Notes From The Field #2: Orphaned and Abandoned Gas Wells

My name is David Platt and I am a father, husband and a member of the Sierra Club. A few weeks ago, I attended an event hosted by the Pennsylvania Chapter of the Sierra Club and Marcellus Matters, an NSF-funded group out of Penn State that focuses on science education. We spent the afternoon stumbling around public game lands but we weren’t hunting for deer. What were we in search of? We were looking for Pennsylvania’s missing orphaned and abandoned gas wells.

According to an estimate from the Independent Petroleum Association of America, there are 200,000 oil and gas wells in Pennsylvania that undocumented. Out of these, the Pennsylvania Department of Environmental Protection (DEP) has located about 12,000 wells. There are potentially thousands of undocumented wells leaking harmful chemicals into the air and into Pennsylvania streams and groundwater. We urgently need people to help find and document these wells.

The industry has been drilling oil and gas wells in Pennsylvania since 1859, when Colonel Edwin Drake struck oil in Titusville. For the first century of drilling, there was practically no regulation or oversight of these operations. There is no comprehensive map or database of these wells. When a well failed to bring enough petroleum to the surface to make it profitable, it was unceremoniously abandoned. Sometimes these wells were plugged to keep gas and oil from leaking out. But many of these “plugs” have failed over the decades. Now, the Sierra Club is partnering with Penn State’s Marcellus Matters to help locate and document these missing wells.

Last month, as part of the Forest Watch Campaign, a group of Sierra Club volunteers gathered in Williamsport where Nooreen Meghani and Terry Noll of Penn State’s Marcellus Matters program showed us how locate and document these missing gas wells. Once the wells are documented, this information is then sent off to the DEP. We started by reviewing old USGS maps of Pennsylvania. These maps, initially drawn up in the 1940s and revised in the 1970s, show tiny circles where oil and gas wells are located and thin lines to show pipelines. But, as we discovered, these maps are only a starting point because most wells never made it onto these maps. Other sources of information used to locate these wells include county records and satellite data. We then headed to the Sproul State Forest near Lock Haven to look at three previously unknown wells.

The first well was found by a small pond near Camp Run at these coordinates. We inspected the rusty monument to see if there was any concrete support around the steel pipes. This monument was found less than 20 yards away from Camp Run. The second well was clearly visible from the road and located near Rock Run. There was a large, wooden oil or gas derrick on the ground next to it. The monument had some kind of gas leaking from the top and it smelled terrible!

As bad as these wells were, however, the third well was by far the scariest! It had water pouring from its monument like a bathtub spigot. This well created its own stream that flowed directly into Cooks Run. (You can see it on a map here.) Not only was the smell absolutely noxious, the water pouring out created a petroleum sheen. How long has pollution from this well been flowing into Cooks Run? No one knows —until Nooreen reported it to DEP, nobody knew it was here.

If you enjoy our state forests and game lands, then please contact us or the folks at Marcellus Matters to participate in future outings in your area. I understand not everyone can do this but you can at least take the opportunity to tell the the state of Pennsylvania to clean up and protect our public lands. A few days after the outing, I gave public comment at the DCNR Bureau of Forestry’s hearing on the proposed State Forest Resource Management Plan. This plan guides the Bureau in managing our state forests and is an important opportunity to speak up in defense of our public lands. At the hearing, I talked about the orphaned and abandoned gas wells I saw on our outing and spoke out against future gas development on public lands. The Bureau will be accepting written comments through January 30th, 2016 so please send an email, fill out a survey, or mail your comments to the Bureau of Forestry.

To learn more about Marcellus Matters, please go to their website and check out their map of orphaned and abandoned oil and gas wells in Pennsylvania.

The goal of the Forest Watch Campaign is to empower Sierra Club members to become the eyes and ears of the forest. We are organizing a series of conservation outings throughout the state designed to take members to areas currently impacted or under threat by coal, gas, and oil and connect them to advocacy opportunities.

Nuclear?

