To: David Bimber, Deputy Regional Permit Administrator, NYSDEC

From: Steve Coffman
To: David Bimber, Deputy Regional Permit Administrator, NYSDEC
January 21, 2011

Dear Administrator Bimber:
In reference to the Finger Lakes LPG Storage project in Salt Caverns near Seneca Lake in Schuyler County, I find this to be an extremely unfortunate and shortsighted project.
Undoubtedly, you have received numerous comments on the many spills and explosions that have occurred in similar projects across the nation. While those accidents are indeed worrisome, my emphasis specifically concerns Seneca Lake.
Seneca Lake is the heart and anchor of the Finger Lakes, not only centrally located but containing 50% of the Finger Lakes’ waters. For the Finger Lakes to remain healthy as a resource and viable to a burgeoning region, Seneca Lake must be protected at all costs.
A 2006 study by Hobart & William Smith’s Finger Lakes Institute portrayed Seneca Lake as a body of water on the brink of unreclaimable contamination. While some slow progress has been made since that report, this proposed project takes our region in exactly the wrong direction for community as well as environmental reasons.
The Finger Lakes are one of the largest sources of fresh water wholly within the United States (the Great Lakes being shared with Canada, of course). I hardly need to point out the importance of fresh water in a world where that most precious of resources is becoming evermore scarce. And what that means for us in the Finger Lakes, as well as for NYS and DEC, is that we have a particular obligation to be long-sighted in this respect.
Perhaps, asking DEC to consider “moral imperatives” is unusual and beyond the parameters of GEIS scoping; however, such a consideration is vital to the future well-being of the Finger Lakes Region, not only for its agriculture, wineries, growing agri-tourism, esthetic qualities, retirement appeal and Mennonite communities, but for the intrinsic value of the water itself. All of these elements fall well within the mission of DEC.
Without doubt, the nation needs energy and LPG is presently an important component of that need, which may necessitate bypassing certain local dissatisfactions, perhaps even weigh against certain “acceptable” risks. But there are things that cannot be put on the bargaining table, and the essence of the Finger Lakes and the value of its waters belong in that non-negotiable category, even if certain local officials are too shortsighted to realize their obligations.
It is for just such necessary oversight that DEC exists.
Finally, I clearly recall when, in conjunction with a proposed waste-to-energy garbage incinerator in our region, it was recommended that the Retsoff Salt caverns would be an ideal receptacle for toxic fly ash from the incinerator.
DEC even referred to the Retsoff salt formation as “essentially eternal,” a description that proved considerably over-optimistic when, as I’m sure you recall, portions of the formation collapsed before the proposal was even off the table, doing considerable damage to many wells and the poor old Genesee River. One can only imagine what the extent of the damage might have been had 20 or 30 years of concentrated toxic incinerator fly ash been added to that salty mess.
Rather than risking repetition of such an overly-optimistic assessment when it comes to the salt caverns adjacent to Seneca Lake, what is required here is an intensely-skeptical approach, which, I have no doubt would lead to the rejection of this half-baked and shortsighted plan.
Thank you.
Steve Coffman

A Brief History and Overview High Volume Horizontal Hydraulic Fracturing In NYS’s Marcellus Shale

There’s no disagreement that our country needs energy, especially domestically-produced energy. On the question of what role high-volume horizontal hydraulic fracture gas drilling should play, disagreement is considerable. While it’s true that gas drilling in the Marcellus Shale would bring some wealth, jobs and business to New York State, the elephantine question is—at what cost?

With regard to hydraulic fracturing there remain numerous unanswered questions concerning health, safety and quality of life issues, typically affecting families in areas where this kind of gas extraction takes place, not only to leasers but also to neighboring homes and farms, water wells and aquifers, even posing threats to our priceless and increasingly-vulnerable lakes. 

While these vital water issues should be under the aegis of the federal Safe Drinking Water Act and the EPA, because of Bush/Cheney/Congressional collusion with avaricious energy corporations and corrupt politicians, hydraulic fracturing has been specifically (and cynically) exempted from federal oversight. 

