Greater Pittsburgh area embroiled in fracking controversy

From the Summary by Marcellus Drilling News, August 16, 2022

Gas Field Specialists, headquartered in Potter County, PA, is an oilfield services (OFS) company that works in the Marcellus Shale in northern Pennsylvania. The company also does OFS work in western New York State. According to a settlement reached with the Equal Employment Opportunity Commission (EEOC), Gas Field Specialists will pay a former employee (rig worker/mechanic) $184,000 after firing him because he had cancer.

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PA Permit Violation Issued to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington County
Description: Environmental Health & Safety violation issued on 8/12/2022 to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington county. 91.34(A) – ACTIVITIES UTILIZING POLLUTANTS – Failure to take necessary measures to prevent the substances from directly or indirectly reaching waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause. Incident Date: 2022-08-12

PA Permit Violation Issued to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington County
Description: Environmental Health & Safety violation issued on 8/12/2022 to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington county. 78a57(a) – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator failed to collect brine and other fluids produced during operation of the well in a tank, series of tanks, or other device approved by the Department for subsequent disposal or reuse. Incident Date: 2022-08-12

PA Permit Violation Issued to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington County
Description: Environmental Health & Safety violation issued on 8/12/2022 to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington county. SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP. Incident Date: 2022-08-12

PA Permit Violation Issued to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington County
Description: Environmental Health & Safety violation issued on 8/12/2022 to RANGE RESOURCES APPALACHIA LLC in Somerset Twp, Washington county. 78a54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth and in accordance with 25 Pa. Code §§ 78a.55 – 78a.58 and 78a.60 – 78a.63. Incident Date: 2022-08-12

PA Permit Violation Issued to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland County
Description: Environmental Health & Safety violation issued on 8/10/2022 to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland county. 78.57(a) – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator failed to collect the brine and other fluids produced during operation, service and plugging of the well in a tank, pit or a series of pits or tanks, or other device approved by the Department or Operator discharged brine or other fluids on or into the ground or into waters of the Commonwealth. Incident Date: 2022-08-10

PA Permit Violation Issued to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland County
Description: Environmental Health & Safety violation issued on 8/10/2022 to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland county. 78.54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth. Incident Date: 2022-08-10

PA Permit Violation Issued to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland County
Description: Environmental Health & Safety violation issued on 8/10/2022 to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland county. 91.34(A) – ACTIVITIES UTILIZING POLLUTANTS – Failure to take necessary measures to prevent the substances from directly or indirectly reaching waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause. Incident Date: 2022-08-10

PA Permit Violation Issued to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland County
Description: Environmental Health & Safety violation issued on 8/10/2022 to MTN V OIL & GAS INC in Hempfield Twp, Westmoreland county. SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP. Incident Date: 2022-08-10

SOURCE of Recent Regional Violations ~ SkyTruth, P.O. Box 3283, Shepherdstown, WV 25443
info@skytruth.org

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SEE ALSO: Can environmental violations define oil and gas companies as bad actors? A judgment awaits | Anya Litvak, Pittsburgh Post-Gazette, August 3, 2022

Marcellus gas well pads & wastewater impoundment in prime forest of north central Penna.

From an Article by Ad Crable, Bay Journal, 5/3/21

Pennsylvania’s robust natural gas industry has been embarrassed by three environmental scandals in 15 months. Among the fallout: temporarily closed pipelines, the state’s largest environmental fine, the elimination of streams, and the illegal burial or alteration of parts of 163 wetlands.

In one case, Texas gas company Range Resources was found to have classified spent gas wells as temporarily inactive, rather than closed, thus avoiding a requirement to plug the wells to prevent leaks of methane, a powerful greenhouse gas.

In another case, Chesapeake Appalachia, an arm of Chesapeake Energy and one of the largest fracking gas companies in Pennsylvania, signed a consent agreement March 24 with the U.S. Department of Justice, U.S. Environmental Protection Agency and Pennsylvania Department of Environmental Protection.

The agreement, which included a $1.9 million civil penalty, acknowledges that Chesapeake Appalachia had, according to its own reports, filled approximately 26 acres of wetlands with dirt, rock or sand, without state or federal authorization, at 76 of its gas wells across five counties.

The company will have to restore about 11 acres of affected wetlands. To compensate for the remaining 15 acres, which are irreparably damaged, the company must create twice that many acres of new wetlands nearby, ideally in the same watershed.

Chesapeake Appalachia’s record of the damage goes back to 2013, when the EPA and Justice Department fined the company $3.2 million for violations in West Virginia. The company agreed then that it had impounded and filled in 2.2 miles of streams and smothered portions of wetlands at 27 well pad sites without required federal permits from the U.S. Army Corps of Engineers. The violations were discovered by routine EPA inspections, complaints from nearby residents and reports from the gas company itself.

After that case and a management shake-up at the company, Chesapeake Energy did an internal audit of 500 gas well sites in Pennsylvania and informed state officials that it had discovered similar violations at 76 sites.

Gordon Pennoyer, a Chesapeake Energy spokesman, said of the enforcement action, “Having voluntarily disclosed these issues with the DEP and EPA seven years ago, we are pleased to resolve this legacy matter.”

Under federal regulations, Chesapeake has a choice of restoring violated wetlands or creating new ones elsewhere at double the amount destroyed. The company has submitted a plan to restore wetlands at some of the drilling sites, restore wetlands elsewhere to compensate for places where steep slopes prevent work at the original location, and conduct a combination of on-site and off-site work in some cases.

