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From The Sun Gazette, 3/17:

Spill from drill site likely contains 2-butoxyethanol

WATERVILLE – A substance used in the natural gas drilling process is discoloring and distorting the texture of spring water running off a Cummings Township sidehill.

. . . . .

The mysterious substance was seen flowing down the slope, under the road and into Pine Creek, said Daniel T. Spadoni, spokesman for DEP’s northcentral region office. Officials from another state agency alerted DEP.

“We were notified (Monday) morning by the Department of Conservation and Natural Resources,” Spadoni said. “There was a white foamy material discharging from a spring down the hill.”

. . . . .

Terming it a surfactant, Spadoni said a substance known as Airfoam HD was causing the water run-off to be unnatural in appearance.

. . . . .

Surfactant used to treat Pennsylvania General Energy wells affected the water run-off, which Spadoni said had nothing to do with hydrofracturing.

Workers for the Warren-based energy company are drilling five wells in the area, high above the road, but he said they have yet to reach the point of using highly pressurized water to break the rock underneath the ground.

They were using the whitening substance as a lubricant that lowers the surface tension between air and water, according to Spadoni.

A receptionist answering a Pennsylvania General Energy phone Tuesday afternoon said company officials were not available to comment.

“They’re attempting to determine what caused this problem and what actions they can take to stop it,” Spadoni said of energy company representatives, with whom DEP members have been communicating.

The only precaution Spadoni recommended to residents is to avoid the suspicious spring water run-off in the area.

“I don’t think you would want to drink this discharge,” he said.

The substance leaking down the hill isn’t listed as dangerous on a Material Safety Data Sheet, according to Spadoni.

“I don’t believe there are concerns about drinking water in Waterville at this time,” Spadoni said, adding that area residents can continue regularly using tap water in their homes.

The investigation will continue.

“We don’t know for sure what its chemical composition is,” Spadoni said.

-end of excerpt of Sun Gazette article-

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Now, you have to wonder what Material Safety Data Sheet Spadoni is talking about.  The one copied below says the component of Airfoam HD is 2-butoxyethanol, also known as 2BE, which is linked to a particular kind of adrenal tumor that’s rare… unless you happen to be Laura Amos, who was exposed to 2BE, got that adrenal tumor, and wrote the following (click above on her name for complete text):

In August 2004 I came across a memo written to the US Forest Service and BLM Regional offices in Delta County, describing the health hazard posed by a chemical used in fluids that are injected underground to enhance the release of methane. Dr. Theo Colborn of Paonia, Colorado submitted the memo in response to decisions that were being made in Delta County by the government officials to allow gas exploration and development on the Grand Mesa. Colborn is the President of the Endocrine Disruption Exchange, Inc (TEDX) and for over 10 years directed the World Wildlife Fund’s Wildlife and Contaminants Program. She has been honored worldwide for her focus on the effects of synthetic chemicals on human and wildlife health. The focus of Colborn’s memo was on a chemical called 2BE, used in fracturing fluids.

The following information was taken from Colborn’s report: “2BE is a highly soluble, colorless liquid with a very faint, ether like odor.” She wrote that at the concentration to be used in Delta county 2BE might not be detectable through odor or taste. “2-BE has a low volatility, vaporizes slowly when mixed with water and remains well dissolved throughout the water column.” “It mobilizes in soil and can easily leach into groundwater.” “It could remain entrapped underground for years.”

She noted it is readily absorbed by the skin and can easily be inhaled as it off-gasses in the home. Colborn cited the Agency for Toxic Substances and Disease Registry Profile that listed the following effects of 2-BE: kidney damage, kidney failure, toxicity to the spleen, the bones in the spinal column and bone marrow, liver cancer, anemia, female fertility reduction, embryo mortality, and the biggie that got my attention – elevated numbers of combined malignant and non-malignant tumors of the adrenal gland.

-end of excerpt-

Here’s the MSDS that Spadoni mentions, but, hmmm, maybe just hadn’t read?

"Component: 2-butoxyethanol"

A deep bow and sweeping tip of the hat to Nastassja Noel for the Material Safety Data Sheet.

For more on this story, and more photos, see
Citizens Alarmed By Foam Discharge

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The Independent Weekender reports:

Landowners’ pipeline group forms

Staff Report
Published: March 17, 2010

A group of Susquehanna and Wyoming County landowners concerned about natural gas pipeline easements has formed, and is willing to share information with other landowners to form their own neighborhood groups or for others to join them.

The Lemon Township Pipeline Group has been meeting for months and its members are looking at a range of easement and right-of-way agreements that leaseholders need to consider as more and more drilling companies come into the area looking to get the gas from the Marcellus shale to market.

Core Lemon group members are concerned that property owners lack adequate information about what’s coming to the area as well as what their rights are when negotiating a natural gas pipeline easement or ‘right-of-way agreements.

Such issues as price, nature, location, type, pipeline depth below surface, installation, road repair, pressure, timetable, abandonment, rights, restrictions and environmental responsibilities are among the many issues that individuals need to consider.

Members of the core group want to impress a sense of strength in numbers in requiring both the drilling and pipeline industry to move forward in a way that indeed is responsible to the region’s environmental well-being, and land stewardship.

Anyone interested in joining the discussion should contact pipelinerowinfo(at)yahoo.com

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Quoting Chamber president Kevin Keeley, The Star Gazette reports:

“This is an information session, not an advocacy session. It’s not a hearing, not a debate,” he said. “It’s simply an opportunity for the chamber constituency, which is the business and professional community, to learn more about some fundamental facets of the gas drilling phenomena.”

