Another Early Rhinestreet Well

A few months ago I wrote a series of posts about early unconventional wells that appear to have been omitted from the Pennsylvania Department of Environmental Protection’s (DEP) Act 13 report, contrary to requirements.

Today I stumbled across another early Rhinestreet Shale well. According to Tarr (1980, p. 4), in November 1979, in the the northeastern portion of the Lake Erie shoreline the Pennsylvania Department of Environmental Resources (DER), the US Department of Energy (DOE) and the Morgantown Energy Technology Center (METC) “completed the Commonwealth of Pennsylvania [COP], 3 DER Presque Isle State Park, Permit #ERI-20846 [now 37-049-20846] in the Devonian Shale interval 117-1247.5′. The well was bottomed at a total depth of 1276 ft in the Middle Devonian Onondaga Limestone. The well flowed 160 Mcfpd natural from the open hole. Reservoir pressure was 170# psig after being shut-in 33 days. Gas production was obtained from the interval 945-1040 ft in the Upper Devonian Rhinestreet Shale.” In other words, this well qualifies an unconventional gas well under Act 13.

As of 1994, ERI-20846 was one of two gas wells in Presque Isle State Park, then known as the “Marina” well. According to a DER report, the Marina well was completed on October 10, 1979, at a depth of 1,276 feet. It was estimated to heat several buildings (marina, manager’s home, and administration building) for 30 to 40 years. The DER provided $23,000 towards the $200,000 project. This well last reported production in 2006. It was not listed in the DEP’s Act 13 report of spud unconventional gas wells.

The same report noted that the second well — the Beach #7 — was drilled in 1910 by the City of Erie at a depth of 3,572 feet. It was used to run machinery at waterworks park and later abandoned in the 1920s. However, the well was apparently not plugged.

In 1970, a black, foul-smelling surface discharge was reported in the Beach 7 well area. The discharge resulted in the release of hydrogen sulfide gas into the air and other hazardous substances into the soil and shallow ground water near the well. As the odors continued, DER uncovered the pavement overlying the discharge in 1979, and identified the well as the source of the discharge. The discharge was found to be emanating from a deep underground formation called the Bass Island formation.

From 1964 to 1971, over one-billion, ninety-million gallons of wood pulping wastes were injected into the Bass Island formation by the Hammermill Paper Company at wells located approximately four miles to the east of the Presque Isle State Park 7 well. An explanation is that the injected wood pulping wastes flowed along the Bass Island formation and surfaced at the Beach 7 well. [The] Beach 7 well was shut off and plugged in April 15, 1980 to 900 feet of the surface. At that time a substantial amount of gas was found near the surface that did have potential for use.

In September 1983, the Beach 7 well was placed on EPA’s National Priorities List. The National Priorities List consists of hazardous sites across the country where cleanup need’s are so serious as to warrant designation as a Superfund site. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as the “Superfund,” was passed by Congress in 1980. The Act addresses the nationwide problem of uncontrolled hazardous sites.

In 1992, EPA delisted the well from the National Priorities List. Restoration work was done on the site.

So, according to this report, wastes injected into a disposal well four miles away traveled from the Bass Island Formation, (which is of Upper Silurian age, and thus, much older and stratigraphically lower than the Marcellus Formation), and a depth of 3,500+ feet, through numerous intervening formations, before finally migrating up the Beach #7 well, with a bottom depth of ~1300 feet. In other words, here is at least one example that suggests fracking fluids may be able to travel laterally and vertically without much difficulty!

From GHG Volumes to GWP Weights

The Montreal Protocol entered force in 1989 and was initially designed to phase out ozone depleting CFCs. It was later amended to also phase out the use of HCFCs.