DEP Secretary Patrick McDonnell applauded Chesapeake Appalachia for coming forward with its violations and called the settlement a “significant benefit to Pennsylvania’s public natural resources” because it will result in an increase of wetlands in the Chesapeake Bay watershed.

Diana Esher, acting administrator of the EPA’s Mid-Atlantic region, said wetlands are “critical ecological and economic resources for all Pennsylvanians.”

The Chesapeake Appalachia penalties followed another high-profile case that concluded in early 2020, when a gas pipeline company was fined an unprecedented $30.6 million by the DEP, partly for widespread wetlands and stream violations.

The case against ETC Northeast Pipeline stemmed largely from a landslide that ruptured the one-week-old Revolution Pipeline in rural western Pennsylvania on Sept. 10, 2018. The blast from ignited natural gas burned one house, caused six power transmission poles to collapse, and destroyed two garages, a barn and several vehicles, as well as forced evacuations.

The DEP found that the company, an arm of Texas-based gas pipeline builder Energy Transfer Corp., used poor construction and oversight practices in building the pipeline. But an investigation after the blast uncovered more widespread environmental harms along the 40-mile pipeline.

According to the DEP, the company’s violations included 120 altered streams, 23 “eliminated” streams, 17 buried wetlands, 70 altered wetlands, 352 cases of erosion and sedimentation, 540 cases of sediment washing into streams, and 1,359 violations of required best management practices.

That laundry list of violations prompted the DEP to take the rare step of freezing pipeline permits for Energy Transfer Corp. subsidiaries, including that of the cross-state pipeline known as Mariner East 2.

That pipeline’s construction had already amassed a list of environmental violations, including sinkholes and 320 spills of drilling fluids. One spill into a central Pennsylvania lake cost Energy Transfer a $2 million fine.

“There has been a failure by Energy Transfer and its subsidiaries to respect our laws and our communities,” Gov. Tom Wolf said at the time of the Revolution Pipeline consent order. “This is not how we strive to do business in Pennsylvania, and it will not be tolerated.”

But after a one-year freeze, the DEP allowed Energy Transfer pipelines to resume or proceed with construction. The DEP ordered Energy Transfer to restore all wetlands and stream sections where possible. Seventy of the 87 damaged or destroyed wetlands will be restored. The other 17 harmed wetlands will be atoned for with the restoration of four times as much wetlands in the same watershed.

In a much smaller case, the DEP and Range Resources agreed in February to a consent order after the DEP found that the company was trying to avoid plugging spent gas wells as required. The agency fined Range Resources $294,000 and required plugging all but one of the 42 wells in question.

“Abandoned wells can be an extreme hazard to the health and safety of people and the environment,” said Jamar Thrasher, DEP spokesman. “That contributes to air, water and soil contamination, so it’s an environmental hazard.” Abandoned wells can leak methane, a potent greenhouse gas. These were conventional gas wells dating mostly from the 1980s or older, and not new fracking wells.

The company had filed paperwork with the DEP, mostly from 2012 to 2016, saying the wells were “inactive.” But an internal memo that Range sent to the DEP three weeks before paperwork was received on one well had reported that the well “was incapable of economic production.”

The DEP then investigated other wells and found 41 more that had been improperly classified.

SELECTED DRILLING & FRACKING VIOLATIONS IN WESTERN PENNSYLVANIA

From Skytruth Alerts, Shepherdstown, WV, February 2021

PA Permit Violation Issued to RICE DRILLING B LLC in Center Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 1/11/2021 to RICE DRILLING B LLC in Center Twp, Greene county. 78a54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth and in accordance with 25 Pa. Code 78a.55 – 78a.58 and 78a.60 – 78a.63.

PA Permit Violation Issued to RICE DRILLING B LLC in Center Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 1/11/2021 to RICE DRILLING B LLC in Center Twp, Greene county. 78A57(A)___ – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator discharged brine and other fluids on or into the ground or into the waters of this Commonwealth.

PA Permit Violation Issued to RICE DRILLING B LLC in Center Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 1/11/2021 to RICE DRILLING B LLC in Center Twp, Greene county. SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.

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PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. 78a54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth and in accordance with 25 Pa. Code 78a.55 – 78a.58 and 78a.60 – 78a.63.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. 78A57(A)___ – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator discharged brine and other fluids on or into the ground or into the waters of this Commonwealth.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. 91.34(A) – ACTIVITIES UTILIZING POLLUTANTS – Failure to take necessary measures to prevent the substances from directly or indirectly reaching waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. 78a54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth and in accordance with 25 Pa. Code 78a.55 – 78a.58 and 78a.60 – 78a.63.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. 78A57(A)___ – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator discharged brine and other fluids on or into the ground or into the waters of this Commonwealth.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/06/2021 to EQT PROD CO in Forward Twp, Allegheny county. 91.34(A) – ACTIVITIES UTILIZING POLLUTANTS – Failure to take necessary measures to prevent the substances from directly or indirectly reaching waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/05/2021 to EQT PROD CO in Forward Twp, Allegheny county. 91.34(A) – ACTIVITIES UTILIZING POLLUTANTS – Failure to take necessary measures to prevent the substances from directly or indirectly reaching waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/05/2021 to EQT PROD CO in Forward Twp, Allegheny county. 78a54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth and in accordance with 25 Pa. Code 78a.55 – 78a.58 and 78a.60 – 78a.63.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/05/2021 to EQT PROD CO in Forward Twp, Allegheny county. 78A57(A)___ – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator discharged brine and other fluids on or into the ground or into the waters of this Commonwealth.

