Fracking Banned in New York

In 2012, the New York State Department of Environmental Conservation (DEC) requested that the New York State Department of Health (DOH) review and assess DEC’s analysis of potential health impacts of hydraulic Fracturing (fracking). Last week the DOH has issued a 186 page report that finds fracking is a complex activity that could affect many communities in New York State because the Marcellus Shale covers a large portion of the state. The number of well pads could be vast and spread out over a significant portion of the state with different environmental conditions. This increase the risk of equipment failures and human error, and increases the risk for exposure to dust, methane gas, air pollution from the operation of equipment, water pollution and adverse health outcomes. Because of these concerns for potential impact to the environment and citizens of the state, New York has banned fracking.

The major findings of the New York DOH report are that there are potential environmental and human health impacts from fracking that include:

• Increased truck traffic associated with fracking could have air quality impacts that could affect respiratory health due to increased levels of particulate matter, diesel exhaust, or volatile organic chemicals.
• Fracking could contribute to increasing climate change by releasing methane to the atmosphere and making it cheaper to use natural gas to heat homes and make electricity delaying the adoption of renewable energy sources..
• Faulty well construction could allow methane and/or fracking water containing a mix of chemical to contaminate potential drinking water supplies.
• Surface spills potentially resulting in soil and water contamination.
• Surface-water contamination resulting from inadequate wastewater treatment.
• Earthquakes induced during fracturing. (Though federal studies have found that induced earthquakes are associated with deep well disposal of waste water not fracking itself.) 
• Community impacts associated with boom-town economic effects such as increased vehicle traffic, road damage, noise, odor complaints, increased demand for housing and medical care, and stress.

This report from the DOH served more as the argument for the ban rather than a scientific study. A recent study by scientists reviewed all 166 fracking studies that have been performed and peer reviewed to consolidate all that we know about fracking and identify the areas where more research needs to be performed. This paper is  a complete and thorough review of all the risks and benefits and area where more study needs to be performed for the hydrocarbon extraction method known as fracking. The paper: “The Environmental Costs and Benefits of Fracking” in the Annual Review of Environment and Resources.( Annu. Rev. Environ. Resour. 2014. 39:7.1–7.36) by Robert B. Jackson formerly of Duke University and now at Stanford, Avner Vengosh, still at Duke University, J. William Carey, from Los Alamos National Laboratory, Richard J. Davies, from Durham University, Thomas H. Darrah, for Ohio State University, Francis O’Sullivan, from MIT and Gabrielle P´etron from the University of Colorado at Boulder.

Fracking is the current method of extracting unconventional oil and natural gas that is locked inside impermeable geological formations. Fracking is enabled by horizontal drilling and hydraulic fracturing (thus the name fracking). Fracking or hydraulic fracturing as it is more properly known involves the pressurized injection of fluids made up of mostly water and chemical additives into a geologic formation. The pressure used exceeds the rock strength and the fluid opens or enlarges fractures in the rock. As the formation is fractured, a “propping agent,” such as sand or ceramic beads, is pumped into the fractures to keep them from closing as the pumping pressure is released. The fracturing fluids (water and chemical additives) are partially recovered and returned to the surface or deep well injected for disposal. Natural gas or oil will flow from pores and fractures in the rock into the wells allowing for enhanced access to the methane or oil reserves.

From USGS the extent of the Marcellus Shale

Throughout their study the scientist recommend a series of research questions that should be answered to more fully model and understand fracking, but not banning . In addition they emphasize the need for greater transparency from companies and regulating agencies in information and the need for baseline studies prior to drilling is critical to even know if water or human health has been impacted. Predrilling data needs to include measurements of groundwater and surface-water quality and quantity as well as air quality, and human health. The scientists pointed out that there have been virtually no comprehensive studies on the impact of fracking on human health while state regulators and law in some instances allow fracking virtually in people’s backyards. The New York regulators have now banned fracking because it is not completely understood, the risks imperfectly managed and will likely contribute to climate change.

