Thursday, December 29, 2011

What's Lacking in Fracking?

I have read the revised Supplemental Generic Impact Statement [SGIS] on high volume hydraulic fracturing [HVHF] for natural gas. It is deficient
I draw attention to Ch 5.4 Fracturing Fluid. It cites 235 products from 15 chemical suppliers of 322 chemicals whose CAS [Chemical Abstract Service #] is known and at least 21 additional ones in which the CAS is not known, listed by the manufactures in what was referred to as MSDS [Medical Safety Data Sheets]. The point to be made is that this list is not complete and the list is misleading. NO ENVIRONMENTAL STATEMENT SHOULD BE ALLOWED WHICH DOES NOT INCLUDE EVERY CHEMICAL USED and no chemical should be an unknown.
In testimony before the US House of Representatives in 2011 investigative report on the chemicals used in hydraulic fracturing, which showed that over a 750 compounds are in hydrofracking products, reference was made to the MSDS as follows: The MSDS is a list of chemical components in the products of chemical manufacturers, and according to OSHA, a manufacturer may withhold information designated as “proprietary” from this sheet. When asked to reveal the proprietary components, most companies participating in the investigation were unable to do so, leading the committee to surmise these “companies are injecting fluids containing unknown chemicals about which they may have limited understanding of the potential risks posed to human health and the environment” . Refer to:
Chemicals Used in Hydraulic Fracturing. U.S. House of Representatives Committee on Energy and Commerce Minority Staff. April 2011. http://democrats.energycommerce.house.gov/sites/default/files/documents/Hydraulic%20Fracturing%20Report%204.18.11.pdf
Another study in 2011, titled “Natural Gas Operations from a Public Health Perspective” and published in Human and Ecological Risk Assessment: An International Journal identified 632 chemicals used in natural gas operations. Only 353 of these are well-described in the scientific literature; and of these, more than 75% could affect skin, eyes, respiratory and gastrointestinal systems; roughly 40-50% could affect the brain and nervous, immune and cardiovascular systems and the kidneys; 37% could affect the endocrine system; and 25% were carcinogens and mutagens. The study indicated possible long-term health effects that might not appear immediately. The study recommended full disclosure of all products used, along with extensive air and water monitoring near natural gas operations; it also recommended that fracking's exemption from regulation under the US Safe Drinking Water Act be rescinded.
You may wonder why hydraulic fracturing for the purpose of oil, natural gas, and geothermal production was exempted under the Safe Drinking Water Act. It was the result of the Energy Policy Act of 2005, also known as the Halliburton Loophole because former Halliburton CDEO Vice President Dick Cheney was involvled in the passing of this exemption.
The revised GEIS statement is further deficient by its own admisision on flowback water:
"Most fracturing fluid components are not included as analytes in standard chemical scans of flowback samples that were provided to the Department, so little information is available to document whether and at what concentrations most fracturing chemicals occur in flowback water." The statement implies that flowback water, which it estimates may be as much as 2.7 million gallons, will be contained in metal, sealed tanks and refers to Chapter 7. Chapter 7 states:
" The volume of flowback water that would require handling and containment on the site is variable and difficult to predict, and data regarding its likely composition are incomplete. Therefore, the Department proposes to require,via permit condition and/or regulation, that flowback water handled at the well pad be directed to and contained in covered watertight steel tanks or covered watertight tanks constructed of another material approved by the Department. Even without this requirement, the pit volume limitation proposed above would necessitate that tank storage be available on site. TheDepartment will also continue to encourage exploration of technologies that promote reuse offlowback water when practical." The statement then goes on to say that, " Fluids would be removed within 45 days of completing drilling and stimulationoperations", but it does not say where to. All this is vague and deficient.
Secondly, there are issues that the revised SGEIS does not address. The State of New York joined as a headwater partner to the Chesapeake Bay program in 2000. About 11% of the state drains into the Bay through the Susquehanna River and its network of tributaries. The part of upstate New York that drain into the Susquehanna River is essentially an overlay of the propopsed hydrofracking area. Yet there is no mention of our partnership obligations to the Chesapeake Bay Program in the SGEIS.
Outside of the criticism of the SGEIS itself is the political implications of the policy statement by Governor Cuomo who supports ending a moratorium on hydrofraking on private land in New York State, but has said the practice should be banned within watersheds serving New York City and Syracuse. Mayor Bloomberg concurs. I sincerely hope the Governor and the Mayor will tell us why their drinking water should be at lest risk than mine. And while we are looking for explanations, perhaps Dick Cheney could tell us where he gets his drinking water in that he has a nice spread on the Easterr Shore of Chesapeake bay.
Finally, I must be noted that in Australia, there is currently a moratorium on hydrofraking in the state of New South Wales, and that their government has banned certain chemicals as additives. In Canada, Nova Scotia is currently reviewing th practice, and that the practice has been suspended in Quebec. In France, hydraulic fracturing was banned in 2011. In South Africa, there is a moratorium in Karoo region despite the efforts of several energy companies.

January 11, 2012 will be the end of public input into the revised Supplimentalhile Generic Eivironmental Impact Statement [SGEIS] on proposed high volume hydraulic fracturing [HVHF] for natural gas in NYS, prepared by the NYS Department of Environmental Convservation [DEC]. This revised SGEIS document is available to all on the internet as a pdf file. Although larbge, 46 Mb in size , it is downloadable and searchable.
In addition, the proposed regulations are in a separage document. http://www.dec.ny.gov/regulations/77353.html. Read them. Then let your representatives know how you feel. I vote for no one who favors hydrofraking.