PA Permit Violation Issued to EQT PROD CO in Forward Twp, Allegheny County, Penna.
Description: Environmental Health & Safety violation issued on 1/05/2021 to EQT PROD CO in Forward Twp, Allegheny county. SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP.

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PA Permit Violation Issued to THE PRODUCTION CO LLC in Redstone Twp, Fayette County, Penna.
Description: Administrative violation issued on 1/05/2021 to THE PRODUCTION CO LLC in Redstone Twp, Fayette county. 78.121(B) – WELL REPORTING – PRODUCTION REPORTING – Operator failed to electronically submit production and status report to the Department through its web site.

PA Permit Violation Issued to THE PRODUCTION CO LLC in Jefferson Twp, Fayette County, Penna.
Description: Environmental Health & Safety violation issued on 1/19/2021 to THE PRODUCTION CO LLC in Jefferson Twp, Fayette county. 78.74 – VENTING OF GAS – Operator vented gas to the atmosphere that produced a hazard to the public health and safety.

PA Permit Violation Issued to THE PRODUCTION CO LLC in Jefferson Twp, Fayette County, Penna.
Description: Environmental Health & Safety violation issued on 1/19/2021 to THE PRODUCTION CO LLC in Jefferson Twp, Fayette county. 78.91(a) – PLUGGING – GENERAL PROVISIONS – Upon abandoning a well, the owner or operator failed to plug the well to stop the vertical flow of fluids or gas within the well bore under 25 Pa. Code 78.92-78.98 or an approved alternate method.

PA Permit Violation Issued to THE PRODUCTION CO LLC in Jefferson Twp, Fayette County, Penna.
Description: Administrative violation issued on 1/19/2021 to THE PRODUCTION CO LLC in Jefferson Twp, Fayette county. OGA3211(H) – WELL PERMITS – LABELING – Failure to install, in a permanent manner, the permit number on a completed well.

PA Permit Violation Issued to THE PRODUCTION CO LLC in Jefferson Twp, Fayette County, Penna.
Description: Administrative violation issued on 1/19/2021 to THE PRODUCTION CO LLC in Jefferson Twp, Fayette county. OGA3211(G) – WELL PERMITS – POSTING – Failure to post the well permit number and the operator’s name, address and phone number at the well site during construction of the access road, site preparation and during drilling, operating or alteration of well.

PA Permit Violation Issued to THE PRODUCTION CO LLC in Jefferson Twp, Fayette County, Penna.
Description: Environmental Health & Safety violation issued on 1/19/2021 to THE PRODUCTION CO LLC in Jefferson Twp, Fayette county. 78.73(a) – GENERAL PROVISION FOR WELL CONSTRUCTION AND OPERATION – Operator failed to construct and operate the well in accordance with 25 Pa. Code Chapter 78 and ensure that the integrity of the well is maintained and health, safety, environment and property are protected.

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PA Permit Violation Issued to EQUITRANS LP in Morgan Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 1/21/2021 to EQUITRANS LP in Morgan Twp, Greene county. 78.91(a) – PLUGGING – GENERAL PROVISIONS – Upon abandoning a well, the owner or operator failed to plug the well to stop the vertical flow of fluids or gas within the well bore under 25 Pa. Code 78.92-78.98 or an approved alternate method.

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PA Permit Violation Issued to DIVERSIFIED PROD LLC in Cumberland Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 2/04/2021 to DIVERSIFIED PROD LLC in Cumberland Twp, Greene county. 78.54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth.

PA Permit Violation Issued to DIVERSIFIED PROD LLC in Cumberland Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 2/04/2021 to DIVERSIFIED PROD LLC in Cumberland Twp, Greene county. SWMA 302(B)3 – DISPOSAL, PROCESSING AND STORAGE OF RESIDUAL WASTE – Person failed to design, construct, operate or maintain facilities and areas in a manner that do not adversely effect affect or endanger public health, safety and welfare or the environment or cause a public nuisance.

PA Permit Violation Issued to DIVERSIFIED PROD LLC in Cumberland Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 2/04/2021 to DIVERSIFIED PROD LLC in Cumberland Twp, Greene county. 78.57(a) – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator failed to collect the brine and other fluids produced during operation, service and plugging of the well in a tank, pit or a series of pits or tanks, or other device approved by the Department or Operator discharged brine or other fluids on or into the ground or into waters of the Commonwealth.

PA Permit Violation Issued to DIVERSIFIED PROD LLC in Dunkard Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 2/04/2021 to DIVERSIFIED PROD LLC in Dunkard Twp, Greene county. 78.54 – GENERAL REQUIREMENTS – Operator failed to control and dispose of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, drilling muds, stimulation fluids, well servicing fluids, oil, and production fluids in a manner that prevents pollution of the waters of the Commonwealth.

PA Permit Violation Issued to DIVERSIFIED PROD LLC in Dunkard Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 2/04/2021 to DIVERSIFIED PROD LLC in Dunkard Twp, Greene county. SWMA 302(B)3 – DISPOSAL, PROCESSING AND STORAGE OF RESIDUAL WASTE – Person failed to design, construct, operate or maintain facilities and areas in a manner that do not adversely effect affect or endanger public health, safety and welfare or the environment or cause a public nuisance.

