Email dated Nov. 14, 2011Don’t Let What Happened in Pavilion, Wyoming Happen Here
They have been fracking In Pavilion, Wyoming for decades. In response to Pavilion residents suffering from neurological impairment, loss of smell, and nerve pain that are associated with exposure to pollutants, the U.S. Environmental Protection Agency (EPA) conducted a 3 year test of their water and found the presence of alarming amounts of underground pollution. In the statement the EPA issued just last week, they announced that the water in the aquifers under 42 homes contains high levels of cancer-causing compounds and at least one chemical commonly used in hydraulic fracturing.
These documented results fly in the face of statements made by both the DEC and the industry denying that aquifers can be contaminated by fracking waste. Clearly, not only can they be contaminated, they are being contaminated.
If you don’t want the Catskills to turn into Pavilion, Wyoming, this is the most critical time to come out in force to make our opposition to fracking known.
To let Governor Cuomo know that we don’t want fracking to ruin our health and our environment, please join our “DON’T FRACK FRIDAYS” call campaign. Please call the Governor’s office, (518) 474-8390, EVERY Friday to let him know that you don’t want fracking in New York State.
Forward this message to your friends, family and neighbors and ask them to forward it on. Get educated, especially about the health issues and threats.
The Catskill Mountainkeeper website is here as a resource for you, please use it.
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Scientific American magazine, Novemeber, 2011 article - Excellent overview
The Truth about Fracking
http://www.scientificamerican.com/article.cfm?id=the-truth-about-fracking
Note: the document below was prepared by Garry Hoffman, member of the Middlesex Citizens Against Hydrofracking.
Introduction and Ground Rules
This document contains only general topic information; not the detailed specific item by item bullets that will be provided later. All data included here are from the DEC’s own documents, none are from either pro or anti Fracking groups - for maximum credibility.
The Timeline
The timeline began for us when the revised, draft, supplemental generic environmental impact statement was released for review on September 7th. A 96 day comment period is allowed, ending December 12th.
Upcoming in October is a draft release of the DEC’s proposed Regulations, a completely separate document. This will have a (presumably) 60 day comment period that will also end on or about Dec 12 . Thus all comments on all documents will be due by then.
Public hearings will be scheduled at times and places TBD, during this period. http://www.dec.ny.gov/energy/75370.html
| Date | Time | Location |
|---|---|---|
| 11/16/2011 | 1:00 PM - 4:00 PM | Dansville Middle School Auditorium, 31 Clara Barton Street, Dansville, NY 14437 |
| 11/16/2011 | 6:00 PM - 9:00 PM | Dansville Middle School Auditorium, 31 Clara Barton Street, Dansville, NY 14437 |
After all reviews and comments are submitted, the NYS DEC will review all comments on both documents and then issue the final Environmental Impact Statement and the Regulations. These will immediately have the force of law.
The Comment Period and How to Submit Comments
While the comment period is open, comments will be accepted by the DEC. Persons may submit more than one comment. Comments may be submitted by paper mail, or by using the DEC’s online comment submission form. No comments will be accepted by email. Comments must be as specific and concise as possible. Generic comments like “I don’t want Fracking” are not helpful. Persons submitting obscene or abusive comments, or sending computer viruses to the DEC website will have their comments deleted and will be blocked from sending any further comments. How to WRITE the DEC - Very Very Important
What’s a Well Pad and What’s On it ?
A well pad is a single fracking site. It is served by an access road, and must have gas pipelines connecting it to the main gas lines in the area. The pad will be generally a concrete surface, extending over some 7 or 8 acres of land. One or more wells (usually 8) will be drilled from a single pad.
Also present on each pad will be several generator sets, each containing a 1,500 HP engine driving a generator. Also present will be several heavy duty compressors, driven by the generators, and producing high volumes of compressed air at about 15,000 psi pressure.
