-Mitsubishi, Goldman Sachs, Wells Fargo, SunTrust, Us Bank, UBS, Compass and others.
Its route travels from Northwestern North Dakota, south of Bismarck, and crosses the waterway made up of the Missouri River and Lake Oahe just upriver of the Standing Rock Sioux Tribal Area. From North Dakota the pipeline continues 1,172 miles to an oil tank farm in Pakota, Illinois. DAPL would carry 470,000 barrels per day (75,000 m3/d) of Bakken crude oil with a maximum capacity up to 570,000 barrels per day. That’s the CO2 equivalent of 30 average sized coal fired power plants.
As documented by the NY Times map, in addition to the Missouri River and Lake Oahe, the pipeline crosses 22 other waterways that also require the pipeline to be drilled deep under these bodies of water. But Standing Rock portion is the only section disputed and as of yet unfinished. Now the pipeline project, known by the protesters as “the black snake,” is over 95% complete, despite having no official easement to cross the body of water created by the Missouri River and Lake Oahe. The easement is required for any domestic pipeline to cross a major waterway and because the land on either side of the Army Corps Lake Oahe project is managed by the Army Corps (shown in the protest map). An easement would allow Dakota Access LLC to drill a tunnel for the pipeline under the federally owned lands, including the lake and river.
Safety & Environmental Racism
Proponents of the project tout the opinion that pipelines are the safest method of moving oil large distances. Trucking oil in tankers on highways has the highest accident and spill rates, whereas moving oil by railways presents a major explosive hazard when incidents do occur. Pipeline spills are therefore considered the “safe” alternative. On November 11, Kelcy Warren was interviewed on CBS News, claiming Dakota Access, LLC takes every precaution to reduce leaks and that the likelihood of a leak is highly unlikely. The problem with comparing the risk for each of these transportation methods is that rates of incidence are the only comparison. The resulting hazard and impact is ignored. When pipelines rupture, they present a much larger hazard than trucks and trains. Large volumes of spilled oil result in much greater water and soil contamination.
We know that pipelines do rupture, and quite often. An analysis by the U.S. DOT Pipeline and Hazardous Materials Safety Administration in 2012 shows that there have been 201 major incidents (with volumes over 1,000 gallons) related to liquid leaks in the U.S. over the last ten years that were reported to the Department of Transportation. The “average” pipeline therefore has a 57% probability of experiencing a major leak, with consequences over the $1 million range, in a ten-year period. FracTracker’s recent analysis of PHMSA data shows the systemic issue of pipeline spills: there have been 4,215 pipeline spill incidents just since 2010 resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion! The recent (December 12) spill of 176,000 gallons of crude oil into a stream just 150 miles from the Standing Rock protest site highlights the Tribes’ concerns.
A previously proposed route for the DAPL would have put Bismarck—a city that is 92% white—just downriver of its Missouri River crossing. This initial route was rejected due to its potential threat to Bismarck’s water supply, according to the Army Corps. In addition to being located upriver of Bismarck’s water intake, the route would have been 11 miles longer and would have passed through “wellhead source water protection” areas that are avoided to protect municipal water supply wells. Passing through this “high consequence area” would have required further actions and additional safety measures on the part of Dakota Access LLC. The route would also have been more difficult to stay at least 500 feet away from homes, as required by the North Dakota Public Service Commission. The route was changed and pushed as close to Sioux County as possible, the location of the Standing Rock Indian Reservation.
Protests: The Water Protectors
The Standing Rock Sioux Tribe has taken an active stance against Bakken Oil Development in the past. In 2007, the Reservation passed a resolution to prevent any oil and gas development or pipelines on the Tribal Lands. However, deep concerns about the safety of DAPL led protesters to begin demonstrations at Standing Rock in April, 2016. The Standing Rock Sioux Tribe then sued the Army Corps in July, after the pipeline was granted most of the final permits over objections of three other federal agencies. Construction of it, they say, will “destroy our burial sites, prayer sites and culturally significant artifacts.” A timeline of The Standing Rock Sioux Tribe’s litigation addressing DAPL through this period can be found on the EARTHJUSTICE website.