More recently there have been renewed discussion about amending the Montreal Protocol to reduce the use of HFCs, a class of high global warming potential (GWP) gases. According to the EPA, “the global warming potentials of HFCs range from 140 (HFC-152a) to 11,700 (HFC-23).” In particular, Canada, Mexico and the United States recently proposed a phasedown (as opposed to a phaseout) to 15% of baseline. So far, 91 countries have indicated their support for such an amendment. (See also: Recent International Developments in Saving the Ozone Layer)

In light of these discussion, I thought it might be worth re-considering the somewhat dated World GHG Emission Flow Chart below (which is based on data from 2000). Instead of depicting volumes of emissions on the right-hand side, if the chart were re-configured to weight emissions by GWP, things would look a lot different. In particular, CO2’s share would fall dramatically, while the share for CH4 (i.e., methane, a.k.a. natural gas), HFCs, PFCs and SF6 would all grow significantly.

World GHG Emissions Flow Chart
World GHG Emissions Flow Chart

Pennsylvania Green Energy

The Environmental Protection Agency’s Green Power Partnership released the top 50 purchasers of green energy in the country. The Commonwealth of Pennsylvania is #5 on the list. The state’s annual purchases totaled 500 million green kilowatt hours, equivalent to 50% of total power consumption. Also in the top 50 from Pennsylvania are several universities, including:

  • University of Pennsylvania (#19; 202 million KWh; 48% of electricity consumption)
  • Carnegie Mellon University (#44; 87 million KWh; 75% of electricity consumption); and
  • Pennsylvania State University (#46; 84 million KWh; 20% of electricity consumption).

Out of curiosity, I translated these figures into KWh per student:

Obviously, these are wide ranges and should be interpreted with care. Students are only one source of electricity demand on a college campus.  Moreover, it is not clear whether the figures for Penn State on the EPA website are for just the University Park campus, or for all the Commonwealth Campuses (out of convenience I have assumed the latter). If instead, these figures are for University Park only, then PSU’s electricity consumption for this campus only would jump to 9,493 KWh per student. Additionally, the Penn State University Park campus steam plant consumes about 7,500 tons of coal per year, and produces about 20,000 MWh per year, or 7% of the campus’s electricity demand, as well as about 175 tons of steam per hour, which is used for heating campus buildings. To make an apples to apples comparison, this would also need to be factored in to the calculations.

EPA Fuel Economy Labels

The EPA and the National Highway Traffic Safety Administration (NHTSA) are in the process of revising the fuel economy label that is required on all new cars and light-duty trucks sold in the U.S. Two prototypes — a horizontal and a vertical version — are the primary label designs under consideration.

Recently, Siegel + Gale, a leading strategic branding agency, completed user testing on both of the proposed label designs. Neither was perfect, but overall the horizontal label tested as more usable.

EPA Fuel Economy Labels

EPA Fuel Economy Labels

Graham Spanier, Gasland and the FRAC Act

Last night I went to see GASLAND at the State Theatre (movie trailer below). As I was headed in for the 9:30pm showing, Penn State President Graham Spanier was headed out from the 7:00pm showing. I bring this up primarily in the interest of turning what is otherwise a bit of trivia into possible common knowledge. Now, we all know, that we all know, that President Spanier has seen the movie and therefore has some responsibility — as do the rest of us — for responding to the issues and challenges it raises. Knowledge is like that. Once you know something, you cannot go back.

The movie is excellent — provocative, heart wrenching, inspiring. And I heartily recommend that anyone living in the NY/NJ/PA watershed see the film. The film starts innocently enough. One day Josh Fox, the film’s director, gets a contract in the mail, offering him some $100,000 for the mineral rights to his 19 acres of property in Northeastern Pennsylvania. He wonders what exactly is involved in drilling for natural gas and so he sets off to Dimock, where a number of wells had recently been completed. From there his journey takes him all across America — West Virginia, New York, Wyoming, Colorado, Texas, etc.

Along the way he discovers that drilling leaves behind a wake of water and health problems. Some of the most poignant moments in the movie are scenes in which tap water is set on fire and others where water turned into plastic when heated because of the glycol ethers that have contaminated it.

If Gasland has a primary message it is that we need to repeal the “Haliburton Loophole” in the Energy Policy Act of 2005 (EPACT 05). This loophole effectively exempted natural gas drilling from the Clean Air Act, the Clean Water Act, the Safe Drinking Water Act and the Superfund Act. In the Q&A session afterwards, Josh Fox stressed that it is only because of these four exemptions that hydraulic fracturing is economically viable. Reinstate these regulations and there is a good chance “fracking” will go away, or at least be reigned in significantly.