By Savanna Lenker, Sierra Club PA Chapter intern

At the Clean Power Listening Session, an idea was brought to the table. Someone offered that Pennsylvania makes up its aforementioned 4% “other” deficit (outlined in the Clean Power Plan article) by means of nuclear energy.

The Sierra Club opposes nuclear. Tragic events at Three Mile Island, just down the Susquehanna from where I sit, and in Fukushima, Japan have proved our fears have merit. The primary issues with this source remain uncorrected.

Three Mile Island. Photo courtesy of Savanna Lenker

The stance will remain the same unless sufficient federal and global policies are developed to restrain energy over-use and nonessential economic growth. Changes need to be made to solve the problems with reactor operation, disposal of spent fuels, and the diversion of nuclear materials that can be use in weapons manufacture. Also, there would need to be an establishment of regulatory machinery to make sure the above conditions will be upheld.

The Sierra Club also is advocating for these changes:

1. Federal legislation to require Nuclear Regulatory Commission (NRC) licensing of both military and nonmilitary radioactive waste management facilities, including research and development facilities;

2. Federal legislation to require Nuclear Regulatory Commission regulation and control of all shipments of radioactive waste, whether of military or nonmilitary origin, and all commercial radioactive materials.

The Sierra Club also supports state and local efforts to provide greater protection in the transportation of radioactive waste and commercial radioactive materials.

3. Presidential appointment of a special citizens' advisory group to advise the president, Congress, and the NRC on the implementation of reforms recommended by the Kemeny Commission and such additional reforms as may be recommended by other studies now underway of the events leading to the Three Mile Island accident;

4. The making of appointments to this advisory group, to the Nuclear Regulatory Commission, and to staff positions in the NRC from a pool of individuals not committed by past experience to the nuclear industry. Such appointment should have a demonstrated commitment to public health and safety.

The Sierra Club is working toward a nuclear free future. 

“… nuclear proliferation and the long-term storage of nuclear waste (which remains lethal for more than 100,000 years) make nuclear power a uniquely dangerous energy technology for humanity.” 

Nuclear energy is not a probable solution to Climate Change (which the Clean Power Plan aims to combat) and every step closer to nuclear is one step farther from truly safe, inexpensive, and renewable energy sources.

Permit to Pollute?

FirstEnergy has a coal ash problem, and it wants us to deal with it.  Since 1975, the Beaver County power plant has pumped about 20 billion gallons of ash mixed with water to an impoundment called Little Blue Run on the border of Pennsylvania and West Virginia.  The problem is that the ash is toxic: it contains loads of heavy metals such as arsenic, lead, and cadmium, and other harmful pollutants like selenium and boron.  For years, this pollution has been finding its way into groundwater, wells, and streams, and even the air as the ash dries and blows around.

In 2012, FirstEnergy was ordered to close Little Blue Run because of the well-documented damage it was doing to the surrounding environment, nearby property, and neighbors’ health.  So FirstEnergy began to look for other places to dispose of this toxic waste.  It has now set its sights on the landfill at the Hatfield’s Ferry power station, a plant that FirstEnergy abruptly retired in 2013.  The ash would be dried out, loaded onto barges, hauled up the Ohio and Monongahela Rivers for 113 miles, then unloaded onto trucks and dumped at the landfill across the river from Masontown.

The proposed route between Little Blue Run (upper left) and Hatfield's Ferry (lower right) along the Ohio and Monongahela Rivers. 

But this landfill has its own set of problems.  The original landfill had no liner, and toxins from the ash disposed there have been contaminating the groundwater and surface water since at least 2001.  The most severe contamination is from arsenic, which has been found in concentrations up to 342 times the legal limit in monitoring wells around the site.  Exposure to arsenic can cause damage to the liver, kidneys, brain and nervous system, and can cause cancer.  Other contaminants that exceed federal standards are aluminum, boron, chromium, manganese, molybdenum, sulfate, and total dissolved solids (TDS).  There are at least seven private water wells within a two mile radius that are at risk of groundwater contamination, and one public water intake.