The 90-minute program will include brief presentations from: Mike Atchie from Chesapeake Energy Corp.; Dale Duncan, Schlumberger operations manager, Northeast Basin; Larry L. Michael, executive director of Workforce & Economic Development, Pennsylvania College of Technology, and Richard C. Stedman, an associate professor at Cornell University in the Department of Natural Resources.

—————————

With a list of presenters frontloaded with representatives of Chesapeake and Schlumberger and a booster like Mr Michael, what else could  this forum legitimately be called but an advocacy session?

If it’s really information – accurate information – that you want, why would you turn to industry representatives to get it?  Do you get your car-buying advice from the salesman at the dealership?

And why can’t regular citizens attend what was apparently first advertised as a public meeting, so they can hear what you’re hearing?  What are you afraid of?

Readers, please, feel free to submit your ideas… Perhaps we can help the Chemung County Chamber of Commerce find the right noun.

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Citizens for Healthy Communities

FOR IMMEDIATE RELEASE:  March 17, 2010

March 19th Chemung Economic Forum Comes Under Fire
Chemung County Chamber of Commerce’s March 19th Economic Forum on natural gas drilling in the Southern Tier, to be moderated by Chemung County Executive Thomas Santulli, is being criticized for prohibiting the public and including presentations dominated by the gas industry and its supporters.  Although the Forum, scheduled for Friday, March 19 at 7:30 am at the Holiday Inn-Riverview in Elmira, was advertised as open to the public, many people who called for reservations to the event were turned down.

“When I called on March 3, I was told that the Forum was sold out,” said David Walczak of Bath, “but others who called for tickets to the breakfast were told that the event was only open to members of the Chamber.”

The scheduled speakers at the forum are heavily biased toward the gas industry.  They are natural gas industry officials from Chesapeake Energy Corp and Schlumberger, Inc., a representative of the Pennsylvania College of Technology who has spoken out extensively in support of hydraulic fracturing drilling of the Marcellus Shale and someone from Cornell University.

“If the Economic Forum was merely a private Chamber of Commerce meeting, they would certainly have every right to exclude non-members,” said Mark Schlechter, a resident of Steuben County, ”but the participation of the County Executive, and possibly other elected officials, turns the Forum into a public event.  The actions of the Chamber and the County Executive in excluding concerned members of the community raise questions about what will be discussed at the Forum and, more importantly, what decisions will be made by our elected leaders about gas drilling in our region.”

There is currently a moratorium on hydraulic fracturing, known as “fracking”, in New York State due to concerns about the environmental and economic effects of the drilling and plans to build a Schlumberger gas drilling service facility in Horseheads are on hold pending a State Supreme Court ruling on the issue.  A number of organizations have formed in area counties to raise public awareness of the hazards of injecting and storing millions of gallons of toxic-laced water into the ground and of the numerous examples of water contamination, air pollution and noise and odor complaints in other states where fracking has occurred.

“If public policy is to be set through closed forums such as the one moderated by our County Executive, then the public has a right to know what is being said and which elected officials are in attendance,” said Patricia Ladley, a Chemung County resident. ”This issue is too important to the health and economic well-being of our communities for us to be excluded.”

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From the Star-Telegram, January 14, 2010:

In D-FW, ’sobering’ asthma numbers

Look at a third-grade class or a youth soccer game, and start counting.

“One, two, three, asthma; one, two, three, asthma,” said Larry Tubb, senior vice president for system planning at Cook Children’s Health Care System. “That’s sobering.”

It represents a growing health problem in North Texas, where 1 in 4 children ages 8 and 9 has the lung disease. The state average for 5- to 9-year-olds is 7.1 percent; the national average for all children is 9.4 percent.

-end of article excerpt-

Now, why would the Dallas-Fort Worth area have a childhood asthma incidence that’s more than 2.5 times the national average?

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Letter to Edmonton Journal: “Letting gas companies have their way has devastating results”

Edmonton Journal

March 15, 2010

Re: “Natural gas and its ‘Drill, baby, drill’ conundrum,” The Journal, March 8.

I am a central Pennsylvania native who lives in the midst of the Marcellus shale region. I cannot begin to describe how devastating it is to witness the wholesale destruction of this once strikingly beautiful state by natural gas firms from both the United States and Canada. If you are a gas company executive living in Edmonton or Calgary for example, you do not have any ancestral bonds or other firsthand knowledge of this predominantly rural and less wealthy corner of the United States. Instead, your singular goal is to extract the natural gas and, accordingly, reap substantial profits. Meanwhile, massive and permanent environmental damage will be the only legacy of the Marcellus shale drilling left for Pennsylvanians. Although drilling only started less than two years ago, the state’s freshwater supplies (including the Susquehanna River, which flows into Chesapeake Bay) are already being depleted at an alarming rate and the forests and farmlands systematically destroyed. So, whenever energy experts like Peter Tertzakian or anyone else raises the “drill, baby, drill” credo, please remember that whatever economic gains are being derived from retrieving natural gas in the Marcellus shale region via hydraulic fracturing, they are coming at a terrible environmental cost comparable to that of the oil-sands, or perhaps even worse.

Marsha Ann Tate, Pleasant Gap, Penn.



