Some Facts to know about Hydraulic Fracking and the revised draft SGEIS.
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 12th. Thus all comments on all documents will be due by then.
Public hearings will be scheduled at times and places TBD, during this period.
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.
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.
Some Facts to know about Hydraulic Fracking and the revised draft SGEIS.
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 12th. Thus all comments on all documents will be due by then.
Public hearings will be scheduled at times and places TBD, during this period.
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.
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.
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
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.
