Protection of Freshwater Aquifers
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January 10, 2012
Attn: dSGEIS Comments NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233-6510.
RE: Aquifer & Karst Protection Considerations in Schoharie and Other New York State Counties (Comments on the NYS High-Volume Hydraulic Fracturing 2011 revised draft SGEIS)
To whom it may concern:
Executive Summary
This report is provided on behalf of the Schoharie Valley Watch. It entails important geologic, hydrologic and hydrogeologic considerations that have not been adequately, and often at all, addressed in the revised draft SGEIS. After review of the NYS High-Volume Hydraulic Fracturing 2011 revised draft SGEIS we find that many significant and substantive issues have not been addressed. These issues are addressed both within the body of this report and within all the HydroQuest documents and figures hereby fully incorporated by reference that are provided at the document web link: http://hydroquest.com/Hydrofracking/. We concur with Congressman Hinchey’s determination that shale gas drilling has been proliferating rapidly across the country and, unfortunately, too many states have not taken the necessary steps to protect our communities, water resources, air quality, and public health. Furthermore, we agree with him that New York must not follow this path, and we urge NYSDEC to withdraw the revised draft SGEIS and restart the process to ensure that the end product fully addresses the scope of the challenges hydraulic fracturing presents.
All of the issues addressed in this report need to be addressed in newly revised SGEIS regulations which, once complete, should undergo full public review and comment. It is important to point out that while these issues are raised using Schoharie County as an example, they apply broadly throughout New York State. A number of these key issues are highlighted in numbered bullet form below:
1.0) Tracers must be required. The costly burden of legal, chemical, and hydrogeologic proof incumbent upon adversely impacted homeowners is onerous and overwhelming. This situation must be remedied BEFORE any additional gas drilling is permitted in NYS. This can easily be done by simply requiring the use of gas company tracers in all fluids. Non-naturally occurring tracers must be added to all gas field drilling and hydraulic fracturing fluids so that contaminant excursions can reliably and immediately
1 be assigned to gas companies, or not, without extensive cost and litigation to homeowners. This measure will afford homeowners the environmental protection the NYSDEC is charged with providing and will provide assurance of rapid connection to alternate water supplies by gas companies should their actions result in groundwater contamination. There is absolutely no reason to not fully institute this mandatory regulation immediately. Tracer selection, concentrations and required detection limits should be determined by an independent panel of tracer experts. Failure to adopt this recommended regulation essentially leaves adversely impacted homeowners with no financially viable and time-effective recourse and, thus, should provide scientific and legal cause to discard the revised draft SGEIS entirely;
2.0) Permanent replacement water supplies must be mandated. NYS gas drilling regulations need to explicitly require gas companies that have adversely impacted homeowner groundwater supplies to develop permanent, alternate, water supplies by establishing and maintaining new water sources or extending existing water lines. Because groundwater flow rates are often slow and the multitude of toxic and carcinogenic chemicals used by gas companies, many of which are not known and not tested for, individual homeowner filters should NOT be accepted as “replaced” or “restored” water supplies. Aquifer purchase via homeowner buyouts, non-disclosure agreements, or other means of not replacing contaminated water supplies (i.e., the water resources of New York State) must be explicitly not allowed under revised regulations. Failure to not incorporate such legally-binding language in revised regulations should provide legal cause to discard the revised draft SGEIS entirely;
3.0) No gas wells should be permitted with existing low durability sealant materials. The draft regulations should be revised to require the use of well sealant materials that have a documented durability in line with the reasonably anticipated life of aquifers, a time period on the order of one million years. Existing sealant materials (i.e., cement and steel), under the best of conditions, may maintain their integrity for less than 100 years, often far less. The concept of using multiple cement and casing barriers to “protect” freshwater aquifers fails to acknowledge that the well-documented failure mechanisms of cement sheaths and casing material will occur regardless of the number of barriers subject to similar failure mechanisms. Failure of the SGEIS to address this KEY flaw in gas field technology and the ensuing certain contamination of NYS aquifers should provide legal cause to discard the revised draft SGEIS entirely;
4.0) Long-term cement sheath integrity from repeated seismic events must be evaluated. The draft regulations should be revised to include a more rigorous assessment of potential loss of integrity of gas well cement sheath sealant material as a result of ground shaking associated with earthquakes. Cracking of cement sheaths may open upward contaminant transport pathways within wellbores to overlying freshwater aquifers. At a minimum, seismic risk assessments should examine seismic risk over a 10,000 year period. Data and ten seismic probability analyses presented in this report indicate that risk of cracking and failure of cement sheaths due to seismic activities is great and should provide scientific justification to not permit gas wells in seismically active portions of New York State;
2 5.0) All New York State Aquifers should be Afforded Equal Protection. The revised draft SGEIS gas drilling regulations seek to provide rationale for providing greater protection for NYC and Syracuse watersheds, as well as for high-yielding primary aquifers. The extra protection sought for the New York City watershed, for example, appears misplaced because the water supply system has great built in redundancy in the form of multiple reservoir back-ups and does not directly tap groundwater wells typically used by many homeowners outside NYC’s watershed areas. Because homeowners outside of NYC and Syracuse have NO backup or alternate water supply options available, they should be given greater protection priority. If NYSDEC truly believes gas drilling poses no significant risk to water supplies this hierarchy protection priority should be reversed. Furthermore, the greater groundwater protection sought for primary aquifers vs. other portions of watersheds fails to adequately take into account the simple hydrogeologic fact that the surrounding watershed areas up-gradient of primary aquifers all drain down- gradient to these primary aquifers. Thus, the draft regulations only forestall and redirect natural groundwater flow, and any gas field contaminant flow, to primary aquifers from outside their mapped boundaries into them vs. directly from within their boundary areas. Other high-yielding aquifers (e.g., principal aquifers) are afforded less stringent additional protection (e.g., p. 21 SGEIS). Simply put, if gas drilling methods are indeed safe – ALL New York State watersheds and aquifers should be treated equally. The draft regulations should be revised to reflect the no risk scenarios claimed in the SGEIS and, as such, afford no New York State watershed or aquifer area anything other than equal regulatory protection;
6.0) Gas drilling in karst terrains should be banned due to high environmental risk. The SGEIS does not address gas drilling in karst terrains and the negative impacts to tourism and the regional economy. The draft regulations fail to address caves, solution conduits, and karst terrains and their extreme vulnerability to contamination, as well as the environmental risk to cave fauna, including the endangered Indiana bat that is protected under the Endangered Species Act. Karst terrains should be exempted from all gas drilling activities. This serious omission needs to be corrected. Once revised, a newly revised SGEIS should be reissued for full public review and comment;
7.0) Gas drilling should not occur within 500-year floodplains. The draft regulations should be amended to preclude permitting any gas wells within the 500-year floodplain of rivers and other waterways. The flood return analysis provided in this report for the Schoharie Creek demonstrates that 500-year floods (like that associated with Hurricane Irene) may well occur again in the future, possibly the near future. Thus, taking the risk of dispersing hundreds of toxic gas field contaminants over expansive floodplains, yards, playgrounds, etc. and into New York State’s waterways is not wise. The SGEIS should be revised to include 500-year floodplain maps where gas wells will not be permitted;
8.0) Long-term contamination of high-yielding valley bottom aquifers must be addressed. The draft regulations do not take into account slow groundwater and contaminant flow rates. Hydrogeologically, contaminant excursions from far up-gradient watershed regions will eventually degrade high-yielding valley bottom aquifers. There is a reasonably foreseeable risk, based on credible scientific evidence, that contaminant
3 excursions at any watershed location will ultimately increase the toxic contaminant load incident to significant aquifers (i.e., primary, principal and other high-yielding unconfined aquifers). Potentially chronic low-level exposure to gas field chemicals should be addressed in a newly revised SGEIS, with input from toxicologists;
9.0) Gas well setback distances need to be based on empirical data, not scientifically unsupported numbers. Setback distances provided in the SGEIS lack any scientifically based support. The SGEIS needs to be revised to provide rigorous, scientific, rationale for all setback distances provided. This report provides scientific justification for a minimum setback distance of 2,100 feet from waterways, wetlands, and wells. Until additional empirical data is provided for lower setback distances, there is no basis to use lower setback distance values. The 500-foot setback distance suggested from private wells in the SGEIS, for example, should be discarded as it is well within documented fracture lengths. Rigorous scientific justification of setback distances must be provided;
10.0) Hydraulic fracking fluids should be designated as point source discharges to aquifers. Chemical additives in drilling mud and hydrofracking fluid that are forced into geologic formations via gas wells are NOT, but should be, officially designated as point source discharges. Some of these chemicals will migrate into freshwater aquifers, homeowner water supplies and surface waters;
11.0) Gas wells must be plugged throughout the entire wellbore. All abandoned, unplugged, poorly-plugged, and soon to be plugged wells must be required to be plugged throughout the entire wellbore from the ground surface to the lowest production zone. Anything less than this is irresponsible and will result in contamination of freshwater aquifers even faster than the short time required for well sealant failure to occur;
12.0) Existing maximum contaminant levels (MCLs) are not sufficient and must be amended to reflect all gas field contaminants. The original MCLs for drinking water were not formulated with consideration given to massive underground injection of millions of gallons of toxic chemicals throughout most of New York State. Therefore adequate drinking water protection cannot be assumed based solely on dated and limited MCLs. The gas drilling regulations in New York State should not be contemplated as complete until such time as toxicologists have fully reviewed all gas field chemicals and worked with State Health Department experts to revise and upgrade MCL drinking water standards; and
13.0 Preliminary gas well hydrologic/aquifer testing should be mandated. The revised draft SGEIS regulations should require preliminary pump testing to confirm that NO direct hydraulic connection is present along fracture pathways between planned gas wells and homeowner wells within a radial distance of at least 2,100 feet. A test procedure is recommended here to reduce rapid homeowner well contamination when gas well sealant materials fail. This readily adopted procedure should be incorporated into revised regulations.
