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Hydrogeologists on Hydrofracking
(High Volume Horizontal Hydrofracking with Slickwater)

On Faults and Seismicity
1. Geologist Robert Jacobi: "Not only are there more faults than previously expected ill NYS, but also, many of tbese faults are seismically active." And "most cultural facilities (e.g., waste disposal sites, bridges, pipelines) are not far from a potentially seismic fault:' (Basement Faults and Seismicity in the Appalachian Basin a/New York Stale. p.75, 105.) 2. US Geological Survey geologists wrote to the DEC about its use of an "outdated" fault map that "grossly under represents the number and extent of faults in the Appalachian Basin of New York". (Feb 2012, p. 10) They highly recommended Jacobi's maps instead. 3. NYC DEP: "Recently released research has documented that low magnitude earthquakes have been triggered by HVHF treatment of shale gas wells near Blackpool in the UK and possibly in Garvin County, OK. In both cases, tbe wells were vertical. The Blackpool site is in a region of Iow seismicity and the fault was unknown prior to the drilling and HVHF stimulation." (H-R Tech Memo, Dec 2011, p.v) 4. NYC DEP: "The Blackpool earthquakes and probably tbe Oklahoma earthquakes demonstrate that hydraulic fracturing can reach a nearby fault and can trigger a seismic event." (Jan 2012, p 8) 5. Hydrogeologist Paul Rubin: "Much of New York State is seismically active. Excessive lubrication of faults and fractures with higbly pressurized hydraulic fracturing fluids, bolstered by repeated hydrofracturing episodes, may result in fault activation and bedrock settlement [earthquakes],' (Jan 2012, p 14) 6. NYC DEP: "Induced earthquakes phenomenon. (Feb 2012, p.3) from [wastewater) injection wells are a well-known

7. Rubin: "Ground motions from even one significant earthquake. among many that occur over time, may catastrophically shear numerous gas well casings or, at tbe very least, may result in fracturing and loss of integrity of well casing cement designed to isolate freshwater aquifers from deep saline waters. As such, earthquakes may instantly destroy the integrity of hundreds of gas wells, thereby forever and irreparably compromising the hydrologic integrity of geologic formations that formerly protected freshwater aquifers. Restoration of contaminated freshwater aquifers is probably not possible ... ." (Nov 2010, p 1) Note on Recent Earthquakes in Albany: There have been 26 seismic events recorded between Aug 22-28, 2011 (Lamont-Doherty Earth Observatory) and 91 "in the Knox-Berne area dating back to the 1980s; between Feb 2009 and Mar 2012, 37 were recorded. (Times Union, Sept. 3, 2011) On Groundwater Flow and Contamination I. Hydrogeologist Arthur Palmer: "Any groundwater hydrologist knows that groundwater flow is not limited to shallow depths. The patterns and physics of flow have been quantified since the 20tb century and have been verified many thousands of times in the field. Even if there are no problems in and around drilling sites, the contaminants will move ... down gradient to the major river valleys .... " (Dec 2011, p 2)