The danger here is not about gas drilling, in general, with which we have co-existed fairly well for many decades, but with multi-national companies like Halliburton, Chesapeake and Schlumberger that bring with them an extensive history of political shenanigans, public disregard, and environmental abuse—now joining that disregard to a technology as potentially destructive as hydraulic fracturing. New York City, whose drinking water also largely comes from the eastern area of the Marcellus Shale, is already battling for a moratorium in their region, even blaming rural western New York as part of the problem—as though we care less about the purity of our water and land arability than they do!

Yet it must be admitted that downstate citizens are far ahead of our area in addressing this urgent danger. In a presentation before the New York City Council Committee on Environmental Protection, Senior Analyst for Public Lands Dusty Horwitt described the hydraulic fracturing process this way:

‘“Gas drilling presents . . . serious risks to New York City’s drinking water. Drilling operations are large and messy involving drilling rigs and other heavy equipment, dozens of tanker trucks to haul toxic chemicals and contaminated water,         extensive pipelines, noisy compressors and waste pits full of polluted and unknown fluids. Western states have documented thousands of spills and leaks from gas drilling, at least some of which have contaminated water supplies. No matter how careful the industry says it will be, accidents are inevitable. Between 2003 and 2008, the Colorado Oil and Gas Conservation Commission recorded more than 1,500 chemical spills by the oil and gas industry. The Oil and Gas Accountability Project found that of these 1,500, 20 percent contaminated water and seven percent polluted surface water. . . .
“A recent Environmental Working Group analysis of oil and gas drilling in Colorado found that these operations use at least 65 chemicals listed or regulated as hazardous compounds under federal environmental laws. As we noted in a recent letter to Mayor Bloomberg and Governor Paterson, if any of these 65 chemicals were emitted or discharged from an industrial facility, reporting to the U.S. Environmental Protection Agency would be mandatory, and in most cases permits would require strict pollution limits and companies would be subject to specific cleanup standards. But when these same chemicals are used at a natural gas well, they are exempt from permitting, reporting requirements and cleanup standards under the Clean Air Act, the Clean Water Act, the Toxic Release Inventory, and Superfund.
“If natural gas drilling operations are allowed to proceed in the New York City watershed, some of these chemicals will be used. The only uncertainty is which ones. That is because companies typically guard the identity of the chemicals they use as a trade secret. This spring, the Durango (Colorado) Herald reported that a nurse became gravely ill after being exposed to fracturing fluids that had spilled on a natural gas worker she was treating. As the nurse suffered from liver failure, heart failure and respiratory failure, the company that manufactured the fracturing fluid refused to tell her doctor what was in it, citing the need to protect trade secrets. . . .
“There is also the problem of waste pits and spills from which chemicals could leak into ground or surface water supplies. Often, after companies inject fracturing fluids, they remove the fluids and dump them in a pit near the drilling rig. The pits can also be used to store so-called ‘produced water,’ or groundwater that is extracted in the drilling process. According to the U.S. Geological Survey, produced water can contain dissolved salts, hydrocarbons, trace metals, and radionuclides. New Mexico documented 800 cases of groundwater contamination by the oil and gas industry of which about half were due to waste pits. . . .
“Tweeti Blancett, who operates a ranch in New Mexico with her husband that has been in the Blancett family since the 1870s, says that natural gas operations including waste pits and fracturing have negatively affected her water supply. ‘My water when it comes up, ninety-seven percent of the time, it’s deadly,’ she said. ‘It’s full of heavy metals, petroleum products and things you don’t even want to talk about. We didn’t know we were going to have these problems when they started drilling out here,’ she said, adding that New York officials ‘have an open invitation to come to the ranch,’ for a tour. ‘You don’t want what we have.’”
—Statement of Dusty Horwitt, JD,Senior Analyst for Public Lands, Environmental Working Group to September 2008 Oversight Hearing on Natural Gas Drilling in the New York City Watershed Before the New York City Council Committee on Environmental Protection, Wednesday, September 10, 2008 

Why is there no federal oversight? Didn’t Congress, in the Safe Drinking Water Acts of 1974 and 1996, place the safety of all our drinking water under the auspices of the EPA, demanding regulation, open reporting and onsite oversight of all toxic chemicals and land contamination in any operation where water safety was at risk?

To see what happened and what has turned us loose us into this deregulated wild-west drilling spree, consider the following eye-opening (nose-assaulting) timeline:



1997: Alabama residents win a ruling in U.S. appeals court that fracturing should be regulated under the federal Safe Drinking Water Act.

