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Testimony of the NRDC at Hydrofracking Forum

Testimony of the NRDC at Hydrofracking Forum

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Published by: New York State Senate Democratic Conference on Apr 30, 2012
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FROM: (Mrs.) Jeannette P. Rice, Concerned NYS resident, taxpayer, and grandmother 31 Pond Hill Road Rensselaerville, NY 12147 518-797-9812 RE: NYS Senate Hearing on Hydraulic Fracturing in New York State Legislative Office Building, Hearing Room B, Albany, NY

DATE: April 25, 2012

Thank you for the opportunity to share my concerns about natural gas extraction in New York State, and particularly, my concerns about natural gas extraction in Albany County. Summary of Testimony:

any hydraulic fracturing activity will be separated by layers of impermeable rocks, thereby protecting groundwater. 2) Marcellus shale is <1,000 feet below the surface in the "Hilltowns" of Western Albany County; Utica shale is 2,000 to 4,000 feet beneath the surface of all of Albany County and is about 300 to 350 feet thick.
3) The EPA Pavillion, Wyoming Draft Groundwater Investigation finds that chemicals

1) The natural gas industry claims ~t

detected in samples are consistent with migration from areas of gas production. The natural gas drilling depths to Utica shale in Albany County and to the Marcellus shale in much ofNYS is similar to the drilling depth of that in Pavillion, Wyoming.
4) All or part of27 NYS counties overlying the Marcellus shale have a depth to the top

of the Marcellus shale <3,000 feet.
5) There is evidence that deep fissures and fractures are naturally present in Albany County and throughout NYS. These geological features, along with Karst topography,

can provide natural conduits for drilling/fracking contaminants to pollute clean water sources though out the State, including the Alcove and Basic Reservoirs, that supply water to the City of Albany and the Town of Bethlehem Water District #1.
6) Groundwater andlor contaminants follow a natural flow from higher elevations to areas of lower elevations, and can eventually end up in bedrock aquifers, unconsolidated aquifers, and reservoirs. 7) Set backs to private water wells are an arbitrary distance.

8) There is concern about well casing failure and drilling/fracking contaminants that remain in the ground. As of 2008, 57,000 gas wells in NYS remain unplugged. This elicits a "no Confidence" response in DEC's future ability to monitor gas extraction activities. 1

9) Naturally occurring seismic activity, induced seismic activity and the HF process increases the risk to well casing integrity; there is an increased opportunity for the intersection of induced fractures with natural fractures, increasing the risk of contaminant migration that may potentially result in groundwater contamination. 10) Historically, ~S has been a minor producer of oil and gas, with the majority of active gas wells having been located in Chautauqua County. There have been numerous complaints of potential surface water contamination and suspected groundwater contamination of private water wells in Chautauqua County.
11) Extracting natural gas in NYS will not have a major impact on National energy

security. 12) Outdated information was used to identify natural gas as the "best" form of energy to sustain our energy needs.

Given the potential problems described in this document, hydraulic fracto ring and natural gas operations in or near the Hilltowns, Albany County, and NYS, would pose significant risk to water quality. Natural gas extraction operations are inconsistent with the goal of providing clean water resources to its residents. These statements are based on the uncertain distribution of natural fractures, and the known patterns of natural groundwater flow, as described in detail in this document. Quite simply: ./ NYS does not have to engage in hydraulic fracking or natural gas extraction activities .••. ./ Given the risks of natural gas operations to our clean water resources, NYS should not support natural gas extraction • ./ Natural gas extraction is contrary to the Declaration of Policy ECL Article 10101; it cannot be demonstrated that HF activity is consistent with our fundamental concern for the quality of our environment and quality of.Ufe, ./ New York State needs to fully protect the health, safety, and well being of its citizens and fully protect its clean water resources; NYS needs to fully protect our water and air resources, agriculture, tourism, and way of life. We do not need to tum our beautiful rural areas into heavy industrial zones . ./ NYS can be the national leaders as the "clean water state" - the agriculture and tourism state. NYS can develop its hydro-electric power and sustainable renewable energy; NYS can lead the nation in energy conservation and lifestyle changes, This is where our strength and hope for the future lies.

" ... it is less expensive to prevent pollution than pay for remediation for environmental problems, health care costs, and lawsuit expenses."-.
(#3 1992 Findings Statement for Gas and Oil GEIS)


Marcellus Perf/Frac TVDs (Line)
















Frac stagl!s (sorted on Perl Midpointl

1) Potential Fluid Migration. Faults & Fractures: The natural gas industry claims that any hydraulic fracturing activity will be separated by layers of impermeable rocks, thereby protecting groundwater. The graph above shows that fracking of gas-containing-shale formations is thousands of feet away from the deepest aquifer.' The development of natural gas relies upon the vertical separation of distance and low permeability of separating rock strata to prevent migration of fluids between the gas bearing formations and shallow aquifers. This gas industry "protective barrier" chart is exclusive of "the test of time" and other inherent problems with natural gas operations identified in the rdSGEIS, September, 2011. (ex: well casing failures, explosions, accidents ... ) Natural gas extraction in Pennsylvania, Ohio, and West Virginia occurs at a deeper level than Marcellus shale found in much of New York State.