In 2006, the landfill was expanded and the new portion included a liner.  However, the original landfill remains unlined, and continues to leach pollutants.  The new lined portion partially overlaps the old portion, so it is difficult to know whether the liner is actually preventing additional toxins from contaminating groundwater.

In 2008, the landfill’s operator was fined for the contamination, and order to take corrective measures.  However, it is not clear that these corrective actions have been consistently followed, or whether new pollution continues to leach out from the site. 

A view of Little Blue Run courtesy of vice.com. Click the image for Vice's coverage of this impoundment. 

FirstEnergy is desperately trying to avoid having to build a new coal ash landfill that meets current federal standards for disposal of this waste that has already proven to be dangerous.  So they are trying to find the cheapest way possible to get rid of it.  First it announced it would ship it to the unlined pit in Labelle, but ongoing pollution problems at that site have prevented it from being able to accept waste from new sources.  So now the company has turned its attention to the Hatfield’s Ferry dump, yet another site with unresolved problems.  FirstEnergy, three strikes and you’re out.

In addition to the risks posed at the sites themselves, the transportation of the ash on open barges risks contaminating the Monongahela.  The Mon has long suffered from industrial pollution and acid mine drainage, and was at one time mostly dead ecologically.  However, it has begun to recover, and was voted River of the Year in 2013.  Multiple efforts are underway to encourage river-centered tourism and recreation, and transportation of millions of tons of toxic waste on open barges seems incompatible with that vision.

The Sierra Club, represented by Earthjustice, appealed a decision by the Pennsylvania Department of Environmental Protection (DEP) allowing FirstEnergy Generation, LLC to dispose of more than 17 million tons of toxic coal ash from the Bruce Mansfield Power Plant into a closed power plant landfill in Western Pennsylvania.

Bruce Mansfield power plant. 

In response to the DEP’s approval of the permit Charles McPhedran an attorney from Earthjustice and Tom Schuster, Pennsylvania Beyond Coal Campaign Representative for the Sierra Club released the following statements:

“This permit puts neighbors at risk” Charles McPhedran, an attorney with Earthjustice said.  “There are several private water wells and one public water intake that are at risk from contamination from this site, not to mention the risk up and down the rivers from transport of this ash. DEP needs to protect the families of Western Pennsylvania, not make them a dumping ground for FirstEnergy.”

“Toxins from the ash disposed at the Hatfield’s Ferry site have been contaminating nearby water since at least 2001. Arsenic has been found in concentrations up to 342 times the legal limit in monitoring wells around the site, and continues to violate health standards” Tom Schuster, Pennsylvania Beyond Coal Campaign Representative for the Sierra Club said. “Exposure to arsenic can cause damage to the liver, kidneys, brain and nervous system, and can cause cancer.  DEP needs to protect this community and require FirstEnergy to clean up this site before any more toxic ash is dumped.”

The Department of Environmental Protection should not issue a permit to all FirstEnergy to simply move its toxic liability from one community to another.  If it must dispose of its ash at Hatfield’s Ferry, it should be required to completely clean up the existing site, line the entire landfill, and monitor extensively to ensure new pollution does not occur.  Better yet, the company should avoid barging the ash up our rivers altogether, and build a state of the art landfill on site.

Sierra Club PA Chapter Testifies at EPA Methane Hearing in Pittsburgh

The following is testimony provided to the EPA by Sierra Club PA Chapter Director, Joanne Kilgour, on September 29, 2015 in Pittsburgh, PA: 

Good afternoon, and thank you for the opportunity to speak here to day on this important topic - controlling methane emissions from oil and gas sources. My name is Joanne Kilgour and I serve as the Director of the Sierra Club PA Chapter, representing 25,000 members and 80,000 supporters across the Commonwealth of PA. Our members have - for decades - been leading climate advocates and clean air champions in their communities, and I know that each of them would be here testifying today if they could. 