The first step in this direction is the so-called FRAC Act (H.R. 2766: Fracturing Responsibility and Awareness of Chemicals Act; S. 1215: Fracturing Responsibility and Awareness of Chemicals Act), which aims to repel the exemptions from the Safe Drinking Water Act. But of course, that still leaves fracking exempt from the Clean Air Act, the Clean Water Act and the Superfund Act.

In addition to these obvious fixes, I found myself wondering why so few people seem to have made a connection between drilling and the Emergency Planning and Community Right-to-Know Act (EPCRA). Of course at the federal level, fracking is exempt — because it is not among the industries regulated by the act. However, considering that natural gas wells use between 30,000 and 80,000 pounds of hazardous and/or toxic chemicals (based on the best estimates I can find), it seems that communities have the right to know this information. It would be easy for one of our congressional leaders to author legislation extending the EPCRA to cover oil and natural gas industries.

But even without such an extension, as best I can tell, natural gas drilling is NOT exempt from the Pennsylvania Worker and Community Right to Know Act (Act 159 of 1984). And considering the quantities of chemicals used, is probably also liable for reporting under the OSHA Hazard Communication Standard and the Pennsylvania Hazardous Material Emergency Planning and Response Act (Act 165 of 1990). And even though the Department of Environmental Protection claims the industry is bound by the Right to Know Act, I was unable to find satisfactory information on this issue. In fact, it appears they are not complying with this regulation.

So, today I contacted Pennsylvania’s Department of Labor & Industry and filed a formal request for clarification on their interpretation of this matter. I also contacted several attorneys asking for their interpretation of whether these statutes might hold jurisdiction over the use of chemicals by natural gas drillers in Pennsylvania. Of course, it is entirely possible I have missed a loophole somewhere. Stay tuned…

Clean Air = Dirty Water?

The New York Times has just released another fantastic story in its “Toxic Waters” series. The article highlights some of the complexities involved when attempting to address externalities and the tragedy of the commons. The article also vividly illustrates how solutions to such externalities and commons problems often create new (presumably unintended) spillovers (on externalities and commons see Coase 1960; Hardin 1968; Dietz, Ostrom, Stern 2003, etc). In other words, we see how new framings rather than solving problems can actually set in motion a cascade of overflows (see Callon 1998, 2007, etc).  In this case cleaner air comes at the expense of dirtier water, at least in part because the institutional arrangements (such as the Clean Air Act and the Clean Water Act) have been designed in ways that do not account for the interrelatedness of these dynamic processes.

Source: New York Times

Source: New York Times

At a more practical level the story is again accompanied by an interactive database of water polluters searchable by location.  For this story the database has been updated with the ability to look specifically at the violation records of coal fired power plants. Of note, Pennsylvania coal plants represent 4 out of the 15 violators of clean water regulations in the United States.  These plants include:

For more on the issue of water pollution, see my earlier post here.

Electric Utilities and Wastewater Regulations

Something must be in the, err, water…

On the heels of my recent post about Toxic Waters, tomorrow’s Wall Street Journal features a story about plans by the Environmental Protection Agency (EPA) to tighten regulations on the quality of the wastewater discharged from coal-fired power plants.  At issue are the toxins left behind from the scrubbing process used to remove the toxins from the air.

“Power plants pump out dirty water in part because of technology installed to stop the spread of soot and ash from smokestacks. The systems that clean smokestack emissions scrub the exhaust with water-based compounds. If left untreated, that mixture of water and metals can contaminate waterways and drinking water, the EPA said.”

For the full story, visit “Utilities Face Stiffer Wastewater Rules.”

Toxic Waters

On Friday night I watched Frontline’s “Poisoned Waters” (from Netflix via Roku), a two hour investigation by Pulitzer Prize winning journalist Hedrick Smith into “the growing hazards of water pollution to human health and the ecosystem.” The program was divided roughly into two segments: First, a look at Chesapeake Bay, and second, an investigation of Puget Sound.  In addition to detailing issues specific to each location, both Chesapeake and Puget were “read” as microcosms of the much larger problem facing America’s waterways.