Marcellus Shale Mapped Fracture Treatments (tVO)


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Utica Shale Layer in NY
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Marcellus and Utica shale in the Town of Rensselaervilleff: Depth of Marcellus shale: Rocky outcrop to 1,000 feet Thickness of Marcellus shale: <50 feet to 100 feet Depth of Utica shale 2,000 feet to 4,000 feet Thickness of Utica shale 300 feet to 350 feet

The "Hilltowns" in Western Albany County overlay a portion of the Marcellus shale fairway and all of Albany County overlays the Utica shale. In the Towns of Beme, Knox, Rensselaerville, and Westerlo, (the Hilltowns) the top of the Marcellus shale is <1,000 feet below the surface of the ground with outcrop.f Also, the evidence that there is high chloride content, iron, and methane in some deeper Hilltown water wells, is an indication that any impermeable barrier has already been naturally compromised, allowing the upward migration of chloride, methane, and iron from deeper layers into water wells. These naturally occurring fractures create hydraulic pathways between formations, and can be further compromised and propagated to interceptother naturally existing fracture during well development and stimulation or fracking."


According to internationally known hydrologist, Dr. Arthur N. Palmer, "It's inevitable that there are some natural fractures in the Town of Rensselaerville that extend to great depth. The town is located in an area of high relief, at the NE edge of the Appalachian Plateaus, where stresses from gravity, plus internal stresses within the earth's rocky crust, are able to produce major fractures that extend to great depth As is true elsewhere, most fissures are relatively small and tight, but there are probably many major ones in the Rensselaerville area because of its geologic position ... The elevated chloride, methane, and sulfur support the contentions that there are deep fissures. Also, the depth of water wells cited" IS unusually great. Elsewhere, most do not penetrate more than a few hundred feet. "

3) A study released in February, 2012 by the Energy Institute at the University of Texas at Austin states "there is at present little or no evidence of groundwater contamination from hydraulic fracturing of shale at normal depths. * (*footnoted in this study: 'Apparently in some cases, such as the Pavilion area, Wyoming, fracturing has been performed at depths shallower than normal for shale gas wells, which are typically more than 2,000 to 3,000jeetdeep.) No evidence of chemicals from hydraulic fracturing flUid has been found in aquifers as a result ojfracturing operations .... it appears that the risk of such chemical additives is greater from surface spills of undiluted chemicals than from actual fracturing activities. "" The report ends with these statements: "Gaps remain in understanding. espeCially in cumulative and lon~-term impacts. We are hobbled by a lack of baseline information." This is a significant argument against fracking. The EPA Pavillion, Wyoming Draft Groundwater Investigation released on December 8, 2011 finds that chemicals detected in samples are consistent with migration from areas of gas production, and that samples showing chemicals, like glycols and alcohols are consistent with gas production and hydraulic fracturing fluids. including benzenes in concentrations well above Safe Drinking Water Act standards and high methane levels. EPA indicates concern about the area's complex geology and the proximity of drinking water wells to groundwater contamination and the migration of contaminants within the aquifer and the safety of drinking water wells over time." The drilling depth of Pavillion. Wyoming and drilling depth to Utica shale in the Hilltowns is similar.

4) There are areas in New York State that currently have leases where the Marcellus shale is at a similar depth to that of the Pavilion Wyoming EPA study area. Out of 29 counties in NYS that overlay Marcellus shale, 27 counties overlay Marcellus shale where the depth to the top of the Marcellus shale is <3,000 feet. (See Figure 4.8 rdSGEIS, September, 2011.) The risk to groundwater contamination can also be increased by the presence of Karst formations, such as in Schoharie County, and in Albany County in the Towns of Knox, New Scotland, and parts of Berne, Rensselaerville, and Westerlo.


Should hydraulic fracturing or natural gas operations occur in these aforementioned areas, there is potential for contaminate migration via surface water, fissure and fractures, and Karst topography, not only down-slope to bedrock aquifers where many people have their private water wells drilled, but also to unconsolidated aquifers that supply hamlets with water, and also into the Alcove and Basic Reservoirs that supply water to the City of Albany and Town of Bethlehem Water District # 1.

~Iareellu$ Shale P.tapped Fracture Treatments (TVO)



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5) There is concern that deep fissures naturally present in the "Hilltown" bedrock extend through the Utica shale. "The best documentation of deep fissures is the escape oj gases and nasty fluids (saline, sulfur-rich) into normal water wells. Bob Jacobi used emanations of that sort to help map his fractures. vii Except for tracking seismic data generated by movement along faults, traditional geophysical methods are poorly effective in mapping normal fractures. Some large faults (with displacement of beds) can be mapped because the layers don't match on either side. But the geophysical methods capable of mapping simple fractures are very


uncertain and require a lot of experience and guesswork All of thefeatures listedare potential pathways for contaminants, but it would be impossible to say unequivocally that there are fractures that communicate with the Utica Shale. However, there's a chance that some do. As much as we know about geology, when it comes to local details such as specific fractures, not much can be predicted without extraordinary cost and effort. None of the maps show the depths of these features, because the depths vary so much, and their traces are visible only at the surface. Even at the surface, most of them are obscured by soil. The topic has to be approached from the standpoint of probability. The only valid source of this kind of information is contamination events that can clearly document. " (Dr. Arthur N. Palmer)
rdSGEIS 6.12.2 "By definition, faults are planes or ZOnes of broken or fractured rock in the subsurface. Geologic conditions associated with afault generally are unfavorable for hydraulic fracturing and economical production a/natural gas. "