4 Many of the topics and issues touched on briefly here in this comment report are detailed at length in a number of documents, fact sheets, testimony, legal documents and graphics that may be viewed and downloaded at: http://hydroquest.com/Hydrofracking/. All this material and the detailed issues and supporting documentation present on this web page are hereby incorporated by reference into this report. The SGEIS should be revised to fully address all the assorted expert fracking related topic areas in these expert reports (e.g., life of aquifers, sealant durability, aquifer risk, seismic risk). Further discussion of the key issues put forth above follows:
1.0 Tracer Use should be Mandated Immediately
Schoharie County and other New York State residents who believe their groundwater has been adversely impacted from gas well contaminants will be faced with an extremely difficult, expensive, and time consuming effort if they hope to prove gas company responsibility. This has been shown to be true elsewhere. The revised draft SGEIS regulations do NOT address this critical issue that WILL occur. This is a daunting effort requiring expensive chemical testing, experts in hydrology, chemistry, toxicology, lawyers and others. If this isn’t enough to deter homeowner attempts to get clean, potable, water they may well have to contend with efforts of gas companies to discredit them and face countless arguments that they themselves are responsible for contaminants detected in their well water. And, at the end of the day, should adversely impacted homeowners prevail in court, there is no way to restore contaminated aquifer water that will almost certainly contain low level contaminants that vary in concentration through time. Toxicologists are concerned about chronic exposure to multiple known, as well as unknown and untested contaminants.
In recognition of this and as an act of good faith on the part of NYSDEC regulators, consideration should be given to requiring tracer use now in all new gas company drilling. Tracer selection should be conducted by an independent group of tracer experts, with careful consideration of tracers that cannot be claimed to be of homeowner origin and of concentrations that allow for natural dilution and extremely low-level detection. McDaniel et al. (2007 and 2009), for example, provide discussion of non-radioactive and radioactive tracers that have been successfully used for assessing fracture geometry. Whether radioactive or other tracers are ultimately selected, it is clear that the technology exists and can be modified appropriately.
The revised draft SGEIS gas drilling regulations do not address and do not require gas companies to use company-specific tracers in their frack and drilling fluids (at concentrations that allow appropriately for dilution by fracking/drilling fluids and groundwater). As a result, adversely impacted homeowners and State regulators have no quick and definitive means of ascertaining whether the gas industry is responsible for contaminant excursions (see HydroQuest DRBC Draft Regulation Comment Report 4-09-11, pages 9, 38-39). A most unfortunate impact of this is the pitting of former neighbors and friends against each other, as some side with gas companies, some accept buyouts, and others advance litigation. Communities are being systematically destroyed. The addition of company specific tracers is cheap compared to well development and production costs. Tracer additions would provide a much needed checks and
5 balance type approach to claims of gas company excursions. On the one hand, tracers would readily allow gas companies to show they are not behind gas field contaminant issues that are not of their making, while on the other hand it would remove the onus of proof from homeowners actually adversely impacted. Importantly, there is no reason whatsoever that ALL future gas well work should not require tracer additions and monitoring effectively immediately, even before gas drilling regulations are promulgated.
Gas and oil drilling in New York State should not be permitted at all without the addition of company specific tracers in all drilling and fracking fluids. There is NO reason whatsoever to not require non-naturally occurring tracer additions to ALL gas company fluids used downhole. Failure to modify the draft SGEIS regulations to require gas company tracer additions should be just scientific and legal cause to retract the entire SGEIS and ban gas drilling throughout New York State and elsewhere. It is imperative that there is a valid means to readily identify responsible parties, should this be needed.
1.1 Contaminant Transport Pathways which Tracers may help Identify
The schematic figure below illustrates assorted contaminant transport pathways available in gas fields that may bring natural gas and other contaminants in contact with New York State’s freshwater aquifers. Statements have been made that conclude that methane contamination is naturally occurring in assorted homeowner wells tested and that it originates from gas-rich shales stratigraphically higher than the Marcellus. The Dec. 5, 2011 paper by Molofsky, Connor, and Farhat (GSI Environmental Inc.) and Wylie, Jr. and Wagner (Cabot Oil & Gas Corp.) that asserts that natural gas in homeowner wells is generally thermogenic, ubiquitous, and from shallow gas- rich geologic formations must be carefully addressed. Even if the analysis provided is correct, it is highly likely that failed gas well boreholes and cement sheaths provide vertical vectors for the release of shallow gases to fractured bedrock aquifers and homeowner wells that were often not present prior to gas well construction. In essence, failed borehole sealants almost certainly serve to integrate and interconnect gas-rich fractures with fracture sets present in freshwater aquifers. Jacobi’s mapping of fractures using soil gas analyses provides conclusive evidence that pre- existing fracture gas pathways are available. A newly revised SGEIS should address the routes and evidence for the interconnection of boreholes and fractures to homeowner wells, ponds, streams, rivers and the land surface as illustrated below:
6 1.2 Additional Tracer and Flow Path Discussion
Tracer addition to all drilling and frack related fluids will provide a means to document many of the numerous contaminant transport pathways illustrated above. After gas exploitation ceases (or where an inward hydraulic gradient is no longer maintained when pumping is conducted) the potential for upward and outward contaminant transport significantly increases. Poor or failing production well construction (e.g., poor grouting, cement cracking, corroded casing) may provide vertical pathways for contaminant excursions from deep shale beds upward into freshwater aquifers. While these cement failure mechanisms have been thoroughly documented, increased well construction will also increase the number of failed wells and resultant contaminant migration. Furthermore, sloppy frack fluid mixing and operations at well sites has
7 undoubtedly contaminated freshwater aquifers, with contaminant plumes moving toward homeowner wells and streams. This has not been adequately investigated and almost certainly has occurred where numerous gas wells are constructed elevationally higher than homeowner wells. Gas field contaminant excursions (whether above or below ground), like other contaminant sites, are not being treated as outwardly expanding contaminant plumes that warrant expensive, full-scale, hydrogeologic characterization, groundwater clean-up, and remedial action. Hydrogeologically, this is short-sighted and virtually guarantees degradation of both surface and groundwater resources. The draft regulations need to be modified to reflect characterization and cleanup of all the toxic chemicals present and moving within the groundwater environment.
The revised draft SGEIS regulations do not adequately address subsurface geologic and hydrogeologic factors that control groundwater flow and contaminant movement. As such, the regulations do NOT recognize that contaminant dispersal to down gradient water resources may be very slow along some vectors (e.g., bedding planes in homogeneous bedrock) and may be very rapid along others (joints and faults). As a result, seemingly distant down valley receptors (e.g., river valley aquifers and streams) toward which frack fluids migrate may not be adversely impacted for many decades or longer, while homeowner wells hydraulically connected to the same fracture set as gas wells may be adversely impacted in hours, days or longer with varying chemical concentrations. For these reasons, it is not prudent based on short-term testing of homeowner water quality, especially testing that is not inclusive of all of the many toxic hydrofracking chemicals, to declare that water previously shown to have contaminants near or above MCL limits as being potable. In a fracture flow situation, rapid fluid transmission along bedrock fractures may greatly exceed slower natural flow conditions as a result of homeowner water pumping (i.e., which artificially increases the hydraulic gradient), episodic increases to pressure from hydrofracking, and deep pressures released upward via fractures and failed cement sheaths. These vectors of contaminant transport help explain the transport of both frack chemicals and deep naturally-occurring contaminants, including upward migration of highly saline waters. Vast groundwater monitoring networks would be required to adequately characterize both slow and fast-moving contaminants as they degrade freshwater resources throughout the New York State. If an elaborate basin-wide well monitoring network were to be required in the gas drilling regulations, it would be too late and impossible to clean-up and restore groundwater resources as the magnitude of contamination was realized through time. In this respect, the lack of solid science behind the regulations underscores the water quality risk to current and future water users. The failure of the draft regulations to comprehensively address the hydrogeologic flow dynamics operating throughout the gas fields of New York State, as related to short and long-term contaminant risk, provides justification for a fully revised environmental impact statement. Again, requiring tracer additions to all drilling and fracking fluids would greatly improve our ability to document contaminant transport pathways.
1.2 Provision for Shut Down of Well Field Operations and Tracers
The draft regulations do not provide thresholds or a rigorous means to force the immediate shut down of ALL gas field well operations when homeowner wells are being actively impacted, inclusive of stopping ongoing gas exploitation in active well fields with existing contaminant
8 problems. The draft regulations do NOT have adequate recognition of hydrogeologic pathways and obvious signs of open groundwater and fracture flow paths that may signal ongoing UNCONTROLLED contaminant excursions from gas wells to homeowner wells and surface water. Examples may include the presence of soapy surfactant-appearing chemicals in homeowner wells, prolonged discoloration of formerly clear water, notable changes in water quality before and after gas well construction, notable change in the ionic concentration of groundwater compared to pre-gas well conditions, variable or fluctuating concentrations of chemicals at levels significantly above background, notable changes in the smell of groundwater before and after gas well construction, elevated/increased methane concentrations at homeowner wellheads, notable changes in well water levels before and after gas well construction, documented new medical problems, and natural gas bubbling in waterways, water bodies, reservoirs, wetlands, and springs. Failure to recognize such obvious signs of compromised hydrogeologic settings is likely to result erroneous determinations that groundwater is safe to drink, thus potentially placing the health and safety of homeowners in great jeopardy. In situations such as this, the burden of proving innocence should be shouldered by the gas companies, not by potentially adversely impacted homeowners. The regulations must be amended to protect the health and safety of homeowners without requiring them to conduct the expensive chemical testing required by experts and lawyers. It is for this reason that tracer addition to all gas company fluids must be mandated. In addition, regular testing of homeowner wells, springs, and other hydrologic features that may become adversely impacted should also be mandated by NYSDEC gas drilling regulations.
2.0) NYS Gas Drilling Regulations Must Preclude Aquifer Purchase
The revised draft SGEIS does not address the actual in-the-field dynamics that are occurring and ongoing between adversely impacted homeowners, gas company representatives, attorneys, and regulators. The expensive and daunting process briefly discussed above sometimes ends in gas company buyouts of homeowners, the signing of non-disclosure agreements, settlements, or homeowner failure to obtain any remedy. While such agreements may be in the best interest of adversely impacted homeowners, these “solutions” do not take into account the hydrogeologic fact that groundwater, and any contaminants in it, flow down gradient beyond homeowner property boundaries.