Photo by Derrick Broze/cc
In August, a group organized on the Standing Rock Indian Reservation called ReZpect Our Water brought a petition to the Army Corps in Washington, D.C. stating that DAPL interferes with their ancestral land and water rights. The Tribe sued for an injunction citing the endangerment of water and soil, cultural resources, and the improper use of eminent domain. The suit argued that the pipeline presents a risk to Sioux Tribe communities who live near or downstream of the pipeline. The Missouri River is the main water source for the Standing Rock Sioux Tribe. In September, members of the Standing Rock Sioux tribe in North Dakota finally made headlines.
Federal Injunction
On September 9, District Judge James Boasberg denied the Standing Rock Sioux Tribes preliminary injunction request to prevent the Army Corps from granting the easement. The Judge ordered Dakota Access to stop work only on the section of pipeline nearest the Missouri river until the Army Corps granted the crossing easement. The excavation of Standing Rock burial grounds and other sacred sites, where direct action demonstrators were clashing with Dakota Access security and guard dogs, was allowed to continue. Later that same day, a joint statement was released by the U.S. Department of Justice, the Department of the Interior, and the U.S. Army:
“We request that the pipeline company voluntarily pause all construction activity within 20 miles east or west of Lake Oahe.”
In the map above the 20-mile buffer zone is shown in light green. Regardless of the request from the three federal agencies to pause construction, Dakota Access’s parent company Energy Transfer Partners LP ignored requests to voluntarily halt construction. Dakota Access LLC has also disregarded the instructions of the federal judge. The Army Corps declared Dakota Access LLC would not receive the easement required to cross the waterway until after 2016, but that has not stopped the company from pushing forward without the necessary permits. The pipeline has been built across all of Cannonball Ranch right up to Lake Oahe and the Missouri River, which can be seen in the map above and in drone footage taken November 2, 2016 showing the well pad for the drill rig has been built.
On November 4 the Army Corps requested Dakota Access LLC voluntarily halt construction for 30 days; then on November 8 (Election Day), Dakota Access ignored the request and announced they would begin horizontally drilling under the waterway within weeks. On November 14 Dakota Access filed a lawsuit against the Army Corps arguing that permits are not legally required. Later that day, the Army Corps responded with a statement that said any construction on or under Corps land bordering Lake Oahe cannot occur because the Army has not made a final decision on whether to grant an easement. In the issued statement, Assistant Secretary of the Army Jo-Ellen Darcy said “in light of the history of the Great Sioux Nation’s dispossession of lands [and] the importance of Lake Oahe to the Tribe,” the Standing Rock Sioux tribe would be consulted to help develop a timetable for future construction plans. The Army Corps has since denied the easement entirely.
Violence Against Protesters
Law enforcement has used physical violence to disrupt demonstrations on public lands and to prevent direct action activities as protesters aim to shut down construction on private land held by Energy Transfer Partners LP. Since September 4, law enforcement agencies led by the Morton County Sheriff’s Department have maintained jurisdiction over the protests. Officers from other counties and states have also been brought in to assist. Morton County and the State of North Dakota do not have the jurisdiction to evict protesters from the camps located on Army Corps land. Well over 500 activists have been arrested.
The majority of clashes with law enforcement have occurred on the roadways exiting the Army Corps lands, or at the access points to the privately owned Cannonball Ranch (shown on the map). Morton County has spent more than $8 million keeping direct action protesters from shutting down excavation and construction activities along the path of the pipeline. Meanwhile, the state of North Dakota has spent over $10 million on additional law enforcement officials to provide assistance to Morton County.
DAPL protests from video by UnicornRiot/cc
The first violent confrontation occurred on September 3 after Dakota Access bulldozed an area of Cannonball Ranch identified by the Tribe as a sacred site hosting burial grounds. At that time, the site was actively being contested in court and rulings still had not been made. The Tribe was seeking a restraining order, known as a “preliminary injunction” to protect their cultural heritage. Direct action demonstrators put themselves in the way of bulldozers to stop the destructive construction. In response, Dakota Access LLC security personnel assaulted protesters with pepper spray and attack dogs. The encounter was documented by Democracy Now reporter Amy Goodman.