Broadly speaking, the show highlighted two major issues: agricultural runoff and storm sewers.  Technically speaking, both are considered “nonpoint source pollution” and susceptible to increased ambiguities in terms of measurement and accountability (as compared with “point source pollution”). On the issue of agricultural runoff specifically, The Washington Post described Frontline’s interviews with Jim Perdue, chairman of Perdue Farms, and Bill Satterfield, spokesperson for the Delmarva Poultry Industry, as “the kind of verbal evasions that would twinkle a tobacco industry scientist’s eye.” I’m pretty sure that having yourself compared with tobacco “scientists” is never good. Frontline also noted the Clean Water Act’s “citizen suit provision,” which allows citizens to sue polluters and the government for enforcement failures.

Another point raised by the Frontline “Poisoned Waters” episode is the growing gap between the contaminants in use and those covered by regulations. In particular, Frontline discussed a study by the U.S. Geological Survey that tested the Potomac River for some 277 new contaminants NOT covered by the Clean Water Act. Overall, they found 85 contaminants. Of these, only about half of the compounds had safety guidelines. But Frontline also noted a second gap — this one between the contaminants in use and the contaminants capable of being detected. Not even the expanded list tested for by the USGS covers the range of contaminants potentially in use.  In other words, here we see the possibility of externalities which are not yet capable of being externalized, let alone interalized.

Then last night The New York Times home page featured a lengthy story on “Toxic Waters,” along with a companion interactive database of more than 200,000 facilities that have permits to discharge water pollutants. The reporting behind the story is massive, drawing on data from the Environmental Protection Agency (EPA), along with “hundreds of thousands of water pollution records [obtained] through Freedom of Information Act requests to every state,” and interviews with “more than 250 state and federal regulators, water-system managers, environmental advocates and scientists.”

A few key points:

  • “Nationwide, polluters have violated the Clean Water Act more than 500,000 times.”
  • “[T]he E.P.A. regulate[s] more than 100 pollutants through the Clean Water Act and strictly limit[s] 91 chemicals or contaminants in tap water through the Safe Drinking Water Act.”
  • According to Lisa Jackson, the EPA’s administrator, “[D]espite many successes since the Clean Water Act was passed in 1972, today the nation’s water does not meet public health goals, and enforcement of water pollution laws is unacceptably low.”
  • “[R]esearch shows that an estimated one in 10 Americans have been exposed to drinking water that contains dangerous chemicals or fails to meet a federal health benchmark in other ways.”
  • “Because most of today’s water pollution has no scent or taste, many people who consume dangerous chemicals do not realize it, even after they become sick.”

According to the database, Pennsylvania is home to 8,654 regulated facilities. Here in the Centre County region where I live, most of the facilities have no reported violations.  However, there were 6 facilities in the area with violations, which I have listed below, first, based on length of compliance failures (e.g., Cerro Metal has been out of compliance 11 of the past 12 quarters), and second, for those facilities not out of compliance, by the number of reported violations (e.g., Mid Centre County PDF has 37 violations, but is not out of compliance). As with Pennsylvania more broadly, NONE of these facilities has been fined for these violations. Again, these data are all from the New York Times website and based on EPA data for 2004-2007 inclusive.

  • Cerro Metal — 61 violations. This facility has been out of regulatory compliance 11 of the past 12 quarters.
  • University Area Joint Authority — 18 violations. This facility has been out of regulatory compliance 5 of the past 12 quarters.
  • Hanover Foods Corp WWTF — 57 violations.  This facility has been out of regulatory compliance 3 of the past 12 quarters.
  • Mid Centre County PCF — 37 violations.  This facility has not been out of compliance in the past 12 quarters.
  • Moshannon Valley Regional — 34 violations.  This facility has been out of regulatory compliance 4 of the past 12 quarters.
  • Port Matilda Boro WWTF — 2 violations.  This facility has not been out of compliance in the past 12 quarters.