The Petroleum Technology Transfer Council's manual for independent oil and gas operators outlines the risks of hydraulic fracturing stimulations penetrating into waterbearing zones even when shale barriers are present. "Even if natural barriers, such as dense shale layers, separate the different fluid zones and a good cement job exists, shales can heave and fracture near the wellbore. As a result of production, the pressure . differential across these shales allows fluid to migrate through the wellbore. More often, this type of failure is associated with stimulation attempts. Fractures break through the shale layer, or acids dissolve channels through it. "viii Another studyix released on March 29,2011, among its objectives, focuses on NYS's Marcellus shale region and uses simplified models and worst-case' release scenarios to evaluate drinking water risks due to surface releases to groundwater and surface water. and hypothetical migration from Marcellus to drinking water aquifers. The study concludes that transport of contaminants via fractures is highly unlikely in Marcellus shale to aquifers as they are separated by thousands of feet of low conductivity rock, and sites Kevin Fisher's report as evidence. The report also claims that HF induced fractures are expected to be constrained. However, Fisher's graph charts induced fractures nearing 2,000 feet in length, at a depth of about 6,000 to 8,000 feet deep. "Generally at shallower depths there is a greater tendency for more numerous and wider (more transmissive) fractures because of the diminishing confining pressure of overlying rocks. There is some probability that this would be a problem in the Rensselaerville area. There is not enough information to tell for certain, and importing data from other regions lacks site-specificity". x The study ends with the stated need for EPA case studies to validate their modeling results. One problem with the study is that sometimes modeling and stated conclusions do not fit with the reality of the local hydrogeology, such as in the Hilltowns. And, needed case studies are coming in, as evident from the Pavillion, Wyoming study that identifies migration ofHF contaminants into drinking water wells.

The depth and proximity of the Marcellus and Utica shale formations in the Towns of Berne, Knox, Rensselaerville, and 'Westerlo to groundwater or bedrock aquifers indicate that there is less vertical separation, or "buffer zone" between gas bearing target zones and aquifers, or drinking water sources, as shown in Fisher's graph above, In addition to evidence of naturally occurring fractures, the gas industry 7

cannot reliably predict or control the future growth of induced fractures. This leaves the clean water resources of citizens potentiaDy vulnerable to groundwater contamination should HF and gas extraction operations occur in the Hilltowns Also, it is "faulty thinking" that there is a natural protective barrier between the Marcellus and Utica shale that will unequivocally protect drinking water: "The Marcellus is underlain by about 100 jt of Onondaga Limestone, which contains large

fractures and bedding-plane partings (approx horizontal fissures between layers, very irregular ones). Beneath there's insoluble sandstone, Siltstone, and some shale, then another 100 jt of limestone (cliffs at Thacher Park). Beneath that is more shale & sandstone above the Utica Shale. All of them can leak, especially the limestones. Karst is rarely Significant at depths of thousands of feet, but it's very abundant near the surface a big threat where leakage at well-heads may take place. Even at great depth a few conduits canform by deep-seated fluids rising toward the surface (natural ones). "
(Dr. A. Palmer) Statements on EPA's 2004 study: From the dSGEIS September, 2011 Appendix 11. Section 1.2.3: • 1.2.3 Case studies of fracturing fiuid migration

"The literature review performed as part of the present study did not identify any published case histories or studies that included direct observation of the migration of frac fluids in hydraulically fractured shale. Studies offracturing fluid migration in geologic materials other than shale have shown some potential for migration beyond the propped portions of the induced fractures. In 2004, EPA summarized data on over two dozen mined-through studies in coalbed methane formations published between 1987"and 1993. In these studies, subsequent mining of subsurface coal seams allowed direct measurement of previous hydraulic fractures. Because shale does not have the economic value of coal and because shale gas formations are generally at much greater depths than coalbed methane deposits, there are no mined-through studies in shale. The coalbed studies indicated that fracturing fluids follow the natural fractures and can migrate into overlying formations. EPA also reported that in half the cases studies, fracturing fluids migrated farther than and in more 'complex patterns than predicted In several of the coalbed studies, thefrac fluids penetrated hundreds of feet beyond the propped fractures either along un-propped portions of the induced fractures or along natural fractures within the coal. "
(please be advised: As of February 6,2012, it has been noticed that this information above, from Appendix 11, section 1.2.3, along with graph data Figures 1-5, has been blocked from the DEC site. J.Rice)


Marcellus Shale Mapped fractUre T~tments (TVD)






Other unique geologic characteristics of Albany County: "intensely folded strata", June, 1992.
"consists offault blocks that have been thrust over ... ", "thick accumulation of glacial lake clay ... ", "exposed rock ... ., see "Soil Survey of Albany County", New York, USDA,

More About Faults!

A map of geologic faults and linear features in New York State was developed by Isachsen and McKendree in 1977, mainly as an aid to geologic interpretation. Notice the faults, shear zones, and fractures and other linear features shown in and near the Hilltowns. These features represent breaks in the bedrock and may act as potential migration pathways for fluids from deeper formations. Also, the mapped structures are only those that are observable, and geologists assume that there are many more fractures present and are not mapped, simply because of the brittle nature of the bedrock. Based on this mapping by Isachsen and McKendree, the Marcellus shale in the Town of Rensselaerville should not be considered an impermeable barrier, since there are fragmentations and fractures. xi


Notice the same map by Isachsen and McKendree, done in 1977, and included in the NYS DEC dSGEIS, September 201 I, Figure 4.13 Many brittle geological features that weredocumented by Isachsen and McKendree have been excluded. The deletion of such information could lead those who are responsible for making sound evaluations of data and risk to water quality from gas extraction to a different, and/or erroneous conclusion.