By holding this hearing in Pittsburgh, you are recognizing the significant impact air pollution from methane emissions has on this region - and regions across Pennsylvania - largely as a result of the dirty oil and gas industry. While we support and appreciate EPA taking this necessary first step to control methane emissions from oil and gas sources, we also recognize the need for action that will address pollution from existing sources.

I live in Lancaster, PA - one of the areas with the worst air quality in the nation. In fact, more than half of the counties in Pennsylvania are at risk because of air quality concerns, which are exacerbated by harmful methane emissions from the oil and gas sector. Just like me, more than four million residents of Pennsylvania live in areas that exceed national ozone standards, meaning that our health and our communities cannot afford to bear pollution from the thousands of existing sources in our state - let alone from new and modified sources. Our children, our elderly, and individuals as greater risk from respiratory complications cannot take another ozone action day.

Since this is the first-ever proposal to control methane pollution from the oil and gas industry we thank you, we support this initial step, and we call for these proposals to be adopted quickly so we can get to work on tackling the threat from methane emissions from oil and gas sources now in existence - sources that by 2018 are projected to account for nearly 90% of all methane emissions in this sector. 

In addition to threatening our climate, the public health threat posed by these emissions is staggering. For this reason, we call on EPA to revise its cost-benefit analysis and include in this revision metrics that monetize the public health benefit the methane standard will generate by reducing VOCs - and this smog and soot - as well as hazardous air pollutants. Without this adjustment, the benefits of implementing the rule will remain understated and the cost-benefit analysis will remain an inadequate assessment. Public health benefits are not simply qualitative or experiential, but have quantifiable financial benefits that must be documented.

I applaud the EPA and the Obama Administration for beginning to address this problem of new and modified sources of methane, and I now look to our state Department of Environmental Protection and the Wolf Administration to follow this lead and address fugitive emissions from existing sources, moving as fast and far as necessary to put the health and prosperity of Pennsylvania families first.

Make a Plan to Vote!

On November 3, several important elections will be taking place in Pennsylvania. Some of the key votes include the mayoral elections in Upper Darby Township, Philadelphia, and Reading. All municipal elections will be on this day as well. 

It is imperative that everyone of age votes between 7a.m. and 8p.m. on the 3rd. Through elections, we are able to voice our opinion and have an impact on decisions made in our towns and municipalities. Every vote counts. 

Click here to see Sierra Club PA Chapter Supreme Court endorsements. 

For more information on voting and polling places click here. 

To learn more about your specific needs as a voter click here.  

Groups Oppose HB 965

The Sierra Club PA Chapter joined the letter below, asking members of the PA House to oppose HB 965, expected to come up for a vote on second consideration today:

October 16, 2015

Re: Opposition to HB 965 (P.N. 1885) and SB 562

Dear Representative:

On behalf of the hundreds of thousands of members we represent in Pennsylvania, the undersigned respectfully request that you OPPOSE House Bill 965 (P.N. 1885), which is scheduled for second consideration this Monday, October 19.         

You may hear that HB 965 (and its Senate counterpart, SB 562) is necessary for legislative “oversight.”  In reality, this legislation would hamstring the current independent and bipartisan process for updating state agency regulations by giving standing committees of the legislature unilateral control to hold up proposals they dislike. At the same time, HB 965 will make Pennsylvania’s regulatory rulemaking process much less transparent to the general public.

At best, these bills are solutions in search of a problem; at worst, they represent legislative overreach that would politicize Pennsylvania’s rulemaking process and take the “independent” out of the Commonwealth's Independent Regulatory Review Commission (IRRC).

We are specifically concerned with two particular changes proposed by HB 965 and SB 562.

First, by enabling standing committees of the General Assembly to repeatedly delay IRRC votes on proposed regulations (and introducing other delays), HB 965 and SB 562 would further complicate an already complicated process – and effectively transfer executive powers to small groups of legislators.