1999: Following up on its ruling, the U.S. appeals court orders the EPA to oversee fracturing in Alabama.

2000: Halliburton, a prime developer and leading practitioner of hydraulic fracturing lobbies in Washington to exempt fracturing from regulation under the Safe Drinking Water Act. (Dick Cheney, Halliburton CEO since 1995, becomes Vice-President of the United States.)


In his second week in office, George W. Bush creates the Energy task force, officially known as the National Energy Policy Development Group (NEPDG) with Dick Cheney as chairman. This group aimed to “develop a national energy policy designed to help the private sector, and, as necessary and appropriate, State and local governments, promote dependable, affordable, and environmentally sound production and distribution of energy for the future.”
May 16, 2001 — NEPDG releases its final report, in response to which EPA chief Christie Whitman presses Cheney to scale back language recommending the exemption of fracturing from the task force report. The exemption recommendation is removed, but the report notes the benefits of fracturing.

3.  NOVEMBER 7,  2003 — ENERGY BILL OF 2003

Bush and Cheney push the Energy Bill of 2003 that includes a provision to exempt fracturing from EPA drinking water regulation, though the provision is excised by Congress from the final draft.


I. A Voluntary agreement in which  the Companies agree to eliminate diesel fuel in hydraulic fracturing fluids injected into coalbed methane (CBM) production wells in underground sources of drinking water (USDWs) and, if necessary, select replacements that will not cause hydraulic fracturing fluids to endanger USDWs.  While the Companies do not necessarily agree that hydraulic fracturing fluids using diesel fuel endanger USDWs when they are injected into CBM production wells, the Companies are prepared to enter into this agreement in response to EPA’s concerns and to reduce potential risks to the environment.  


A. The Companies and EPA acknowledge that only technically feasible and cost- effective actions to provide alternatives for diesel fuel will be sought. The determination of what is technically feasible and cost-effective will vary and it is at the discretion of each Company to make that determination. 
B. The Companies and EPA will exercise good faith in fulfilling the obligations of this Memorandum of Agreement (MOA). 
C. Nothing in this agreement constrains EPA or the Companies from taking actions relating to hydraulic fracturing that are authorized or required by law.  Nothing in this agreement should be understood as an EPA determination that use by the Companies of any particular replacement for diesel fuel is authorized under the Safe Drinking Water Act (SDWA) or EPA’s Underground Injection Control (UIC) Regulations, or that the elimination of diesel fuel or use of any replacement fluid constitutes or confers any immunity or defense in an action to enforce the SDWA or EPA’s UIC regulations. Nothing in this Agreement shall, in any way, be considered a waiver of the Companies’ right to challenge any subsequent regulations or limitations on the use of hydraulic fracturing or its components by any state or Federal agencies. 

[Note:  Following this agreement, these companies and others have consistently continued to use benzene and other petroleum distillates in their hydrofracking processes in numerous states. When, after 2009-2010 discovery, this bad faith continuance was pointed out, the common industry response was that these companies had only promised not to use such products in reference to “coalbed methane,” and had never promised anything in reference to “hydraulic fracture drilling of natural gas.”] 

A. To the extent consistent with Agency authorities and policies governing 
recognition awards, EPA agrees to consider providing the Companies with 
recognition for their achievements in replacing diesel fuel in fracturing fluids 
injected into USDWs for CBM production and for their public service in protecting the environment. . . .
C. EPA agrees to issue a final version of the draft report entitled Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs as soon as reasonably possible. 
5.  JUNE 2004 — EPA PUBLISHES FINAL VERSION OF STUDY: Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs  

[The report contains results of a Phase I investigation undertaken by EPA to evaluate the impacts to underground sources of drinking water (USDW) by hydraulic fracturing of coalbed methane wells. Based on the information collected, EPA has concluded that the potential threats to public health posed by hydraulic fracturing of CBM wells appear to be small and do not appear to justify additional study.] 