Note on HVHHF Chemicals: Of the 632 chemicals currently being used in hydrofracking elsewhere, 353 have federal CAS numbers and can be researched. Of these 353, 37% are known endocrine disrupters and 25% are cancer and mutation causing. These statistics are from a peerreviewed study published in a science journal, Sept 2011. (www.endocrinedisruptors.com) 2. Palmer: "Natural fractures are widespread and unpredictable. Tbey [including vertical joints, major fault lines, and deep basement faults] offer tbe most likely patbways for rising Roids. Most Row follows major fractures, tbe way traffic follows interstate bigbways, and tberefore much groundwater, including contaminants, is concentrated in zones of relatively bigb-velocity Row, moving much faster than average grouadwater," (Mar 2012, pi) flow takes place tbrougb major fissures (joints, faults), and because the hydraulic bead is lower in tbese efficient chaanels, grouBdwater in surrounding areas converges toward tbem, and they provide major cbannels for contaminants." 4. Palmer: [Existing fractures enlarged and propped open by Cracking, or newly bydrofracked fractures of] "typically 500 feet", [will also serve to move deep fracking contaminants) "slowly but inevitably down gradient to tbe major river valleys. 10 tbe Appalachiaos, that bappens to be wbere most of the population centers and highest-yielding aquifers are located. And "this kind of cootamination bas a vile bistory ... remember DDT, PCB's ... T" (Dec 2011, p 3) 5. Palmer: "No landowner is allowed to contaminate water that flows onto ao adjacent property, and yet this happens regularly, out of sight below the surface. Many of tbe problems caused by hydrofracturing have involved contamination of neigbboring wells. Worst of all, contamination affects the entire down-flow part of tbe groundwater system and is not confined to tbe fracking site." (Mar 2012, p 4) 6. Palmer: "In the bydrofracturing process, up to 5 million gallons of water are injected into each well over its productive life. Usually no more that 2% of the fluid consists of additives tbat retard dogging and aid in gas recovery. There are more than 700 different eompoaents, most of them known or possible carcinogens. More than 200 are unidentified trade secrets. Once hydrofracturiog is completed, the Rowback of fluids accounts for an average of20-70% of the total fluid, leaving 30-80% in the ground." (Mar 2012, p 2) 7. Palmer offers "a crude example [of a contaminant load] based on reported concentrations, but it is the kind of approach needed if we are to assess the pros and coos of hydroCracturiog." Using the percentage of the known carcinogen (cancer-causing) benezene in one fracked well, Palmer calculates that one square mile, 600 ft deep, of underground formation can be initially saturated with an amount of benezene that is "more than 5000 times the EPA standard .... This scenario considers just a single contaminant in a single well. Additional wells will contribute." (Mar 2012, p 2) 8. Palmer: "The shale itself contains a variety of materials of concern, including toxic heavy metals and radium. Radium is tbe source of radon gas; botb are radioactive. Ordinarily these materials are not released into groundwater supplies because of the low permeability of sbale, but artificial fracturing tends to release them in unnatural quantities, and they are contained in the fluids withdrawn from tbe gas well." (Mar 2012, p 2)

3. Rubin: "Tbe most rapid [groundwater]

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9. Palmer: "While injection is taking place, (fracking) Ouids can easily be driven upward through intervening beds, including aquifers. This involves water, fracking nuids, and gases. The pressure is exerted not only vertically but in all directions, so contaminants, natural or introduced, can be injected into surrounding strata, including aquifers .... It doesn't matter tbat typical aquifers are only hundreds of feet below tbe surface while shale gas production is thousands of feet below. While fracking is in progress, the pressure in tbe shale is enough to drive fluids as high as the land surface if the rocks are permeable enough." He calculates that "high pressures, typically about 2500 pounds per square inch at the injection well ... is enough to raise a column of water to rise 1.09 miles." (Jan 2012, pi) 10. Retired Mobile Exe VP Lou Allstadt: "The (DEe's] draft SGEIS proposes that the target fracturing zone must be toOO feet below the deepest drinking water 2000 feet below the surface, whichever is deeper. (But mdustry's own data for the shale) shows some fractures extending more than 1800 feet vertically." (Jan 2012,
11. Rubin: "Numerous

the top of aquifer or Marcellus p 11)

joints [vertical fracturesJ ... even in the absence of gas well installations, provide open, functioning, avenues for upward migration of methane. Gasrich joints encountered by exploration well boreholes may interconnect and enhance preexisting joint pathways for methane, deep-seated saline water, radioactivity and, following development of horizontal gas wells, for contaminated LNAPL (Light NonAqueous Phase Liquids; e.g., chemicals with a density less than freshwater, such as benezeae) fracture fluids to migrate to aquifers, reservoirs, lakes, rivers, streams, wells. and even homes! (Nov 2010, P 4) 12. Palmer: "The distribution of major fracture zones in New York has been competently mapped by Jacobi (2002), but most fractures still remain unidentified. Most are almost impossible to detect even witb geophysical methods. Large ones are best identified by the presence of natural gas leaks, saline water in wells, hot springs, or highly mineralized springs. Also tbe world's deepest known limestone caves (karst) follow intersecting fracture systems to depths greater than a mile .... " (Mar 2012, p 2)

On Karst
1. Rubin: " ... Conduit portions of karst aquifers are THE most hydrologically vulnerable aquifers anywhere •••Gas drilling in and under NYS carbonate should be permanently banned." (Jan 2012, p. 23) N<;>te: band of carbonate or cavernous limestone (karst) stretches across central NYS from A Albany to Buffalo, and another runs south from Albany along the west side of the Hudson. 2. Palmer: "In typical karst areas in the East, most groundwater now is shallow. This poses a problem for constraining the dispersion of contaminants at drill sites, e.g., from accidental spills, routine minor leakage, or from ruptured seals around wells. Ordinarily contamination from such spills moves slowly through low-permeability soil and rocks. But where karst is present, groundwater velocities are up to hundreds or even thousands of times greater. This bas been shown witb innumerable dye traces." (Dec 2011, p 9) 3. Palmer: " ... avoid karst areas (which contain caves and sinkholes) because contaminants can spread rapidly and over large distances through solution conduits (caves and shafts):' (Jan 2012, p 3)