PA Permit Violation Issued to DIVERSIFIED PROD LLC in Dunkard Twp, Greene County, Penna.
Description: Environmental Health & Safety violation issued on 2/04/2021 to DIVERSIFIED PROD LLC in Dunkard Twp, Greene county. 78.57(a) – CONTROL, STORAGE AND DISPOSAL OF PRODUCTION FLUIDS – Operator failed to collect the brine and other fluids produced during operation, service and plugging of the well in a tank, pit or a series of pits or tanks, or other device approved by the Department or Operator discharged brine or other fluids on or into the ground or into waters of the Commonwealth.

Mariner East pipeline involves dangerous conditions over 300 miles

From Susan Phillips, StateImpact Penna., August 29, 2019

Energy Transfer/Sunoco Logistics will pay a combined $313,000 for two penalties related to Mariner East 2 construction violations in 2017 and 2018. This latest assessment brings the total financial penalties assessed to the company for Mariner East construction to more than $13 million.

One penalty stems from the pipeline company’s horizontal directional drilling activities, which caused drilling mud spills in 16 streams and wetlands in 10 counties in 2018. Drilling mud consists of bentonite clay, which is not toxic but can damage aquatic life. The company’s actions violated the Clean Streams Law and the Dam Safety and Encroachment Act. The penalty assessed for that violation is $240,840.

“PA-DEP is committed to ensuring that Sunoco and other companies are held to the highest standard possible. These actions, which resulted in violations of permits and laws that are meant to protect our waterways, are unacceptable,” PA-DEP Secretary Patrick McDonnell said in a statement. “PA-DEP will maintain the stringent oversight that we have consistently exercised by monitoring Sunoco and taking all steps necessary to ensure that the company complies with its permits and the law.”

The company also violated the Clean Streams Law during 2017 pipeline construction, which led to erosion and sedimentation at a number of waterways in Cumberland County. The company will pay $78,621 to the state and the Cumberland County Conservation District.

Construction on the $2.5 billion Mariner East project began in February 2017, after the Department of Environmental Protection identified hundreds of deficiencies in its water-crossing and earth-moving permits. Since then, the PA-DEP has issued more than 80 violations to the company for polluting wetlands, waterways, and destroying about a dozen private water wells.

“We are happy to have resolved this issue with the PA-DEP as we remain focused on safely completing construction of this important pipeline,” Energy Transfer spokesperson Lisa Coleman said.

The pipeline brings natural gas liquids from eastern Ohio and western Pennsylvania to an export terminal near Philadelphia. The majority of the product shipped through the pipelines will go to Scotland to make plastics. Completion of the third and final pipeline in the project, the Mariner East 2x, is expected by the end of this year.

In the summer of 2017, PA-DEP, along with several environmental groups, agreed to a consent decree with Sunoco after dozens of drilling mud spills led to the pollution of high value wetlands and trout streams, and the loss of drinking water for residents of a Chester County community.

As part of the consent decree, the agency is developing new permit conditions and policy guidelines for future pipeline projects.

>>> About StateImpact Pennsylvania — StateImpact Pennsylvania is a collaboration among WITF, WHYY, WESA, and The Allegheny Front.

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See also:
Criminal Defense Counsel Represents PA-DEP in Mariner East Probe, Susan Phillips, StateImpact Penna., August 30, 2019

The Pennsylvania Department of Environmental Protection has engaged a criminal defense attorney to represent at least one employee with regard to a criminal investigation of the Mariner East pipeline project — a move several environmental attorneys said is unusual and possibly unprecedented for the regulatory agency. Agency says it’s routine to have outside counsel, but several environmental lawyers say they haven’t seen it before.

MVP pipeline has violations and court challenges

From an Article by Laurence Hammack, Roanoke Times, May 14, 2019

Developers of the Mountain Valley Pipeline have agreed to pay a fine of nearly $266,000 for violating environmental regulations in West Virginia.

The agreement, outlined in a consent order from the West Virginia Department of Environmental Protection, marks the first financial penalty for problems with storm water runoff caused by building a 303-mile pipeline that will also cross the New River and Roanoke valleys.

Photographs included in the 179-page document show a “drastic change” in streams since work on the buried pipeline began last winter, said Angie Rosser, executive director of the West Virginia Rivers Coalition. “These are clear-running streams and they have been forever,” Rosser said. “And you look at the photos now and they are just brown.”

Mountain Valley faces similar issues in Virginia. A lawsuit filed in December by the Department of Environmental Quality alleges more than 300 violations of erosion and sediment control measures. Online court records indicate the case is still pending.

In West Virginia, 26 notices of violation filed from April to November of last year were resolved by the consent order.

The agreement, signed May 6 by Robert Cooper, Mountain Valley’s senior vice president for engineering and construction, states the company will pay a fine of $265,972 and submit a plan of corrective action to state regulators.

A public comment period on the agreement runs through June 20.

Most of the violations “were the result of unprecedented rainfall throughout the spring and summer of 2018,” Mountain Valley spokeswoman Natalie Cox wrote in an email.

“MVP appreciates the oversight of the WVDEP and the MVP team will continue to work closely with project inspectors to maintain its high standards of safety and environmental stewardship,” the email said.