2.1 Permanent Replacement Water Supplies must be Mandated
The revised draft SGEIS regulations do NOT have legal provision requiring gas companies to completely restore the hydrogeologic integrity of freshwater groundwater flow systems to pre- existing conditions before drilling commenced. Instead, as has recently occurred in Dimock, PA, regulators have signed off on “whole-house gas mitigation devices” that leave affected households questionable filters and high vent pipes discharging methane from their wells into the air they breathe. This “band-aide” approach to aquifer restoration, home valuation, and quality of life is simply redirecting the problem and does nothing to correct the problem resulting from breached confining beds, uncontrolled escaping gas, and contaminant excursions. Regulations that might be construed to assert that such band-aide measures have sufficiently corrected
9 groundwater problems such that drilling and hydrofracking can continue must be tabled immediately. The draft regulations must be worded to require permanent “replacement” water supplies.
Because the intent of the regulations is to preclude groundwater contamination, it is reasonable that they should include a solid mechanism whereby the groundwater and surface waters of New York State are remediated or restored to the same pristine quality that was present before gas drilling. However, it is essentially impossible to remediate aquifers that may become contaminated with fracking fluids, especially since a large volume of source fluid remains underground permanently. In such contaminant cases, the only means of replacing contaminated homeowner water, and that which becomes contaminated in down gradient directions as groundwater flows, is to establish a new remote water supply source or connect to a pre-existing water supply. If private agreements are made between gas companies and homeowners, gas companies would essentially be cheaply purchasing New York State aquifers and leaving them permanently degraded. The regulations must be amended to ban non-disclosure agreements between gas companies and homeowners. There cannot be a veil of secrecy regarding any contaminant information. Similarly, the regulations should be modified with legally-binding wording that precludes anything less than full alternate and permanent water source replacement. This should NOT allow permanent use of water filtration systems that may not be capable of removing unknown, proprietary, and untested fracking related chemicals. Replacement water supplies should be required in newly revised SGEIS regulations.
2.2 Considerations Relative to Development of Alternate Water Supply Systems or Extension of Existing Water Supply Lines
The NYSDEC gas drilling regulations should be strengthened to require that gas drillers responsible for contaminating aquifers fully clean them up to the maximum extent possible AND either develop permanent alternate water supply systems for all adversely affected water supplies or extend existing water supply lines to them. With this, the regulations should be written to provide for system operation and maintenance costs in perpetuity. Otherwise, there will not be adequate provision to protect the health and safety of homeowners. Gas field contaminant excursions must be treated as outwardly expanding contaminant plumes that warrant expensive, full-scale, hydrogeologic characterization, groundwater clean-up, and remedial action. The importance of this must be underscored because aquifer restoration on a gas field scale, even if cost were not an issue, is virtually impossible.
Whereas monetary compensation to adversely affected homeowners may be warranted as settlement for inconvenience, property devaluation, and health issues, these settlements should in no way remove the responsibility of gas companies to restore the waters of the State of New York to pre-drilling conditions. Provision of whole house water filtration systems and gas vent pipes extending above well casings should not be an acceptable means of abdicating responsibility and liability. It is highly unlikely that homeowner filtration systems can effectively remove the hundreds of potential toxins that may be present in frack water (many unknown), not to mention the costly and undeveloped water quality monitoring needed. The regulations should be amended to reflect this, thereby insuring that gas companies cannot, in
10 essence, purchase aquifers. Hydrologically, it needs to be borne in mind that the “buy out” of properties or hiding contaminant issues via non-disclosure agreements fails to address other down gradient properties and streams where contaminated groundwater will flow in years to come. Similarly, health risks that may result from incomplete or lack of full reporting are not acceptable from a toxicologic standpoint. Again, the importance of tracer use and testing is underscored.
3.0 Gas Wellbore Failure and Aquifer Contamination will Occur
Foremost among significant and substantive issues that have not been adequately addressed in the revised draft SGEIS is that the durability of the cement and steel casing sealant technology available today will degrade in less than 100 years, quite likely far less. This will result in long- term contamination of both groundwater and surface water resources.
The revised draft SGEIS fails to address the critical issue of the durability of cement and steel used to isolate and protect aquifers. The material used in gas wellbores to isolate freshwater aquifers from deep brines and other gas field contaminants has limited durability, ranging roughly from a few years to about 100 years. When failure of wellbore sealant materials occurs “irreparable harm” to freshwater aquifers will take place if the proposed regulations are advanced. The revised draft SGEIS (2011 Glossary, Page 2) defines cement sheath as “A protective covering around the casing, segregates the producing formation and prevents undesirable migration of fluid.” Research conducted on well sealant durability and the many failure mechanisms of cement sheaths and casing reveals that the technology does not currently exist such that long-term protection of aquifers is possible.
Breaching of confining beds that now naturally serve to separate and protect our freshwater aquifers will result in long-term contamination by naturally-occurring deep chemicals and gases, toxic hydrofracking chemicals, and saline water. The revised draft SGEIS regulations do not adequately address the short and long-term hydrogeologic picture and, as such, will not adequately protect the water resources of the State of New York to meet present and future needs. Reference to two documents hereby incorporated by reference (http://hydroquest.com/Hydrofracking [HydroQuest DRBC Draft Regulations Comment Report 4-9-11; April 9, 2011 DRBC Comment Report Figures; Aquifer Protection Expert Fact Sheet Front 9-2-11]) establish, based on industry literature, that widespread cement sheath and casing failure will occur in less than 100 years and 80 years, respectively. This important omission must be addressed, including an assessment of actions required for long-term protection of the State’s freshwater aquifers. Industry documents firmly establish that gas field technology has not evolved sufficiently to guarantee long-term protection of freshwater aquifers. Until such time as well sealant technology has significantly advanced, it is neither safe nor prudent to permit any gas drilling in Schoharie County, New York or elsewhere.
11 3.1 Limited and Low Durability of Cement Sheaths and Casings
The risk of long-term contamination of freshwater resources is borne out by extensive research and publications of the petroleum industry and others and is well-documented throughout industry literature. The durability and mechanical properties of well sealant materials are NOT sufficiently advanced such that freshwater aquifers will be safely protected for hundreds of thousands of years. Current “state-of-the-art” plugging and abandonment (P&A) practices and materials are not sufficiently advanced to insure long-term isolation between saline and freshwater zones. The aquifers we enjoy today took about a million years to form and can reasonably be expected to last another one million years (HydroQuest April 9, 2011 DRBC Comment Report). Without unnatural alteration from gas drilling activities, aquifers should be capable of providing potable water for future generations for another one million plus years. Industry documentation establishes that, under the best of circumstances, cement and steel used to effect zonal isolation may last up to 100 years and 80 years, respectively – often far less (HydroQuest April 9, 2011 DRBC Comment Report). While all the key elements that cumulatively lead to failure of cement sheaths and casing material are discussed at length in the HydroQuest April 9, 2011 Comment Report, they are nicely summarized on the Aquifer Protection Expert Fact Sheet (front side) referenced above. Once the inevitable failure of cement sheath and casing sealant material occurs, additional contaminant migration pathways are available (see HydroQuest Gas Contamination Pathways figure). As illustrated in the schematic figure below, methane released under pressure from failed cement sheaths and casings follows fractures to homeowner wells, water bodies, and the land surface.
The HydroQuest figure above illustrates natural gas and methane released under pressure from failed cement sheaths and casings follows fractures to homeowner wells, water bodies, and the land surface. Boreholes provide gas release points for methane derived from shallow and deep fractures. High-yield pumping tests performed on gas well boreholes before they extend below
12 freshwater aquifers and before they are cased and grouted provide a means of assessing likely fracture connectivity and guaranteed homeowner well contamination when cement sheath and casing failure occurs. The Aquifer Protection fact sheet and 4-09-11 report address cement sheath and casing failure mechanisms that will occur in less than 100 years, often far less (see http://hydroquest.com/Hydrofracking/ hereby incorporated by reference).
The draft revised SGEIS does not provide legally-binding and enforceable provisions to guarantee long-term maintenance of production well sealant materials. Since most cement plugs will fail in less than 100 years from shrinking, debonding, cracking, and corrosion, all existing gas wells must be fully replugged from the ground surface to the lowest production zone at least once every 100 years over the 1,000,000 plus year life of freshwater aquifers – some 10,000 times per well. The draft gas drilling regulations must be amended to provide for regular, long-term, replacement of well sealant materials at least once every 100 years. If provision is not made for long-term maintenance of degrading wellbore sealant materials, Schoharie County and other gas wells will become long-term aquifer and surface water contaminant sources.
HydroQuest (April 9, 2011 report: see http://hydroquest.com/Hydrofracking/ incorporated here by reference) has carefully documented pipe durability and failure mechanisms while documenting maximum pipe durability on the order of 80 years. The revised draft SGEIS 2011 provides important documentation relative to the “long-term” integrity/durability of casing material (e.g., Consultant Bibliographies, p. 3) where they reference a Curran International paper titled Corrosion Control in Gas Pipeline Systems. Some important quotes from this paper include:
“If you see evidence of corrosion and fouling, chances are it is occurring throughout the length of the pipes. If the corrosion is left untreated, it can weaken the pipe walls to the extent that the entire pipeline will need to be completely replaced, a costly solution. … Additionally, pipelines erode many times faster than coated lines, and their useful life is diminished to no more than a handful of years in corrosive service (emphasis added) requiring costly rehabilitation.”
Clearly, as with the maximum durability of cement sheaths of about 100 years, there is no doubt that the revised draft SGEIS does not adequately address water quality protection. Once the integrity of gas well cement sheaths, casing, and plugging material has been breached through natural corrosion and assorted failure mechanisms (HydroQuest, April 9, 2011 report), then upward hydraulic pressure gradients present will result in natural gas and contaminant migration into overlying aquifers. The revised draft SGEIS needs to be revised throughout so that it is clear to all that much of the safety precautions designed to protect both groundwater and surface water resources are not physically capable of protecting New York State’s freshwater aquifers beyond 80 years – and in all likelihood far less.
