Concerns of Local Residents
| residents_concerns.doc |
The Penn State Cooperative Extension Office states in their Marcellus Shale Wastewater Issues in Pennsylvania. "In the last half of 2010, the gas industry reported to the Pennsylvania Department of Environmental Protection (DEP) that they had recovered about 235 million gallons of wastewater. The fluid that emerges from the top of a Marcellus well shortly after hydrofracturing (within ~ 30 days) is called "flowback water.” Untreated "flowback water" is toxic to aquatic life, particularly trout and other sensitive species. DEP estimates that it will cost between $0.12 and $0.25 per gallon to treat TDS ("total dissolved solids" is a measure of dissolved matter in water) wastewater originating from the natural gas industry. This is expensive compared to municipal wastewater treatment (pennies per gallon), but treatment costs are miniscule in light of the industry's expected annual revenue in Pennsylvania."
Concerns of Citizens Located Near Proposed “Disposal Injection Wells”
Summary of Disposal Injection Wells in Pennsylvania
“Deep injection wells are a form of waste disposal that pumps untreated wastewater down through very deep wells and out onto rocks bounded above by an impermeable rock layer(s). The U. S. Environmental Protection Agency (EPA) is responsible for permitting these wells in Pennsylvania. Pennsylvania currently has about seven such brine disposal wells. Only one is a commercial well, and it has limited or no available capacity and is not permitted for Marcellus wastewater disposal (note the other wells are owned by a specific company for their own disposal usage). Although Pennsylvania may eventually have additional deep injection wells for Marcellus wastewater, they are not expected to solve the problem, as they do in Texas, which has about 7,000 brine disposal wells. Deep injection wells are difficult and costly to permit and relatively few locations in Pennsylvania have suitable geology. Another limitation is that old shallow oil and gas wells in the area of influence of any deep injection wells would have to be plugged. Pennsylvania has thousands of old shallow oil and gas wells, so this would be a significant challenge.” (Cited from the Penn State Cooperative Extension Office Marcellus Shale Wastewater Issues in Pennsylvania.)
Concerns of Citizens Located Near Proposed “Disposal Injection Wells”
- Placement of "disposal injection wells" in residential neighborhoods. Once one "disposal injection well" is successfully located and permitted by EPA more will probably follow. So it may affect other residential areas once they are able to locate them anywhere. [For example, Windfall Gas & Oil located in Falls Creek (Jefferson County) is preparing to file for an EPA permit in a residential area of Clearfield County where over 20 water wells reside in a 1/4 mile radius (the Area of Review is the 1/4 mile zone size from the disposal injection wellhead for the EPA permit). The proposed placement is on top of a hill above wells and springs serving area residents. Additional water wells are located just outside the "area of review" and used by many residents who reside in the local area along with Brady Township water wells located three miles away providing water for 775 customers and the wells are in the same aquifer as the "City of DuBois." Sandy Township is located next to Brady Township and is approximately 1,000 yards from this proposed disposal injection well. The “City of DuBois” is located about two miles away along with a local elementary school. Jefferson County borders Clearfield County and is about three miles by road from this proposed “disposal injection well.]
- Fluids are stored in these "disposal injection wells" yet it is ambiguous since nothing states what is contained in the fluids. Some classes of "disposal injection wells" may contain frack wastewater from Marcellus drilling, medical waste or nuclear waste. Just having flowback wastewater disposed is toxic to aquatic life, plant life, environment and it is dangerous to human life. The Penn State Cooperative Extension Office stated that Range Resources Corporation released a list of the chemicals added to water for fracking. One of the chemicals is an antimicrobial agent. Antimicrobial is a substance that kills or inhibits growth or microorganisms underground so that the microorganisms don't plug the wells. On October 5, 2009, the "Scientific American" published an article on Dunkard Creek that flows through West Virginia from Pennsylvania and it explains some of the effects of wastewater issues. "With Natural Gas Drilling Boom Pennsylvania Faces Flood of Wastewater: a spate of water contamination problems in Pennsylvania have been linked to natural gas drilling in the state" ("Scientific American") the article states in 2011 a potential to have 19 million gallons of wastewater daily in Pennsylvania.
- Contamination may accidentally happen to water supplies from casings leaking due to breakage, cracks or malfunctions that leach into the ground and affect water supplies. (For example, read about Dimock, Pennsylvania a rural, northeastern area where methane gas affected the aquifer.)
- A primary source of water in our area is water wells and underground disturbance has potential to affect the water source (aquifers) and water supply. Any surface disturbance or underground disturbance is able to affect our wells and surface reservoirs. Leaking, poor casings or faulty cement jobs have the potential to affect our water sources. Cement through a layer of natural gas can make it weak or you can have gaps in the cement that will affect the casings. An earthquake would be able to affect the casings with one happening this year in Pennsylvania. "A potential shadow over generating geothermal energy from hot dry rock is the possibility that the process of making the cracks will trigger earthquakes large enough to matter to people living nearby, or will upset their water wells or otherwise change things in ways they don't like, with earthquakes especially important. We have long known that injecting fluids into Earth, for whatever reason, can trigger earthquakes. One famous series of quakes in the early mid 1960s near Denver, Colorado, with many having magnitudes of between 3 and 4, was triggered when people tried to dispose of waste fluids by injecting them under pressure into deep rocks. (Source: "Earth: the operator's manual" by Richard B. Alley the Evan Pugh Professor of Geosciences at Penn State University on page 275)
- Abandoned gas wells have been found that are not on DEP maps near "disposal injection wells" and these have the potential to artisan the toxic waste onto another property. Some of the old gas wells probably had the casings removed for the war effort when they needed to recycle supplies.