The $4.6 billion project is still scheduled for completion by late this year, Cox wrote. However, at least two members of the five-partner venture have said in recent financial reports that a delay is likely, considering legal challenges that led to suspended permits.

Rosser said the fine, which represents well less than 1% of the project’s cost, is unlikely to lead to significant change. “The concern is that paying the fine is cheaper than doing it right in the first place,” she said.

Mountain Valley and other pipelines being built in West Virginia have all encountered the same problems, Rosser said, and it’s becoming apparent that state-approved plans to control erosion are not working.

“It’s a lot of erosion and a lot of sediment that doesn’t belong in our streams,” she said. “Looking at the photos, you just can’t deny that these pipelines affect water quality.”

Critics say the worst pollution will come when crews begin to run the 42-inch diameter pipe through streams and wetlands. Water body crossings have been on hold since October, when the 4th U.S. Circuit Court of Appeals threw out a permit issued by the Army Corps of Engineers.

Mountain Valley hopes to obtain new permits from the Corps later this year.

But the project must also get renewed approval to cross through the Jefferson National Forest — a process that was complicated by a separate opinion from the 4th Circuit that invalidated a U.S. Forest Service approval for the crossing of the Appalachian Trail by a similar project, the Atlantic Coast Pipeline.

About two-thirds of the pipeline, which will transport natural gas from the Marcellus and Utica deposits to a pipeline in Pittsylvania County, is in West Virginia, where problems with construction were first documented by state regulators.

The consent order from West Virginia documents a variety of improper steps taken by Mountain Valley to control erosion. Sediment-laden water often left the construction sites and made its way into nearby streams and rivers, the order states.

Other violations included a failure to clean debris from adjacent public and private roads, a lack of temporary stabilization of areas where construction was dormant for more than 21 days, and no reseeding of denuded areas where vegetation had failed to take root after 30 days.

In a written defense to the lawsuit claiming regulation violations in Virginia, lawyers for the company blamed the problems on “extraordinary, high-intensity storm events and flooding beyond MVP’s control.”

They also wrote that the company would be willing to settle the Virginia case.

Steep terrain also an erosion issue

From an Article by Laurence Hammack, Roanoke Times, February 15, 2019

The Mountain Valley Pipeline is under criminal investigation into possible violations of the Clean Water Act and other federal laws, one of the companies building the project has confirmed.

EQM Midstream Partners, the lead company in the joint venture, made the disclosure in an annual report filed Thursday with the U.S. Securities and Exchange Commission. EQM Midstream was formerly EQT Midstream.

Since construction of the buried natural gas pipeline through Southwest Virginia started last year, crews have repeatedly run afoul of regulations meant to keep muddy runoff from contaminating nearby streams and rivers.

Although Mountain Valley has been named in enforcement actions brought by the Virginia Department of Environmental Quality, and in a lawsuit filed by Attorney General Mark Herring, this week’s filing is the first confirmation of a criminal investigation.

On January 7th, EQM received a letter from the U.S. attorney’s office in Roanoke stating that it and the Environmental Protection Agency were looking into criminal and civil violations related to pipeline construction, according to the SEC filing.

About a month later, a grand jury subpoena was issued “requesting certain documents related to the MVP from August 1, 2018 to the present,” EQM reported in the filing.

“The MVP Joint Venture is complying with the letter and subpoena but cannot predict whether any action will ultimately be brought by the U.S. Attorney’s Office or what the outcome of such an action would be,” it said.

Last month, two attorneys told The Roanoke Times that they had asked the EPA in November to investigate what they called “a substantial body of evidence” gathered by Preserve Bent Mountain, an organization they represent.

Photographs and other documentation from construction sites indicate that work in streams and wetlands continued well past Oct. 5, 2018, when a permit for such activity was suspended by the U.S. Army Corps of Engineers, Charlie Williams and Tom Bondurant said at the time. It was not clear Friday if their request prompted the investigation mentioned by EQM in its SEC filing.

Chainsaw crews began cutting trees in February 2018, clearing a 125-foot wide swath for the 303-mile pipeline through West Virginia and Southwest Virginia. By spring, heavy equipment had moved in to grade land along steep mountainsides and dig trenches for the 42-inch diameter steel pipe.

Herring’s lawsuit, filed on behalf of VA-DEQ and the State Water Control Board, alleges more than 300 violations of erosion and sediment control measures, beginning as early as May 2018. The criminal probe appears to be focused on events that began later in what is expected to be a two-year construction period for the $4.6 billion project.

In their January letter to Mountain Valley, federal prosecutors directed the five companies that comprise the joint venture — along with their contractors, suppliers and other entities involved with construction — to preserve any relevant documents dating back to September 1st. The grand jury subpoena, which came a month later, was for documents going back to August 1st.

Environmental groups and other pipeline opponents were saying last summer that the worst environmental damage was yet to come, when Mountain Valley would begin blasting bedrock and digging trenches along the bottoms of streams to bury the pipe.

A lawsuit filed by the Sierra Club and others challenged a permit issued by the Army Corps of Engineers that allowed stream crossings in West Virginia. The 4th U.S. Circuit Court of Appeals vacated the permit October 2, 2018. Based on that ruling, a second Army Corps permit that covered Southwest Virginia was suspended three days later.

If Mountain Valley continued to work in streams and wetlands after losing its authorization from the Army Corps, that could constitute a criminal violation, Bondurant, a former federal prosecutor, said earlier.