13 4.0 Protection of Freshwater Aquifers: Seismic Threshold Requirements
The seismic risk to the integrity of well sealant materials used to isolate freshwater aquifers is great. Naturally-occurring earthquakes will almost certainly disrupt and degrade the cement sheath materials used in gas wells to protect freshwater aquifers.
Gas production wells should not be placed within seismically active regions where ground shaking/motion will damage the integrity of cement seals. The SGEIS draft gas drilling regulations do not adequately address seismic risk either naturally occurring or resulting from hydrofracking activities, nor do they identify New York State areas prone to higher seismic activity and measures to prevent earthquake damage potentially associated with hydraulic fracturing. The HydroQuest April 9, 2011 DRBC Comment Report (pages 41 to 46, Figures 8 to 15) details the great seismic risk and likely resultant damage to cement sheaths. Repeated hydraulic fracturing may activate pre-existing faults or induce shifting or settlement along lubricated fractures, as is recently indicated with underground injection of gas drilling wastewater in Youngstown, Ohio and elsewhere.
Much of New York State is seismically active. Excessive lubrication of faults and fractures with highly pressurized hydraulic fracturing fluids, bolstered by repeated hydrofracturing episodes, may result in fault activation and bedrock settlement. This, in turn, may result in shearing of production well boreholes and casing strings even in the absence of natural seismic activity. While assessment is warranted to establish acceptable threshold values, appropriate maximum values for Richter magnitude and modified Mercalli shaking-vibration intensity may be on the order of 3.0 (III) or less for both. Philadelphia, PA, for example, recently experienced structural damage to buildings from an earthquake some 200 miles to the SW. Clearly, if the related earthquake intensity of 4.7 could damage buildings, it was also likely to result in damage to the integrity of cement sheaths, especially with repeated seismic events through time. Seismic hazard risk must be evaluated over the duration of the life of aquifers – 1,000,000 plus years. It would not be prudent to promulgate gas drilling regulations without thoroughly evaluating long- term seismic risk.
As an example, the probability of earthquakes with magnitudes of greater than 5.0 and 6.0 was examined. HydroQuest assessed the probability of earthquakes in the greater Schoharie County area using Howes Cave as a focal point. Modeling of earthquake probability was conducted using the USGS 2009 Earthquake Probability Mapping model and related data available from the USGS Geologic Hazards Science Center. A series of model runs were conducted to assess and graphically display earthquake probabilities that were computed from the source model of the 2008 USGS-National Seismic Hazard Mapping Project (NSHMP) update for Howes Cave, NY (42.69º N, -74.40º W). The ten generated maps show the probability of earthquakes with magnitudes of > 5.0 and > 6.0 within a radius of 50 km for 100, 500, 1000, 5,000, and 10,000- year events. The USGS web-based model runs determined earthquake probability percents for these events to be:
14 Time Interval (yrs) > 5.0 >6.0
100 2-3 0-1 500 10-12 2-3 1000 15-20 4-6 5000 60-80 20-25 10000 80-90 30-40
These very real and high earthquake probabilities stem from USGS web-based model runs conducted by HydroQuest. The probabilities for each of these events are based on known, recorded, earthquakes. The associated ten probability maps may be viewed at: http://hydroquest.com/Schoharie/ [Earthquake Probability Figures]. Clearly, earthquake probability and the great risk to the integrity of cement sheaths and casing materials used to protect the integrity of freshwater aquifers must be addressed in a newly revised SGEIS.
Based on the Howes Cave seismic analysis presented here, it can be stated that the probability that seismic shaking will result in cracking of cement sheaths and then massive upward release of contaminants is great. To intentionally risk permanently jeopardizing the purity of our freshwater aquifers by permitting gas well installations in seismically active portions of New York State would be irresponsible. Similar evaluations should be conducted and further analyzed for all portions of New York State over gas-rich shales.
5.0 All NYS Aquifers should be Afforded Equal Protection: Geologic Similarity between Schoharie County and NYC West of Hudson Watersheds
Geologically, the bedrock geology present in Schoharie County is essentially the same as that present in neighboring New York City watersheds. As such, the hydrogeologic flow regime in the bedrock formations is also the same as in the adjacent NYC watersheds. The hydrologic risk to groundwater is, however, greater because impacted residents and business have NO additional or backup water supply options should their water quality become degraded. Individual groundwater wells are these people’s only water supply option – their sole source aquifers with no additional reservoir, stream, or groundwater backup options as exist in the NYC watershed. For these reasons, groundwater aquifers outside of NYC watersheds should be afforded an even greater degree of water quality protection.
Hydraulic fracturing of shale formations and related surface activities has the potential to permanently and irreparably harm ground and surface water resources in New York State. Extensive existing fracture and fault networks throughout the Appalachian Basin may provide upward pathways for contaminant and gas migration through geologic zones believed to be physically isolated, based on incomplete data. As a result, there are significant health and environmental risks associated with advancing horizontal gas drilling in Schoharie County, New York and elsewhere in the Appalachian Basin.
15 Herein, HydroQuest provides a comparison between Schoharie County ground and surface water resources and those in New York City’s West of Hudson River watershed, demonstrating that they are virtually indistinguishable and require similar water quality protection. I offer this conclusion based on my training as a geologist, hydrogeologist, and hydrologist with more than thirty years of professional environmental experience which includes work conducted for the New York State Attorney General’s Office (Environmental Protection Bureau), Oak Ridge National Laboratory (Environmental Sciences Division), the New York City Department of Environmental Protection, and as an independent environmental consultant as President of HydroQuest. Within the broad field of hydrology, I have specialized expertise in both ground and surface water hydrology.
The notion has been recently advanced that some Appalachian basin watersheds (i.e., New York City West of Hudson River and Syracuse) are more vulnerable to contaminant excursions and therefore, should be afforded greater protection through a more stringent permitting process. The decision to exclude New York City and Syracuse from the “generic” review process must stem from the respectively larger populations supplied by these water resources. It appears to be largely a risk-based political decision, without defensible scientific, geologic or hydrologic basis.
The potential environmental threats to Schoharie County ground and surface water resources from hydraulic fracturing-related contaminant excursions are not significantly different than those present in New York City’s West of Hudson River or Syracuse watersheds. An important graphic figure was developed to illustrate the similar geologic setting. Please refer to: http://hydroquest.com/Schoharie/ [Schoharie Bedrock].
The bedrock geology of the Schoharie County and New York City West of Hudson River watershed areas is essentially the same, with the major exception of a band of carbonate bedrock in the northern portion of Schoharie County. As depicted in the Schoharie Bedrock figure, many of the upper bedrock units present in Schoharie County are the same as those present in New York City's West of Hudson watersheds. Geologically, these units are comprised of a series of sedimentary shales, siltstones, sandstones, and some conglomerates layered from the Honesdale Formation downward through and below the Marcellus Formation. These rock units were deposited under the same hydrologic conditions through the widespread area now recognized by geologists as the Catskill Delta. Before the sediments of these rock units were lithified into bedrock, they were shed northwesterly from the ancestral Acadian Mountains.
As reflected in the Schoharie Bedrock figure, it is apparent that erosion has, in places, removed some of the uppermost bedrock units through glaciation and erosion. In places, both Schoharie County and New York City watershed areas have the same bedrock units exposed at the ground surface (e.g., Oneonta Formation, Unadilla Formation). A portion of the New York City West of Hudson watershed lies within Schoharie County. Significantly, geologically and hydrologically, ground and surface water flow in both the Schoharie County and New York City watershed areas behaves similarly – all potentially being vulnerable to gas field related contaminants from below and above. Indeed, because some of the northern Schoharie County bedrock formations are stratigraphically closer to the Marcellus Shale than those in portions of New York City watersheds, the risk of contamination is even greater there. Assuming that there were a means of effectively remediating aquifers contaminated with hydraulic fracturing chemicals, it would be
16 equally difficult and expensive to do so within heterogeneous fracture networks both within and beyond the New York City watershed. The possibility of effectively remediating aquifers contaminated with fracking fluids is essentially zero. Also, the hydrogeologic situation is compounded because gas companies cannot remove all of the chemicals they inject underground. Geologically, there is no reason why Schoharie County watersheds should not be afforded the same degree of protection as NYC watersheds. The same is true of neighboring Otsego County.
The omission of New York City watersheds and a “protective” 4,000-foot buffer area from NYS gas drilling erroneously implies geologically and hydrologically that some watersheds are more vulnerable to contamination than others. The concept/argument has been advanced that gas drilling should be precluded from watersheds of New York City (e.g., p. 20 SGEIS). Apparently, the argument for this hinges on the fact that a very large populous is provided with water from these sources and any potential risk to water quality is unwarranted because high- volume hydraulic fracturing activity is not consistent with the preservation of NYC watersheds as an unfiltered drinking water supply. First, the underlying premise here, simply stated, is that accidents, surface spills, problems or even operator error could potentially degrade the New York City water supply system. Logically then, the same reasoning applies everywhere else. Next, the presence of multiple reservoirs directly allows for use of alternate water sources within the system by taking portions of the existing system off-line. If some or all reservoirs were to become contaminated, then a groundwater supply could be exploited as an additional backup. Yet, the vast majority of homeowners who rely on groundwater wells elsewhere for their water supplies have NO other possible alternate water supply options. Once their aquifers have been contaminated by fracking-related contaminants, these people have NO other water supply options. For the larger populous using groundwater wells, their aquifers are effectively their sole-source aquifers. If NYSDEC truly believes gas drilling poses no significant risk to water supplies this hierarchy protection priority should be reversed. Furthermore, the greater groundwater protection sought for primary aquifers vs. other portions of watersheds fails to adequately take into account the simple hydrogeologic fact that the surrounding watershed areas up-gradient of primary aquifers all drain down-gradient to these primary aquifers. Thus, it is the larger land areas outside the New York City and Syracuse watersheds that should be given primary groundwater protection priority because no backup water supply options are available to adversely impacted homeowners.