In addition, a supply of fracking chemicals will be kept on hand on the pad for immediate use. These are both dry and liquid chemicals kept in plastic totes (dry) or bottles (wet) in sufficient quantities for the wells to be drilled on that pad. Also present will be a supply of sand for use as proppant. Large pipes and many large tanks will be provided to receive and hold fresh water and produced water for disposal.
In addition, either one or two 10,000 gallon tanks of diesel fuel will be located on site, to supply the huge engines on the generators. Heavy duty industrial lights will be erected on the pad, and will be on all night during drilling.
Finally, from one to eight drilling rigs will be erected on the site, each having a height of up to 150 feet, plus the “Christmas tree” of attachments on top, which include the blowout preventers, separators, and other plumbing devices. There will also be a control shed, called the dog house, where rig operators will shelter during the bedlam of drilling.
What’s a Single, Fracked Well ?
On each well pad, up to 8 single wells may be drilled, possibly all at once, or maybe 2 at a time. Each single well has its own single vertical hole extending down to the shale layer. Thus there will be up to 8 vertical holes on each pad. Each must have its own, triple layer, well casing of pipe and cement layers.
Each single well has to be drilled with its own drill rig. Each single well will then have one horizontal run in the shale layer, that may extend some 5000 feet laterally. Each of these single runs will be perforated and then fractured. Up to 8 million gallons of water will be used for a single well. Thus up to 64 million gallons of water will be used on each well pad. This will result in about 19.2 million gallons of highly contaminated, radioactive, produced water to be disposed of from each pad.
Perforation means the punching of holes through the pipe in the 5,000 ft horizontal section. Shaped explosive charges are used for this - similar to anti-tank rounds. Once perforated, then the fracking fluid is forced into each single well, one at a time, at 15,000 psi pressure. This is what actually fractures the shale rock layers.
http://www.nytimes.com/interactive/2011/02/27/us/fracking.html
http://www.nytimes.com/interactive/2011/02/27/us/fracking.html
Unfiltered Water Supplies
There is some obvious disinformation being spread about unfiltered water supplies. In actual fact, even New York City dwellers don’t want ground up fish heads appearing in their water faucets. Thus it is obvious that rudimentary filtering is always present, consisting of coarse screens and coarse particulate filters sufficient to keep out fish, logs, seaweed, and bulk dissolved solids like mud.
Similarly these “unfiltered” supplies are always chlorinated before going to homes to kill pathogens that would otherwise cause serious human health issues. At the least, protozoa, amoeba. and common bacterial must be killed before they reach the home.
If nothing more than the above is done, then the water supply is still considered unfiltered as a practical matter. Nothing more complex than those items mentioned above is removed from the water. Thus chemicals, insecticides, fertilizers, animal waste, and who knows what else can still make its way into the home. The fact that our towns do in fact provide this elementary degree of treatment does not mean that our water is filtered.
Only very high quality water supplies, such as the water in the Finger Lakes, can be used with such rudimentary precautions. It is obvious that if these waters were to be polluted in any way by chemicals or radioactivity, or just about anything else, that the water would then be rendered unusable for humans or domestic animals. This would end the use of the Finger Lakes as a source of drinking water, end the sport fisheries, and halt all agricultural activities in the area.
As an unfiltered water supply, it is obvious that the same exemptions allowed to the New York City and Syracuse watersheds should be extended without question to the Finger Lakes.
Health Effects of Fracking Chemicals
In order to summarize potential human health effects the DEC has divided all of the chemicals used or encountered during fracking into several classes of chemicals. Then the effects of each class are briefly listed. The following are extracts from this material.
• Petroleum Distillate Products - Adverse effects on the gastrointestinal system and the central nervous system. Contact can also cause skin irritation, blistering, or peeling.
• Aromatic Hydrocarbons - Adverse effects on the nervous system, liver, kidneys and blood forming tissues. Increased risk of leukemia. Damage to unborn offspring. Adverse effects on red blood cells. Damage to respiratory tract and increased risk of nasal and lung tumors.
Glycols - May adversely affect the kidneys and reproduction.