*Substitute your state environmental regulating agency

Guest post by Lynn Senick:

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  • On Feb. 2, DEP fined Talisman Energy $3,500 for violations at its “Cease” well pad in Troy Township discovered during inspections in 2009.
  • A February 2009 inspection revealed that the company had not publicly posted the permit number and other required information at the entrance of the well pad. During a follow-up inspection in June 2009, a DEP statement explains, “flow-back fluids — or the fluids that are used to break up underground rock and then return to the surface — were found discharging into a drainage ditch, an adjacent sediment basin, and eventually through a vegetated area into an unnamed tributary of the south branch of Sugar Creek.” The Daily Review

  • “A vertical drilled well in The Marcellus Shale zone costs $810,000 to drill while a horizontal drilled well will cost you roughly 3-5 million dollars.” oilshalegas.com
  • In the Marcellus shale, Talisman drilled nine gross (nine net) wells during the quarter, for a total of 12 gross (12 net) in the first half of the year. The development plan is ahead of schedule and the company is now producing at rates in excess of 30 million cubic feet of gas per day. ugcenter.com
  • .

    COST OF DRILLING ONE HORIZONTAL WELL; $ 4 MILLION

    A FINE OF $3500 is 0.0875%  – the value of a a used Chevy Caravan.

    VALUE OF CLEAN AIR, LAND, & WATER?

    PRICELESS

    .

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    photo credit The Daily Star

    Excerpt from The Daily Gazette, Schenectady, NY on the pipeline explosion in North Blenheim, NY, twenty years ago on March 13, 1990:


    Effects of deadly blast still felt

    EDWARD MUNGER JR

    Earth scarred by the massive explosion that rocked this rural Schoharie County town 20 years ago has since healed and buildings reduced to smoldering rubble have long since vanished.

    But people who recall the sudden death of two neighbors and the devastation caused when a pipeline burst say they don’t expect to ever forget the fateful morning of March 13, 1990.

    The pipe carrying liquid propane, running north of state Route 30 near West Kill Road in North Blenheim, ruptured and sent a cloud of flammable gas drifting downhill.

    The cloud exploded about 7:30 a.m. when it got to the intersection of Route 30 and West Kill Road, killing Blenheim resident and firefighter Robert Hitchcock, 53, and Central Bridge resident Richard Smith, 43. The explosion destroyed 14 homes and injured five people.

    New gear added to the pipeline’s infrastructure and town buildings built after the blast — dedicated in honor of Hitchcock –  stand as reminders of the devastation today.

    And in the 20 years since, more stringent regulations governing pipelines and an added emphasis on safety have accompanied a 10 percent reduction in serious accidents, a government spokesman said.

    North Blenheim resident Peter Giesin recalls being in the cellar of his West Kill Road farmhouse when his daughter called to him asking what was going on in the field outside their home.

    “I looked out, there’s this white plume. At the time, I thought it was smoke. I thought an airliner had crashed or something,” Giesin said.

    The white cloud was a plume of gasified propane that leaked out of the Texas Eastern Products Co.’s underground pipeline — a pipeline run underground in the 1960s despite resident opposition that was ultimately overpowered by eminent domain.

    “I realized it was the pipeline blowing this plume of gas across the field which, naturally, was going downhill away from us. Then, within less than five minutes, a ball of fire came back over the hill from downtown where it ignited,” Giesin said.

    “The village looked like a war scene. It was just destroyed,” said Blenheim resident Gail Shaffer, who was working as secretary of state in Albany and rushed to the scene.

    “When we got to the village, it was all charred remains of buildings. There were 12 or 15 different fire companies with their hoses still on. It was organized chaos at that point,” Shaffer said. “I will never forget.”

    photo credit The Daily Gazette

    Today, offshore and onshore gas transmission lines carrying hazardous liquid such as propane stretch for more than 2.5 million miles in all 50 states, according to the federal Pipeline and Hazardous Materials Safety Administration, or PHMSA.

    New York state accounts for a total of 53,275 miles of underground pipelines.

    PIPELINE MAINTENANCE

    Following the 1990 disaster in North Blenheim, engineers hired by the government determined that several months before the accident, workers from the pipeline company raised the pipe to insert a rubber washer between it and a casing pipe around it. The work was in response to a short circuit detected in the system that uses a small electrical charge to keep the pipe from corroding.

    Engineers at the time said the crew filled the pipeline hole back in but the dirt might have been frozen. Once thawed, it allowed the pipe to settle and a weak point in the pipe — a manufacturing defect — broke in half.

    A National Transportation Safety Board investigation that followed criticized the fact that the pipeline’s operators were unable to detect a drop in pressure when the pipe leaked; the nearest monitoring location was in Gilbertsville, Otsego County, about 15 miles west of Oneonta and roughly 68 miles from North Blenheim. Afterward, the pipeline company installed remote terminal units to monitor the pressure at pump stations and receiving stations.

    The same 4,200-mile-long pipeline, which stretches from Texas to Selkirk, Albany County, sprang a leak in January of 2004. An explosion that followed destroyed one home in Delaware County but no injuries were suffered.

    Engineers determined the 2004 pipeline leak was caused by frost heave separating a valve from the pipe. Roughly 5,000 gallons of propane in the pipe burned for three days after the blast.

    In the 20 years since the blast in North Blenheim, the federal Department of Transportation has created the Pipeline and Hazardous Materials Safety Administration, expanding the department’s inspection and enforcement abilities and doubling the number of inspectors and accident investigators, said Damon Hill, a spokesman for the federal DOT.

    “Since then, we’ve had a number of regulations introduced that includes regulations for [pipe] integrity management programs, operator qualifications, control room management and quite a few other things to help make pipelines a lot safer,” Hill said.

    Among the new standards is a requirement that pipelines be capable of undergoing an internal inspection, he said.

    The “call before you dig” number was developed after the Schoharie County explosion, Hill said, to help stem third-party damage to pipelines he said are responsible for the bulk of pipeline failures today.

    The pipeline changed hands in terms of ownership, with TEPPCO merging with Enterprise Products Partners LP in October of 2009, Enterprise spokesman Rick Rainey said.