Water from potentially gas-bearing shale formations is generally not drinkable. However, it is evident from the methane, iron and chloride content in some Town of Rensselaerville water wells, that there are existing fractures that transmit fluids from deeper formations, and should hydraulic fracturing occur in the Town of Rensselaerville, fluids from such operations, including chemicals used in hydraulic fracturing could migrate to water wells. Some chloride detected in surface water downhill from roads probably comes from de-icing salts. 6) Groundwater Flow
Water and/or contaminants will follow a natural flow from higher elevations to areas of lower elevations, and will eventually end up in hamlet, unconsolidated aquifers, and reservoirs. Should gas extraction operations come to the Hilltowns, and should contaminants be released into the groundwater, contaminants would spread following this natural pattern offlow. The presence of fractures would increase the contaminant level and speed at which contaminants would move.
non-pumping well pumping well

Local Pattern of groundwater flow in the vicinity of water weils, before and after gas production. toward the valleys, interrupted only locally by pumping of wells. (Dr. Arthur N. Palmer)

Note the flow paths

During hydraulic fracturing activities, the purpose of fracking is to increase the permeability of rock, thereby providing a larger conduit for releasing natural gas. This fracking pressure forces fluids in all directions, especially vertically or horizontally, and the fluids can be driven upward through other layers or rock into aquifers. "Although typical aquifers are only hundreds of feet below the surface while shale gas production is pressure all the way to the surface if a significant and continuous network of fractures is

thousands offeet below, gas andfracking fluid can be driven by the highfracking


present." Naturally present fractures and those that have been created and enlarged by fracking will provide a pathway for fluid migration. Natural fractures tend to get wider upward, they offer the path of least resistance for fluid flow. Movement of contaminants toward the surface is most likely in the vicinity of valleys. where upward-flowing groundwater is dominant. xii 7) Setbacks to Private Water Wells The arbitary 500 foot setback distance of gas well pads from private water wells is quite inadequate to protect well water quality. nor is that distance part of the "best regulations" in the country. Indeed, Santa Fe County, New Mexico has a 750 foot setback:, and the Town of Flower Mud, Texas has a 1,500 foot setback distance. xiii

"The revised dSEIS affords limited protection to domestic well owners with a proposed 500ft buffer around domestic wells and springs unless waived by the homeowner. The 500 ft buffer around domestic wells does not take local geohydrologic conditions and topographic setting into account. Nearly all domestic wells in upland areas tap the fractured bedrock aquifer. The low storage in these aquifers relative to a sand and gravel aquifer means that changes brought about by drilling, including water quality changes, can be felt rapidly at significant distance from a disturbance -especially if a domestic well is downgradient 0/ a well pad Upland areas of thick till provide some level of protection to local domestic wells from drilling related accidents at land surface. Protection of individual wells on a site by site basis is notfeasible; however, siting well well pads immediately upslope of domestic wells in bedrock aquifer areas should be avoided and well pads should not be sited (as much as possible) where bedrock is exposed at land surface. ,>Xiv
See pg. 7-44 "NYSDOH recommends water well quality testing and private water well testing based on review offracturing fluid constituents and flowback characteristics. " • According to information in Ch 5;sec. 5.11.3, DEC describes the lack of information on fracturing chemicals from out-of-state operations and no direction or oversight of sample collections Of analysis efforts on DEC's part. Therefore, DEC and NYSDOH are making recommendations and decisions that will affect environment and health with incomplete data. The inherent risks of irreversible environmental damage from HVHF operations demands that DEC take direct responsibility for scientific studies before HVHF operations are considered to be allowed in NYS, and before any permits are considered. The operator will be responsible to test all residential water wells within 1,000' of the well pad, and if no contamination is detected a year after the last hydraulic fracturing event on the pad, then further routine monitoring should not be necessary. And, NYSDOH recommends the water well analysis listed in Table 7.3, which is not intended to constitute a comprehensive evaluation. • There is no recommendation to pre-test water wells for methane pollution. This pre-test needs to include methane analysis, as methane, as a result of HVHF operations, has compromised and polluted water sources. (Riverkeeper, Sept. 2010, and PA DEP) ,


• •

There is no requirement for gas operators to test private water wells for any chemical constituents of fracking fluids. According to the proposed regulations, gas operators may dispose of any water well testing records 5 years after the completion of gas well activities. Time and example have taught that sometimes contamination doesn't show up until years later... This can leave the homeowner and user of private water wells as their sole source for drinking water in a discouraging situation. If there is suspected pollution., the only recourse a private water well user has is to file a complaint. See dSGEIS, Sept., 2011, Ch. 7, pg. 48. This places the burden of proof on the citizen, leaving them with great legal, financial, and emotional stress.

8) Wen Casing Integrity and Fluids Remaining in the Ground: The dSGEIS readily acknowledges groundwater contamination from ongoing problems with gas extraction: accidental spills, blowouts and explosions, faulty cementing, well casing breaches, and more, and provides some systems for mitigating such problems. Proposals to mitigate such risks are included in the dSGEIS. According to research by Dr. Ron Bishop, Chemistry & Biochemistry Department, SUNY Oneonta, two to eight percent of shale gas wells developed by the intensive new technologies commonly fail. "The results have been fouled surface waters and aquifers,
polluted soil, contaminated groundwater, decreased livestock birth rates, and deaths from at least one explosion caused by irfiltrating gas." (report sustainableotsego)

There is concern about the volume of chemical contaminants that will remain in the ground after gas extraction ceases leaking: The 1992 GElS addresses well casing corrosion and deterioration due to the corrosive chemical environment and age. Although the gas industry states that it will be using improved materials, the dSGEIS does not address the cumulative impact of millions of gallons of chemicals remaining in the ground and well shafts. It is suggested that wells will have to be monitored into the future and possibly re-caulked if there are signs of deterioration. However, given that the NYS DEC Division of Mineral Resources (the lead agency in regulating natural gas extraction) has "consistently neglected to plug 89% of its depleted wells", monitoring offuture wells is of concern. As of2008, 57,000 gas wells in NYS remain unplugged. xv In addition., leaks have been shown to develop in half of well casings studied in just fifteen years. xvi (Also see 1992 GElS, Chapter XI Plugging and Abandonment of Oil and Gas Wells) The immediate and long-term effect of casing failure and deterioration, and release of chemicals into groundwater is of concern.