Fracking, Zoning and the Courts

On Monday, June 30th the New York Court of Appeals, the highest court in the state, ruled that the state's Oil, Gas and Solution Mining Law (OGSML) does not preempt the towns of Dryden and Middlefield from banning fracking under their local zoning laws. At issue in the cases was the supersession clause of the OGSML, which says it “shall supersede all local laws or ordinances relating to the regulation of the oil, gas and solution mining industries; but shall not supersede local government jurisdiction over local roads or the rights of local governments under the real property tax law.”

The court upheld the right of local governments to ban natural gas drilling using hydraulic fracturing techniques also known as hydrofracking or fracking. The court maintained the home rule capacity of municipalities to pass zoning laws that exclude oil, gas and hydrofracking activities in order to preserve the existing character of their communities. While this decision seems to clearly places the control of fracking in communities within those communities; since 2008 there has been a statewide moratorium on drilling in the Marcellus Shale. The moratorium has dragged on while New York assessed the effects of fracking. The New York Department of Environmental Conservation’s (DEC) draft environmental impact statement (EIS) on drilling was released in the fall of 2011 and recommended that drilling be permitted, but with conditions. The comment period was extended and the DEC began a revision to the EIS with comments from other agencies that has been on going with no end in sight.

A large swath of southwestern New York sits atop the Marcellus Shale, which is the third-largest natural gas field currently known in the world and underlies significant portions of Pennsylvania, West Virginia and Ohio. The Marcellus Shale alone is estimated to contain 500-trillion-cubic-feet of gas reserves. This resource could heat our homes for a generation or more, and power our electrical generating plants, even fuel cars either directly or through plug in hybrids. The possible impacts to our economy and environment are far reaching. The potential risks are also far reaching.

In December 2013, the Pennsylvania Supreme Court affirmed a 2012 Commonwealth Court decision striking down portions of Act 13 a 2012 Pennsylvania law that would have created a single statewide zoning for all oil and gas activities, and would in effect have taken away from the municipalities in Pennsylvania the ability to use zoning to exclude fracking of shale gas formations in residential neighborhoods. According to Richard A. Ward, Township Manager Robinson Township, PA, Act 13 turned the entire state of Pennsylvania into one large industrial zone. Robinson Township joined by several other communities challenged Act 13 and won.

The Pennsylvania state Supreme Court based its decision not in the property rights of surface landowners, but on Pennsylvania’s Environmental Rights Amendment. The Pennsylvania Supreme Court stated in its opinion that Act 13’s elimination of zoning and land use planning authority was unconstitutional because that was the primary method through which municipalities act as trustees under the Pennsylvania Environmental Rights Amendment of the state constitution. The Court found that the state cannot interfere with the constitutional duty of municipal governments to carry out the Environmental Rights Amendment.

Advances in horizontal drilling which allows a vertically drilled well to turn and run thousands of feet laterally through the earth combined with advances in hydraulic fracking, the pumping of millions of gallons of chemicals and water into shale at high pressure have increased our ability to recover natural gas from shale. Hydraulic fracking while old has made tremendous advances in the past 15 years that have made it possible to economically access this gas. Hydrofracking has increased our ability to recover natural gas buried a mile or more beneath the earth. Our knowledge of the impacts from hydrofracking has lagged behind our ability to access the gas.

In hydraulic fracking on average 2-5 million gallons of chemicals and water is pumped into the shale formation at 9,000 pounds per square inch and literally cracks the shale or breaks open existing cracks and allows the trapped natural gas to flow. Each stage of the fracking water cycle is a potential area for impact to drinking water supplies especially from human error and irresponsibly and improperly handling chemicals and contaminated water and poorly managing and protecting our water resources.