6.  OCTOBER 8, 2004 — EPA ENGINEER WES WILSON blows the whistle on EPA’s study (in an 18 page report to Senators Wayne Allard, Ben Nighthorse Campbell and Rep. Diana GeGette) challenging the conclusions of the EPA study

“Recent events at the EPA have caused me and several of my peers at EPA great concern. In June of this year, EPA produced final report pursuant to the Safe Drinking Water Act that I believe is scientifically unsound and contrary to the purposes of the law. In this report, EPA was to have studied the environmental effects that might result from the injection of toxic fluids used to hydraulically fracture coal beds to produce natural gas. . . . While EPA’s report concludes that this practice poses little or no threat to underground sources of drinking water, based on the available science and literature, EPA’s conclusions are insupportable. EPA has conducted limited research reaching the unsupported conclusion that this industry practice needs no further study at this time. EPA decisions were supported by a Peer Review Panel; however five of the seven members of this panel appear to have conflicts-of-interest and may benefit from EPA’s decision not to conduct further investigation or impose regulatory conditions.” 

[Three of the five conflicted members of the panel were present employees of BP Amoco, Halliburton and the Gas Technology Institute; one a former employee of BP Amoco, one a former employee of Mobil Exploration.]


from) “Halliburton’s Interests Assisted by White House” By Tom Hamburger and Alan C. Miller:

“Over the last four years, the Bush administration and Vice President Dick Cheney’s office have backed a series of measures favoring a drilling technique developed by Halliburton Co., Cheney’s former employer. The technology, known as hydraulic fracturing, boosts gas and oil production and generates $1.5 billion a year for the company, about one-fifth of its energy-related revenue. 
“In recent years, Halliburton and other oil and gas firms have been fighting efforts to regulate the procedure under a statute that protects drinking water supplies.
The 2001 national energy policy report, written under the direction of the vice president’s office, cited the value of hydraulic fracturing but didn’t mention concerns raised by staff members at the Environmental Protection Agency.
“Since then, the administration has taken steps to keep the practice from being regulated under the Safe Drinking Water Act, which Halliburton has said would hurt its business and add needless costs and bureaucratic delays.
“’From my perspective, the vice president’s office was driving the issue of hydraulic fracturing,’ said Jeremy Symons, a former EPA staffer.
“Rep. Henry A. Waxman (D-Los Angeles), a member of the House Energy and Commerce Committee who has followed the fracturing study’s progress, said the EPA review ‘made a faith-based leap to conclude that injecting toxic materials’ underground posed little or no threat, he said. ‘The unanswered questions in EPA’s report cry out for further study.’” 

8.  APRIL 2005 — OIL AND GAS ACCOUNTABILITY PROJECT (OGAP) REPORT shows 2004 EPA Study to be a high-pressure whitewash 

“The Oil and Gas Accountability Project (OGAP) has conducted a review of the EPA study. We found that EPA removed information from earlier drafts that suggested unregulated fracturing poses a threat to human health, and that the Agency did not include information that suggests fracturing fluids may pose a threat to drinking water long after drilling operations are completed. OGAP’s review of relevant data on hydraulic fracturing suggests that there is insufficient information for EPA to have concluded that hydraulic fracturing does not pose a threat to drinking water. 
“The hydraulic fracturing company Schlumberger recommends that many of its 
fracturing fluids be disposed of at hazardous waste facilities. Yet these same fluids 
are allowed to be injected directly into or adjacent to USDWs. Under the Safe Drinking 
Water Act no other industries are allowed to inject hazardous wastes–unchecked– 
directly into USDWs. EPA does not provide any scientific data to demonstrate that the 
hazardous characteristics of fracturing fluids are reduced enough to make it safe to 
inject these chemicals into or close to USDWs. 
“What are the problems with EPA’s study into the effects of hydraulic fracturing on underground sources of drinking water? OGAP and many others question EPA’s conclusions. Many who have studied the EPA report believe that EPA failed to provide adequate data and information to support its claim that hydraulic fracturing does not pose a threat to drinking water. OGAP and many others believe that EPA should continue investigating the risks posed by hydraulic fracturing. OGAP has just completed an in-depth critique of EPA’s hydraulic fracturing study, Our Drinking Water At Risk: What EPA and the oil and gas industry don’t want us to know about hydraulic fracturing.”