9) Naturally Occurring Seismic Activity:
dSGEIS, Sept. 2011 Effects of Seismicity OD Wellbore Integrity. Naturally occurring seismic activity in California damaged 14 (oil) wells. Also, see Youngstown, Ohio quake, Dec. 31, 2011 associated with 1.7 mile deep wastewater disposal well. The dSGElS gives DO scientific study or consideration to the potential environmental impact of naturally occurring seismic activity or to areas of special geological risk. See Executive Summary page 12-13: would be reviewed on a site-specific basis .. "
tl •••

Seismicity in Albany County (Earth Quakestvii • Table 4.2 Of all the counties that overlay Marcellus and Utica Shales, Albany County has a (disproportionately*) high number of recorded seismic events. (Dec. 1970 - July 2009) Albany County has 50 recorded events «2 - 3.9 magnitude), followed by Wyoming Co.- 13 recorded events «2 - 2.9 mag.), and Erie Co. -12 recorded events «2 - 2.9 mag.) 16 counties show no seismic events, 6 counties show 1-3 seismic events, and 3 counties show 7-8 seismic events. There have been 26 seismic events recorded between August 22, 2011 and August 28,2011. According to Won-Young Kim, research professor at Columbia's Lamont-Doherty Earth Observatory, " ... one of the issues that we do not understand, what is going on at this depth." There have been clusters of earthquakes in Knox and nearby Berne - 91 in total dating back to the 1980s. 37 earthquakes were recorded between February 2009 and March 2010. (Times Union Sept. 3,2011) Table 4.1 "Modified Mercalli Intensity Scale" indicates the effects that are "typically observed near the epicenter of a seismic event". Subsurface effects of naturally occurring seismic events are not indicated; The significance of rupturing of well sealants and casings has not become an issue until fairly recently. The epicenter for recorded seismic events for Albany County are mapped in SW Albany County. (Figure 4.15) Figure 4.13 shows two mapped fault lines and other smaller geologic faults mapped throughout the County. (This map in the dSGEIS has been "cleaned up.") 6.12.2 "By definition.faults are planes or zones of broken or fractured rock in the subsurface. Geologic conditions associated with afault generally are unfavorable for hydraulic fracturing and economical production of natural gas. " From the 1992 GElS: 9-11 "During the Waiting-an-Cement (WAC) time, there should be no activity ... any jostling can disturb the cement." It is suggested that there not be any truck traffic movement in the area while cement is drying, in addition to natural seismic activity concerns. (also see 16-18,19,20)

• • •

The disproportionately* high number of seismic events in Albany County increases the risk of adverse impacts to surface and groundwater resources.


The integrity of well casings, caps, plugs, and waste disposal wells have an increased risk of failure due to the naturally occurring seismic events in Albany County; that, along with inevitable casing deterioration, increase the potential for surface and groundwater contamination.
*"New York's history of earthquakes was also understated by the DEC. For example, Schoharie and Otsego Counties border on a "high risk" earthquake epicenter, not far from the NYC Watershed The SGEIS, however, lists Schoharie as having a total of seven earthquakes since 1970 and Otsego none. But a USGS database lists 91 earthquakes at this county border (Richmondville/East Worcester)in the same time period" (1. Maher-Johnson, SkyHill Farm, Cobleskill, NY) Also, fault maps published in 20~2 by independent geologist RD. Jacobi showing a web of deep basement faults that criss-cross NYS were not included in the dSGEIS, September 2011. (1. Maher-Johnson)

Chapter 8-2 dSGEIS Public input normally provided under SEQRA: o Issuance of a permit to drill when HVHF is proposed shallower than 2,000 ' anywhere along the entire proposed length of the wellbore; • Issuance 0/ a permit to drill when HVHF is proposed where the top of the target fracture zone at any point along the entire proposed length of the wellbore is <1,000' below the base a/a known fresh water supply,' (more) Given the shallow depth of the "Marcellus and Utica shale in the Hilltowns, it is currently not known if drilling permits would be issued by DEC for HVHF horizontal wells, single horizontal wells using <300,000 gallons of water, or for vertically hydraulically fractured wells.

10) Historically, New York State has been a minor producer of oil and gas. During the gas and oil boom of the 1970s-1980s, the majority of active gas wells were in Chatauqua County. xviii The Chautauqua County Department of Health, Division of Environmental Health Services, received numerous complaints of surface water contamination resulting from above ground well drilling activities and suspected groundwater contamination of private drinking water wells associated with drilling and hydraulic fracturing. The Chautauqua County Health Depannent responded to 120 complaints between 1986 and 1988 and as drilling activity decreased, so did the complaints. A representative from NYS DEC Division of Minerals insisted that the potential for drinking water well contamination from oil and gas well drilling is almost non-existent. xix Also see: http://www.toxicstargeting.comIM:arcellusShaleidocumentsldec-letter



New York State's Marcellus Shale Gas Does Not Add Significantly To The US Energy Supply Or Energy Security
120 .~--------------------------------~--

. Annual US Energy


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Nuclear Hydro Marcellus
Natural Gas