Water used for fracturing fluids is acquired from surface water or groundwater in the local area. Billions of gallons of water will be used in each region for fracking. Wastewaters from the hydraulic fracturing process (flowback or water produced in the well) needs to be properly treated before it is returned to the waters of the earth. The reality is all water on earth has been here for 4.5 billion years and no new water is being created. The fate of the water that flows back after fracturing has to be addressed, but not all fracturing fluids injected into the geologic formation are recovered. The EPA estimates that the fluids recovered range from 15-80% of the volume injected depending on the site. The long term fate of any residual fluid has just begun to be studied.

In 2011, the U.S. Environmental Protection Agency (EPA) began a series of research projects into the impacts and potential impacts of fracking on water that are scheduled for completion later this year. Data from 333 oil and gas wells from across the United States are being examined to assess the effectiveness of current well construction practices at containing gases and liquids before, during, and after hydraulic fracturing. In addition, computer models are being developed to evaluate the potential risk to water resources from water acquisition, well injection, wastewater treatment and waste water disposal from hydrofracking. The computer models are also being used to explore the possibility of subsurface gas and fluid migration from deep shale formations to overlying aquifers in different scenarios.

The effectiveness of the models will be dependent on how closely the model predicts transport behavior in rock and shale and the similarity in behavior of different formations. These studies will be the basis for future regulations for oil and gas operations. Whether the EPA will regulate oil and gas exploration nationally or leave the oversight in the hands of the states is an open question. There is an argument that water resources and geology are very local phenomena and cannot be generalized over the nation and that hydraulic fracturing should remain under local oversight. This decision from the New York Court of Appeals and the Pennsylvania decision in 2013 clearly state that local municipalities are responsible for deciding if hydrofracking within their communities is in the best interest of their community.

New York Fracking Report Leaked to the New York Times

Extent of Marcellus Shale within the Devonian Shale of the Northeast- USGS

Last Thursday the New York Times reported that an analysis on fracking prepared in early 2012 was leaked to their paper. This analysis was prepared last year after the New York Department of Environmental Conservation’s 2011 draft environmental impact statement (EIS) on drilling comment period was closed and might have been prepared in response to the comments received. The 8 pages obtained by the New York Times were characterized by the paper as containing an analysis that showed that hydraulic Fracturing, or fracking, could be safely done in New York by implementing the proper mitigation measures. The report, obtained by the New York Times from and “expert who did not believe it should be kept secret,” was characterized by State Department of Environmental Conservation, DEC, as an out of date summary that was nearly a year old and will undergo significant changes. The revised version of the Environmental Impact Statement has not yet been completed or released and the DEC’s health assessment is being reviewed by three outside experts. I think someone may have violated the terms of their consulting contract.

The report (or summary) the New York Times had seems to be in agreement with the recommendations made in the report of the Shale Gas Subcommittee of the Secretary of Energy Advisory Board in 2011. That report had a rational approach to regulation recommending disclosure, testing, evaluation and modification of regulation and practices based on the information and data obtained. It assumes information and data will be gathered and analyzed and seems to be the accepted view, but fracking is a highly complex issue whose greatest risks are to our water resources. There needs to be much more data collected over time and analyzed. That has not being done in the past and until extensive data is collected and studied we will not truly know. The data needs to be collected on a state by state basis and provided to the US Geological Survey (USGS) and US EPA to consolidate on a national level. It is essential that the USGS be involved because of the unique expertise and research in geology and water resources.

In 2011, the EPA began a series of research projects into the impacts and potential impacts of fracking on water that are scheduled for completion in late 2014. These projects will be the basis of their actions and future regulations for oil and gas operations. Whether the EPA will regulate oil and gas exploration nationally or leave the oversight in the hands of the states is an open question. There is an argument that water resources and geology are very local phenomena and cannot be generalized over the nation and that hydraulic fracturing should remain under local oversight. According to the New York Times the leaked report rejects performing a quantitative risk assessment because such an assessment would ‘involve making a large number of assumptions about the many scenario-specific variables that influence the nature and degree of potential human exposure and toxicity.”