    Complete story available for fee from The Daily Gazette

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    TO:
    Attn: dSGEIS Comments
    Bureau of Oil & Gas Regulation
    NYSDEC Division of Mineral Resources
    625 Broadway, Third Floor
    Albany NY 12233-6500
    dmnsgeis@gw.dec.state.ny.us

    FROM:
    Brian Brock, retired geologist
    Franklin NY

    DATE:
    30 December 2009

    RE:    CONSIDERATIONS  FOR  REVISIONS  TO  dSGEIS

    Aquifer Depths, Database of BOGR states that depths to the base of aquifer is so poorly known that they need to set a default value of 850 feet.  Despite this, there in no mention of a database for the driller’s report of the depth of fresh and brine waters at each well, which could be then used to predict depths to the base of the aquifer for future well permits.

    Bedding Planes and Fractures Flow of groundwater is usually controlled by these discontinuities, but there is no adequate discussion of bedding planes and fractures in Chapter 4, Geology.  Large roadcuts, quarries, railroad tunnels, and aqueduct tunnels can provide data.

    County Health Departments Many have neither the expertise or resources to investigate reports of water pollution, as suggested by SGEIS.  This responsibility is an unfunded mandate.  Health departments from counties in the fairways of the black shales should provide input.

    Cumulative Impact Draft SGEIS has only a few scattered and brief discussions of this.  If a boom in extraction of gas from black shales develops in NYS (as it has elsewhere), then cumulative impacts will be substantial.  Final SGEIS should have comprehensive Cumulative Impact Assessment to include: water withdrawal, waste disposal, traffic, road damage, air pollution, manpower, and community.  Current SEQRA handbook covers cumulative impact.

    Disclosure of Frac Chemicals to Public While BOGR requires that companies report all chemicals used to them, there is no provision for releasing this information to the public.  These chemicals will be injected below the public’s property and might contaminate the public’s drinking water.  Without such information, the public can not monitor the purity of its drinking water.

    Fairway, Extent of Alpha Environmental consultants defines “fairway” by rock properties (pages 4-14 and 4-18) without considering the setting of the rock units.  As a result, Fig. 4.7 and 4.12 show fairways of Utica and Marcellus shales extending north and east to outcroppings.  Production of economic quantities of gas require the hydrostatic/lithostatic pressure differential produced by thousands of feet of overlying rock.  As drawn, these figures give the mistaken impression that areas that are immediately south and west of shale outcroppings will have gas extraction and should be revised.

    Faulting
    Figure 4.13 gives the mistaken impression that the fairways for Utica and Marcellus shales are mostly free of faults — faults that could provide pathway for waters from black shales to aquifers.  True the figure is labeled “Mapped Faults …”, but the distinction between mapped faults and total faults is not discussed.   The bedrock is monotonous and poorly exposed, so probably many faults have gone unmapped.  This figure is based on a compilation over 30 years old, and could be updated with data from natural seismicity, seismic imaging, and mapping from NYC reservoir and tunnel construction.

    Figure 5-1 This schematic of a well pad  is confusing at best, and much of it is wrong.  If it is of a multi-well pad in development, then it should be so labeled.  This figure should be completely redrafted.  There is too much wrong to detail here, but contact me if you want suggestions.

    Flowback Disposal
    Destination  Within months of the approval of the final SGEIS, wells will each begin producing hundreds of thousand or millions of gallons of flowback.  A safe way to dispose of this is required, but there appears to be none in NYS.  Draft SGEIS does not estimate the volume of flowback expected nor discuss which sites could accept this volume.
    Reporting  In Appendix 6, the proposed Environmental Assessment Form does not require reporting of frac fluids that leave New York State.  Given the lack of a significant disposal option in state, most of this water may be sent out of state.

    Formation Waters, Composition of Draft SGEIS provides a summary of flowback analyses but not analyses of formation waters, despite BOGR regulating gas drilling for over a century.  Without such, several key points of the SGEIS can not be finalized, including:
    * How can formation waters be distinguished from flowback?
    * Can formation waters be processed through POTW?
    * Can formation water be safely spread on roads?

    Frac Trespass
    CI Hearings Currently a hearing for compulsory integration can be held after well work is completed as long as land has been leased where drilling takes place.  Presumably a frac job is designed to fracture throughout entire drilling unit.  May they frac before the whole unit is leased or integrated?
    Taking Fracing is a new technology with imperfect control of the extent of resulting fractures.  How can neighbors to the drilling unit be assured that fracing will not extend under their properties, neither trespassing nor taking “their” gas?

    Funding and Staffing Although this is outside the scope of SGEIS, until BOGR obtains adequate resources for enforcement, the public can have no confidence that GEIS and SGEIS are anything more than ink on paper.

    ICF International Analysis. Appendix 11
    Pore Flow The mathematical analysis of fluid flow through intact rock via pore space (pp. 24 – 31) is a pointless.  There is no doubt that 1000 feet of unfractured rock would provide a barrier to frac fluids over short times, but how often is this the case?
    Fracture Flow Despite wasting pages on calculating pore-flow rates, ICF dismisses chances of an open flow path from fractures, faults, or well bores as “theoretically possible but extremely unlikely” (pg. 31) without attempting to quantify this risk.  The experience of NYC in drilling their aqueduct tunnels suggest that the risk could be substantial.
    Reporting Fluid Flow Even if the odds of an open flow pathway “is very small” (pg. 32), given the large number of wells expected, then occurrence of open pathways is almost certain.   Therefore one of the required non-routine incidents that drillers should report (Appendix 10, Supplementary Permit Conditions, #46) should be failure to hold pressure or anomalous fluid loss during fracing.
    Injection Wells ICF consultants may be correct that high-pressure fracturing for a short time (“typically less than a day per stage”, pg. 34) make it unlikely that frac fluids could immediately reach aquifers.  On the other hand, injection wells do pump waste water at high pressures for longer times.  The consultants neglect to consider long-time flow of fluids from injection wells.  Injection wells remain one of the few ways to dispose of waste water from drilling, flowback, or plugging.
    Lack of Evidence The final conclusion (pg. 34): “There are no known incidents of ground water contamination due to hydraulic fracturing.” is deceptive.  Because there has been no testing of groundwater before and after fracing by either drillers or BOGR, it is more correct to say that no proof exists that groundwater remains uncontaminated due to hydraulic fracturing.  “Absence of evidence is not evidence of absence.”