October 27, the Morton County Sheriff’s Department reinforced with 300 police from neighboring counties and states, raided the frontline camp site making mass arrests. In response, demonstrators reinforced a blockade of the 1806 bridge, shown in the map above. The most violent clash was witnessed on public lands on November 20, 2016 at this bridge, which demarcates Army Corps land. The Police forces’ use of “non-lethal” bean bag rounds, rubber bullets, tear gas, pepper spray, water hoses, LRAD, and explosive flash grenades on peaceful demonstrators has been criticized by many groups. Fire hoses were used on protesters in freezing conditions resulting in dozens of demonstrators needing treatment for hypothermia. In total 300 people were injured according to a release from the standing rock medic and healer council.
Most recently, the Army Corps has targeted the Standing Rock Demonstration by determining that it is no longer safe to stay at the Sacred Stone and Oceti Sakowin camps located on Army Corps property. North Dakota Governor Jack Dalrymple has frequently blasted the Army Corps for not removing the protesters.
As of December 5th, federal authorities consider the protesters to be trespassing on federal lands, leaving protesters vulnerable to various citations and possible arrest. The Army Corps has also said that emergency services may no longer be provided in the evacuation area. The Army Corps has jurisdiction on Army Corps lands, and only federal authorities can remove the protesters from federal lands. There are now more than 5,000 activists demonstrating at Standing Rock, and an additional 2,000 U.S. veterans joined the protest this past week for an action of solidarity. Nevertheless, U.S. authorities have said that there are no plans to forcibly remove activists, despite telling them to leave.
Victory and an Uncertain Future
Perhaps as a result of this mass outcry, the Army Corps announced on December 4th—only a day before trespassing claims would be imposed—that Dakota Access LLC’s permit application to cross under the Missouri River and Lake Oahe had been denied. Jo-Ellen Darcy, the Army’s Assistant Secretary for Civil Works, announced:
“Although we have had continuing discussion and exchanges of new information with the Standing Rock Sioux and Dakota Access, it’s clear that there’s more work to do…The best way to complete that work responsibly and expeditiously is to explore alternate routes for the pipeline crossing.”
To determine alternate routes, the Army Corps has announced it will undertake an environmental impact statement which could take years to complete. While this is a major victory for the “water protectors” demonstrating at Standing Rock, it is not a complete victory. Following the Army Corps’ announcement, the two main pipeline investors, Energy Transfer Partners LP and Sunoco Logistics, responded that they:
“…are fully committed to ensuring that this vital project is brought to completion and fully expect to complete construction of the pipeline without any additional rerouting in and around Lake Oahe. Nothing this Administration has done today changes that in any way.”
In fact, prior to the Army Corps denying the easement, numerous democrats in congress called for President Obama to shut down the pipeline. While President Obama has not heeded these calls to shut down the project entirely, he also has not given the green light for the project either. Instead the President stated that the situation needed to be handled carefully and urged the Army Corps to consider rerouting the pipeline. “We’re monitoring this closely and I think, as a general rule, my view is that there’s a way for us to accommodate sacred lands of Native Americans…. I think right now the Army Corps is examining whether there are ways to reroute this pipeline,” the President said.
The Corps decision to conduct a lengthy environmental impact statement is encouraging but, ultimately, the Trump administration may have the final say on the DAPL easement. President-elect Trump has voiced support for the easement in the past, and on December 5th, just one day following the Army Corps’ decision, Trump spokesman Jason Miller commented:
“That’s something we support construction of, and we will review the full situation in the White House and make an appropriate determination at that time.”
Energy Transfer Partners LP CEO Kelcy Warren donated $103,000 to the Trump campaign and the President-elect has investments in Energy Transfer Partners LP totaling up to $1 million according to campaign financial disclosures. President-elect Trump has made it clear that pipeline projects, specifically the Keystone Access Pipeline rejected by President Obama, will be allowed to move forward along with additional fossil fuel extraction projects.
If the construction company, Dakota Access LLC, continues building the pipeline they are liable to be fined. It is not yet clear whether Dakota Access LLC will “eat” the fine to continue building and drilling, or whether the Army Corps will forcefully stop DAPL. Analysts say the expense of changing the route, such as to the south of the tribal lands, would make the economics of the pipeline a total loss. It is cheaper for Dakota Access LLC to continue to fight the protest despite overwhelming disapproval of the project.
