Accounting Cumulative Impacts of Highly Industrialized Infrastructure

The Team

• Concerned residents in the Washington County, PA communities of Buffalo Township, Robinson Township, Smith Township, West Pike Run Township, led by Cathy Lodge, Robinson Township resident, [email protected]
• Albert Presto, Associate Research Professor, Mechanical Engineering, Carnegie Mellon University, [email protected]
• Leann Leiter, Oil and Gas Field Advocate, Earthworks
• Lisa Graves Marcucci, Environmental Integrity Project, Pittsburgh, Allegheny County, PA, [email protected]
• SW Pennsylvania Environmental Health Project team, McMurray, Washington County, PA

The Challenge

[caption id="attachment_22579" align="alignleft" width="392"] Driving tour of shale gas operations, Washington County with Dr. Albert Presto, CMU [Photo courtesy of L. Graves-Marcucci][/caption]Areas like Washington County, PA are home to massive industrial buildouts of the shale gas industry. In fact, some communities are, literally, being surrounded by increased infrastructure. For some, this increased industrialization is being unfairly focused on areas chosen by companies with a vested interest with little to no regard for the ever increasing risks to the same communities. As oil and gas operations continue to dot the landscape, many continue to ask the following important questions:

• How can concerned residents get much needed attention on the risks?
• When will the cumulative impacts be considered?
• Who will be responsible for determining when the public risks outweigh the private benefit – i.e., when stepping forward to perform the necessary evaluations to properly and objectively consider when is too much, too much?
• And, how can concerned citizens seek to achieve this additional oversight?

In an attempt to answer some of these long-standing questions, local citizens in Robinson Township, Smith Township, and West Pike Run Township sought help from Southwestern Pennsylvania Environmental Health Project (SWPA EHP) as well as experts from the Environmental Integrity Project (EIP), Earthworks, and engineers at Carnegie Mellon University (CMU).

The Methods

The team had several in-person planning meetings, including a tour of shale gas development sites in Buffalo Township, Robinson Township, Smith Township and West Pike Run Township – all in Washington County, PA.

Additional phone meetings were held and fieldtrips were conducted – specifically, with regard to FLIR (Forward Looking Infrared) camera imaging and some limited in-home and exterior monitoring. Team members also met with families who participated in the project.

Participants in the project accepted the fact that the project would be limited in scope, but would attempt to identify locations where increased infrastructure could be posing increased risk exposures and where additional monitoring made sense. This was a challenge given limited resources meant limited monitoring – all while seeking to find a method to demonstrate the need for increased monitoring by state and local authorities.

Sites for inclusion in the project were chosen using the following factors:

• Visual line of sight close enough to the facility without causing trespass
• Known resident living near the site willing to participate in the project
• Compatibility for FLIR imaging

The Washington County, PA sites selected included:

• EQT Blue Moon Compressor Station, West Pike Run Township, PA
• EQT Twilight Compressor Station, West Pike Run Township, PA
• ETC Bulger Compressor Station, Smith Township, PA
• MarkWest 3 Brothers Compressor Station, Smith Township, PA
• MarkWest Harmon Creek Cryogenic Plant, Smith Township, PA
• MarkWest Welling Compressor Station, Buffalo Township, PA

Limited resources provided for some additional monitoring that included:

• Speck monitors for particulate matter
• Summa canisters for total VOC monitoring
• Aldehyde badge monitoring
• A review of current air quality monitoring sites currently in place and overseen by the PA Department of Environmental Protection (PA DEP) and/or the Allegheny County Health Department (ACHD)

Additionally, the project also sought to accomplish the following:

• Petition the PA DEP to add more permanent, stationary air quality monitors – closer to the affected communities in Washington County, PA.
• Seek additional, stationary Volatile Organic Compound (VOC) air quality monitors to be placed on properties adjacent to a select number of compressor stations and cryogenic processing plants, including those sites included in this project.
• Seek meetings with regulatory agencies including the PA DEP, the US EPA and the Allegheny County Health Department in order to share first-hand accounts from families impacted by the massive industrialization of these Washington County communities. The goal of these meetings would be to urge a change in how applications for additional facilities and/or modifications to existing operations are evaluated and reviewed by regulatory authorities. Specifically, seek a commitment from regulators to require mapping of the current and proposed facilities by staff members as part of the permit application review process so that cumulative impacts can be considered.

The Results

[caption id="attachment_22577" align="alignright" width="450"] MarkWest 3 Brothers Compressor Station, Smith Township, PA.
[Photo courtesy of Bob Donnan.][/caption]Although we knew our project would not provide a definitive data outcome, our goal was to use existing public file documents coupled with limited, real-world monitoring data, news accounts, and citizen testimonials to call attention to the fact that there are certain rural communities that are experiencing disproportionate risks when it comes to impacts from oil and gas expansion. In addition, citizens want decision-makers to recognize that a single project cannot be considered in a vacuum; full consideration must be given to cumulative impacts when weighing whether another project should go forward.