9.  ENERGY POLICY ACT OF 2005 — exempting hydraulic fracturing from federal oversight and law

MAY 19, 2005 — S. 837  JAMES INHOFE (R – OK) AMENDMENT

Amends Safe Drinking Water Act of 1996 (SDWA) to exempt hydraulic fracturing related to oil and gas production from the definition of underground injection and, thus, exclude this practice from potential underground injection regulations related to the protection of underground sources of drinking water.  (Similar to H.R. 6, Section 322.)  Introduced April 18, 2005; [referred to the Committee on Environment and Public Works]. 

AUGUST 8, 2005  —  P.L. 109-58, H.R. 6  JOE BARTON (R – TX) AMENDMENT

Section 322 of The Energy Policy Act of 2005, amends SDWA to exempt from regulation the underground injection of fluids (except diesel fuel) into underground sources of drinking water for hydraulic fracturing purposes related to oil, gas, and geothermal production. 


Timeline Conclusions

Only the most credulous or blindly partisan mind could conclude that there is anything “coincidental” about this timeline. Still, the question that jumps out is: What is there about the process of hydraulic fracturing that would prompt such persistent and devious action by our former President and Vice-President to remove its oversight from an already weak and pliable Environment Protection Agency? 

What awful danger is being covered up here that so desperately needs to be exempted from the Safe Drinking Water Act, removed from the aegis of the EPA and kept unavailable to public scrutiny?

Is the truth about hydraulic fracturing really as bad as that? Or is it simply that the energy corporations and their sycophants are only afraid that public fear (however warranted or unwarranted) will slow the flow, and no energy corp worth its briny wastewater can abide the effrontery of that?

What I suspect is that they don’t really know and don’t really care how bad it is, just want to get as much gas out of the ground and money into some Cayman Islands bank before anyone else knows either.

But we who reside and raise families here cannot afford such a cavalier attitude toward the quality of our water, air, soil, and the Finger Lakes themselves—those essentials to our quality of life and health, and to that of future generations. 

We who live here cannot abide the carte blanche given to these companies who have colluded to dodge meaningful oversight or regulation and arrogated to themselves the right to selectively buy up the subterranean rights out from under us . . . suck out trillions of cubic feet of gas from a mile or two under our land, lakes and aquifers . . . use millions of gallons our fresh water, lacing it with tons of unnamed chemicals, break up the 300 million year old, 200-foot-thick layer of shale beneath our homes. 

Then, after dropping a few thousands of dollars on local landowners, scramming with their loot and leaving our communities to deal with the residual waste pits, ruined roads, salted topsoil, strained relations, ripped up underworld, unknown effects on groundwater aquifers and lakes. . . . of course making sure to spill out a gusher of political campaign contributions as they head on up the road . . . to reprise their performance like a traveling stage show of Paradise Lost.

Is that too dramatic? Perhaps, but as many as 18,000 such wells are presently envisioned for western New York alone. 

In his 2008 statement before the New York City Council Committee on Environmental Protection, Senior Analyst for Public Lands Dustin Horwitt wrote:

“Environmental Working Group is not opposed to all natural gas drilling. But due to the highly polluting nature of the oil and gas industry, the likelihood that thousands of wells could be drilled, and the multi-billion-dollar cost of building a treatment facility to clean up contaminated water, we strongly recommend that New York officials not allow any drilling in New York City’s watershed.
“In hydraulic fracturing, companies inject water laced with toxic chemicals under high pressure to break open rock formations  . . . [and] also inject acid to dissolve the rock to increase the flow of natural gas or oil—a process known as ‘acidizing’ or, if the acid is injected under high-pressure to fracture the rock, ‘acid fracturing.’. . . .
“It is at best unclear what might happen if hydraulic fracturing fluids are injected underground. One industry report from 2003 found that ‘even if natural barriers, such as dense shale layers, separate the different fluid zones, and a good cement job exists, shales can heave and fracture near the wellbore. As a result of production, the pressure differential across these shales allows fluid to migrate through the wellbore. More often, this type of failure is associated with stimulation attempts. Fractures break through the shale layer, or acids dissolve channels through it.’ The report also noted that ‘an improperly designed or poorly performed stimulation treatment can allow a hydraulic fracture to enter a water zone.’”