The EPA research projects may help with that though all the answers will not be known in 2014.  The current fracking projects at the EPA are a series of studies. Existing Data from multiple sources have been obtained for review and analysis. Well construction and hydraulic fracturing records provided by well drillers are being reviewed for 333 oil and gas wells across the United States; data within these records are being examined to assess the effectiveness of current well construction practices at containing gases and liquids before, during, and after hydraulic fracturing.

Computer models are being developed (or expanded) to identify conditions that may lead to impacts on drinking water resources from hydraulic fracturing. The EPA has created hypothetical scenarios for water acquisition, well injection, and wastewater treatment and waste disposal stages of the water cycle that they hope to have the models evaluate. Computer models are also being used to explore the possibility of subsurface gas and fluid migration from deep shale formations to overlying aquifers in different scenarios. The effectiveness of the models would be dependent on how closely the model predicts transport behavior in rock and shale and the similarity in behavior of different formations.

Laboratory studies are being performed to identifying potential impacts of inadequately treating hydraulic fracturing wastewater and discharging it to rivers. Experiments are being designed to test how well common wastewater treatment processes remove selected contaminants from hydraulic fracturing wastewater, including brines, heavy metals, radionuclides and organic contaminants. Since wastewater treatment plants are not designed to remove more than biological waste and bacteria, any removal of fracking chemicals and contaminants would be incidental.

The EPA has identified chemicals used in hydraulic fracturing fluids from 2005 to 2011 and chemicals found in flowback and produced water. The EPA is performing toxicity assessments based on chemical, physical, and toxicological properties for chemicals with known chemical structures and using exiting toxicology models to estimate properties in cases where information is not available. The important thing that EPA is doing is bringing together all the data and previous work to get as complete picture of what we know about how hydraulic fracturing may be impacting our water resources and that would allow a broad quantitative health risk assessment to be performed along the identified routes of exposure.  

New York placed a moratorium on drilling in the Marcellus Shale in 2010 while it assessed the effects of fracking. New York DEC’s draft environmental impact statement (EIS) on drilling was released in the fall of 2011 and recommended that drilling be permitted, but with conditions. The comment period was extended and the DEC began a revision to the EIS that has been going on for over a year. The leaked report indicates that the DEC is recommending lifting the ban on hydro fracking in New York, but that is not certain and fracking remains controversial for good reason.

A large swath of southwestern New York sits atop the Marcellus Shale, which is the third-largest natural gas field currently known in the world. The Marcellus Shale alone is estimated to be 500-trillion-cubic-feet of gas reserve. This resource could heat our homes for a generation or more, and power our electrical generating plants, even fuel cars either directly or through plug in hybrids. The possible impacts to our economy and environment are far reaching. The potential risks are also far reaching.

Our ability to recover natural gas buried a mile or more beneath the earth has increased. Advances in horizontal drilling which allows a vertically drilled well to turn and run thousands of feet laterally through the earth combined with advances in hydraulic fracking, the pumping of millions of gallons of chemicals and water into shale at high pressure have increased our ability to recover natural gas from shale. Hydraulic fracking while old has made tremendous advances in the past 15 years have made it possible to economically access this gas. Our knowledge of the impacts from fracking has lagged behind our ability to access the gas.

 

In hydraulic fracking on average 2-5 million gallons of chemicals and water is pumped into the shale formation at 9,000 pounds per square inch and literally cracks the shale or breaks open existing cracks and allows the trapped natural gas to flow. Each stage of the fracking water cycle is a potential area for impact to drinking water supplies especially from human error and irresponsibly and improperly handling chemicals and contaminated water and poorly managing and protecting our water resources. Water used for fracturing fluids is acquired from surface water or groundwater in the local area. Billions of gallons of water will be used in each region for fracking. Wastewaters from the hydraulic fracturing process (flowback or water produced in the well) needs to be properly treated before it is returned to the waters of the earth. The reality is all water on earth has been here for 4.5 billion years and no new water is being created. The fate of the water that flows back after fracturing has to be addressed, but not all fracturing fluids injected into the geologic formation are recovered. The EPA estimates that the fluids recovered range from 15-80% of the volume injected depending on the site. The long term fate of any residual fluid has not been studied.