• Alcohols and Aldehydes - May affect the central nervous system. Ingestion may cause severe pain, vomiting, coma, and possibly death. More cases than normal of cancers of the nose and throat.
• Amides - Can damage the reproductive system, and cause cancer.
• Amines - Adversely affects the liver and kidneys. May also cause genetic damage and cancers.
• Organic Acids, Salts, Esters, and related chemicals - Corrosive or irritating to skin. Also affects mucus membranes.
• Microbiocides - Data are limited for many of these. However may cause at least effects on the respiratory and gastrointestinal tracts, and on the liver, kidneys, and nervous system.
•Other Constituents - Data are either lacking or have been withheld. However some are known to affect the eyes, liver, and kidneys, and to cause cancer in some cases.
Problems with the Produced Water
Produced water emerges from the drilled well in the period immediately after fracking. In addition to containing all the toxic chemicals that were in the original fracking fluid, the produced water brings to the surface chemicals that are found deep in the shale layers. These include most notably salt, in heavy concentrations, and radiation and radioactive isotopes found in the shale. These include alpha, beta, and gamma radiation, as well as dissolved amounts of at least 3 isotopes of radium.
Radium can become quite concentrated, and has a half life of over 1600 years. There is no way of making radium non-radioactive, and so the only solution is to try and secure the radioactive material someplace safe for thousands of years. In the past, this waste has in some cases been buried in landfills. In other cases it is suggested that this material be injected into deep underground caves. Both methods require the material to be transported which can obviously lead to worker exposure and accidental spills.
The non-radioactive components of produced water require very complex treatment procedures in themselves. Thus special disposal plants have to be built and operated and thus are subject to failure, wear out, and human error. If the treatment plants are not at the drill site (and they never would be) then the produced water must also be transported many miles, in hundreds of thousands of truck trips. Truck accidents are thus virtually certain when this many trips are undertaken. No plants presently exist in NYS that can accept this waste.
Problems with the Production Brine
Production brine is the salt laden water that is continually brought to the surface along with the natural gas, during the entire productive life of each single well. The brine contains not only salt, but if the gas produced is “sour” then there may also be sulpher present. Since both are incompatible with passage through natural gas pipeline and use infrastructure, then a separator must be located at each producing well head. This takes out the salt and other contaminants, and then passes the purified gas into the pipeline.
The resulting wastes are temporarily stored on site, and then must be periodically transported to a treatment plant capable of handling these wastes. Special treatment plants are required, as the salt especially would destroy the steel pipe and pumps in standard plants, nor can those plants remove sulpher. Thus this waste would also have to be transported, with the associated risks, and special plants would have to be built to accommodate these wastes.
Of course it goes without saying that the production brine is also radioactive, as is any water returned to the surface from the depths. There are no provisions in place as yet to deal with this serious concern.
Visual Impacts
It is important to note that so called “triple” drill rigs that would be used in many cases are over 150 feet tall. Thus they are visible for a very long distance. In addition there are bright lights extremely visible at night. Finally the generators, compressors, chemical storage pallets and 18 wheel trucks are also highly visible. None of this is compatible with the natural environment of the Finger Lakes.
Noise Impacts
According to the DEC, the noise from drill rig operations is literally deafening. That is to say that the sound levels exceed 80 dBA on the A-weighted Sound Pressure Level scale. Depending on the number of rigs operating at once, and the distance from the wells, the persons near well pads may be exposed to levels that even exceed this value.
80 dBA is a significant number because persistent exposure to sounds at or above this level are specifically known to cause hearing damage. The DEC has proposed to mitigate this problem by possibly limiting the number of simultaneously operating rigs at a site. However this is not guaranteed to reduce exposures to below 80 dBA for every person, even if this regulation can be realistically enforced by observation, and sound pressure level measurements made at each drilling site.