6.0 Carbonate Bedrock and Karst in Schoharie County and Beyond
Karst terrains and their hydrologically vulnerable aquifers are not addressed in the revised draft SGEIS. Karst terrains in New York State are comprised of limestone and dolostone bedrock that has been dissolved by surface and groundwater. Modern karst researchers agree that the most important criterion for identifying a karst area is the way groundwater behaves. If surface streams are pirated underground through closed depressions, there must be a hydraulically efficient karst aquifer regardless of the presence or absence of surficial karst features. Similarly, abrupt variations in discharge at springs and in caves provide irrefutable evidence for karst aquifers. Thus, portions of karst aquifers are characterized by rapid groundwater flow through cave-like conduits. This is analogous to open flow through pipes. [For a more detailed discussion of karst hydrology in NYS, please refer to the text of a professional guidebook paper
17 titled: Karst of the Silurian-Devonian Carbonates in Eastern New York State, with emphasis on the Cobleskill Plateau by Arthur N. Palmer and Paul A. Rubin (2007). It may be reviewed at: http://hydroquest.com/Schoharie/.
Carbonates (i.e., calcium and/or magnesium rich limestones and dolomites) of the Onondaga Formation and Helderberg group outcrop in the northern portion of Schoharie County. These carbonate formations, while stratigraphically lower than the Marcellus shale, overlie other shale beds that may be gas rich (e.g., the Utica shale of the Trenton Group). This is indicated by gas leases over these formations (see: http://hydroquest.com/Schoharie/ [Cobleskill Plateau karst]). Note that one likely direction of horizontal projections (i.e., laterals) extends under Helderberg Group and Onondaga carbonates. These carbonate formations are recognized among karst hydrologists as being karstic or cave/conduit bearing in nature. An important aspect of karst is its effect on water supply and contaminant transport. Water in solution conduits (i.e., cave-like passages with rapid, turbulent, groundwater flow) can travel up to several kilometers per day, and contaminants can move at the same rate. This poses serious problems when monitoring for water quality. Contaminants enter the ground easily through sinkholes and sinking streams, and filtering is virtually non-existent. Even small solution conduits can transmit groundwater and contaminants hundreds of times faster than in typical non-dissolutionally enlarged fracture/joint networks where groundwater flow is slow and laminar. Hydrofracking related contaminants that may enter karstic solution conduits, from below or above, may quickly degrade groundwater and surface water quality. It is important that karst and related environmental concern omissions in the revised draft SGEIS be rectified. As the SGEIS stands now, it fails to acknowledge vulnerable karst terrains and major water and air quality concerns.
6.1 Outcrop Pattern of Carbonate Formations in New York State
The SGEIS should be amended to include a geologic map of the outcrop pattern (i.e., near surface exposure) of all carbonate formations throughout New York State. The map below provides a generalized view of NYS carbonate formations and their outer boundaries. Once finalized, this carbonate or karst map of New York State should form the foundation for a ban on hydraulic fracturing and gas well permits both above and below carbonate formations, inclusive of no laterals beneath carbonate formations.
18 19 The map below illustrates the carbonate outcrop pattern, groundwater flow routes, and example horizontal projection (i.e., lateral) locations in the Cobleskill Plateau area of New York State. The orange polygons reflect existing gas leases as of 2010 in this area. Contaminant excursions from gas field activities in this area have a high likelihood of degrading aquifers, springs, and streams.
Map note: In places, surface water is pirated underground via sinkholes and the fractured epikarst (often buried under a soil mantle) where surface water infiltrates via joints to conduits and caves below. Groundwater flow in carbonates occurs predominantly along joints and bedding plane partings in a downdip direction (S-SSW here) and has been measured at rates in excess of 5 km/hr in Howe Caverns. Strike-oriented passages, such as the one depicted above, that aligns McFail’s Cave and Howe Caverns developed at a water table interface when the Cobleskill Creek was higher over one million years ago.
Gas field contaminants that reach cave environments, from above or below, may jeopardize endangered species protected under the Endangered Species Act (e.g., Indiana bat). The
20 schematic figure below illustrates the major contaminant flow vectors that are likely to degrade cave environments and water resources. The SGEIS fails to address these important concerns and should, therefore, be revised. In addition, degradation of water and air resources in major New York State commercial caves may adversely impact the local and regional economy. A significant drop in ecotourism may have far reaching impacts. These issues must be addressed in a newly revised SGEIS.
Contaminant transport pathways illustrated in a cross-sectional schematic. Here, upward hydraulic pressures drive brine and contaminant-rich waters to overlying freshwater aquifers along fractures, faults, and failed cement sheaths in gas wells. Where caves are present, the environmental risk to groundwater and cave- dwelling species is not justifiable. As illustrated, sloppy wellhead practices also pose a contaminant threat to groundwater resources. It is unlikely that gas wells that encounter cave or mine voids can be adequately sealed such that natural gas and other contaminants will not be able to enter them. In addition, cement and casing exposure to calcium-under-saturated flowing water would almost certain degrade these sealant
21 materials. The figure above graphically illustrates the concepts addressed throughout the HydroQuest April 9, 2011 DRBC comment report, with emphasis on the risk to the cave environment. The blue circle represents a spring resurgence into surface waterways issuing from the yellow cave. Here, the following potential gas migration pathways are shown:
A) Inside orange production casing that will eventually corrode and leak (and possibly shear if subjected to active faulting);
B) Outside production casing within debonded, shrunken, cracked or otherwise failed cement sheaths;
C) From failed cement sheaths and corroded casings into inclined and vertical fault planes that intersect caves;
D) From failed cement sheaths and corroded pipes into vertical fractures and into caves. While this may appear to be the least likely contaminant excursion pathway because not all vertical fractures extend from gas-rich shales to the ground surface, there is geologic evidence to support it. In NYS, for example, a respected structural geologist (Jacobi) has used naturally and upward leaking methane to map extensive vertical fracture systems exposed on the ground surface. This means that fractures already extend upward from gas-rich shales to the ground surface, through our freshwater aquifers. The pathways are already there and functioning, open for contaminant migration into our freshwater aquifers. Thus, this pathway is a real possibility; and
E) Downward from drill rig/well pad areas where poor housekeeping atop gravel pads has routinely allowed undocumented chemical spills from frack fluid mixing tanks coincident with hose disconnections. This is in addition to site chemical spills and frack fluid pit leakage and overflow to both groundwater and surface water resources.
6.2 Gas Drilling in NYS Karst Terrains is not addressed in the SGEIS
As graphically illustrated in the Eastern US Karst map above, portions of Schoharie County contain karstic or cave-bearing strata of the Helderberg Group and Onondaga formations which are far more vulnerable to natural gas and fracking-related contaminants than fractured bedrock aquifers more typical of sandstones and shales. Caves, solution conduits, karst terrains, turbulent groundwater flow, and cave fauna are not addressed in the revised draft SGEIS. Contaminant excursions into caves from below and above may degrade both the water and air quality required for the recovery of White-Nose Syndrome impacted bat species. Caves receiving natural gas from below via fracture interconnections may become confined spaces where natural gas accumulates – perhaps to concentrations in excess of the lower explosive limit. Continuous and unrestricted excursions of natural gas into caves, such as that documented in gas field homeowner wells, when inhaled may lead to tourist fatalities in Howe and Secret Caverns. In essence, this likely scenario would be analogous to unfortunate deaths which occurred in Howe Caverns in 1930 when two individuals were overwhelmed by blast-related gas fumes that accumulated in the cave.
22 Because groundwater moves rapidly through caves, much like that in surface streams, almost no natural cleansing of contaminants occurs. For this reason, conduit portions of karst aquifers are THE most hydrologically vulnerable aquifers anywhere. Contaminated karst streams resurge as springs where their adverse impact to streams, lakes, reservoirs, ecosystems, and wetland species and water quality may be rapid. The carbonate aquifers in Schoharie County should be afforded even greater protection than that contemplated for the bordering New York City watersheds, where alternate reservoirs and groundwater resources could be tapped in the event of likely extensive groundwater and surface water contamination from failed gas plays. We strongly recommend that the carbonate band in the northern portion of Schoharie County that includes Howe Caverns, Secret Caverns, National Speleological Society owned McFail’s Cave and many other caves used as bat hibernacula, for cave science, and tourism be added to areas considered as unsuitable and unsafe for hydraulic fracturing activities. It is important to recognize that this band of carbonate rock extends far to the west, east, and south of the Howe Caverns area used for discussion purposes here to accent the vulnerability of karst aquifers (see Eastern US Karst map above). Gas drilling in and under this NYS carbonate band should be permanently banned.
The potential adverse impact to Schoharie County and New York State’s tourist and satellite tourist-related businesses may be huge, possibly undermining the entire ecotourism industry. Beyond this, fracking-related contaminants will almost certainly migrate upward under strong hydraulic gradients to bedrock fractures used for private water supplies. In turn, toxic and carcinogenic contaminants in fractures will slowly migrate down gradient into major unconfined, unconsolidated, aquifers present in valley bottoms, including all those depicted on the HydroQuest Unconsolidated Unconfined Aquifer figure discussed in section 8.1 of this report (e.g., Schoharie Creek and Cobleskill Creek valleys).
6.3 Gas Drilling should be prohibited in Karst Terrains
Regarding the drilling of gas wells in karst terrains, Dr. Arthur N. Palmer (the most frequently cited karst hydrologist in the world) and I agree on the following points, which should be reflected in a revised SGEIS that incorporates regulations banning gas drilling New York State karst terrains:
A. Gas drilling regulations governing drilling in karst terrains cannot be voluntary, they must be mandatory. Anything less will result in a lack of protection of environmentally vulnerable karst aquifers and their receiving streams.
B. There are no adequate drilling procedures or protocols that may be used in karst terrains that will guarantee aquifer protection. Even if mandated procedures were developed, it is impossible to map the distribution and sizes of underground voids with geophysics or any other method - even borehole geophysics does not provide sufficient resolution to do so. Geologists who have spent their lives mapping the distribution of caves and their controlling geologic structures are unable to do so. In other words, even from inside the caves it is impossible to predict exactly where the unexplored caves and solution conduits extend.
23 C. Where gas drilling and fracking are proposed, as in the Howe Caverns area of Schoharie County, New York, caves are only part of the problem. Many openings of all sizes are present in karst, many of them connected to accessible caves, but many are not. Again, it is impossible to predict or map their distribution, regardless of the method used. Many karst hydrologists throughout the world would like to know how to do this.