2008 Update  — ( from) “ProPublica”

“In July [2008], a hydrologist dropped a plastic sampling pipe 300 feet down a water well in rural Sublette County, Wyo., and pulled up a load of brown, oily water with a foul smell. Tests showed it contained benzene, a chemical believed to cause aplastic anemia and leukemia, in a concentration 1,500 times the level safe for people.
“The results sent shock waves through the energy industry and state and federal regulatory agencies. Sublette County is the home of one of the nation’s largest natural-gas fields, and many of its 6,000 wells have undergone a process pioneered by Halliburton called hydraulic fracturing, which shoots vast amounts of water, sand and chemicals several miles underground to break apart rock and release the gas.
“The 2004 EPA study is routinely used to dismiss complaints that hydraulic-fracturing fluids might be responsible for the water problems in places like . . . the Sublette County gas field. . . .But documents obtained by ProPublica show that the EPA negotiated directly with the gas industry before finalizing those conclusions and then ignored evidence that fracking might cause the kinds of water problems now being recorded in drilling states. Buried deep within the 424-page report are statements explaining that fluids migrated unpredictably and that some of the chemicals involved ‘can cause kidney, liver, heart, blood, and brain damage through prolonged or repeated exposure.’” 
—“Drilling process causes water supply alarm,” By Abraham Lustgarten 
ProPublica, November 17, 2008

“As ProPublica has reported, it’s difficult for scientists to say which aspect of drilling—the hydraulic fracturing, the waste water that accidentally flows into the ground, the leaky pits of drilling fluids or the spills from truckloads of chemicals transported to and from the site—causes such pollution. . . . Without those data, environmental officials say they cannot conclude with certainty when or how certain chemicals entered the water.
“Ask officials in New Mexico and Colorado: Are there any cases in which we can prove beyond a reasonable doubt that hydraulic fracturing caused water contamination? Answer: No, we’ve never studied that question. Ask those same officials: Are there hundreds of cases of water contamination in drilling areas, the vast majority of which use hydraulic fracturing? Answer: Yes.”
—”Setting the Record Straight on Hydraulic Fracturing,” by Abraham Lustgarten, ProPublica – January 12, 2009


The Marcellus Shale is of marine origin, which means it contains high levels of salt, some of which will dissolve in the hydrofracking fluid. This is a major issue for disposal of the retrieved hydrofracking fluid. Though these fluids might be processed through a water treatment plant, they would have to be sufficiently diluted by other fresh water before being safely discharged into any freshwater ecosystems, a significant limitation on the amount of hydraulic fracture wastewater that facilities can treat. 

Needless to say, salinated water is almost as unfriendly to arable soil as it is to potable water. 

Lake Dangers

“Recent analyses of Seneca Lake, the largest and deepest of the 11 Finger Lakes and source of drinking water for over 100,000 people, reveal a degradation in water quality that is of deep concern.” —Kinnevey and Halfman, “Water quality analysis in the Seneca Lake watershed,” (2006).

Lamoka and Waneta lakes are already strangled with weeds. 

Keuka Lake drinking water is still “AA.” Does that make it an “attainment zone?”

Where is the water going to come from? Even more importantly, where is the fracking-fluid, heavily-salinated wastewater going to go? These issues must be subject to EIS, independent analyses, and public discussion BEFORE we get too deep in the muck with the likes of Halliburton. Are we really supposed to trust our precious Finger Lakes to their environmental and ethical standards?

Nuclear Contamination  

“The Marcellus also contains uranium, and the radioactive decay of the uranium-238 makes it a source rock for radioactive radon gas (222Rn).” [Wanty, Richard B. (1993). 

“The Marcellus Shale contains naturally occurring radioactive materials (NORMs), including uranium. A 1999 investigation of NORMs in oil and gas wells found that the concentrations of NORMs on oil and gas production equipment and wastes pose no threat to the public health and the environment. . . . 
“However, the Marcellus shale apparently was not included in the geological formations tested for this report. Therefore, it would seem prudent to test for NORMs in this rock, as well as the reactions it will undergo when exposed to fresh water in a lined pit.” — (

“Close proximity to the surface of Marcellus bedrock south of the New York outcrops makes an east-west band running through the city of Syracuse a high risk area for radon as an indoor air pollutant.” — “The State of Radon in New York,” NYS Department of Health Wadsworth Center.