 There have been documented cases of seepage into drinking water wells through improperly sealed or abandoned drilling wells.  An ongoing monitoring and data collection program needs to be part of the permitting process. Potential impacts to our water supply from hydraulic fracking needs to be studied over time and regulations modified to better protect our water supplies and natural resources as fracking expands in the region. Our water resources are sacred and irreplaceable. The gas will be there when we know how to access it safely.  The least risky course might be to delay lifting the moratorium until the US EPA finishes its research in late 2014 and then slowly allow a limited number of wells that will include monitoring over decades of the groundwater resources in the area with all the data given to the USGS for analysis.  Any area in consideration for fracking should have several years of quarterly groundwater testing and analysis before fracking begins to establish a base line for groundwater study. Now would be a good time to start developing groundwater monitoring programs.    

Fracking and Groundwater We Still Don’t Know

A study based on a computer model was created by Tom Myers, PhD, commissioned by the Catskill Mountainkeeper a Youngsville, NY Environmental group and The Park Foundation in Ithaca, NY and recently released. The model was commissioned after the NY New York Department of Environmental Conservation’s (NY DEC) initial finding in 2009 that hydraulic fracturing could not impact groundwater. The NY DEC went on to commission an environmental impact statement (EIS) on drilling that was released for public comment in September 2011. The EIS recommends that drilling be permitted, but with conditions. The comment period for the EIS closed on January 11, 2012 and the DEC is now developing regulations.

Dr. Myers’ model is being submitted too late to be part of the public comment period, and the model did not use sampling or case histories to build the relationships that project  contamination risks. Rather, Dr. Myers, a PhD in hydrology and a consultant in Reno, NV; built a computer model designed to predict how fracking fluids would move over time. I have not seen the model and do not know how simulations account for the natural fractures and faults in the underground rock formations and fluid flow in the underground, the permeability and stress dependent permeability, and fracture porosity changes. The model simulations have not been tested in field studies.

The Myers model predicts that fracking will dramatically speed up the movement of chemicals injected into the ground. Fluids in his simulation traveled distances within 100 years that would take tens of thousands of years under natural conditions. When the model factored in the Marcellus’ natural faults and fractures and an assumed shale permeability, fluids could move into an aquifer region an order of magnitude faster than that- in as little as three years. Terry Engelder, PhD geology at Pennsylvania State University an expert on the Marcellus Shale and considered by some to be an advocate for hydraulic fracturing has reviewed the model. In a recent interview Dr. Engelder questions the permeability of rock that Dr. Myers assumed in his model. I do not feel I am qualified to judge this work.  

Dr. Myers work is in conflict with other studies done on the topic, but that does not prove him wrong, only actual field studies over a number of years can actually prove him right or wrong. At present there is little or no evidence of groundwater contamination from hydraulic fracturing of shale at normal depths. In Pavillion, Wyoming, were groundwater has been contaminated they used hydro fracking within the water table near drinking water wells. EPA initially announced that the glycols, alcohols, methane and benzene found in a test well the EPA drilled to the drinking water aquifer in Wyoming were likely due to fracking and then back peddled on that stating now the results were inconclusive and is performing additional testing. In an interesting coincidence or not, NRDC, the Wyoming Outdoor Council, Sierra Club and the Oil and Gas Accountability Project commissioned the same Tom Myers to review EPA’s draft report and Dr. Myers found “… the evidence presented in the EPA report …it is clear that hydraulic fracturing … has caused pollution of the Wind River formation and aquifer.” I did not find the evidence quite as compelling and agreed with the EPA that additional testing needs to be done. Dr. Myers continues with: “Three factors combine to make Pavillion-area aquifers especially vulnerable to vertical contaminant transport from the gas production zone or the gas wells – the geology, the well design, and the well construction.” True.