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WitnoUit Marcellus Gas

With MarceUus GasH OH

Assuming 2,000 new weDsare drilled each year in New York, New York's share of the Marcellus shale gas adds less than 1% to the annual US energy supply.
• • • • • Less than 20010 of the Marcellus shale gas lies in New York l No scientifically-reviewed estimates of the amount of gas have been published; the box at right uses 250 trillion cubic feet, five times the original estimate2 but half the highest number reported in the media3 Production from shale gas weUs declines a lot with time (~5001othe first year) and drilling all the required wells will take many years. Because old wells decline even as new ones come on-line, not a lot of gas is produced in any one year. The gas industry bas an incentive to overstate the total amount of gas because it is trying to attract investors and convince people to lease. Investing in non-fossil fuel energy alternatives and conservation measures can add as much or more energy to the US energy supply without the negative environmental, health, economic, and societal impacts tbat accompany shale gas extraction. See, for example, "A Path To Sustainable Energy by 2030,» Scientific American, November 2009, by Mark Jacobson and Mark Delucchi.

Increasing Natural Gas Does Not Improve Energy Security Extracting natural gas does not reduce dependence on foreign oil because natural gas and oil are used differently: two-thirds of oil is used for transportation, but natural gas cannot be used for transportation without large investments to change vehicles and Infrastructure. Gas and oil use overlap only in space heating, but less than 20% of 011 is used for space heating.4 According to Alan Krueger, Assistant Secretary for Economic Policy at the US Treasury, using less oil and investing in clean technologies are more effective at Increasing our energy security than is increasing domestic fossil fuel production.5
1 Draft SGEIS, page 4-24.

2 Engelder T., and Lash, G.G. 2008. ''Marcellus shale play's vast resource potential. creating stir in Appalachia. " American Oil and Gas Reporter, v. 51, No.6, pp. 76-87


3 Engelder, T. 2009. ''Marcellus 2008; Report Card on the Breakout Year for Gas Productivity in the Appalacbin Basin, Fort WOfth Basin Oil & Gas Magazine. August 2009, pp. 19-22. 4 Energy Information Administration (ElA). See data at bttp;/ltonto.eia.doe.gov/dnav/petlpet_cons_PllUp_dc_llllS_mbbl_a.htm and http://tonlo.eia.doe.gov/dnav/ngfng_ coos_sum_ dcu _nus _a.htm. 5 Kroeger, Alan B. October 15,2009. Remarks at American Tax Policy Institllte Coofereace, Washington, DC. http;llwww.ustreas.gov/officesleconomic-policv/AK-ATPI-1015.pdf


Marcellus Accountabili!I_ P~ns




"Best" Form of Energy

Chapter 9 dSGEIS: Natural gas is identified as the "best" form of energy for NYS based on outdated information referred to in Chapter 21, 1992 GElS, Table 21.1. "Alternate Energy Sources and Associated Adverse Impacts". The information in this table is incomplete as there is no reference to new solar technologies, wind energy, ethanol, tidal current production of energy ... and, is highly subjective. There is also no surveyor discussion of the kinds of energy the general public is willing to transition to, nor is there any discussion of more energy efficient community planning, life-style changes, or conservation measures.
<The sacrifices the general public is expected to make to permit natural gas extraction are unacceptable. Natural gas is a finite, limited energy resource, and HVHF activity is not consistent with our clean water and air resources, agriculture, and way of life. *Just as there were economic and lifestyle changes that occurred when this country transitioned from "sea oil" to "land oil" i.u the mid-1800s, there win be changes made in this necessary transition to renewable/sustainable energy forms, *NYS DEC needs to suspend its quest for natural gas, be a leader in the county, and transition the public to renewable energy resources, backed by better community planning, life-style changes, and energy conservation measures.
~."Data Confinn Safety of Well Fracturing", Kevin Fisher, The American Oil & Gas Reporter, July, 2010 " MCOR www.marcellus.psu.edu ~I NYS DEC rdSGEIS, September, 2011, Figure 4.2 & Figure 4.8. "Final Impact Assessment Report", NYC DEP, Hazen & Sawyer, Environmental Engineers & Scientists, December 2009, p. 13. • "Fact-Based Regulatiion for Environmental Protection in Shale Gas Development", Charles G. Groat, Thomas W. Grimshae, Energy Institute, The University ofTexas at Austin, February, 2012, p. 22. ~."EPAReleases Draft Findings of Pavillion, Wyoming Ground Water", EPA, December 8,2011 . ." "Basement Faults and Seismicity in the Appalachian Basin of New York. State", Robert D. Jacobi, UB Rock Fracture Group, Geology Department, SUNY at Bllffalo, April 26, 2002. viii "Produced Water and Associated Issues - Manual for the independent operator", Rodney R Reynolds, Prepared far the South Midcontinent Region of the Petroleum Technology Transfer (PTIC) and Oklahoma Geological Survey (OK Geological Survey Openfile Report 6-2003). http://www.pttC.OfEYDwmlpw stoc.httn#toc2 . ix "Modeling Drinking Water Related Human Health Risks from Hydraulic Fracturing (HF) Additives", MIIJIIISharma, M.S.,P.E., Gradient, Cambridge, MA, EPA Woxkshop, March 29, 2011. x Dr. Arlhur N. Palmer, March 4, 2012 coWl to J. Rice. xi "Final Impact Assessment Report, NYC DEP, p.l4-15. >il "Some Concerns about High-Pressure Hydrofracturing of Shale Gas Reservoirs", Arthur N. Palmer, Professor Emeritus, Water Resources, SUNY Oneonta, January 23, 2012. "'"''Wont Fracking Regulations inthe United States", James L. Northrup, Cooperstown. NY. http://www.scribd.comIdoc!7254S747IWcm-Fraclcing-RegE xiv "U.S. Geological Survey, New Y <Ilk Water Science Center Comments on tbe rdSGEIS", John Williams. .. "History of Oil and Gas Well Abandonment in New York", Ronald E. Bishop, Ph.D. C.H.O., Chemistry & Biology Departmeut, SUNY College at Oneonta. X'oi Claudio Brufatto, Jamie Cochran, Lee Conn, David Power, Said Zaki Abd Alia EI-Zeghaty, Bernard Fraboulet, Tom Griffin, Simon James, Trevor Munk. Ferderico Justus, Joseph R. Levine, Carl Montgomery, Dominic Murphy, Jochen Pfeiffer, Tiraputra Pompoch, ~d Lan Rjshmani (2003), "From Mud to Cement _ Building Gas Wells", Oilfield Review (Schlllmberger), Angust 2003, P 62-76. m. NYS DEC dSGEIS, September zen, mil ''DisposallRecovery Option for Brine Waters from Oil & Gas Production in New York", (Energy Authority Agreement No. 1591~ ERER-RIER-91) Mark R. Matsumoto & o1hCl"s,. SUNY at Buffalo, October 9, 1992. xix Letter "Impacts of Gas Well Drillingto Drinking Water Wells", William T. Bona, Water Resource Specialist, Chautauqua County Department ofHea1tb, Division of Environmental Health Services, July 30, 2004.