    Incident Response With a large enough number of wells, everything that could go wrong will go wrong: surface spills, well seeps, aquifer pollution, fires, explosions, etc.   While SGEIS requires the reporting of any non-routine incidents by drillers, there is no mention of the response required by BOGR.

    Inspections
    Frequency For most wells, no inspections are required during the entire life cycle of a site: site preparations, drilling, fracturing, completing, and production.  (A single inspection during surface casing is required only for the minority of wells in primary and principal aquifers.)  Considering that much of the BOGR oversight is limited to the review of paperwork self-reported by drillers, a minimum number of random and unannounced inspections is necessary to encourage honest reporting and should be required.
    Surface Casing and Initial Fracing Site visits should be required for these two steps.  These two visits by Mineral Resource Specialists would also allow inspection of the general operation.  If this is beyond the current staff, it only argues for an increase in staffing.
    Transparency There is no written procedure for monitoring and inspecting a well over its life cycle from site preparation to production.  Without this, the public has no way to determine if BOGR is fulfilling its responsibility to protect the environment.
    Workload BOGR has stated that it has and will continue to provide sufficient oversight of each gas well.  Should there be a rush of permit request, the number of permits issued would be limited by the workload of mineral resource specialists.  Neither final GEIS nor draft SGEIS lists what the workload is for permitting and oversight of a single well.  Nor is there a limit to the number of active wells in a mineral resources specialist’s caseload.  Without such information, the public can not be assured that BOGR is providing sufficient oversight.  Without sufficient oversight, GEIS and SGEIS are only ink on paper.

    Loss of Springs and Wells During the drilling of the first several hundred feet through aquifers, there is a risk of loss or fouling of neighboring water sources until the surface casing is cemented.  Special attention in inspection or reporting should be required during this period.

    LPG Fracing If this water-free fracing may someday be proposed for use in NYS, will a second SGEIS be required?  Wouldn’t it make sense to include this technology in the current SGEIS?  Obtaining and disposing of millions of gallons of water for each well constrains future fracing.

    Metering Currently BOGR does not require periodic recertification of gas meters at well heads, spot check reading of meters that is done by companies, or audit company records – procedures that are routine in other states.  (These deficiencies were cited in NYS Comptroller audit 2005-S-54.)  Such procedures are required to assure that landowners and state receive what are legally due them.  The much greater volumes of gas produced by horizontal wells make a true accounting all the more important.

    Methane in Groundwater Draft SGEIS mentions that methane naturally occurs in groundwater.  It does not discuss that this proves that there are pathways between black shales and aquifers — although not necessarily the targeted shales.  Gas is much more buoyant and less viscous than frac fluid, and therefore it is not clear how much of these fluids would follow the same pathways and over what time.  Nevertheless the nature and implication of these pathways should be discussed.

    Multiple Plays There is substantial overlap of the fairways for Marcellus and Utica shales.  A smaller area additionally includes the fairway for Herkimer tight sandstones.  (Indeed Nornew brags that it has this “triple play” in Madison and Chenango Counties.)  There is also a chance of the spotty occurrence of Trenton/BlackRiver plays   Multiple plays multiply the effects at each well pad, but the draft SGEIS ignores the effects of multiple plays of gas, particularly on cumulative impacts.

    Pollution
    Bonding Drillers should be bonded for the clean-up of any pollution caused by their activities.  (Currently they are bonded only for plugging well and restoring the site.)  Commonly companies will set-up a shell company for drilling each well with assets just sufficient to cover expenses.  Without bonding, should there be major pollution, the company has no reserves that could recovered for the clean-up.
    Database BOGR can state that it knows of no incident of pollution from fracing in NYS.  This claim can not be confirmed because BOGR does not maintain a database of reports of pollution.  Such a database should be built.
    Liability In neighboring Pennsylvania, any pollution within 1000 feet of well head is presumed to be the responsibility of the driller who must provide sufficient water and remediate the pollution to the satisfaction of DEP.  (Purity of the provided water must be independently certified.)  There is no such provision in the final GEIS or draft SGEIS.  Without it, a individual land owner could have the expense and aggravation of dragging a polluting company through the courts for years to get satisfaction, whereas the owner needs are immediate.
    Risk Despite BOGR statement that there are no case of pollution of aquifers from fracing, there are numerous documented cases of pollution of aquifers from gas drilling.  To the land owner who has lost their drinking water and a much of the value of their property, the distinction between drilling and fracing is academic.  The SGEIS should more fully discuss causes of pollution during the entire drilling process and how to eliminate any causes not covered in GEIS.

    Publicly-Owned Treatment Works, Appendix 21 Despite this list of 135 POTWs, there is no guarantee that a single one of these works is capable of treating of produced waters, from drilling, flow back, or plugging.  POTW do not remove the chemicals from these waters but only dilute the toxins to below legal limits.  All the toxins are dumped into the river.  Without representative analyses of produced waters, it is not possible to even know if it is safe to pass these waters through these works or what dilution is required.  Indeed the vast majority of operators are not even considering applying for permission from DEC to accept this waste.  Including this long list in the SGEIS deceptively give the impression that there are many possible sites to receive the waste waters produced.

