The dSGEIS fails to adequately address frack waste disposal.
There is nowhere to safely dispose of frack waste in New York state. No drillingpermit should be issued without a final disposition plan for frack waste.
The lack of facilities to dispose of fracking wastes is emblematic of the State’s lack of preparedness for horizontal hydrofracking shale. The dSGEIS attempts to mask this lack of preparedness by speculating on how frack waste
disposed of in Section5.13.3, but does not require any those solutions to be in place prior the issuance of permits, nor does it require the permit applicant to show how the frack waste will befinally disposed of, it merely suggests that it will attempt to
such waste. To
exactly ? Frack waste from Pennsylvania was trucked into the state to the municipaltreatment plant at Auburn. The closest EPA permitted disposal wells are located acrosstwo state lines – in Ohio. Or, once in Pennsylvania, a New York frack waste truck maysimply dump it into the nearest trout stream.
The “bootlegging” of frack waste acrossstate lines has drawn the scrutiny of the EPA.
Proceeding without adequate preparation simply repeats the mistakes on frack wastemade in Pennsylvania. That state issued permits without any clear disposal plan in placefor the frack waste generated. The results were shameful.
The SGEIS lists various ideasof how to address frack waste disposal – but offers no conclusive solutions. There areonly 6 permitted disposal wells in New York, only 3 of which take brine, none of whichtake fracking flowback.
Texas has almost 12,000 EPA permitted disposal wells or a totalof 50,000 including injection wells that can take produced water.
5.12.2. 1 Recycling of Fracking Flowback
The proposed regulations mention re-use, but re-use is not disposal; it simply increasesthe net toxicity and radioactivity with each re-use - to the point of becoming to “hot tohandle” and too toxic to move safely on rural roads.
5.13.3 Flowback Water
Cumulatively, the DEC’s proposed dSGEIS would facilitate the production of billions of