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H: 46 FAX 5184263052



HALL R CLOT.BIER BUILDING MAYVn..LE, NEW YORK 14757-1027 (716) 7534481. lAX (716) 753-4344
ComntiJlio1l8r o{Hetzllh STEVEN M. JOHNSON. P.

DirectDr ofEnwronmenral HeaJthServices

Re: D~}

Impacts of Gas Well Drilling to Drinking Water Wells

In response to your request regarding potentia! impacts of oil and gas well drilling to nearby water wells,
I offer the following comments.' As you know, the New York State Department of Environmental Conservation (NYS DEC) regulates oil and gas well drilling in the state. The regulations that govern the industry were prepared bl 1972 and no major changes have been made since then. There have been some efforts to substantially revise these regulations, mostrecently in 1998, but they were never finalized. New York regulations do not contain any requirements for offset distances beh¥een an oil and gas well and private water wells. They do require that oil and gas wells be located at least 1000 feet away from a public water sUpply we~. This would include the Jamestown Audubon's well. In addition' the current regulations do not include any provisions that cover stimulating or hydraulically fracturing the gas reservoirs (i.e. hydro-fracturing).

A representative I spoke with at the NYS DEC. Division of Minerals insists that the potential for drinking water well contamination by oil and gas well drilling is .~ However, this Department has investigated numerous complaints of potential contamination problems resulting from oil and.gas well drilling: activities. Most of these investigations took place in the·1970s and <gOs during the oil and gas dnlling boom. They can'be categorized intO twO. groups: surface water contamination ~used by above ground drilling-related activities, and suspected ground water contamin~tion ofpriYatt drinking water wells asSociated with drilling and hydro-fracturing. One of the most widespread problems was in the Levant area in the Town of Poland in the early 19805 where methane gas was intruding into water wells. In response to this, the Health Department began to keep detailed. records of complaints received of water well problems suspected of being caused by oil. and gas well drilling. The Depaitment responded to 120 of these complaints between 1986 and 1988. As drilling activity , decreased, so did the complaints, we responded to only nine from 1989 to 1990' and, over the past 12 years since I've been with the Department, we have recejved about Ii dozen such complaint.s. Those complaints that were reported are probably just a fraction of actual problems that occurred:, ~ The Pennsylvania Department of Environment a! Protection (P A DEP) has much more stringent regulations with respect to oil and gas well drilling. They.require that oil and gas wells be drilled at least 500 feet away from private drinking water wells' and at least 1000 feet away from public water supply wells. If oil and gas wen s are to be drill ed within 1000 feet of a private well. then the water wen must be


14:47 FA! 5184263052

Page 2 tested by the 'drilling company before the gas well 'is drilled and again between three and four weeks after the well is completed for a number ofbaseline chemicals. If the oil and gas well is located within a known ground water recharge area of a public water supply well. that water well must also be tested as noted above. . A colleague with ourDepartment contacted a senior engineer in P A DEP who indicated that the have co ed numerous mstances were water wells had been negativdy impacted by oil and Q:aswell, , driIlinS. _These impacts were seen in pans of the state that have a similar geologic setting as o~ county. namely in the Allegheny Plateau. A detailed review of our files found correspondence from the United States Geological Survey (USGS) regarding the likelihood oil and gas weI! drilling to contaminate nearby water wells with methane gas. This was in response to the previously mentioned problem in Levant. The USGS noted that methane e-as could "misrrate into water wells at considerable distances from the 2as wells where the gas encountered the [rock] fracture §Ystem. The problem is not unique tQ ChautauQua County, Similar problems occur in northwest Pennsylvania and northern Ohio as far west as Cleveland and Sandusky." The close of the letter reads: "In conclusion, the most likely source oftbe [methane] gas is the open boreholes of the producing gas wells." I've attached a copy of this letter as it __ . also makes recommendations about how to reduce the contamination potential.