    Refrac Permits Black shales in NYS may be refraced as soon as one year after the initial frac – although five years is more typical elsewhere.  Draft SGEIS requires a permit for refracing (8.3.2), but does not specify what information will be necessary to obtain this permit.

    Road Spreading of Produced Fluids Permitting for a Beneficial Use Determination for road spreading does not specify what are the acceptable concentration of pollutants.

    Set Backs, Residential GEIS requires set backs of 100 feet from drill pads to residences for a single well and this is not increased in the draft SGEIS.  This is the smallest setback of any state, with most having setbacks of 200 to 600 feet.  Even if this is adequate for single vertical wells, this is inadequate for single horizontal wells, let alone pads of multiple wells, multiple plays, and refacturings.  One site could be actively drilled and fractured for three years for a single play.

    Seismic Monitoring Fracing is a developing technology with an imperfect control of the extent of resulting fractures.  Without seismic monitoring during fracing, the owners of neighboring can not be assured that gas will not be withdrawn from beneath them.  At least for a trial period, this should be required for a few wells and the results reported.

    Toxicity of Chemicals Draft SGEIS does not compare the toxicity of chemicals used in drilling and fracing, claiming that there is no way to measure this: “there does not seem to be a US-based metric” pg. 9-10.  However the Federal Mineral Management Service does such rating of such chemicals in its capacity of regulator of off shore drilling. Their methodology should be applied to the land-based use of such chemicals.

    Trial Period Once the final SGEIS is adopted, BOGR should begin with a limited number of permits for the new horizontal drilling and high-volume hydraulic fracturing of low permeability gas shales — maybe one multi-well pad in each county.  After a formal review, the annual number of such permits could be gradually increased.

    Unconventional Gas Reservoirs While they are mentioned, it would help if there was a brief discussion of the differences among coal beds, tight sandstones, and black shales and of the differences in extracting gas from them.

    Water Testing
    Composition While water testing is required around the drill site, what is required to be tested does not include chemicals in frac fluids.  Without these, results  will be less useful for showing contamination.  What is more, this testing is not required to be done such that the results would be admissible in a court of law, thereby giving a false sense of security to the property owner.
    Location For vertical wells, testing within a circle1000 feet in diameter may be sufficient, but for horizontal wells, a corridor at least 330 feet on either side of the horizontal well bore should be included.  Without this, BOGR is assuming that fracing could never pollute aquifers and avoiding any evidence that could contradict.

    The Bureau of Oil and Gas Regulation is to be commended for compiling so much information for the SGEIS, but much work remains to be done.  Indeed, so much needs to be revised in and added to the draft SGEIS that a second round of comments will be necessary before the final SGEIS is adopted.  However from my experience with the public hearings this fall at Chenango Valley High School, comments should be limited to written submissions.



    Citizens Group Worried About Water Pollution

    “Luzerne County Citizens for Clean Water is starting out small . . . but is going to grow, said Dr. Tom Jiunta of Lehman Township… Area residents don’t realize that the number of people who will benefit from Marcellus Shale drilling in the region is small compared to those who could potentially be harmed by it, he said.”



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    Guest post by Maura Stephens, originally published at Reader Supported News


    13 March 2010

    “Update: PEMA urges residents to prepare now for possible flooding.”

    “DEP directs gas drillers to replace water.”

    “Man killed by fall off Towanda drilling rig.”

    I read these three stories in that order. The first two were in the Pike County [Pennsylvania] Courier, the third in the Binghamton [New York] Press & Sun Bulletin. The headlines of the first (get ready for a flood) and third (a man died in a gas-drilling accident) are self-explanatory. The second, about “replacing” water, went like this:

    “The Department of Environmental Protection (DEP) . . . ordered Schreiner Oil and Gas Co. to provide a permanent solution to water supply issues at two homes the company’s drilling activity impacted near Hedgehog Lane, McKean County.

    “DEP previously determined that the company, based in Massillon, Ohio, was liable for affecting the water supplies of homes. . . . among the contaminants identified were total dissolved solids, chlorides, manganese, iron, dissolved methane and ethane gas.”

    Does this not terrify everyone who lives in the huge gas-drilling and potential gas-drilling region? (The Marcellus Shale encompasses large swaths of New York State, almost all of Pennsylvania, Ohio, and West Virginia, and parts of Maryland, Virginia, Tennessee, and Kentucky. A total of 31 or 32 states have deposits of so-called “natural” gas, more properly termed “fossil-fuel gas.”)

    Here are some facts:
    1) The horizontal, slick-water hydraulic fracturing process of gas drilling (“chemo-fracking”) uses and releases numerous toxic chemicals — carcinogens, endocrine disruptors, naturally occurring radioactive materials.
    2) Accidents happen.
    3) People make mistakes.
    4) Floods occur.

    Anyone who has ever experienced a flash flood knows that you’re going to run for your life and your loved ones’ lives first, and for your most expensive and/or most precious possessions next.

    Even if gas companies had our best interests at heart — and you’d have to be a total naïf to think they do — there is simply no way to protect us from all these toxins that would go streaming into our water systems in the event of a flood, let alone the inevitable accidents and mistakes that will occur.

    Because they will.

    In the cases where the gas companies have to “replace” water, what are we talking about?