Meanwhile, protestors have refused to leave Standing Rock in fear that the Army Corp will reverse its decision and allow DAPL to proceed, despite requests by the chairman of the Sioux Tribe that demonstrators go home. Many are hopeful that, by stalling the project past January 1st—the deadline by which Energy Transfer Partners LP promised oil companies it would complete construction—the possibility exists that contracts will expire and DAPL loses support from investors.
Other Mapping Resources
This web map shows the current construction progress of the pipeline.
The New York Times website is hosting a map focusing on the many water crossings of the pipeline route.
The Guardian has a static map on their website similar to our interactive map.
Header photograph by Joe Brusky/flickr/cc
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/12/DAPL_header.jpg 400 900 Kyle Ferrar, MPH https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg Kyle Ferrar, MPH2016-12-10 16:52:482019-07-22 11:59:40The Dakota Access Pipeline: An Uncertain Future
Mariner East 2: At-Risk Schools and Populations
December 9, 2016 /10 Comments/in Articles, Environmental Justice, Health/Community, Pennsylvania, Pipelines /by FracTracker Alliance
with technical assistance from Seth Kovnant
In September, the Pennsylvania Department of Environmental Protection (DEP) rejected a number of permits for wetland crossings and sedimentation control that were required for Sunoco Pipeline’s proposed “Mariner East 2” pipeline. According to Sunoco, the proposed Mariner East 2 is a $2.5 billion, 350-mile-long pipeline that would be one of the largest pipeline construction projects in Pennsylvania’s history.
If built, Mariner East 2 could transport up to 450,000 barrels (18,900,000 gallons) per day of propane, ethane, butane, and other liquefied hydrocarbons from the shale fields of western Pennsylvania to export terminals in Marcus Hook, located just outside Philadelphia. A second proposed pipeline, if constructed, could carry an additional 250,000 barrels (10,500,000 gallons) per day of these same materials. Sunoco submitted revised permit applications to PADEP on Tuesday, December 6th.
The industry often refers to ethane, propane and butane collectively as “natural gas liquids.” They are classified by the federal government as “hazardous, highly volatile liquids,” but that terminology is also misleading. These materials, which have not been transported through densely populated southeast Pennsylvania previously, are liquid only at very high pressure or extremely cold temperatures. At the normal atmospheric conditions experienced outside the pipeline, these materials volatilize into gas which is colorless; odorless; an asphyxiation hazard; heavier than air; and extremely flammable of explosive. This gas can travel downhill and downwind for long distances while remaining combustible. It can collect (and remain for long periods of time) in low-lying areas; and things as ordinary as a cell phone, a doorbell or a light switch are capable of providing an ignition source.
Many who have followed the proposed Mariner East 2 project note that, while much has been written about the likely environmental impacts, insufficient investigation has been conducted into safety risks to those who live, work and attend schools in the proposed pipeline’s path. We address these risks in this article, and, in doing so, emphasize the importance of regulatory agencies allowing public comments on the project’s resubmitted permit applications.
The Inherent Risks of Artificially Liquified Gas
Resident of Pennsylvania do not need to look far for examples of how pipeline accidents pose serious risk. For instance, the 2015 explosion of the Enterprise ATEX (Appalachia to Texas) pipeline near Follansbee, WV, provides a depiction of what a Mariner East 2 pipeline failure could look like. This 20-inch diameter pipeline carrying liquid ethane is similar in many ways to the proposed Mariner East 2. When it ruptured in rural West Virginia, close to the Pennsylvania border, it caused damage in an area that extended 2,000 feet—about ½ square mile—from the place where the pipeline failed.
In another recent instance, the Spectra Energy Texas Eastern methane natural gas pipeline ruptured in Salem, PA, this April as a result of corroded welding. The explosion, seen above (photo by PA NPR State Impact), completely destroyed a house 200ft. away. Another house, 800ft. away, sustained major damage and its owner received 3rd degree burns. These incidents are not unique. FracTracker’s recent analysis found that there have been 4,215 pipeline incidents nation-wide since 2010, resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion (“incident” is an industry term meaning “a pipeline failure or inadvertent release of its contents.” It does not necessarily connote “a minor event”).