Ifthe Jamestown Audubon Society pursues a lease with an oil 'and gas drilling company, I recommend that you: take the following precautions to minimize the possibility of ground water contamination. It is also important to consider that most oil and gas wells drilled in the county, there are about 5000 of them, have had no known impact to our water resources, .. Require a 1000 ft setback from the Jamestown Audubon water well and reasonable setbacks ' from private water wells. either 500 or 1000 ft at your discretion .(if directional drilling is used then the setback should consider the location of both the wellhead and the well bottom). .. Conduct baseline water quality sampling in the Jamestown Audubon well and surrounding private water wells for: iron, manganese) chlorides, sodium, barium, total dissolved solids, pfl, .turbidity, bacteria and methane/ethane. Water samples should be collected and analyzed by a NYSDOH certified laboratory. This could be made a requirement of the drilling company in the lease. • Hire a consultant who is knowledgeable about oil and gas well dril1ing who could provide comments on the land lease, site plans and drilling plans, and also provides drilling inspection, • Place adequate restrictions and.safeguards in 'the lease to protect ground- and surface-water quality including the preparation and implemention of a storm water management plan that includes on-site erosion control measures. Please note that an area surrounding the Route 62 - Riverside Road intersect-jon has been mapped by the USGS (Miller, 1988) as overlying a "principal aquifer." New York State DEC oil and gas well drilling regulations state, "The casing and cementing practices above are designed for typical surface casing cementing. The Department will require additional measures for wells drilled in environmentally or technically sensitive areas (i,e. primary or principal aquifers). NYS DEC oil and gas well regulations can found at htto:/Ivv.ww.dec_state.ny.uslwebsiteldmnlwelltrg.htm. . ,



.' u···

July 30, 2004 age 3'


Should you or the Board of Directors of the Jamestown Audubon have w'y questions regarding this correspondence, or you would like to review any of the information cited herein, feel free to contact me at 753-4481. .

William T. Boria Water Resource Specialist






14;47 FAX 5184253052

Ial 004

~':".', I!J
> -. ,J..i.



United States Department of the Interior





(518) 472-310'7




1984 '

Ecuse of Re?~:s~~~acives Washington, D.C. 20515 Dear Congressman Lundine:


Eon. Stan Lundine

We have revie'Jed the several reports -pert.s.inin~ to tbe "methane.-gas p rob Lem" in ChalJtauqua County in response to your reque'st of July 30, 1984.. At your suggestion, we cout ac t.ed _your District Representative, ·Pat Kinney, 'Who g r aciou.sly sup p Li e d u.s 'With consultant reports. oral, s tatel'llents, and some leads ·to more in£o~tio'C. Most r e ce n t l y , ii'e received the New York State De-psrtment pf Enviro~mental Conservation's (NYSD~C) initial ~eport on the incident. We feel tha ~ fi·eid inve 5 t i gat i o ns by the State and consul tants a r e sufficient to a l l cv interpretation and ~valuation of thei~ ~onc.los1ons. Despite some discrepancies in the z epo r t s and a lack of the following coeaae n t.s , which include those of a me.mber . Division, Oil and Gas Resources. Our c01lllIleots· are: 1) Natural



d e t a we offer

our Geolegic

ip.:e r c onne c:. teJ

gas is present in abundance in the b Lack upper Devonian gas shales. has been piovid"ad commercially in Ch"atitauqua COl:loty since' 18'21. Tb i.s gas moves- f~om the organ·ie: material, in the black ah a Le s into f rac tures W"h~re it: may ac.cumu 1a t e >lnde_t:.cons iderab le pre.s sure. It may a 1 migrate vet' t ieally for hundreds or thousands oE feet laterally or ~ertically iE a syscem of




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part of Chautauqua County where the Devonia~ gas shal~s are near the surface. Natural gas bubbles.up in Lake Erie and gas seeps are cornman in many locilities in the streams draining i~to Lake E~i~,
2) The most lik.ely source of the gas is shale bedrock, from which gas is migrating u~w~rd into sha.llow permeable zones through the ~ncased iections of 'producing Sa.! wells. Commonly, Some 2,000 teet: of Devonian sha'l e 'bedrock. is left uncas~d and uncemented between the cement cap above the gasp roducing Medina fOnJL2.tion and the cer..ented-in su r f ac e casiag·,

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The na tura.l pre sence of ~rac tun s (join ts. bedding pla.lle s, faul ts) in all" rock enables m~grat~otl of fldids or gasesj and th~ directiou of flow de ends on t e pressure gra unts.' U~~ ;Ltlcre.ased gradient chan es induced b d~~l 1ng act~~1tlesJ earthquakes, or injection pressures can cause a . cha.nge in the movement. of fluids or gases. 'Marsh or swamp gas is found in wetland sedimeats. It se~ms unlikely that such gas would migrate Laterally iIl.,. unconsolidated material becaus e it call rea.dily diffuse upward to the' at.lllosphere, especially il1 an area of permeable surficLal material, whe.e precipitation Can readily re'ehs'rge the formation in whi~h the gas is being gene.ated. The chemical analyses of the gas emitted f.om th~ soil are too variable to be conclusive. It wo~ld have helped to analyze ga. froQ the well Waters i:tvolved t.o see if ga~ "ere ~llt,erittg .a deeper ~o.nes. t



In conclusion. the most likely source of the gas is the open boreholes of the producing gas yells. We understand it LS standar~ practice that gas wells are completed without a cemented- outer easing that extends to t.he producing horizon. It would seem prudent t·o reconsider·this practi.ce because of the risk or migration of any encQunt.e,red gas (al .... ay!'! under pressure) and associated bri-' nes in an uncas~d hole.
We will

keep abreast







and your Distric~ Representative.

F"or The District Since rely yours

,,;0,.- ...

R~ger Waller
District RW:cmm cc : Kinney Ground Wate" Specialist


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