    You can’t “replace” water that has been contaminated with poisons. You can bring in huge “water buffaloes” with 300 or 500 gallons of “fresh” water from elsewhere (and who is monitoring that water? Where does it come from?) to resupply a family with drinking, cooking, and bathing water, but the ground is still contaminated.

    The vegetables and flowers and shrubs in the family’s garden are still reliant on that water for survival. The squirrels, bunnies, and raccoons . . . the chickadees, warblers, and woodpeckers . . . the frogs, fish, and turtles . . . the crickets, bees, and peepers . . . the family cat and dog . . . all drink the water from that contaminated ground. Toddlers in sandboxes eat the dirt. Kiddie pools and grown-ups’ pools, bird baths, ponds, streams, rivers, and lakes . . . all can be contaminated from just one spill.

    You can’t “replace” bad water with good. Period.

    There is not enough recompense in the world to mitigate this kind of permanent damage to a person’s home and property or to our surrounds, or to our own health and our children’s health.

    It is up to communities to decide if the risks are worth the riches that will go to the gas companies and to a few members of the communities.

    Let’s think about these risks for a moment: Someone in my community will die because of fracking. It’s inevitable. The man who was killed on a gas rig in Towanda, Pennsylvania, has a name: Greg Allen Henry. He was from Athens, Tennessee. He was 31 years old and was killed when he fell from a rig and suffered massive head trauma.

    Are the risks worth the reward? How many lives are worth how many dollars? The job (of the many promised to Pennsylvanians and New Yorkers) came, no doubt, with pretty good pay to bring a Tennesseean so far from home. But was it enough for Greg Henry’s family? Will it help ease their grief?

    Will you be getting free energy for life, if you lease your land and it’s fracked? Will you ever feel safe drinking the water? Will the royalty fees cover the loss of your home’s value? Where will you go if you are forced to leave your valueless home? What will happen to the investments of time, equity, sweat, and tears—let alone cash—you’ve poured into it? How much money is enough?

    Is a Tennessee man’s life worth as much as a Towanda child’s life? If your child drinks contaminated water today and develops cancer in five years, will a gas company come forward to help you pay for your child’s chemotherapy and radiation treatments, and hold your hand while you wait for the latest medical test results that will tell you if she will live or die?

    Are the risks worth the reward?

    Whose risks? Whose reward?

    Are the risks worth the reward?

    Every community must come up with its answer.

    See also Is the juice worth the squeeze?

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    http://1490newsblog.blogspot.com/2010/03/spill-now-believed-to-be-accidental.html reports:

    “Although emergency crews first thought the oil spill on Hedgehog Lane this morning was malicious, police now believe a valve was accidentally opened, according to Bradford Township Supervisor Gayle Bauer. She said the investigation is continuing.
    . . . . .

    “The operation is run by Aiello Brothers.

    “Bauer said three vacuum trucks are still on the scene working on containment, and that another environmental cleanup company is coming in to help.

    “Just over two weeks ago Schreiner was ordered by DEP to provide a permanent solution to water supply issues at two homes the company’s drilling activity impacted near Hedgehog Lane.

    “DEP had previously determined that Schreiner was responsible for affecting water supplies at other homes in the area.”

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    Wheeling, WV  Wheeling News-Register story, 3/8/2010

    http://www.news-register.net/page/content.detail/id/535302.html?nav=511

    SILVER HILL – As Chesapeake Appalachia prepares to drill for Marcellus Shale natural gas in Oglebay Park, Wetzel County resident Raymond Renaud says those living near the proposed drilling sites may get far more than they bargained for.

    Renaud, whose residence lies about a mile from a Chesapeake drilling well in the Silver Hill area, isn’t talking about money. He’s talking about the impact he and other members of the Wetzel County Action Group have seen on the surrounding area and residents’ way of life since Chesapeake began drilling there about three years ago.

    “Our first concern is the traffic, by far,” said Renaud. “The situation has become quite dangerous.”

    The winding roads leading to the drilling sites, he noted, are simply not designed for large trucks to travel safely.

    “Our infrastructure does not support the activity. Our roads are such that a tractor-trailer simply cannot maintain his lane around our turns,” Renaud said.

    He added that Chesapeake has been cooperative in taking steps to minimize the danger to residents, including putting escort vehicles in front of tractor-trailers and providing security vehicles to observe traffic conditions.

    “Without those steps, we would have had countless fatalities,” said Renaud. Still, he estimated three to four accidents per day occur in the Silver Hill area involving gas drilling vehicles “going into a skid, sliding across the center line and off the road.”

    Renaud said Brock Ridge and County Road 89, two major access roads for Silver Hill residents, “have taken a major beating” as they’re not designed to bear the load of so many large trucks. He said to Chesapeake’s credit, the company repaved both roads at its own expense – but the repairs haven’t held.

    “They finished in the late fall, and Brock Ridge is completely destroyed,” said Renaud. “Their new paving job is gone. It’s a mud road.

    “We’re talking about massive road failure. … We’re talking about some pretty massive effects. If your road totally disappears, that’s a pretty massive effect,” he continued. And during the winter, said Renaud, those roads are blocked by oversized vehicles multiple times each day.

    “Locals who used to drive Brock Ridge now go out of their way and use other roads,” he said, noting he’s also a member of the Wetzel County Emergency Medical Service. “It’s normally a 14-minute trip, and I was an hour and a half getting to the Silver Hill Fire Department.”

    Photo credit: Ed Wade, Wetzel County Action Group

    Water pollution also is a concern, Renaud noted. He said in snowy weather, the company lays down “tremendous volumes” of cinders so its trucks can gain traction. When the snow melts, the cinders mix with the water, creating “a lava flow of cinders going into the creeks,” Renaud claims.