D. Groundwater hydrologists are unable to characterize the distribution of permeability and porosity in karst, even from borings and aquifer tests. Most of them admit this, while others ignore karst entirely.
E. When a well is fracked, artificial pressures are applied directly to shale formations (typically greater than 4000 psi in the producing zone). Fracking fluids extend not only through much of the shale, but also leak into underlying and overlying formations. Any groundwater hydrologist can give estimates of how much leakage can be expected, from the simplest flow equations to complex models, but always assuming typical permeabilities of the rocks involved. The detailed pattern of permeability in limestone aquifers is unpredictable, but it is very high.
F. Although karst solution conduits are usually limited to shallow depths (less than 500 or so feet), all limestone formations, regardless of depth, contain some dissolution conduits formed by deep-seated processes (usually accompanying petroleum fields). Many recent sessions at professional geological meetings (e.g., Geological Society of America) have focused on these processes.
G. The term "karst" is misleading. People assume that unless caves and sinkholes are present, limestone aquifers are not "karst" aquifers. This is not true. All limestone and dolomite aquifers have flow characteristics that lie outside the normal range of groundwater behavior.
H. High-pressure fluids in shale will leak into any limestone formation in the vicinity. Once in the limestone, contaminants will spread in most directions. Individual details are unpredictable, but the overall result is not -- the contaminants will disperse over large areas and cannot be remediated.
I. The conclusion is that any fracking activity in the vicinity of limestone formations (and all have some aspects of karst) should be prohibited. Dire consequences are not guaranteed, but the probability is high enough that they should be avoided. The alternative is a widespread contaminant situation that is impossible to remediate, both physically and economically. Such problems are unlikely to appear until long after the fracking, but then it will be too late. This sounds like an exaggeration, but it is not.
6.4 Protection of Karst & Other Species: Environmental Considerations
24 The draft drilling regulations fail to recognize, locate, investigate, inventory, and characterize rare, threatened, and endangered species and their habitats which are likely to be degraded from hydrofracking-related contaminant excursions. One of the species of greatest concern is the federally endangered Indiana bat [Myotis sodalis]. There are real environmental, water quality, air quality, explosive, health, and endangered species concerns regarding gas exploitation below carbonate beds, inclusive of in caves. Carbonate formations in portions of New York State are recognized among karst hydrologists as being karstic or cave/conduit bearing in nature. Surprise Cave, for example, which overlies the Utica Shale was purchased by the State of New York specifically to protect the Indiana bat. Hydrofracking- related contaminants that may enter karstic solution conduits, from below or above, would quickly degrade groundwater and surface water quality. Beyond this, the build up of methane and other toxic chemicals in caves and mines may pose both an explosive and health risk to cavers, cave scientists, and cave-dwelling fauna. People and bats in caves may potentially be overwhelmed by the build up of methane and other toxic chemicals, where health and safety concerns normally reserved to confined spaces should not be an issue. The potential widespread devastation and far reaching adverse impact to bats and other cave-dwelling species in New York State and elsewhere far overshadows the recent bat population reduction from Geomyces destructans (a.k.a., white-nose syndrome). Now, more than ever, untainted cave and mine habitat is needed for restoration of bat species. Bat conservation organizations such as Bat Conservation International, Organization for Bat Conservation, and the National Speleological Society should be actively incorporated into the decision making/regulatory process within the context of a full environmental impact statement process, complete with public review and comment. Concerns of this nature (i.e., leakage of gas or fluids into cave passages that could kill cave life or cause explosions) have been recognized in other areas (e.g., New Mexico), where gas and oil drilling on BLM lands was coordinated to avoid intersecting and adversely impacting known cave systems, including world-famous Lechuguilla Cave.
6.5 Overall Karst Terrain Conclusions
Groundwater moves rapidly through caves and solution conduits, much like that in surface streams. Because the conduits are open, almost no natural cleansing of contaminants occurs. For this reason, conduit portions of karst aquifers are THE most hydrologically vulnerable aquifers anywhere. Contaminated karst streams resurge as springs where their adverse impact to streams, lakes, reservoirs, ecosystems, and wetland species and water quality may be rapid. Furthermore, release of natural gas and contaminants into caves will lead to the loss of threatened and endangered species, including the Indiana bat (Myotis sodalis). In the wake of White-Nose Syndrome (WNS) bats require untainted habitat if they are to slowly restore their populations. Contamination of karst aquifers would comprise a taking of threatened and endangered species under the Endangered Species Act. As such, the SGEIS should be revised to assess the associated risks. It is the professional opinion of Dr. Arthur N. Palmer (the most frequently cited karst hydrogeologist in the world) and HydroQuest that the risks attendant to gas drilling specific to aquifer degradation and species protection are not warranted. Gas drilling should not be permitted within karst areas. The draft regulations should be revised to exclude karst areas from gas drilling. 7.0 Gas Drilling should not occur within 500-year Floodplains
25 The SGEIS states that the Department would not issue permits for proposed high-volume hydraulic fracturing at any well pad in 100-year floodplains. However, a 100-year flood is a statistically-based number that may, in fact, occur back-to-back in consecutive years. The extreme damage of August 28, 2011 flooding is well illustrated in the Winter 2011 (vol. 26, no. 4) issue of Kaatskill Life. Flood levels far exceeded the 100-year floodplain. Clearly, had well pads been present within the 100-year floodplain, untold quantities of toxic gas-field chemicals would have been widely disseminated across farm fields and into yards, houses, playgrounds and streams. This is unacceptable.
It is best that we learn from the dire consequences of this flooding and, using hydrologic data from the August 28, 2011 flood event, evaluate what flood return interval floodplain would better be used for regulatory protection. Recent 2011 flooding throughout large portions of New York State provides a solid foundation for prohibiting any well pads from within the 500-year floodplain. The determination to increase the protective area to a 500-year floodplain, vs. say a 200-year floodplain, is founded on an example flood return interval analysis conducted by HydroQuest using long-term peak water year data (102 years) for the Schoharie Creek at Prattsville, inclusive of USGS’s peak flow estimate there for the Hurricane Irene storm of 8-28- 11. USGS (pers. comm.) estimates the peak flow at Prattsville between 100,000 cubic feet per second (cfs) and 120,000 cfs. A value of 110,000 cfs was used by HydroQuest to conduct a statistical analysis of the flood return interval associated with floodwaters of Hurricane Irene. The HydroQuest Log-Normal Distribution plot and related statistical data supporting a 500-year flood return are presented at: http://hydroquest.com/Schoharie/. The regulations should be amended accordingly to prohibit well pads within 500-year floodplains. A revised SGEIS should include maps of 500-year floodplains throughout New York State so that floodplain areas can be avoided.
8.0 Long-term contamination of high-yielding valley bottom aquifers must be addressed
Importantly, gas well contaminants that enter freshwater aquifers slowly migrate down gradient until reaching moderate and high-yielding unconsolidated (e.g., non-compacted deposits such as sand and gravel) aquifers used by larger population centers. Low level chronic exposure to unknown and untested toxic and carcinogenic fracking chemicals is likely to needlessly place the population at risk.
The draft gas drilling regulations do not take into account slow groundwater and contaminant flow rates. Hydrogeologically, contaminant excursions from far up-gradient watershed areas will eventually degrade high-yielding valley bottom aquifers. There is a reasonably foreseeable risk, based on credible scientific evidence, that contaminant excursions at any watershed location will ultimately increase the toxic contaminant load incident to significant aquifers (e.g., primary, principal and other high-yielding unconfined aquifers). The hydrogeology of contaminant migration toward high-yielding valley-bottom aquifers and the potentially chronic low-level exposure to gas field chemicals should be addressed in a revised SGEIS, with input from toxicologists.
26 8.1 Relationships between Aquifers, Schoharie County Creeks & the Schoharie Reservoir – A New York State Case Example
Excursions of gas-field contaminants into fractured bedrock and unconsolidated aquifers anywhere in watersheds tributary to the Schoharie Creek and its major tributaries will ultimately flow down gradient and degrade the county’s most significant and needed aquifers. Contaminated groundwater may flow many miles underground before reaching high-yielding unconfined aquifers (e.g., groundwater with a water table open to infiltration from above; not confined under pressure) and discharging as base flow to major creeks. If the southern portion of Schoharie County that encompasses part of New York City’s West of Hudson watershed area is afforded permanent groundwater and surface water protection stemming from a ban on hydraulic fracturing, then this portion of New York City’s watershed will be protected. However, Schoharie County watershed areas north of the New York City watershed boundary will remain at risk of groundwater degradation. Because these areas do not have multiple reservoir and untapped groundwater reserves to serve as backup or alternate water supplies as NYC does, there are no readily available alternate water supply options should aquifer degradation occur. A discussion of the hydrologic setting helps set the stage for understanding the risk to both groundwater and surface water resources.
A number of major waterways flow into and out of Schoharie County (e.g., see HydroQuest Unconsolidated Unconfined Aquifer figure; also JIMAPCO Schoharie and Otsego Counties map). In the southernmost portion of Schoharie County, the Schoharie Creek and its tributaries (e.g., West Kill, Batavia Kill) flow northward into New York City’s Schoharie Reservoir. The drainage area tributary to the USGS gaging station 0.2 miles upstream of this reservoir is 237 mi2. The Schoharie Reservoir extends from the northern end of Greene County into the southern portion of Schoharie County. Surface water and numerous unconfined and bedrock aquifers drain down gradient within the watershed tributary to the Schoharie Reservoir. Much of the flow incident to the Schoharie Reservoir is diverted underground in a man-made aquaduct to the Esopus Creek in Allaben, where it then flows into New York City’s Ashokan Reservoir. Overflow from the Schoharie Reservoir follows the natural channel of the Schoharie Creek, proceeding northward through the lower Blenheim Gilboa Reservoir, North Blenheim, Fultonham, Middleburgh, Schoharie, and Esperance until ultimately reaching the Mohawk River. North of the high dam at the terminus of the Schoharie Reservoir, numerous major tributaries join the Schoharie Creek along its northward flowing pathway. These include Wharton Hollow Creek, Panther Creek, West Creek, Cobleskill Creek, Louse Creek, Fox Creek, and Cripplebush Creek, all of which flow in a dendritic pattern, much like the branches of a large maple tree coalescing toward its base. This tributary stream network is depicted on the HydroQuest figure titled: Major Unconsolidated Aquifers of Schoharie County, New York. Reference to this same map shows the black line boundary of NYC Watersheds projecting into the southern portion of Schoharie County.