Dr. Myers current study deals with the Marcellus Shale. The model appears to assume that fluid migration will be away from the well. According to a research summary at the University of Texas at Austin, in the long term after fracturing is completed, the fluid flow is toward (not away from) the well as gas enters the well bore during production. Some with concerns about fracking allege while there may be a relatively small risk to water supplies from any individual hydraulic fracturing, a large number of wells within a formation like the Marcellus shale has a higher likelihood of negative impacts. However, the impact on a shale formation of a group of fracturing wells has not been studied. Fracking has outpaced our knowledge of the consequences.

In hydraulicfracking on average 2-5 million gallons of chemicals (< 1%), propping agent(<4.5%)  and water (>94.5%) are pumped into the shale formation at 9,000 pounds per square inch and literally cracks the shale or breaks open existing cracks and allows the trapped naturalgas to flow. After hydraulic fracturing a shale gas well, the fluid pressure is relieved and a portion of the injected fluid returns to the well bore as "flowback" water to the surface for treatment, recycling, and/or disposal. The amount of injected fluid returned as flowback ranges widely from 20% to 80%  due to factors that are not well understood by scientists, regulators or industry. It is not known whether the fracking fluids are absorbed into shale formation or instead migrate.  The route of escape may be through propagation of the induced fractures out of the target zone and into the aquifers, or intersection of induced fractures with natural fracture zones that lead toaquifers. The fracking fluid does not just disappear. No evidence of chemicals from hydraulic fracturing fluid has been found in aquifers as a result of fracturing operations, but impacts of hydraulic fracturing on groundwater have not been carefully monitored over a period of years.

 It is essential to determine the vertical and horizontal separation that is necessary to protect the drinking water aquifers from fracking and what impact new rounds of hydraulic fracturing can have on previous developed areas with old abandoned wells or currently producing wells before watersheds are damaged or destroyed. Building dueling computer models based variously on Hookes’ Law, and Darcy’s law or classical theory is not the way to determine this. The fate of the unrecovered fracking fluid needs to be found. It is believed by many geologists and engineers that the intervening layers of rock would prevent a fissure from extending thousands of feet to the water table this assumption needs to be tested in the real world, and the long term impact of fracking, deep well injection and fluid disposal has on watersheds needs to be studied and monitored and a safe separation distances from aquifers need to be determined. Then increased oversight needs to be implemented to ensure that this separation is maintained (despite inevitable requests for waivers), improve well-design requirements and ensure their consistent implementation and require the appropriate treatment and recycling of drilling waste water. Use of waste water treatment plants that were designed to address biological solids to treat millions of gallons of water used for hydraulic fracturing or ponding the waste is short sighted and imprudent. The deep well injection commonly used in Texas may have consequences beyond small earthquakes. 

Right now there is an excess of natural gas and the price is still well below $3 per million BTU which is the estimated cost of shale gas from fracked wells in the Marcellus Shale. This is a great time to intensely study the environmental impacts from fracking- when we aren’t desperate for the natural gas and EPA has just released a set of air release rules and draft water permitting rules addressing fracking and is about to release a set of regulations for fracking on Federal land. The Department of the Interior estimates that over 3,000 wells are fracked on Federal and Tribal land each year. Sounds like a good number of test sites. Though it would help to baseline the water quality (or at least reduce the costs for analysis) to know the chemicals used in the hydraulic fracking water before not after the frack. However, since long term monitoring is needed it should not make much of a difference in analytical costs. 

Fracking in New York

Last year, New York placed a moratorium on drilling in the Marcellus Shale while it assessed the effects of fracking. New York Department of Environmental Conservation’s draft environmental impact statement (EIS) on drilling was released almost three months ago and recommends that drilling be permitted, but with conditions. The comment period ends on December 12, 2011 and most likely the ban on hydro fracking in New York will end with it despite several groups’ attempts to extend the comment period three more months.