- Marcellus drilling caused methane migration into drinking water posing public health threats and safety threats enough times that DEP created new regulations in February 2011. (Penn State Cooperative Extension Office Marcellus Shale Wastewater Issues in Pennsylvania and the case in Dimock, Pennsylvania.)
- We don't know where everything is like abandoned gas wells and abandoned mines throughout Pennsylvania. These could affect the flow of "fluids" being disposed or an accident might happen. [Just outside the "area of review" in Clearfield County for the new proposed "disposal injection well" at least one abandoned gas well is located and the area has old abandoned mines that probably honeycomb with mines through Clearfield and Jefferson County.]
- Potential to drastically decrease property values of home owners living in the proposed "disposal injection well" area especially if no potable water is available or the threat of contamination exists. If the site is considered a brownfield then property values will decline or it may be impossible to sell homes.
- This industry moving into a residential area may create a brownfield site because residences would be located over a landfill. Appraisers may consider your home in a brownfield when figuring the value of your home. Residual waste is considered landfill so you might be living over a landfill which could make it a brownfield and affect real estate values. Brownfield sites are sometimes referred to as a brown zone or brown land. The definition of brownfield sites are abandoned or underused industrial sites previously used for industrial purposes and land may be contaminated by low concentrations of hazardous waste or pollution.
- One important concern is how a "disposal injection well" that is placed say 200 feet from your property underground that doesn't benefit you and benefits someone else is able to be permitted when it will devalue your property.
- Potential deterioration due to heavy truck traffic on roads and also the need for a traffic study along with the review of bridges being affected by truck traffic. [In the example of Clearfield County, an elementary school is located on the road along with bridge in need of repair plus it intersects with Route 322 at a dangerous section of highway.]
- Permanently injecting and disposing of brine and frack water into the Oriskany layer at 7,300 feet. [Note: In the Oriskany layer is salt water that must be removed as residual waste so some companies when drilling shallow gas wells want to avoid use of this layer due to the residual waste.]
- It has been reported that Exxon bought 400 old gas wells to be used for "disposal injection wells" that may include medical waste. Using old gas wells is a concern due to deterioration of casings over time.
- Cost to test water on a regular basis at the cost to a home owner may become burdensome. Baseline information is often needed to prove water contamination if anything would happen accidentally. Plus the potential concern of residents accidentally drinking contaminated water till a problem is reported. Often it takes longer for those outside the “area of review” to have their drinking water affected yet the potential still exists for their water to be contaminated. [Please note that these tests may become costly so proof would hold up in court since it requires a certified lab test to maintain chain of custody by a third party.]
- Pennsylvania has seven brine “disposal injection wells” currently while geologists have presented information that the fractured ground in Pennsylvania was not suitable for "disposal injection wells." (Cited from the Penn State Cooperative Extension Office Marcellus Shale Wastewater Issues in Pennsylvania)
- Technology is being developed to clean up the "wastewater" so why not just do it right instead of dumping it into a "disposal injection well." Especially, if it has been proven that this is not the best solution for Pennsylvania. [Clearfield County is working on a treatment plant for Marcellus Shale wastewater.]
- DEP and EPA representatives need to do more to monitor the Marcellus drilling industry and the "disposal injection wells" since they are only reviewed every two years.
- The Oil and Gas Act needs updated since it was not created to handle the Marcellus Shale drilling industry. Also, the Oil and Gas Act supersedes the "Clean Air Act." It also may supersede a municipality ordinance. [For example, Fox Township in Pennsylvania created an ordinance that no drilling is to be done within 1,000 feet of a water source. The Oil and Gas Act actually states no drilling is to be done within 200 feet of a water source. So drillers might try to get the Oil and Gas Act to supersede the Fox Township ordinance if they wanted to drill closer than allowed by the municipality ordinance.]
- “Economic Development” overrules water quality. Pennsylvania Code for Water Quality allows water degradation if it is in the best interest for an economic or social reason.
- Many areas have the potential to have “disposal injection wells” without prior knowledge. The “area of review” is a ¼ mile radius. You must know about the request for an EPA permit to request a public hearing since the public hearings must be requested. [Procedures for “Decision Making from the EPA” state a, “Public notice of a public hearing shall be given at least 30 days before the hearing. (Public notice of the hearing may be given at the same time as public notice of the draft permit and the two notices may be combined.”)]
Summary of Disposal Injection Wells in Pennsylvania
“Deep injection wells are a form of waste disposal that pumps untreated wastewater down through very deep wells and out onto rocks bounded above by an impermeable rock layer(s). The U. S. Environmental Protection Agency (EPA) is responsible for permitting these wells in Pennsylvania. Pennsylvania currently has about seven such brine disposal wells. Only one is a commercial well, and it has limited or no available capacity and is not permitted for Marcellus wastewater disposal (note the other wells are owned by a specific company for their own disposal usage). Although Pennsylvania may eventually have additional deep injection wells for Marcellus wastewater, they are not expected to solve the problem, as they do in Texas, which has about 7,000 brine disposal wells. Deep injection wells are difficult and costly to permit and relatively few locations in Pennsylvania have suitable geology. Another limitation is that old shallow oil and gas wells in the area of influence of any deep injection wells would have to be plugged. Pennsylvania has thousands of old shallow oil and gas wells, so this would be a significant challenge.” (Cited from the Penn State Cooperative Extension Office Marcellus Shale Wastewater Issues in Pennsylvania.)