Publicly traded companies are required by law to report any legal proceedings that might affect their operations to the SEC, which is responsible for protecting investors and maintaining public trust in U.S. markets.

In past filings, EQM has documented a number of lawsuits, most of them filed by environmental groups against regulatory agencies that granted permits or certifications to Mountain Valley.Thursday’s filing marked the first time a criminal investigation was mentioned.

On the same day, executives with EQM held a teleconference to discuss 2018 year-end results with financial analysts. They talked about the loss of several permits due to legal challenges, but did not bring up the criminal investigation.

Despite all the regulatory and legal difficulties to date, company officials said the project is still on schedule to be completed by the end of the year, when it will begin to transport natural gas to customers in the Mid-Atlantic and Southeastern regions of the country.

Sediment flow penetrates barrier from stormwater

From an Article by Kate Mishkin, Charleston Gazette, November 8, 2018

As battles over two major natural gas pipelines play out in court, state regulators have continued to cite the Atlantic Coast Pipeline and Mountain Valley Pipeline for environmental problems.

The Mountain Valley Pipeline has received 19 violation notices from the West Virginia Department of Environmental Protection for failing to comply with the project’s West Virginia/National Pollutant Discharge Elimination System general water pollution control permit. The violation notices date back to early April, and the most recent was issued in early October, according to the DEP’s database.

The violations happened in several West Virginia counties, including Greenbrier, Harrison and Doddridge. The pipeline is approved to span 303 miles from Wetzel County, West Virginia, into Pittsylvania County, Virginia.

In many cases, a DEP inspector visited the site of construction and warned the site operator to take measures to comply with its permit. Then, the inspector wrote up a Notice of Violation, telling developers to provide a written response to the violation within 20 days. The violations don’t come with a monetary penalty.

In the most recent case, an inspector followed up on a citizen complaint in Monroe County and found sediment was flowing off the right-of-way. The inspector, Jason Liddle, issued a Notice of Violation, citing three sections of the permit the pipeline builders had violated. Liddle also wrote that developers had violated state legislative rules governing water quality standards by letting “distinctly visible settleable solids in pond and stream.” Photos that accompany the Notice of Violation show muddy water and sediment deposits.

The Atlantic Coast Pipeline, which would also start in northern West Virginia and span 600 miles into North Carolina, has been cited twice for problems in Upshur and Randolph counties. Neither pipeline company responded to inquiries about the violations.

These are the kinds of problems residents feared from the very beginning, said Joan Walker, senior campaign representative for the Sierra Club’s Beyond Dirty Fuels campaign.

“Absolutely, we saw it coming,” she said. “There’s no safe way to build these fracked gas pipelines in any terrain, especially in mountainous terrain in West Virginia and Virginia. This is not a surprise, this is what we warned about in hundreds and hundreds of public comments to FERC [Federal Energy Regulatory Commission], this is what we feared would happen and sadly it’s playing out that way.”

Both pipelines are part of a rush to tap into the region’s Marcellus Shale formation. And though they’re being built by different companies, they’ve followed similar patterns and fielded similar challenges in court.

Over the summer, the 4th Circuit Court of Appeals ruled that the U.S. Forest Service and Bureau of Land Management has skirted environmental rules when approving work on the Mountain Valley Pipeline. One week later, FERC issued a stop work order.

Then, FERC stopped the Atlantic Coast Pipeline, citing the 4th Circuit’s order that said the U.S. Fish and Wildlife Service and National Park Service had also sidestepped environmental rules.

In September, a panel of judges on the 4th Circuit heard four back-to-back cases, half about the Mountain Valley Pipeline and half about the Atlantic Coast Pipeline. In each case, environmental lawyers brought up a similar theme: the pipelines were rushed. In one case, lawyers said the Mountain Valley Pipeline was violating its Clean Water Act permit issued by the U.S. Army Corps of Engineers,and the federal appeals court subsequently vacated the permit.

Wednesday afternoon, the same judges ordered a stay to the Atlantic Coast Pipeline’s water-crossing permit, too. “That’s why everything is stopping and starting is because the processes were flawed, the permits had such big holes and gaps in them,” Walker said.

In the case of both pipelines, citizens have submitted complaints advising the DEP of spills along the pipelines’ paths. “Hundreds more [have] been reported by community watchdog folks, so there’d probably be a lot more if the DEP had enough staff to check on those accusations,” Walker said.

Mariner East 2 parallels Mariner East from OH & WV to the Delaware River

From an Article by Bill Rettew, Daily Local News, West Chester, PA, January 2, 2018

SILVER SPRING TOWNSHIP >> Sunoco is again feeling the heat after the PA Department of Environmental Protection accused the pipeline builder of drilling without authorization. The 350-mile Sunoco Mariner East 2 pipeline is now under construction.

The PA-DEP alleges that Sunoco impacted two fresh water wells on December 18, about 10 miles west of Harrisburg, when utilizing horizontal directional drilling, without authorization. The PA-DEP maintains that the approved method of pipeline installation at that location was by open trench.

The PA-DEP also alleges that a November 17 inspection in Berks County also revealed unauthorized drilling.

Sediment first showed up in a West Whiteland Township couple’s well water in July. Sunoco later agreed to hook up about 30 residents to public water and pay each homeowner $60,000.

Sunoco was also rebuked for likely causing a six-foot backyard sinkhole in West Whiteland and not reporting it in a timely fashion.