The EIS places restrictions on drillers to address groundwater concerns. EIS mandates that drillers must not drill within a certain distance of watersheds or aquifers and more stringent well construction standards be met. These recommendations are in line with the recommendations issued by the Shale Gas Subcommittee of the Secretary of Energy Advisory Board this past spring. The report had a rational approach to regulation recommending disclosure, testing, evaluation and modification of regulation and practices based on the information and data obtained. The report is to some extent a collection of the best regulatory framework among the states and covers little new ground overlooking some of the significant questions. This was a subcommittee at the Department of Energy that reports to the Secretary of Energy. However, EPA will be the regulatory agency and is currently engaged in a multi-year study of hydraulic fracturing. There is not enough data to fully understand the full impacts of fracking.

There is tremendous pressure to lift the moratorium on fracking. A large swath of New York sits atop the Marcellus Shale, which is the third-largest natural gas field currently known in the world. The Marcellus Shale alone is estimated to be 500-trillion-cubic-feet of gas reserve. This resource could heat our homes for a generation or more, and power our electrical generating plants, even fuel cars either directly or through plug in hybrids. The possible impacts to our economy and environment are far reaching. The potential risks are also far reaching.

Our ability to recover natural gas buried a mile or more beneath the earth has increased. Advances in horizontal drilling which allows a vertically drilled well to turn and run thousands of feet laterally through the earth combined with advances in hydraulic fracking, the pumping of millions of gallons of chemicals and water into shale at high pressure have increased our ability to recover natural gas from shale. Hydraulic fracking is a technology that was unknown 60 years ago and advances in the past 15 years have made it possible to economically access this gas. Our knowledge of the impacts from fracking has lagged behind our ability to access the gas.

In hydraulic fracking on average 2-3 million gallons of chemicals and water is pumped into the shale formation at 9,000 pounds per square inch and literally cracks the shale or breaks open existing cracks and allows the trapped natural gas to flow. While geologists and engineers believe that there is little risk that the fracking “water,” a mix chemicals and water, will somehow infiltrate groundwater reserves though a fissure created by the fracking there are other routes of contamination and impact. It is believed that the intervening layers of rock would prevent a fissure from extending thousands of feet to the water table; there are other risks in how we build wells and fracture the shale that the EIS attempts to address.

There have been documented cases of seepage into drinking water wells through improperly sealed or abandoned drilling wells. An ongoing monitoring and data collection program needs to be part of the permitting process. Potential impacts to our water supply from hydraulic fracking needs to be studied over time and regulations modified to better protect our water supplies and natural resources as fracking expands in the region. Drilling requires large amounts of water to create a circulating mud that cools the bit and carries the rock cuttings out of the borehole. After drilling, the shale formation is then stimulated by hydraulic fracking, using up to 3 million gallons of water.

Data needs to be gathered on the impact to water resources of supplying water for the construction of thousands of wells per year. For gas to flow out of the shale, nearly all of the water injected into the well during fracking must be recovered and disposed of. Though less than 0.5% by volume, the proprietary chemicals can account for 15,000 gallons in the waste from a hydro fracking job. The chemicals serve to increases the viscosity of the water to a gel-like consistency so that it can carry the propping agent (typically sand) into the fractures to hold them open so that the gas can flow. Determining the proper methods for the safe disposal of the large quantities of this fracking fluid that may also contain contaminants from the geological formation including brines, heavy metals, radionuclides and organic contaminants and monitoring the impact from this disposal must also be done. The impact of so much waste water on our water resources must be measured and monitored. Finally, care must be taken to avoid degradation of watersheds and streams from the industry itself as large quantities of heavy equipment and supplies are moved on rural roads and placed on concrete pads. The watersheds must be monitored and permitting should not exceed our ability to monitor the impacts.