As expected, achieving compelling data was difficult for the following reasons:

• Limited visual access to some of the sites
• Limited access to monitoring equipment on a more regular basis
• Lack of on-going monitoring for longer periods of time
• Lack of funding for continuing summa canister monitoring/testing

However, some important results were obtained as a result of the project. These include:

• FLIR images of emissions from project sites were obtained, where possible. Although FLIR images, themselves, are not conclusive of exactly what is being emitted, those images are a valuable means to begin important conversations involving citizens, local leaders, scientific experts and overseeing regulators. And, when more definitive information can be discerned from FLIR images, that information could be used to urge more oversight and accountability by decision makers. Links to the FLIR images captured as part of the project are included in Table 1 in the Observations and Other Resources section, below.
• Due, in part, to the concerned citizen teams participating in this project, key local, regional and national news stories resulted. Links to key news stories are included in Observations and Other Resources, News Stories section, below. Additional news stories are included at the end of this report in the Additional Resources section.
• In the final phase of the project, a day-long tour involving in-person meetings with local families in the communities and two air quality team members from the PA DEP, SW Regional Office was arranged. Families participating in the project were able to meet with the head of the air quality inspection team as well as the newly assigned air quality inspector for their area. This meeting provided a foundation for future, constructive dialogue between concerned community members and key regulatory staff members.
  • In the following weeks, additional meetings between the PA DEP staff and local concerned residents, local government officials and advocacy teams took place. The results included the possibility of a Notice of Violation (NOV) being issued to one of the sites included in the project: MarkWest’s Harmon Creek cryogenic plant.
  • A tentative commitment from the PA DEP to consider the addition of at least one more stationary monitor closer to some of the project’s sites.
  • Increased oversight by a newly hired PA DEP Air Quality Inspector, specifically assigned to the Robinson Township and Smith Township areas.
    • This oversight now involves more communications between the PA DEP Inspector, local concerned residents, Smith Township officials and their Solicitor. Important lines of communication are being created where none previously existed.
• And, as part of discussions with team members from Carnegie Mellon University (CMU) CREATE Lab, expanded monitoring for total VOCs is now underway. Monitors will be placed in four Washington County, PA locations – near several of the project sites – on a permanent basis. Those monitors will assist in determining when additional summa canister monitoring can be done in a more precise timeline.

Reflections

[caption id="attachment_22575" align="alignleft" width="429"] Citizen team member showing mapping project, shale gas operations permitted in several Washington County communities. [Photo courtesy of L. Graves-Marcucci][/caption]The challenges with this project were significant as our resources were limited.  Although the team is grateful for the assistance and resources provided by partner groups, those resources were not enough to achieve sufficient data-driven evidence that could be used to require more monitoring and analysis of cumulative impacts.  However, in the absence of sufficient scientific evidence, the team did achieve some meaningful results including more engagement between the PA DEP and concerned local residents.  Important conversations have begun that could very well yield additional oversight of several of the project sites.  And, there is serious consideration by the state regulators to add more, stationary air quality monitoring.  Last, our team has a new commitment for the placement of four, total VOC monitors by the CMU CREATE Lab team.  Those developments could be significant in achieving some of the data-driven evidence this project was unable to obtain.  Important progress is underway.

Given the challenges of this project, the effort was worthwhile.  Future attempts to replicate this project should include more resources to ensure long-term, stationary monitoring earlier in the process.

Conclusions

[caption id="attachment_22573" align="alignright" width="388"] Two cryogenic plants in Smith Township, PA. [Photo courtesy of Bob Donnan.][/caption]This project sought to obtain scientific evidence pointing to a need for more air quality monitoring in these heavily affected communities.  However, the goals outlined in the initial project proved daunting without more dedicated resources in order to provide the necessary long-term monitoring.  The lack of sufficient data-driven monitoring information made it difficult for our scientific lead, Dr. Albert Presto, to provide definitive recommendations even though the team was in agreement that additional, increased consistent, stationary monitoring would be important for these communities in an effort to better understand the risks posed by the shale gas buildout.

We greatly appreciate Dr. Presto’s interest in the project and his time in reviewing the limited data collected, however, without more definitive data, scientific recommendations were also limited.  It is the hope of the citizen team involved in this project that should a commitment be made by the PA DEP to add air quality monitors in these communities, we could call upon Dr. Presto as well as the CREATE Lab and SW PA EHP teams to assist the residents in making recommendations on exactly where those newly added monitors should be placed in order to facilitate increased data collection.

And, as a result of the project several key developments were realized.  Those include:

• Important meetings between the PA DEP staff, local concerned residents, local government officials and advocacy teams have now paved the way for more regulatory oversight and the inclusion of local families’ concerns.
• Increased oversight by a newly hired PA DEP Air Quality Inspector, specifically assigned to the Robinson Township and Smith Township areas.
• A tentative commitment from the PA DEP to consider the addition of at least one more stationary monitor closer to some of the project’s sites.
• And, for the first time, expanded total VOC monitoring made possible by the Carnegie Mellon University (CMU) CREATE Lab is now underway. Monitors will be placed in four Washington County, PA locations – near several of the project sites – on a permanent basis.  Those monitors will assist in determining when additional summa canister monitoring can be done in a more precise timeline.