Calculating Immediate Ignition Impact Zones
It is difficult to predict the blast radius for materials like ethane, propane and butane. Methane, while highly flammable or explosive, is lighter than air and so tends to disperse upon release into the atmosphere. Highly volatile liquids like ethane, propane and butane, on the other hand, tend to concentrate close to the ground and to spread laterally downwind. A large, dispersed vapor cloud of these materials may quickly spread great distances, even under very light wind conditions. A worst-case scenario would by highly variable since gas migration and dispersion is dependent on topography, leak characteristics, and atmospheric conditions. In this scenario, unignited gas would be allowed to migrate as an unignited vapor cloud for a couple miles before finding an ignition source that causes an explosion that encompasses the entire covered area tracing back to the leak source. Ordinary devices like light switches or cell phones can serve as an ignition source for the entire vapor cloud. One subject matter expert recently testified before a Municipal Zoning Hearing board that damage could be expected at a distance of three miles from the source of a large scale release.
The federal government’s “potential impact radius” (PIR) formula, used for natural gas (methane) isn’t directly applicable because of differences in the characteristics of the material. It may however be possible to quantify an Immediate Ignition Impact Zone. This represents the explosion radius that could occur if ignition occurs BEFORE the gas is able to migrate.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) provides instructions for calculating the PIR of a methane natural gas pipeline. The PIR estimates the range within which a potential failure could have significant impact on people or property. The PIR is established using the combustion energy and pipeline-specific fuel mass of methane to determine a blast radius: PIR = 0.69*sqrt(p*d^2). Where: PIR = Potential Impact Radius (in feet), p = maximum allowable operating pressure (in pounds per square inch), d = nominal pipeline diameter (in inches), and 0.69 is a constant applicable to natural gas
The Texas Eastern pipeline can use the PIR equation as-is since it carries methane natural gas. However, since Mariner East 2 is primarily carrying ethane, propane, and butane NGLs, the equation must be altered. Ethane, propane, butane, and methane have very similar combustion energies (about 50-55 MJ/kg). Therefore, the PIR equation can be updated for each NGL based on the mass density of the flow material as follows: PIR = 0.69*sqrt(r*p*d^2). Where: r = the density ratio of hydrocarbons with similar combustion energy to methane natural gas. At 1,440 psi, methane remains a gas with a mass density 5 times less than liquid ethane at the same pressure:
The methane density relationships for ethane, propane, and butane can be used to calculate an immediate-ignition blast radius for each hydrocarbon product. The below table shows the results assuming a Mariner East 2-sized 20-inch diameter pipe operating at Mariner East 2’s 1,440psi maximum operating pressure:
Using these assumptions, the blast radius can be derived as a function of pressure for each hydrocarbon for the same 20in. diameter pipe:
ME2 Immediate Ignition Blast Radius
Note the sharp increase in blast radius for each natural gas liquid product. The pressure at which this sharp increase occurs corresponds with the critical pressure where each product transitions to a liquid state and becomes significantly denser, and in turn, contains more explosive power. These products will always be operated above their respective critical pressures when in transport, meaning their blast radius will be relatively constant, regardless of operating pressure.
Averaging the “Immediate Ignition Blast Radius” for ethane, propane, and butane gives us a 1,300 ft (about 0.25 mile) potential impact radius. However, we must recognize that this buffer represents a best case scenario in the event of a major pipeline accident.
Additional information on these calculations can be found in the Delaware County-based Middletown Coalition for Community Safety’s written testimony to the Pennsylvania Legistlature.
Living near the Mariner East 2
FracTracker has created a new map of the Mariner East 2 pipeline using a highly-detailed GIS shapefile recently supplied by the DEP. On this map, we identify a 0.5 mile radius “buffer” from Mariner East 2’s proposed route. We then located all public and private schools, environmental justice census tracts, and estimated number of people who live within this buffer in order to get a clearer picture of the pipeline’s hidden risks.
