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It Does Not Know What They Are New York State has no standards for seismic testing, no setbacks for seismic test blasts - except on state land. Meaning a seismic crew can shoot a shot-hole with dynamite anywhere in the state, including next to a daycare center – so far as the DEC cares. Needless to say, this is not the case in other states that actually know how to regulate oil and gas production, and, unlike the DEC, have a complete set of rules and regulations, including setbacks for seismic tests : Montana – 1,320 feet from any building, water well or spring North Dakota – 600 feet from buildings, water wells, springs Wyoming - 1,320 from building or water well Maryland – 500 feet from a building Oklahoma – 200 feet from a water well Arkansas – 200 feet from a residence Louisiana – 1,000 feet from a boat Boats in Louisiana have more protection from seismic testing than do residents of New York. Why are New York’s seismic regulations nonexistent ? Two reasons: If the DEC had regulations on seismic tests, they would have to actually enforce those regulations, which the DEC does not want to do.1 Secondly, the DEC has consistently deferred to local land use ordinances, leaving the municipalities the task of dealing with the impacts of shale gas industrialization, including seismic testing. 2 In the absence of local ordinances, New Yorkers are left with no protection from the hazards of seismic tests. Why did the DEC completely ignore seismic testing ? The 2009 DSGEIS addressed naturally occurring seismic events (ie. earthquakes) in Chapter 4, but was silent on the impacts seismic tests via shot-hole blasts, which are commonly used to locate subsurface gas reservoirs including shale gas targets. This oversight persisted in the 2011 RDSGEIS. The 2011 RDSGEIS
http://www.scribd.com/doc/76085928/Worst-Practices-at-the-DEC http://www.scribd.com/doc/63141534/NY-Gas-Well-Zoning 1
discusses earthquakes - and seismically induced fractures from fracking operations, but does not include any analysis of the potential impacts or mitigation needed for seismic blasts used to target shale formations for drilling. These seismic tests are also useful to identify local fault systems, which are both poorly understood in New York, and, according to the USGS, are understated by the DEC. 3 In January 2011, NYS’ consultant, Alpha Geoscience provided a misguided recommendation to NYSDEC to ignore seismic data collection mitigation in the RDSGEIS, as “irrelevant.” Because seismic data collection is typically the first step in unexplored areas, seismic tests to identify localized faulting is hardly “irrelevant.” Absent any mention in the SGEIS, it is unclear whether NYSDEC is even familiar with the use of seismic tests to target shale formations or localized faults - or whether shale gas operators have told NYSDEC that they don’t intend to collect seismic data prior to exploring in the Marcellus Shale. If the latter is the case, localized faulting in New York will continue to remain a mystery – at risk of both aquifer pollution and the inducement of earthquakes. Seismic Testing Seismic exploration equipment is used to send shock waves into the earth. Shock waves are generated by a surface positioned source and are measured by a surface positioned receiver. The rate that seismic energy is transmitted and received through the earth crust provides information on the subsurface geology, because seismic waves reflect at different speeds and intensity off various rock strata and geologic structures. A seismic survey involves generating hundreds to tens of thousands of seismic source events, or shots, at various locations in the survey area. The seismic energy generated by each shot is detected and recorded by sensitive receivers (“geophones” ) at a variety of distances from the source location. Geophones are connected by long cables to relay the collected information back to a centralized computer.