There remains much to be done, however, we see this as the beginning of a long overdue process.

Thanks to our project team members including the following:

• Cathy Lodge, resident Robinson Township, Washington County, PA
• Lois Bjornson, resident of Scenery Hill, Washington County, PA
• Kasey and Sam Duran, residents of Smith Township, Washington County, PA
• Trina and Mike Tokarski, residents of Smith Township, Washington County, PA
• Dave Matijevich and Robin Walker, residents of Smith Township, Washington County, PA
• Jim Powell, resident of Buffalo Township, Washington County, PA
• Lisa Graves Marcucci, Environmental Integrity Project, Pittsburgh, Allegheny County, PA
• Leann Leiter, Earthworks, Canonsburg, Washington County, PA
• Albert Presto, Associate Research Professor, Mechanical Engineering, Carnegie Mellon University, Allegheny County, PA and members of the CMU CREATE Lab.
• The wonderful team of health professionals and community outreach team with the SW Pennsylvania Environmental Health Project including:
  • Raina Rippel, Director
  • Jill Kriesky, Ph. D, Associate Director
  • Nathan Ribar, MS, Environmental Health Educator
  • Hannah Blinn, Environmental Health Educator
  • Sara Rankin, MPH, BSN, OCN, Public Health Nurse
• And, a special thanks to the American Geological Union for the opportunity to initiate this project under the leadership of Natasha Udu-gama, Ph. D., Senior Specialist, Thriving Earth Exchange. We are grateful for her help in initiating the project, introducing the team to Dr. Albert Presto and guiding the team throughout the entirety of the process.

Full Report: Expanding Shale Gas Operations: Is Current Monitoring Enough?

Robinson and Smith Townships, located in Washington County, Pennsylvania, are close knit, idyllic, rural and agricultural communities. In recent years, shale gas extraction has boomed in Washington County, proving a divisive issue among residents and straining relationships between neighbors, as industry changes the landscape of communities with the development of wells, pipelines, processing plants, and compressor stations. As public health concerns mount, residents are looking for expertise to aid with understanding the cumulative air quality implications of hydraulic fracturing operations and associated industrial infrastructure development clustered in these rural communities.

This challenge will focus on the less studied equipment and operations that lack meaningful, transparent permitting and/or do not provide complete monitoring, in particular pigging operations, compressor stations and processing plants, and the flaring that accompanies such operations. Residents want to understand how the equipment is intended to function, how much equipment and operations are necessary, and what planned releases of contaminants accompany each portion of the operations. Volatile organic compounds (VOCs) are the contaminants of concern, particularly benzene, methane and formaldehyde.

Robinson Township officials originally challenged the Act 13 regulations that stifled municipalities’ long established zoning authority with regard to the new shale gas industry in Pennsylvania.  A Pennsylvania Supreme Court ruling in December of 2013, reaffirmed local zoning authority, however, this legal decision angered some lease holders, fearing their opportunities to reap the benefits of potential shale gas royalties.  As a result, the Robinson Township officials responsible for initiating the landmark Robinson Township v Commonwealth of Pennsylvania challenge to Pennsylvania’s Act 13 were voted out of office and replaced with decision-makers sympathetic to the oil and gas industry, including some leaseholders.  As one of the centers of oil and gas extraction in Western Pennsylvania, residents in Robinson and Smith Townships, Washington County are concerned about the cumulative impacts of industrial operations, particularly air quality implications, as the regulatory oversight is lacking in this regard.

Background on the Robinson Township v Commonwealth of PA ruling:  https://stateimpact.npr.org/pennsylvania/2013/12/19/state-supreme-court-strikes-down-act-13-local-zoning-restrictions/

A literature review is requested prior to project start to anticipate specific compounds to monitor. Of interest to the local residents would be canister testing, FLIR camera imaging and/or other equivalent monitoring that can provide scientific data detailing what emissions are being released from the oil and gas operations near their homes, farms and school.  It is the citizen team’s hope that Albert Presto will coordinate access or ownership of monitoring equipment, including the ability to set up, maintenance of the equipment, as well as gathering of and analysis of data.

Contact

Cathy “Cat” Lodge will serve as the primary point of contact. She will be supported by other partners and neighbors and by the Environmental Integrity Project (EIP). Cat will be the interface with the community for monitoring sites, engaging with other community members. The community is self-taught, aware, has developed maps, acquired photos and detailed knowledge of area, location of facilities, and the like. If air monitoring is possible, there are property owners willing to place monitors abutting or adjacent to various types of facilities.

This project is part of one of Thriving Earths’ new cohorts.  Thriving Earth Exchange has partnered with AGU’s GeoPolicy Connect in 2017 to bring community leaders from eastern Ohio and western Pennsylvania affected by ongoing hydraulic fracturing together with scientists and policymakers. Thriving Earth Exchange is working with three local community groups to connect them with scientists who can help them better understand and cope with the effects of hydraulic fracturing.