Soil Contamination

“Exposures from cut and fill road construction in Virginia and Pennsylvania have resulted in localized acid rock drainage due to oxidation of the pyrite inclusions. The newly exposed shale on the cut face weathers rapidly, allowing air and water into the unexcavated rock, resulting in acidic surface runoff after precipitation events. Acidic runoff disrupts aquatic ecosystems, and highly acidic soil contaminated by this runoff will not support vegetation, which is unsightly, and can lead to problems with soil erosion.” —[Orndorff, Z.W.; Lee Daniels, W. (2004). “Evaluation of acid-producing sulfidic materials in Virginia highway corridors” ]

Air Pollution

“In addition to pollution from diesel generators, drill rigs, truck, and equipment, flaring and condensate tanks are significant sources of VOCs (volatile organic compounds) and nitrogen oxide, the components of ozone. Proposed Marcellus shale drilling in New York will be high density. In high density drilling areas in Colorado and Wyoming, rural communities have ozone level higher than Los Angeles. Ozone can cause respiratory problems and lung disease. . . .
“To put our concerns into a more specific context, Rocky Mountain Clean Air Action reviewed data and assumptions related to VOC emissions from natural gas well completions in the Denver metro area and found that industry developed emission estimates are likely underestimated by as much as 500% or more. . . .
“Our calculations revealed that VOC emissions from well completions averaged 1.56 tons/completion based on one day of flowback. Based on COGCC data showing that 972 natural gas wells were completed in the Denver metro nonattainment area in 2006, this would amount to over 4 tons of VOCs/day.” 
  — Colorado Department of Public Health and Environment Air Pollution Control Division Response to Stakeholder Comments on Draft Oil and Gas Ozone Reduction Strategies, April 10, 2008; 

Destabilizing Geological Substructure

As scientifically-simpleminded as I am, I do know enough about Legos and Tinkertoys to know that if you weaken a structure’s foundation, certain reactions above it are likely to occur. In the case of a 50-to-200 foot thick layer of shale with an aquifer on top of it and an ocean of compressed gas beneath it, my layman’s stupidity would not be surprised if, by multiply fracturing the shale and removing the gas beneath it, there could be some unpredictably rearranging of the surrounding earth, rock and water up above.

“Damage to structures constructed on fill consisting of pyritic Marcellus shale has been caused by expansion from sulfuric acid (H2SO4) runoff reacting with the calcite (CaCO3) in the shale to produce gypsum (CaSO4), which has doubled the molar volume. Other sulfate minerals that can be produced by reactions with pyrite include anhydrite, melanterite, rozenite, jarosite and alunite. The reactions have generated a heave pressure on the order of 10,000 pounds per square foot (500 KPa), but may be able to generate four times this pressure — enough to heave foundations in a 5 story building. Limestone, which is used to neutralize the acid drainage, can actually exacerbate the expansion problem by promoting sulfate—sulfate reactions that form the minerals thaumasite and ettringite, which have even higher molar volumes.” —Doden, A.G.; Gold, D.P.; Hoover, S.E.; Scheetz, B.E.; Ellsworth, C.J. (2008), :// 

“Drilling boreholes through the Hamilton Group shales in the subsurface can be problematic. The Marcellus has a relatively low density, and these shales may not be chemically compatible with some drilling fluids. The shale is relatively fragile, and may fracture under pressure, causing a problem in circulating the drilling fluid back up through the borehole known as ‘lost circulation’. The formation may also be under-pressurized, further complicating the drilling process.” —Wickstrom, Lawrence H.; Ernie R. Slucher, Mark T. Baranoski, and Douglas J. Mullett (2008). “Geologic Assessment of the Burger Power Plant and Surrounding Vicinity for Potential Injection of Carbon Dioxide”

Roads and Bridges

Sullivan County Commissioner of Planning and Environmental Management, William Pammer, noted that based on statistics and experiences elsewhere, the high volume of Class 1 and 2 roads in Western Sullivan County areas where drilling would occur, would likely lead to a huge increase in infrastructure costs.  Expect an “80 percent degradation” warned Pammer.

DEC Oversight? 