For every source event, each geophone generates a seismogram or trace, which is a time series representing the earth movement at the receiver location. A record of all traces for each shot is transmitted to a computer for storage and conversion into a seamless crosssectional representation of the subsurface for subsequent study and interpretation by a trained geophysicist. Seismic operations involve generation of seismic vibrations by explosive energy sources or by mechanical sources. One type of energy source for seismic exploration is an explosive charge. Small holes (“shot- holes”), typically 4 inches in diameter are drilled into the earth surface, 10-60’ deep depending on surface terrain. Although, some drill holes have been drilled to 200 feet – deeper than most Upstate water wells. The hole must be drilled into a hard layer of soil that is sufficiently dense to carry the seismic wave. Explosive charges (typically 5-50 pounds each of dynamite) are lowered into the hole and detonated to create a shock wave. Most states have limits on the size of charges that can be deployed near environmentally sensitive areas, human inhabitation and near roadways. New York has no such limitations. Mechanical vibrators are an alternative to explosives. Mechanical vibrators can include: a pad that thumps the surface of the earth (“thumper trucks”), driven by gravity or compressed air; a truck that generates vibrations and compressed air guns. The use of thumper trucks is not considered best practice because it involves dropping a steel slab that weighs about three tons to the ground to create a seismic vibration. Thumper trucks are large, requiring extensive tree and vegetation removal, and can leave land scars. The absence of setbacks for seismic can create real problems, since the seismic blast can damage nearby water wells and springs. Seismic should be required as a condition of permitting Since localized faulting is poorly understood in New York,4 drillers should be required to shoot seismic on each lateral drilled – and submit their findings to the DEC for the purpose of mapping fault
systems. Setbacks should be established for seismic shoots Setbacks should be established for seismic shoots. This is an important issue to resolve, because seismic surveys can create significant surface impacts and disruptions and shot blasts can damage water wells. “Worst Practices” at the DEC The lack of any standards for seismic – either to require such tests or to regulate their use, is indicative of how lax the DEC has been on regulating oil and gas drilling. The DEC talks about industry’s “best practices” as if they were tantamount to regulations, which they are not, or a panacea, which they are not. When the DEC’s regulatory practices were audited in 1994, they flunked.5 Part of the problem is that the department that oversees gas drilling has never been adequately staffed. The DEC has never had adequate regulations. The DEC has very few regulations for gas wells. They have avoided making their generic guidelines, the GEIS, into a set of rules and regulations – since they would then have to abide by and enforce those regulations. The least prepared regulatory agency The DEC has neither the workforce nor the funding to regulate shale gas industrialization. All the DEC can do is prevaricate about how tough its shale gas regulations are. And grossly overstate the prospects for shale gas in the state.6 An activity that the DEC has no ability to adequately regulate, and that the state has no ability to tax. It is clear that the DEC does not thoroughly understand the technical and environmental challenges it faces. 7 The DEC has gone out of its way to understate those challenges and discount the hazards to the point of attempting to discredit sound science.8 This will only perpetuate New York’s abysmal regulations and lead to litigation.
http://www.scribd.com/doc/76085928/Worst-Practices-at-the-DEC http://my.brainshark.com/Voodoo-Frackonomics-663835911 7 http://www.scribd.com/doc/65577477/SGEIS-Well-Construction 8 http://www.scribd.com/doc/73405864/Anomaly-in-the-Duke-Methane-Study 4
Why is New York the worst prepared state in oil and gas ? Why does New York have the worst gas well regulations ? Why is New York the only state without a state tax on gas wells ? Why does New York have the worst compulsory integration law ? Because all of those indulgences have been have been paid for by the gas lobbyists in Albany.9 It is cheaper for the gas industry to bribe elected officials with campaign contributions than to pay a state tax on gas. It’s a bargain. It is easier to find a well location if there are no protections for surface uses. With the possible exception of Pennsylvania, no state has been more thoroughly corrupted by the gas lobby. Conclusions The DEC wrote three iterations of the dSGEIS, dozens of hearings and thousands of pages of boilerplate from there is no requirement for seismic testing on wall - and the setback for seismic testing is zero – from anything. The DEC has been compromised beyond repair. Under the circumstances, the only appropriate recourse left to a city or town is to prohibit shale gas industrialization within its corporate limits. If Albany ever gets its regulatory act together, if the industry ever demonstrates that they can tap shale gas without massively impairing the environment and surface uses, then the town can reconsider its prohibitions. Until then, it would be irresponsible for a New York town to allow shale gas industrialization under current conditions. Each town must protect itself.
James L. “Chip” Northrup Cooperstown
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