By way of background, one of the stated intentions of the Regulatory Review Act is “to provide ultimate review of regulations by the General Assembly” (see section 2(a)). That step already exists in our current IRRC process. After the IRRC votes on a regulatory proposal by a state agency, legislative standing committees already have the power to further review or disapprove the proposal. When a committee invokes its power to review or disapprove, the regulatory proposal is stayed for fourteen days, so that it can be brought to a vote before the full legislature. For three decades, this process has given the General Assembly ample time to review new regulations proposed by state agencies.

HB 965 and SB 562 would turn this orderly process on its head by (among other things) giving legislative committees the additional power to “further review” proposed regulations before the IRRC ever votes – and to do so repeatedly. By exercising this power, a standing committee could postpone a vote by IRRC indefinitely, and thereby effectively block the executive rulemaking process. In addition, the bills would needlessly inflate several post-vote periods during which the legislature can take action against proposed regulations. These changes would only serve to create bureaucracy and red tape, hinder the passage of much-needed regulations (which are often necessary to implement federal law or statutes passed by the General itself has), and subject the formerly independent IRRC to the control of small groups of legislators.

Second, the bills would block publication of agency “Statements of Purpose” (SOP) in the Pennsylvania Bulletin. The only effect of this prohibition would be to make it harder for your constituents to understand proposed regulatory changes. The sponsorship memo for SB 562 suggests that blocking Bulletin publication will prevent courts from interpreting SOPs in a way that is inconsistent with the regulations or the intent of the General Assembly. But courts do not review and interpret SOPs because they are printed in the Bulletin; they do so because SOPs are drafted by agencies and introduced into evidence in judicial proceedings. Blocking Bulletin publication will prevent neither of these things. It will only eviscerate the ability of the public to learn about and comment on new regulations.

Please tell your leadership that you OPPOSE HB 965 and vote to keep the “independent” in the Independent Regulatory Review Commission.

Thank you for in advance for standing up for the integrity and transparency of our regulatory process and OPPOSING HB 965.

Sincerely,

David Masur, Executive Director                   Joanne Kilgour, Chapter Director

PennEnvironment                                        Sierra Club, Pennsylvania Chapter

Joseph Otis Minott, Executive Director           Matthew Stepp, Policy Director

Clean Air Council                                          Citizens for Pennsylvania’s Future

Jackson Morris, Director Eastern Energy      Gretchen Dahlkemper, National Field

Mark Szybist, Senior Program Advocate       Manager

Natural Resources Defense Council          Moms Clean Air Force

Josh McNeil, Executive Director                     Phil Wallis, Executive Director

Conservation Voters of Pennsylvania         Audubon Pennsylvania

Alice Tong, Eastern States Advocate               Khari Mosley, Pennsylvania Regional

Environmental Entrepreneurs (E2)               Programs Manager

                                                                          BlueGreen Alliance

Steve Hvozdovich                                            Mary Booth

Clean Water Action                                        Partnership for Policy Integrity

What you need to know about the Pennsylvania Clean Power Plan

President Obama and the Environmental Protection Agency (EPA) took historic action on August 3, 2015 when they announced the finalized Clean Power Plan (CPP), a step to reduce carbon pollution and combat climate change. The plan extends to the year 2030 and focuses on lowering emissions from power plants and increasing renewable energy and efficiency. States will individually develop plans to meet the guidelines laid out by the CPP.

Pennsylvania already has programs that would get us over halfway to our goal, if they are fully put into effect. These current policies would meet 51% of the goal. The other 49% will be covered by increasing energy efficiency, increasing renewable energy, and taking other additional measures. By adjusting the energy efficiency savings goal to 1.5% (which is consistent with leading states),PA  would get to 14% of the target.  The state can also increase the percent of renewable energy to 20%, which again compares to surrounding states and would alone get us 31% closer the aim. The leftover 4% is easily attainable by updating building codes and the efficiency of power plants. 

The Wolf administration's Department of Environmental Protection (DEP), will be holding 14 community listening sessions across to state to provide the public and opportunity to share their thoughts and opinions about the Clean Power Plan.  Click here to learn more about these sessions.

Members and staff at the first listening session held in Harrisburg on 15 September.