Kathryn Urbanowicz, staff attorney with Clean Air Council, fired off a letter to associates. “For this secret, unauthorized drilling to happen even once is outrageous,” she wrote. “For it to happen twice – that we are aware of — makes an utter mockery of PA-DEP and all the calls of the public for increased safety and transparency.” Also: “It is painfully clear the PA-DEP’s enforcement efforts are not consequential enough for Sunoco to deem it worthwhile to follow the law.”

The PA-DEP alleges that the permittee (Sunoco) was not authorized to use horizontal directional drilling at the central Pennsylvania site.

The December 22 notice of violation reads: “A request to modify the permit must be submitted by the permittee and approved by PA-DEP before the permittee may commence any construction or earth disturbance activities that are not included in the information submitted in support of the application.”

Plans call for the Sunoco Mariner East 2 pipeline to stretch from Marcellus Shale deposits in West Virginia, Pennsylvania and Ohio, to the former Sunoco Refinery in Marcus Hook, Delaware County.

Jeff Shields, Sunoco Pipeline Communication Manager, released the following statement Tuesday:

“The Clean Air Council is making statements that are simply false. We have made every effort in the construction of this more than 300-mile project to respect and follow the stringent conditions of our environmental permits.

“In instances where a different construction method was used other than what was outlined in the permit, the method chosen had a lesser environmental impact. We are working with the PA-DEP to address any construction issues and to ensure that any changes to permitted activities are approved in advance.

“Regarding the Clean Air Council’s water claims, there have been no wells impacted in Cumberland County in the way they suggest. We did have some residents complain of a drop in water levels, which we are investigating. Finally, nothing we do in building this important infrastructure project is ‘secret.’

“All our construction is subject to extensive and unprecedented agency oversight and reporting requirements, which are published by the PA-DEP, making Mariner East 2 not only the largest construction project to date in Pennsylvania, but also the most transparent.”

Urbanowicz said during a Tuesday phone interview that the violations were not accidents. “It seems like Sunoco is making a decision to go against the environmental protections in place,” she said. “They’re undermining the whole process and the public’s ability to protect itself.”

The PA-DEP required Sunoco to submit daily construction logs, including logs, covering the time when drilling started. Those logs should document each day of activity, start and stop times for drilling, stage of drilling process, approximate progress, drill pressure, depth of cover, and any loss of pressure or drilling fluids.

Sunoco was also reminded that it had to offer well water users located within 450 feet of all horizontal directional drilling sites free water sampling, before, during and after the start of drilling.

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State halts Mariner East II pipeline construction over environmental violations

Article by Jacob Tierney, Pittsburgh Tribune Review, January 3, 2017

The Pennsylvania Department of Environmental Protection has ordered Sunoco Logistics LP to stop work on the 306-mile, $2.5 billion Mariner East II pipeline.

Sunoco violated its permits, using unauthorized drilling methods that leaked nontoxic drilling fluid into trout streams and water wells across the state, according to the DEP.

The state discovered Sunoco was using unauthorized drilling methods after learning of a drilling fluid leak into a Berks County creek in November, according to the DEP order.

Over the next few weeks, the state discovered numerous other sites in Berks, Blair, Cumberland, Dauphin, Huntingdon, Perry and Washington counties where unauthorized drilling methods were being used, often resulting in drill fluid leaking into nearby bodies of water, several of which were designated trout streams, according to the DEP.

Sunoco’s permits for the affected areas called for digging a trench to install the pipeline. Instead the company used horizontal directional drilling — which takes place almost entirely underground.

“They are bound by the permit conditions, and in this case they violated them by using different techniques,” said DEP spokesman Neil Shader. “Our inspectors have to be aware of what is going where when they go out to do spot checks and other inspections.”

The DEP has recorded more than 100 “inadvertent returns” — leaks of drilling fluid and other liquids — related to the construction of the pipeline since May. These range from tiny spills of less than a pint to 160,000 gallons leaked into a Cumberland County wetland. There were 20 spills in Westmoreland County, mostly around Loyalhanna Lake.

Under the DEP order, Sunoco must immediately stop all work previously authorized by state DEP permits, which cover all 17 of the Pennsylvania counties spanned by the pipeline, until a slew of conditions are met.

According to the order, Sunoco has 30 days to submit a full report of any trout streams crossed by the pipeline, along with a report of any other sites that use unpermitted drilling techniques, a list of all drilling contractors and subcontractors associated with the project, an explanation of how and why the permits were violated and a plan to prevent further violations.

Sunoco must also replace or restore private wells in Silver Spring Township, Cumberland County, where property owners reported cloudy water as a result of unauthorized drilling, according to the DEP.

“This project remains critically important for our commonwealth. Sunoco and DEP should work expeditiously to resolve this matter so safe construction can resume and this vital project can get back on track,” Kurt Knaus, spokesman for the Pennsylvania Energy Infrastructure Alliance, said in a statement.

Municipal leaders in Westmoreland County said as far as they know local drilling for the pipeline is already done, or nearly so.

“What I see through the township here is they’ve got some dressing up to do, but they’re pretty much done,” said Salem Township Supervisor Robert Zundel.

A December newsletter from Sunoco said work on the project was 91 percent done, with work in Washington, Allegheny and Westmoreland counties 84 percent complete.

A judge previously halted work on the project in July when Sunoco was accused of violating a 2015 settlement with West Goshen Township, but work resumed the next month when a settlement was reached.