Sound barriers have also been proposed. However the barriers shown in illustrative pictures from the DEC are improperly designed, being composed of straight walls of limited height. Straight walls reflect the sound back into the center where they combined with fresh sound and thus reinforce the total sound level to up to 30 dBA higher than it would be. Thus if the barrier reduces sound through it by 30 dBA (which would be very good performance) all this does is cancel the reverberant buildup and thus has no net effect. Finally the limited height of the barriers will fail to contain the sound to the inside of the barrier, as sound waves can easily refract over the top of barriers of limited height.
Even if the mitigation measures were to prove adequate to limit exposures to below levels that cause hearing damage, the remaining loud noises are clearly not compatible with our natural environment in the Finger Lakes.
What are Regions A, B, and C ? How might they affect us ?
The NYS DEC has identified 3 regions of the State, called A,B, and C, which combined contain the majority of the gas available from shale in NYS. Region A contains the best resources, and includes Chemung, Tioga, and Broome counties. Region B contains medium gas resources, and includes Delaware, Otsego, and Sullivan counties. Region C contains the least productive (but still usable) gas resources, and includes Cattaraugus and Chautauqua counties.
It should be noted that, taken together, these three areas contain about 80% of the recoverable natural gas in NYS. Also these areas located along the border with PA are among the poorest in the state, and are most in need of economic development. It should be noted that persons in these areas generally tend to support fracking.
On the other hand, the areas in the state outside of A, B, and C contain only limited gas resources. Also, the vast majority of the fresh surface waters of the state are located in Lake Ontario and the Finger Lakes, which lie outside of these areas. Finally, the majority of the persons opposed to fracking are located outside of these areas, which obtain their wealth from the value of the lands surrounding the scenic lakes, as well as from tourism, wine growing, farming, and other activities which are incompatible with fracking.
One could imagine a reluctant compromise that would permit hydrofracking in areas A,B, and C, but not elsewhere in the state. This would give the gas companies access to the vast majority of the gas available. It would tend to satisfy most of the pro-frackers and most of the anti-frackers as well. While one could wish for no fracking at all in NYS, this position might represent a viable compromise that our elected officials might actually be willing to support.
How can the wastes be disposed of ?
As mentioned previously, the wastes from hydrofracking require highly specialized disposal plants. These would have to be built and operated at great expense. Due to their complexity, they would be very susceptible to failure. Maintenance costs would be high. Transportation of the wastes to the plants would raise serious issues, as mentioned previously. Finally, radioactive wastes really have no satisfactory disposal methodology, and at best, would be buried deep underground - we hope permanently.
What are the Biggest Risks ?
In view of all that has been written above, this question can be easily answered. The greatest risks come from surface spills and accidental discharges. These in turn will be caused by human error and equipment failures, as well as basic accidents.
Given the huge scale of the handling and transporting efforts that must be undertaken, it is absolutely certain that spills, errors, and accidents will occur. The only unknowns are exactly where and when.
Discharge of wastes into large surface bodies of water such as the Finger Lakes and Lake Ontario are the worst case scenarios as they affect not only the greatest numbers of people, but are also the slowest to clean up through natural means. There are no means of cleaning these up by human intervention. The scale of the problem is simply too large.
How do we balance risks and rewards ?
If we accept that some Fracking will occur in NYS because of lack of political will to prevent it, then from the foregoing we can see that the only somewhat balanced risk/reward scenario is one that keeps the fracking away from the major bodies of surface water, and also to use areas where the returns are large enough to be somewhat worth the risk.
This points to the scenario outlined above with respect to areas A,B, and C, or some reasonable variation on that scheme.
Master Plan
The NYS DEC states that if a permit is applied for in a community where the master plan and/or zoning requirements do not allow fracking, then the permit cannot be issued without a further review, in which the local community will have a significant input. Quite possibly the local communities will prevail in these instances.
It is therefore absolutely necessary that every community in NYS has an updated Master Plan in place BEFORE fracking permits are ever issued. Thus, given the fast moving pace of events, all communities should be updating their master plans NOW.
Since fracking is an industrial activity, one key is to allow industrial activity, if at all, only in areas which are not suitable for fracking.
There are numerous examples of master plan language given in the DEC document, which communities would do well to consult.