An elongate south-southwest to north-northeast trending unconfined aquifer is depicted traversing through the eastern third of Schoharie County from just north of the Schoharie Reservoir northward to and beyond Esperance on both this HydroQuest map and on a mid- 1980’s USGS map titled: Potential Yield of Wells in Unconfined Aquifers in Upstate New York – Hudson-Mohawk Sheet by Bugliosi, Trudell and Casey. Note that a section of the unconfined
27 aquifer is missing on these maps in the location of the Schoharie Reservoir. It was almost certainly removed here coincident with the development of the reservoir. The SSW-NNE trending river bottom unconfined aquifer is joined by two major segments from the west (Wharton Hollow Creek and Cobleskill Creek) and one from the east (Fox Creek). These interconnected unconfined, highly transmissive, sand and gravel aquifers support well yields in excess of 100 gallons per minute. It is extremely important that their quality not be compromised by gas field contaminants.
The Schoharie Reservoir itself and the high dam at the southern terminus of the Schoharie Reservoir effectively behead or separate unconfined aquifer segments that were formerly contiguous along the valley floor of the Schoharie Creek. This unnatural alteration of this unconfined aquifer, in effect, serves to protect the New York City watershed from potential gas field contaminant excursions that might occur from permitted gas wells in southern Schoharie County. This is because groundwater flow immediately north of the Schoharie Reservoir dam and watershed divide (see black watershed divide line on HydroQuest Unconsolidated Aquifer map) is almost certainly to the northeast, northwest, and north toward the lower hydraulic gradient of the north-flowing Schoharie Creek. Similarly, the small area in the southern portion of Schoharie County that lies within the watershed of the Schoharie Reservoir (e.g., Manor Kill) flows directly into the Schoharie Reservoir over a series of waterfalls and through a bedrock- floored gorge. It is highly likely that the footings of the Schoharie Reservoir dam are tied into underlying bedrock, thus effectively truncating what certainly once was a formerly interconnected unconfined aquifer along much of the Schoharie Creek valley. Even if the footings of the Schoharie Reservoir dam do not reach bedrock, there is little doubt that the dam and reservoir truncate the formerly intact unconfined aquifer here.
The HydroQuest map titled: Major Unconsolidated Aquifers of Schoharie County, New York (see http://hydroquest.com/Schoharie/) has wide blue Hydrologic Unit boundary lines that enclose watershed areas that drain down stream and down gradient to high-yielding unconfined aquifers and the Schoharie Creek. With the exception of the band of carbonate bedrock in the northern portion of Schoharie County, both surface and groundwater flow may reasonably be interpreted as flowing toward the low regional base level (i.e., hydrologic control) of the north- flowing Schoharie Creek. Groundwater flow within the carbonate band, while influenced by relict water tables and faults, is ultimately also controlled by regional base level elevations (Rubin, 2009; go to http://hydroquest.com/Schoharie/ HydroQuest 3-02-09 ICS Paper; incorporated here in this report by reference), such as that afforded by the headward incision of Cobleskill Creek (see HydroQuest map: Karst Hydrology of the Cobleskill Plateau & 2010 Gas Leases at http://hydroquest.com/Schoharie/). Within the Cobleskill Plateau, where New York State’s largest and longest caves have developed, groundwater flow is ultimately, as in non- carbonate areas, graded to base level stream valleys. Thus, gas field contaminants would not be expected to flow southward toward the New York City watershed, against steep hydraulic gradients.
The real issue relative to gas drilling in Schoharie County is that of long-term protection of groundwater resources. The purpose of the mid-1980’s USGS map titled: Potential Yield of
28 Wells in Unconfined Aquifers in Upstate New York – Hudson-Mohawk Sheet by Bugliosi, Trudell and Casey is provided on the map:
“New York State’s increasing need to develop ground-water-protection and management policies has led to an effort to identify and delineate the location and extent of its significant aquifers – those that consist of sand and gravel and yield substantial amounts of water to wells.”
This map was constructed in cooperation with the NYS Department of Environmental Conservation. Reference to either the HydroQuest Unconsolidated Unconfined Aquifers map or that of the USGS (both being based on the same data set) shows that both surface and groundwater flow serves to recharge important high-yielding unconfined aquifers present in major river valleys. Thus, all gas field contaminant excursions, whether they originate as overland spills or as a result of failed cement sheaths into freshwater aquifers will either rapidly or slowly make their way toward and into the very best aquifers available for present and future water supply purposes. As seen on HydroQuest Unconsolidated Unconfined Aquifers map, contaminant transport within watershed areas may occur from gas wellfield locations far removed from stream valleys down gradient into them. This is particularly true of contaminants that have entered groundwater flow systems via direct infiltration into unconsolidated and fractured bedrock aquifers. In addition, any hydraulic fracturing related contaminants incident to streams may, if not fully assimilated (i.e., diluted) by stream water may also recharge underlying aquifers with contaminants.
In time, all gas field related contaminants that enter freshwater aquifers anywhere within watersheds tributary to stream and river valleys will ultimately flow into major base level, river valley, aquifers. In Schoharie County, for example, the elongate light and dark orange unconfined aquifers depicted on the HydroQuest Major Unconsolidated Aquifer map are the receiving aquifers of all up-gradient contaminant excursions that enter groundwater flow systems within the Hydrologic Unit boundaries illustrated that are tributary to the Schoharie Creek. These are the aquifers that towns require now and for future growth. As gas well sealant failure occurs within a few to about 80 years (as documented by industry literature – see HydroQuest 4- 09-11 report [http://hydroquest.com/Hydrofracking/] incorporated here by reference), contaminants will migrate down gradient, slowly building contaminant levels for many decades and centuries into the future. While contaminant concentrations may not ultimately exceed NYS drinking water standards, the population drinking this water will continue to have low-level chronic exposure to a suite of toxic and carcinogenic hydrofracking chemicals with untested and unknown health impacts. A more detailed discussion of groundwater and contaminant flow routes, along with a discussion of important concerns and figures showing hydrogeologic flow vectors is provided here as part of this report (Addendum A, found at http://hydroquest.com/Schoharie/). Its author, Dr. Arthur N. Palmer is a world-recognized hydrologist who is well-acquainted with Schoharie County. The issues presented here and by Dr. Palmer, while using Schoharie County as an example, apply worldwide. All these concerns and issues need to be fully addressed in a revised SGEIS, followed by fully public review and comment.
29 It is important to recognize that all the watershed areas depicted as being within the HydroQuest Major Unconsolidated Aquifers map of Hydrologic Units area tributary to the Schoharie Creek will ultimately be recharged with contaminated hydrofracking chemicals. Because the revised draft SGEIS fails to recognize that well sealant technology does not exist today that is capable of protecting freshwater aquifers for their long-term life, shale gas exploitation should be banned until such time as the technology significantly improves. At this time, the groundwater protection contemplated when constructing Unconfined Aquifer maps in New York State is not possible if gas wells are to be permitted.
9.0 Setback Distances from Gas Wells and Gas Well Laterals
The revised draft SGEIS should be modified with setback distances that are empirically based. Setback distances should be based on sound scientific data and consideration. Gas production well arrays are allowed to be placed within distances of less than 2,100 feet from water bodies (e.g., reservoirs, lakes, rivers, streams, wetlands), dams, pipelines and other vulnerable features. Regulatory setback distances (with short time limitations) from well pads (i.e., not well lateral arrays) in the revised draft SGEIS draft drilling regulations (4,000 feet of NYC and Syracuse watersheds; 2,000 feet from public water supply wells, river or stream intakes and reservoirs; 500 feet from principal aquifers, private water wells and domestic use springs) have no scientifically defensible basis and, as such, should be discarded until justifiable, empirically- based, setback distances are established. Based on aquifer test results obtained in NYS, gas well setback distances of less than 2,100 feet, inclusive of all horizontal projections, have a high probability of degrading groundwater, wells, caves, and surface water bodies from natural gas, fracking chemicals, and Light Non-Aqueous Phase Liquid (LNAPL) excursions along fracture and borehole pathways.
For example, the 500 foot principal aquifer/private well buffer number lacks any actual empirical data to support it. Alternately, HydroQuest has analyzed empirical NYS aquifer test data and has determined that a minimum setback distance of 2,100 feet is warranted (see aquifer test drawdown and recovery data graphic below that documents nearly instantaneous (i.e., less than five minutes) hydraulic connectivity along fractures to at least 2,100 feet from pumping wells. This is a minimum, data-based, setback distance number that should be used as a base point in assessments designed to expand this number based on additional empirical studies. Because the 500-foot and other setback distances cannot hold up to rigorous scientific scrutiny and lack any empirical basis, they should be discarded.
HydroQuest has provided this minimum setback distance based on empirical aquifer test data collected within the Delaware River Basin (see 4-09-11 HydroQuest DRBC Comment Report, pages 33 to 37 and the Aquifer Protection Expert Fact Sheet back available at http://hydroquest.com/Hydrofracking/ and incorporated by reference here). The drawdown and recovery pumping test figure below depicts rapid hydraulic connectivity between wells connected by bedrock fractures up to about 2,100 feet distant. This empirical hydrogeologic data collected from within a New York State portion of the Delaware River Basin should receive priority when determining setback distances vs. whimsical setback distances with no scientific foundation.
30 Setback distances should be established from beyond the outer boundary of gas well lateral as depicted below, not outward from individual well pads. The structural and gas anomaly work of Jacobi, Fountain and others, of visible joint lengths in New York State caves, as well as the results of the aquifer test illustrated above, document the presence of joints and faults extending over distances in excess of 2,100 feet. This distance is a minimum number. When cement sheaths and casing sealant materials fail (i.e., < 100 years) contaminants will move upward under hydraulic pressures into interconnected fracture sets and into freshwater aquifers and wells. Some of the inevitable contaminant impacts may be lessened by establishing setback distances outward from the outer boundary of well arrays where a combination of natural and man-made or embellished fractures may provide upward contaminant pathways. The illustration below depicts this improved setback distance setting.