    “The worst part about this, when it dries up, you’re inhaling tremendous volumes of cinder dust. The summer irritant for us is dust. … People have to power wash their homes,” he said.

    Another worry stems from an industry process called hydraulic fracturing, or “fracing,” in which million of gallons of water, sand and chemicals are blasted into each well to break up the tightly compacted shale. Once the rock is fractured, some of the water – estimates range from 15 percent to 40 percent – comes back up the well. When it does, it can be five times saltier than seawater and laden with dissolved solids such as sulfates and chlorides, which conventional sewage and drinking water treatment plants are not equipped to remove.

    Chesapeake officials have maintained they “aggressively implement best practices to reduce the possibility of leaks, spills and discharges” with regard to fracing.

    Another industry practice, called flaring, occurs when drilling companies burn off surplus combustible vapors.

    “They literally burn it out of the stack. Our concern is, we don’t know how toxic that gas is,” said Renaud. “If you live downwind or in a hollow, it’s a gagging odor. … It’s just not very pleasant.”

    Renaud believes all these factors are adding up to plummeting property values for landowners near natural gas drilling sites.

    “I moved here in the ’70s,” he said. “I moved to get away from the city, to live in a nice rural atmosphere, and now I live in an industrial zone. ”

    If you live on a rural road and experience 40 trucks going by your house a day, you would have a hard time selling your house. … These people are now trying to get Chesapeake to buy their property because they can’t recover what they paid for the property. Mortgages outstanding are greater than the value of the property today,” Renaud claimed.

    Renaud is calling on government officials to step in and help “exploit the Marcellus Shale in a way that benefits the citizens of Wetzel County and West Virginia.”

    “I really don’t fault the gas development companies, because if they went out of their way to satisfy what we’re asking for, it’s going to increase their costs,” he said. “They wouldn’t be able to compete. It’s an industrywide thing. To me, this is a social issue that requires local, state and federal government.”

    Please go to the story to see reader comments section

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    Mayor Calvin Tillman of DISH, Texas says the people of his town “have seen the worst of what the natural gas industry is capable of.”  DISH  hosts eleven massive natural gas compressors, four metering stations, eleven high-pressure gas lines, and numerous gas wells and gathering lines.  Its busy mayor had been warning other small cities located over the Barnett Shale that the chaotic growth of gas transmission lines and compressor stations could seriously jeopardize their economic future.

    But numerous cases of respiratory distress reported recently by DISH residents have pushed public health concerns to the forefront.

    In the face of inaction from the Texas Commission on Environmental Quality, DISH contracted chemist Wilma Subra, recipient of a 1999 MacArthur Fellows Program “genius” grant, to compile and analyze information gathered in a survey of DISH-area residents who reported  health problems thought to be related to air quality.

    Subra focused solely on the 16 chemicals detected at levels beyond the state’s screening limits. “They aren’t just a little over the limits,” Subra said. “They’re a lot over the limits.” Sixty-one percent of reported health problems were associated with toxic air emissions detected here, according to an independent analysis released by the nationwide nonprofit group Earthworks Oil and Gas Accountability Project on December 18, 2009.

    Mayor Tillman will be sharing his experience at six public events sponsored by a coalition of  local groups concerned about the impacts of gas drilling in the Marcellus Shale region of New York State and Pennsylvania.  He will also be meeting with five groups of local elected officials in the Southern Tier.

    Tillman, whose position as mayor is unremunerated, has refused any compensation for traveling to central New York. He says, “I would like to reach as many people as possible during this visit.” Tillman will speak to the public on “Air Quality Problems of Pipelines and Compressor Stations in Shale-Gas Production.” Delaware County residents, who will see many compression stations built along the Millennium Pipeline, will have the opportunity to hear the Mayor on Wednesday, Feb 17, at 7 pm at the Downsville Central School.  The event is  free and open to all.

    For a complete listing of events during Mayor Tillman’s visit to New York, please visit http://www.un-naturalgas.org/events.htm

    Mayor Tillman’s report  is disturbing and vital to hear now, as gas companies prepare for a massive hydrofracking offensive throughout our area that will include the highly dangerous infrastructure such drilling requires.



    Home water supply after gas drilling, Hickory, PA

    Governor Rendell, Governor Paterson, will you join us?
    Mr Grannis? Mr. Gruskin?  There’s plenty for all.

    I live in Hickory, PA… just to update what is going on here, we had our water sent to an independent lab. The amount of toxic chemicals found were off the chart.  We had the DEP come to the house (they are a complete joke!).  They took a sample of the water months ago and we have had no report come back from them. My landlord called them and they said it was safe to drink. We still have had no report from them. The same day they took the water sample, I took a picture of our water, you won’t believe it.
    From time to time our water quits running so I have to reset the pump, this is when this brown oily water flows through our pipes. Believe it or not, the DEP took three vials of this same water for testing.  The lab told us not to drink the water, not to use it for cooking and not to use it for bathing. When you can’t [get] help and you can’t get another water supply because too many people have their pockets padded, what are you to do? We take quick, lukewarm showers (pray for me) we do not drink it and don’t use it for cooking, we buy alot of bottled water.
    Here is a picture of the brown water, it’s not always brown but it’s always full of toxins!
    It’s strange how people are so scared of the swine flu, but when you talk about how the gas drillers poison our water supply they think you’re crazy or they get mad because they think they can become rich off of a deal with a gas company, money is more important to them than their health.  Finally, but too late for them, people’s eyes are starting to open to see the truth.
    Thank you and keep up the fight, I know I will, the future of our nation’s health depends on it!

    Hickory, PA resident, to Damascus Citizens for Sustainability, January 13, 2010