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4. Rubin: "High pressure fluids in shale will leak into any limestone formation in the vicinity [even if DO caves and siakholes are present). Once in tbe limestone, contaminants will spread in most directions." (Jan 2012, P 24)

5. Rubin: "People and bats [endangered species} in caves may potentially be ovenvhelmed by tbe build up of methane and other toxic cbemicals." (Jan 2012, p 25)
6 Rubin: "Cootaminated karst streams resurge as springs where their adverse impact to streams, lakes, reservoirs, ecosystems, and wetJand species and water quality may be rapid." (Jan 2012, p 25) On 500 Year Flood Plains 1. Rubin: "Gas drilling sbould not occur within SOD-year floodplains" (which are not yet mapped). "Excursion of fracking fluids from breached flow-back wastewater containment structures, whether via rupture, leakage, or overflow, poses a real threat to groundwater quality." (Nov 2010, p 14.) Note: Slow infiltration to groundwater becomes rapid during flooding and through karst. On Valley Aquifers 1. USGS: "Nearly all domestic wells in upland areas tap the fractured bedrock aquifer. The low storage io these aquifers relative to a sand and gravel aquifer [valley aquifer] means that changes brought about by drilling, including water quality cbanges, can be felt rapidly at significant distance from a disturbaaee- especially if a domestic well is down gradient of a well pad." (Feb 2012, P 7) 2. Palmer: "It is well known tbat natural groundwater follows long curving patbs tbat extend deep below tbe surface and rise into valleys ...• It has been well documented tbat more than 75% of tbe flow in nearly all surface rivers is delivered by groundwater." (Mar 2012, p 3)

3. Palmer: "Valley aquifers are tbe greatest sources of groundwater for municipal, domestic, and industrial use, because tbat's where tbe greatest population centers are located in the gas-rich plateau regions of tbe state. That is also where the most productive saod-andgravel aquifers are located, as well as all reservoirs, including those that supply New York City. The concept of "offset" from water supplies (e.g., 4000 feet) [NYC Watershed setback proposed by the DEC] is entirely inappropriate for this kind off contaminant transport." (Mar 2012, p 4)
Map Note: a-USGS geologists mapped the largest valley aquifers of NYS in 1988 (Bugliosi et al). These maps depict valley aquifers as broad underground rivers of groundwater flowing beneath and in the same down-gradient direction as the major surface creeks and rivers, but much wider than the surface water above. These aquifers flow beneath and recharge surface reservoirs, rivers and lakes through seepage into their beds and banks, and through underground springs. Groundwater and surface water are interconnected. b-USGS indicated that the small scale of these Bugliosi maps allows for up to 30% inaccuracy of aquifer boundaries (Feb 2012) c-The DEC plans to permit HVHHF into these valley aquifers, calling for site review for the first two years of permitting.

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00 the Long Term 1. NYC DEP: "HVHF has only been ill widespread use for about ten years." (Jan 20]2, p 13) 2. Myers: "Preferential flow [from shale] through natural fractures and fracking-induced fractures could ••. [take] as little as just a few years to ten years to reach aquifers." 3. Rubin: "Long term aquifer contamination is assured." (Jan 2012, p 34)

4. Rubin: "Radioactive radium present tbe the Marcellus may be mobilized in Ouids aod thus become available for transport in the groundwater Row system ••••In addition, uranium tainted flow back water poses tbe risk of contaminating streams, wetlands, and ecosystems!' (Nov 2010, P 14) Legislative Note: To prevent toxic fracking wastewater from being returned to surface water and then infiltrating their aquifers, Long Island Republican Senators have recently united to sponsor a bill to ban frack wastewater treatment there, i.e., in areas of sole source or primary aquifers. "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 .v.," (Jan 2012, p 2) 6. Rubin: "Once the integrity of gas well cement sheaths, casing, and plugging material has been breached through corrosion and assorted failure mechanisms. then upward hydraulic pressure gradients will result in natural gas and contaminant migration into overlying aquifers." (Jan 2012, p 13) 7. Palmer: "Poorly sealed (or entirely unsealed) wells allow mucb greater leakage. There are thousands in New York that are abandoned and mostly undocumented. Leaks all the way to the surface are possible." (Mar 2012, p 3) 8. Rubin: "Even if all fracking fluids were composed of non-toxic cbemicals, the risk of interconnecting deep saline-bearing formations and lor radioactive fluids with freshwater aquifers is great" (Nov 2010, P 14) 9". Rubin: "The population driokiog tbe water will continue to have low-level chronic exposure to a suite of toxic and carcinogenic hydrofracking chemicals with untested and unknown health impacts." (Jan 2012, p 29) 10. Palmer: " •.•there is real potential for contamination within our own lifetimes." (Dec 201 I, P 5) in surrounding river valleys

s. Rubin:

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A. Palmer: Professor Emeritus of Hydrology and Geochemistry and former director of the Water Resources program. SUNY Oneonta; SUNY Distinguished Teaching Professor and Chancellor's Award for Research. lie is a fellow of tile Am Asso for the Advancement of Science, National Speleological Society and Geological Society of Am, as well as a GSA Kirk Bryan Award recipient (based on his work in groundwater hydraulics of limestone caves). He has also worked as a consultant to oil and gas companies. P. Rubin: See hllp.1I hydroguesl.oorn for a full resume R. Jacobi: See University of Buffalo website Papers and maps by hydrogeologists at ht!p:/lbydmques!.coml : www.ruraicornmunjties.org:hgp:/lbydroques!.com/hvdrofracl;ing/ Compilation prepared by L Maher-Johnson, SI.,:yHil1 Fann, mahcriohnsonfalgmail.com, 312112

USGS Valley Aquifer Map - Finger Lakes Region Segment (BugUosi et ai, 1988)

Valley groundwater aquifers (darkened) flow beneath lakes (rivers and reservoirs}, supplying more than 75% of the surface water.

Faults & Fractures Abound in the NYC Watershed Can Act as Underground "Interstate Highways" for Fracking Toxins One Toxin from One Fracked Well: SOOOX EPA Limit Over A Square Mile
Of more concern than earthquakes---is pressurized fracking contaminants moving rapidly through our underground grid or "interstate highways" of "earthquake" faults and fractures. Palmer, hydrologist, geochemist and former head of Water Resources at SUNY Oneonta, is concerned about pressurized fracking fluids moving rapidly through these underground highways, even under mountain top divides and into adjacent valleys, where toxins will then move more slowly into the valley aquifers that provide more than 75% of the groundwater for reservoirs, lakes and rivers. So fracking outside the NYC Watershed could fast track contaminants beneath the topographical divide protecting the Watershed and they could then seep up into any of the six NYC reservoirs in valleys at the edges of the Watershed. The NYC DEP is also concerned and has called for a seven mile setback outside the boundaries (while the DEC proposes less than a mile). But Palmer says ''the concept of 'offset' from water supplies is entirely inappropriate for this kind of contaminant transport." Using the percentage of the known carcinogen benzene in one fracked well and the average amount of frack fluid left in the earth after fraeking, Palmer roughly calculates that one square mile, 600 ft deep, of underground rock formation can be initially saturated with an amount of benzene that is "more than 5000 times the EPA standard .... This scenario considers just a single contaminant in a single welL" Indeed, the DEC is asking for eight wells on a single well pad. This saturation will then move through fractures and, eventually, down gradient toward valley aquifers in valleys where most people, farms and industries locate. The DEP has taken on the task of mapping faults and fractures in and around the WS, using logs from construction of its water tunnels, etc. But "most fractures still remain unidentified. Most are almost impossible to detect even with geophysical methods." And the DEC doesn't plan to require detection. Are the fractures and the contaminants they will bring to our drinking water tomorrow's problem? "Preferential flow [from shale] through natural fractures and fracking-induced fractures could ... [take) as little as just a few years to ten years to reach aquifers," according to a new hydrological study just accepted for publication. Palmer says "there is a real potential for contamination in surrounding river valleys within our own lifetimes." One of our larger river valleys is the Capital District, where the huge flowing valley aquifer not far beneath the Mohawk River moves slowly down gradient toward and merges with the aquifer below the Hudson River. So Albany will get to play tap-water roulette along with every town and city in our small watersheds and large river basins. Farm and wild animals, pets and crops and industry can also play this water roulette game of mostly "low-level chronic exposure to a suite of toxic and carcinogenic hydrofracking chemicals," far into the future.

Respectfu 11 y,
L. Maher-Johnson, SkyHiIl Farm, maherjohnson@gmail.com
Attachments: Quotes of Hydro-Geologists Three maps of faults and fractures in area of NYC Watershed Map of valley aquifers in Finger Lake region, depicting aquifers moving below lakes to recharge them,

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