31 10.0 Hydraulic Fracturing Fluids should be designated as Point Source Discharges
Chemicals in drilling mud and hydrofracking fluid that are forced into geologic formations via gas wells are NOT, but should be, officially designated as point source discharges. Some of these chemicals will migrate to aquifers, homeowner water supplies and surface waters. This WILL occur via failed cement sheaths and bedrock fractures, within a time period of less than one year to about 100 years when well sealant materials naturally degrade. Dissolved methane excursions along bedrock fractures from gas wells to homeowner wells (i.e., as documented in PA DEP – Cabot consent orders relative to the Dimock, PA area) have already established the presence of hydraulic connections and viable pathways for chemical transport via the existing groundwater flow system. The revised SGEIS draft regulations do not address the likely
32 relationship between chemicals found in homeowner wells that exceed MCLs and highly concentrated flowback fluid constituents that exceed groundwater effluent limitations (e.g., NYS §703.6) for discharges to Class GA waters from a point source or outlet or any other discharge within the meaning of the Environmental Conservation Law that will or may enter the waters of the State. Any documented violation of groundwater standards found in homeowner wells that chemically stem from gas wells anywhere in New York State should be recognized as originating at gas well point sources. Thus, discharges into the ground at gas wellheads represents multiple point source discharges to groundwater. As such and using New York State as an example, effluent or contaminant limits of all fracking/drilling fluids should adhere to those set forth in Table 3 of subdivision (e) of §703.6 for all parameters listed. This should have an overall effect of reasonably forcing the gas industry to use non-toxic, environmentally-friendly, chemicals. Once a physical connection is established once between one or more gas wells and one or more homeowner wells, henceforth all frack-related fluids should, by regulation, adhere to groundwater effluent limitations for point sources. As addressed previously, most cement sheaths and casing material will fail in less than 100 years, often far less, after which thousands of wellbores will provide open contaminant vectors upward into fresh groundwaters. Thus, even before a chemical and hydraulic connection are established between individual failed gas wells and homeowner wells, gas well fluids should properly be designated as and subjected to groundwater effluent limitations. The groundwater effluent limitations should be incorporated in SPDES permits for discharges to groundwaters. Tables of frack flowback water chemistry indicate that hydrofracking point source waters grossly exceed existing point source effluent limitations and federal and state groundwater standards. Thus, hydraulic fracturing of gas wells should not be permitted until all additives are environmentally safe (see, for example, HydroQuest April 9, 2011 DRBC Comment Report, pages 39-41).
11.0 Need to Plug Gas Wells throughout the Entire Wellbore
All abandoned, unplugged, poorly-plugged, and soon to be plugged wells must be required to be plugged throughout the entire wellbore from the ground surface to the lowest production zone. If this is not required first, hydrofracking chemicals will follow fracture and poorly-plugged wellbore pathways into our freshwater aquifers. Because groundwater flow rates are slow, contaminant plumes may take decades or even centuries before widespread groundwater degradation reaches our water supplies. All contaminant excursion pathways should be sealed. The regulations should reflect this to reduce the near-future and long-term likelihood of aquifer contamination.
12.0 Existing Maximum Contaminant Levels (MCLs) are Not Sufficient
State and Federal standards for groundwater, against which adversely impacted homeowner well water will be compared in Schoharie County and elsewhere, are limited and do NOT adequately require sampling and analysis for all the many toxic and carcinogenic chemical compounds used in fracking/drilling fluids. As a result, State sign-off on supposedly clean, potable, groundwater will almost certainly occur while people’s health remains in serious jeopardy from unknown and untested chemicals. In the absence of company specific tracers discussed above, the list of well-
33 specific chemical analytes MUST be significantly increased to include numerous NON- NATURALLY OCCURRING toxic contaminants that do not have MCLs, as well as proppant resin chemicals (e.g., 2-butoxyethanol, formaldehyde, phenols). The presence of any of these parameters in freshwater resources (e.g., homeowner wells, springs, streams, lakes) should provide sufficient documentation of uncontrolled gas field excursions. Comparison of well water samples with only a limited number of Maximum Contaminant Level (MCL) chemicals may erroneously instill a false sense of potable water quality when people’s health may be adversely impacted. Even the gas industry acknowledges that more effort is required toward using non-toxic chemical additives (see HydroQuest DRBC Draft Regulation Comment Report 4-09-11, pages 39-41). We strongly recommend that the gas drilling regulations in New York State not be contemplated as complete until such time as toxicologists have fully reviewed all gas field chemicals and worked with State Health Department experts to revise and upgrade MCL drinking water standards. This upgrade should include full public review and comment.
13.0 Preliminary Well Testing Requirements should be Mandated by Regulation
The revised draft SGEIS regulations should require preliminary testing to confirm that NO hydraulic connection is present along fracture pathways between planned gas wells and homeowner wells within a radial distance of at least 2,100 feet, as determined by a short-term (~ 24 hr), high-yield, pumping test. Because horizontal components of gas wells extend may thousands of feet and may intersect numerous planar vertical pathways, large-scale aquifer degradation is possible. Mapping of existing fractures should be completed before promulgating regulations in order to assess the probability of risk of contamination. Initially, aquifer degradation can be expected above and adjacent to boreholes with poor grout seals. With time and successive hydrofracturing episodes conducted in individual wells, methane and LNAPLs that are released upward through fault planes and related fractures will widely contaminate freshwater aquifers and surface water receptors. As discussed previously, at best, industry sealant technology used to isolate and protect freshwater aquifers will fail within 100 years - generally far less.
While long-term aquifer contamination is assured, regulatory agencies and homeowners can predict and therefore decrease the immediate risk of contaminant migration to their water supplies by requiring basic hydrologic testing in advance of production well development. As put forth in the HydroQuest April 9, 2011 comment report to the DRBC, 2,000 feet should be considered as the minimum groundwater monitoring distance. Recently (October 2011), scientists at Pennsylvania State University completed a report on The Impact of Marcellus gas Drilling on Rural Drinking Water Supplies. In it, based on increased bromide concentrations detected near Marcellus gas well sites, they recommend that a 3,000 foot distance between the location of gas wells and nearby private water wells may be a reasonable water testing distance. The schematic below depicts geologic and hydrologic features exposed along a fracture face. Water table drawdown (depicted with inverted triangles) is shown advancing downward and outward during a short-term (~ 24 hr), high-yield, pumping test designed to ascertain whether there is a hydraulic connection along fractures between planned gas wells and a homeowner wells. All homeowner and farm wells should be electronically monitored with transducers before, during, and after aquifer testing. If a hydraulic connection is determined via pumping,
34 then the planned gas production well should be abandoned and completed as a water supply well, or plugged and abandoned as per regulations. This testing should be mandatory on all planned wells before they are drilled below the base of freshwater aquifers. There is absolutely no reason to not require and conduct this preventive testing for all planned gas wells. No additional gas wells should be drilled without conducting this basic, simple, testing procedure.
35 Conclusions
The well sealant technology available today is not capable of protecting our freshwater aquifers in the long-term. It is not a question of whether aquifer contamination will occur, but rather one of when. To advance gas well drilling in New York State and elsewhere knowing this would be irresponsible. Should gas wells be permitted in New York State despite this fact, it is critically important to add non-naturally occurring tracers to all drilling and hydraulic fracturing fluids. Otherwise, adversely impacted residents of New York State will needlessly be placed in an untenable position. There is NO sound reason why NYSDEC should not require tracer additions immediately, even before a newly revised SGEIS is completed.
Prior to promulgation of New York State gas drilling regulations, it is first necessary to thoroughly evaluate ALL the hydrogeologic, seismic, sealant, floodplain, karst, endangered species, and environmental issues raised in this report and in the April 9, 2011 HydroQuest report (incorporated by reference in this report). It would be prudent to adopt a moratorium on all drilling activities until after this is complete and has been publicly evaluated in the form of a newly revised SGEIS.
The risk to New York State’s groundwater and surface water quality is too great to fail to adopt or maintain a moratorium and undertake additional comprehensive environmental analyses. Furthermore, as written, the draft regulations do not adequately address the long-term liability associated with failed and failing gas wells. The regulations should be amended so that the NYSDEC and its officers and the Governor, as New York State’s permitting and regulating authority, become legally and financially responsible for short and long-term aquifer and stream degradation should they at any time release project sponsors from long-term liability.
Finally, we concur with Congressman Maurice Hinchey’s determination that shale gas drilling has been proliferating rapidly across the country and, unfortunately, too many states have not taken the necessary steps to protect our communities, water resources, air quality, and public health. Furthermore, we agree with him that New York must not follow this path, and we urge NYSDEC to withdraw the revised draft SGEIS and restart the process to ensure that the end product fully addresses the scope of the challenges hydraulic fracturing presents.
Sincerely,
Paul A. Rubin Hydrogeologist HydroQuest
36 References
McDaniel, R.R., Borges, J.F. and Dakshindas, S.S., 2007, A New Environmentally Acceptable Technique for Determination of Propped Fracture Height and Width. SPE 109969, SPE Annual Technical Conference and Exhibition, 11-14 November 2007, Anaheim, California.
McDaniel, R.R., Holmes, D.V., Borges, J.F., Bajoie, B.J., Peeples, C.R. and Gardner, R.P., 2009, Determining Propped Fracture Width From a New Tracer Technology. SPE 119545, SPE Hydraulic Fracturing Technology Conference, 19-21 January 2009, The Woodlands, Texas.
Palmer, A.N. and Rubin, P.A., 2007, Karst of the Silurian-Devonian Carbonates in Eastern New York State, with emphasis on the Cobleskill Plateau. Guidebook for the Hudson-Mohawk Professional Geologists’ Association Spring 2007 Field Trip, “Carbonate Geology of the Howes Cave Area, Schoharie County, New York”, p. 17-35.
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