Proposed Mariner East 2 and At-Risk Schools and Populations
Populations at Risk
In order to estimate the number of people who live within this 0.5 mile radius, we first identified census blocks that intersect the hazardous buffer. Second, we calculated the percentage of that census block’s area that lies within the buffer. Finally, we used the ratio to determine the percentage of the block’s population that lies within the buffer. In total, there are an estimated 105,419 people living within the proposed Mariner East 2’s 0.5 mile radius impact zone. The totals for each of the 17 counties in Mariner East 2’s trajectory can be found in the interactive map. The top five counties with the greatest number of at-risk residents are:
Chester County (31,632 residents in zone)
Delaware County (17,791 residents in zone)
Westmoreland County (11,183 residents in zone)
Cumberland County (10,498 residents in zone)
Berks County (7,644 residents in zone)
Environmental Justice Areas
Environmental justice designations are defined by the DEP as any census tract where 20% or more of the population lives in poverty and/or 30% or more of the population identifies as a minority. These numbers are based on data from the U.S. Census Bureau, last updated in 2010, and by the federal poverty guidelines. Mariner East 2 crosses through four environmental justice areas:
Census Tract 4064.02, Delaware County
Census Tract 125, Cambria County
Census Tract 8026, Westmoreland County
DEP policies promise enhanced public participation opportunities in environmental justice communities during permitting processes for large development projects. No additional public participation opportunities were provided to these communities. Furthermore, no public hearings were held whatsoever in Cambria County and Delaware County. The hearing held in Westmoreland County took place in Youngwood, nine miles away from Jeanette. Pipelines are not specified on the “trigger list” that determines what permits receive additional scrutiny, however the policy does allow for “opt-in permits” if the DEP believes they warrant special consideration. One would assume that a proposed pipeline project with the potential to affect the safety of tens of thousands of Pennsylvanians qualifies for additional attention.
At-Risk Schools
One of the most concerning aspects of our findings is the astounding number of schools in the path of Mariner East 2. Based on data obtained from the U.S. Department of Education on the locations of schools in Pennsylvania, a shocking 23 public (common core) schools and 17 private schools were found within Mariner East 2’s 0.5 mile impact zone. In one instance, a school was discovered to be only 7 feet away from the pipeline’s intended path. Students and staff at these schools have virtually no chance to exercise their only possible response to a large scale release of highly volatile liquids, which is immediate on-foot evacuation.
Middletown High School in Dauphin County in close proximity to ME2
One reason for the high number of at-risk schools is that Mariner East 2 is proposed to roughly follow the same right of way as an older pipeline built in the 1930s (now marketed by Sunoco as “Mariner East 1.”). A great deal of development has occurred since that time, including many new neighborhoods, businesses and public buildings. It is worth noting that the U.S. Department of Education’s data represents the center point of schools. In many cases, we found playgrounds and other school facilities were much closer to Mariner East 2, as can be seen in the above photograph. Also of note is the high percentage of students who qualify for free or reduced lunch programs at these schools, suggesting that many are located in disproportionately poorer communities.
Click here to view a complete list of at-risk schools
Now that PADEP has received revised permit applications from Sunoco, presumably addressing September’s long list of technical deficiencies, the agency will soon make a decision as to whether or not additional public participation is required before approving the project. Given the findings in our analysis, it should be clear that the public must have an extended opportunity to review and comment on the proposed Mariner East 2. In fact, public participation was extremely helpful to DEP in the initial review process, providing technical and contextual information.
It is, furthermore, imperative that investigations into the potential impacts of Mariner East 2 extend to assess the safety of nearby residents and students, particularly in marginalized communities. Thus far, no indication has been made by the DEP that this will be the case. However, the Pennsylvania Sierra Club has established a petition for residents to voice their desire for a public comment period and additional hearings.
Seth Kovnat is the chief structural engineer for an aerospace engineering firm in Southeastern PA, and regularly consults with regard to the proposed Mariner East 2 pipeline. In November, Seth’s expertise in structural engineering and his extensive knowledge of piping and hazardous materials under pressure were instrumental in providing testimony at a Pennsylvania Senate and House Veterans Affairs and Emergency Preparedness Committee discussion during the Pennsylvania Pipeline Infrastructure Citizens Panel. Seth serves on the board of Middletown Coalition for Community Safety and is a member of the Mariner East 2 Safety Advisory Committee for Middletown Township, PA. He is committed to demonstrating diligence in gathering, truth sourcing, and evaluating technical information in pipeline safety matters in order to provide data driven information-sharing on a community level.
NOTE: This article was modified on 12/9/16 at 4pm to provide additional clarification on how the 1,300ft PIR was calculated.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/12/ME2_schools_header.jpg 400 900 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpg FracTracker Alliance2016-12-09 08:36:102019-07-19 06:43:59Mariner East 2: At-Risk Schools and Populations