The 20- and 16-inch pipelines will be able to carry 275,000 barrels of liquid natural gas a day and cross 270 properties over 36 miles in Westmoreland County. The new pipelines will run parallel to the existing Mariner East I line.

Drilling mud spill on Rover Pipeline (See Video)

Ohio EPA orders Rover pipeline builder to pay $431,000 for violations

From an Article by Marion Renault, The Columbus Dispatch, May 8, 2017

The Ohio Environmental Protection Agency has ordered Energy Transfer, the company building the Rover natural gas distribution pipeline, to pay $431,000 for water and air pollution violations at various locations across the state.

In its order issued Friday, OEPA also instructed Energy Transfer to submit plans to address potential future releases and restore impacted wetlands along the $4.2 billion underground pipeline route, which stretches from Washington County in southeastern Ohio to Defiance County in the northwest.

Work on the pipeline began in mid-February, and state officials say a total of 18 incidents involving mud spills from drilling, stormwater pollution and open burning at Rover pipeline construction sites have been reported between late March and Monday to the agency.

That includes a 200-gallon release of mud Monday in Harrison County. Other Rover pipeline incidents include a spill that impacted one village’s public water system and another that smothered a protected wetland with several million gallons of bentonite mud, a natural clay which is used as a drilling lubricant.

“All told, our frustration is really high. We don’t think they’re taking Ohio seriously,” said OEPA Director Craig Butler. “Normally when we have … a series of events like this, companies respond with a whole lot of contrition and whole lot of commitment. We haven’t seen that. It’s pretty shocking.”

Alexis Daniel, an Energy Transfer spokeswoman, said Monday in an email statement that the “small number of inadvertent releases of ‘drilling mud’ during horizontal drilling in Ohio … is not an unusual occurrence when executing directional drilling operations and is all permitted activity by (the Federal Energy Regulatory Commission).

“We do not believe that there will be any impact to the environment,” Daniel said, adding that the company — the same one behind the controversial Dakota Access pipeline — is managing the Rover pipeline situation in accordance with its federal- and state-approved contingency plan.

After a pair of wetlands spills in April, Energy Transfer still planned to finish the Rover project and begin operating the pipeline this year.

“I believe and have told them that they’re rushing and building so quickly that they’re not paying attention to best management practice,” said Butler. “With oil and gas expanding in Ohio, we’ve seen a lot of pipeline activity. We’re not unaccustomed to seeing an occasional release. “This is pretty systemic — that’s when the alarm bells go off in my head.”

Butler said the OEPA has referred the matter to the FERC for analysis and is exploring other legal options.

“It’s very concerning. These violations are a swath across our entire state,” said Cheryl Johncox, a Sierra Club organizer. “We have no faith in their ability to operate a pipeline safely.”

OEPA inspectors across the state will continue to assist with monitoring, response and cleanup, Butler said.

But Sierra Club and other environmental groups are calling for the state to go further and seek an immediate injunction to shut down the project. Either this company is completely irresponsible or they just don’t care,” said Johncox. “We want the construction halted.”

Butler said the state “is limited in that we cannot ask them to shut down their operations. It’s a story left unfinished.

With $24 Billion Already Invested in the U. S., and Losses of $2 Billion, Royal Dutch Shell is Shuffling & Studying

From an Article by Scott Detrow / StateImpact — Pennsylvania / October 7, 2013

Shell’s outgoing CEO Peter Voser tells the Financial Times of London that he regrets the company’s large investment into U.S. shale.

In an exit interview with the Financial Times, outgoing Royal Dutch Shell CEO Peter Voser says the company has yet to profit from its $24 billion investment into “unconventional” shale oil and gas in the United States.

Voser’s comments come just a little more than a week after Shell announced it would be selling its stake in Texas’ Eagle Ford Shale and after a $2 billion write down on its shale assets. Voser told the Financial Times that company was disappointed by the results of exploration in U.S. shale beds.

This may not be good news for Pennsylvania where Shell has been actively drilling in Tioga County and has proposed building a gas processing plant called an ethane cracker in Beaver County. In August, the company announced it was going out to bid for suppliers as part of an ongoing site evaluation process. But in an e-mail to StateImpact Pennsylvania, a Shell spokeswoman downplayed the news as merely a project update. The deadline for bids was on Friday, October 4 and the company is not expected to make a final decision until next year.

Governor Tom Corbett has high hopes for the project and is doing what he can to convince Shell to seal the deal by pushing for large tax breaks and touting the thousands of jobs it could bring to western Pennsylvania.

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Know Your Drillers – Shell (Royal Dutch Shell)

 From “Frack University” via Occupy the Hollers, October 18. 2013

Shell has a 5:6 violation-to-well ratio. Out of 603 wells drilled, we found that Shell subsidiaries, East Resources Inc., East Resources Mgmt. LLC and SWEPI LP, were cited for 494 violations by PA DEP.

90 percent of Shell’s violations were environmental in nature. Out of 494 violations, we identified 443 that were environmental in nature, which have, or are likely to cause harm to the environment.

Shell has been cited for a casing failure rate of about one percent of wells for a total of six citations. It is important to note that well casings are meant to protect aquifers from contamination by chemicals used in the hydraulic fracturing, or “fracking” , process. 

Shell was cited violations 45 times for Improper Construction of Waste Impoundments, 37 times for Faulty Pollution Prevention Practices, 25 times for Discharge of Industrial Waste. This presents imminent danger to surface and ground water supplies.