On DEC’s hydraulic-fractured website on Marcellus Shale Gas Drilling, it does not even see fit to mention (let alone address) any of the aforementioned environmental issues. It does, however, mention the quantities of required water.

from NYS DEC WEBSITE [Hydraulic Fracturing Considerations for Natural Gas Wells of the Marcellus Shale]:

Quantity of water needed for hydraulic fracturing

“Hydraulic fracturing of the Marcellus Shale will require large volumes of water to fracture the rocks and produce the desired amount of gas. Each well may use more than one million gallons of water.”

Where does the water come from?

“The average annual precipitation that falls in the Marcellus shale area is 
approximately 43 inches and is evenly distributed over the course of the year.  This precipitation over the Marcellus Shale Boundary production area (estimated to be between 54,000 square miles and 95,000 sq. mi) results in between 710,000,000,000 and 1,250,000,000,000 gallons of water input into the Marcellus Shale area annually from precipitation. In comparison to other shale plays, there is substantially more available water in this region than many others, making the area ideal for shale gas development.” 

“Operators developing the Marcellus Shale are evaluating safe and economic practices for the disposal of produced waters from the drilling and fracture treating of wells. Flow-back and produced water from hydraulic fracturing events are being contained in enclosed fluid capture systems to reduce their exposure to the environment and the potential for spills to occur. Operators are using a variety of containment tanks and storage trucks to reduce the potential for exposure of fluids to the environment during the transport of chemicals to disposal locations away from the well pad.  Many Marcellus operators in states like New York are actively researching options where Class II disposal wells and municipal and industrial treatment facilities can be used to manage flow-back water. . . .    
“The disposal of flow-back and produced water is evolving in the Appalachians. The volumes of water that are being produced as flow-back water is likely going to require a number of options for disposal that may include municipal or industrial water treatment facilities, Class II injection wells, and the recycling of flow-back water.”   

WHAT? DEC is “evaluating” safe practices? “Researching” disposal options that are “evolving” . . .  “that may include” . . .? 

Wouldn’t you think this would have to be done before drilling was allowed to begin?

That engenders about as much confidence as the company, All Consulting, who prepared this “Final Report” for DEC in 2008. 

Who exactly is ALL Consulting? It’s a Texas-based consulting firm that specializes in Gas & Oil Exploration projects. For instance: “Improving Access To Onshore Oil & Gas Resources on Federal Lands,” March 2007. This was a study conducted by the Interstate Oil and Gas Compact Commission and ALL Consulting as co-researchers in cooperation with the oil and gas agencies of Alaska, Montana , Wyoming, Kansas and Oklahoma—overseen by The National Petroleum Technology Office located in Tulsa, Oklahoma.]

My concerns are not exactly allayed. Are yours? “The Report,” as the DEC website refers to it, never even mentions radioactivity or radon. Never mentions the Finger Lakes. Never mentions seismic activity. Never mentions corruption of surrounding soils and roads. Never mentions the constant roar of compessors and endless truck traffic. And, as to the disposal of toxic volumes of water, its expert solution is: “We’re working on it. Advances are being made. Don’t worry about it—the more we drill the better we get.”

And maybe they’re right. Maybe it is just a little dirt falling and not the sky. Do I really understand all this? Hardly. All I really know is enough that I absolutely want some people who do understand it to be responsible for assurances that: 1) water wells and aquifers will not be contaminated; 2) uranium and radon will not infect me or my neighbors; 3) our lakes will not be harmed; 4) our farmland will not be unduly eroded or rendered infertile; 4) our air will remain compatible with our lungs, 5) earthquake activity or any subterranean damage will not be our legacy from these carpetbagging corporations.

Lastly, in response to the desperate cry that we have to find and use up every drop and dram of polluting fossil energy now before alternatives make them as antediluvian as the Iron Age and Bronze Age, I can only preach temperance and moderation. To our public spirited representatives, I can only ask that they ignore the enormity of money that seeks to brainwash politicians and press alike into believing that opposition to any energy industry desire is akin to battlefield desertion. To the panic call of Drill! Drill! Drill!, I can only say that this gas has been trapped where it is for 300 hundred million years and isn’t going anywhere while we wait for a few answers. In all probability, if and when drilling the Marcellus Shale proves to be safe and efficacious, natural gas will likely still be needed. And if not, if alternative energy sources have surpassed our need for fossile fuels by then—all of us except the energy companies will be the richer for it. 

Steve Coffman, Dundee
March 15, 2009