Last year, contributor Joe Levine wrote a letter to Commissioner Joe Martens of the NYS Department of Environmental Conservation regarding the failure of the draft SGEIS to address the issue of fluid and gas migration related to horizontal hydro-fracking. The letter attached numerous primary source documents, but itself stands as a valuable and concise reference summary of the scientific evidence related to this topic. We are publishing it here as a three-part series, of which this is the first part.

My comments focus on migration of fluids and gases through natural faults and fractures in the NYS geology that will be precipitated by high volume, slick-water hydraulic fracturing. This issue is of critical importance because it will have a profound detrimental and potentially catastrophic impact on ground and surface water. There is no way to control migration of fluids and gases caused by fracking. The most recent draft SGEIS however dismisses the fact that migration of fluids and resultant contamination is a probability, although there is overwhelming scientific evidence to the contrary. Attached is a selection of reports, studies and scientific papers documenting migration of fluids and gases through faults, fractures and fissures in the naturally fractured bedrock geology of New York State.

In response to the previous draft SGEIS there was a significant body of reputable, scientific work submitted by geologists, hydro-geologists, petrochemical engineers, many environmental engineering firms and various governmental agencies that addressed the migration/ contamination link. However there is no indication, based upon the attention given this subject in the draft SGEIS 2011, that this material was reviewed or considered. The following is the greater part of any reference in the draft SGEIS made on the migration issue. On page 11 of the Executive Summary, the following is stated:

“Chapters 5 and 6 contain analysis that demonstrate that no significant adverse impact to water resources is likely to occur due to underground vertical migration of fracturing fluids through the shale formation. The developable shale formations are vertically separated from potential freshwater aquifers by at least 1000 feet of sandstone and shales of moderate to low permeability…That shales must be hydraulically fractured to produce fluids is evidence that these types of rock formations do not readily transmit fluids. The high salinity of native water in the Marcellus is evidence that fluid has been trapped in the pore spaces for hundreds of millions of years, implying that there is no mechanism for discharge of fluids to other formations. Hydraulic fracturing is engineered to target the pro pective hydrocarbon-producing zone. The induced fractures create a pathway to the intended wellbore, but do not create a discharge mechanism or pathway beyond the fractured zone where none existed before. Accordingly, there is no likelihood of significant adverse impacts from migration of fracturing fluids.” 1

It is in response to the above statement that I submit the attached compilation of reports that contradict the above statement in its entirety. But in terms of “no likelihood…from migration of fracturing fluids” (stated above), I submit an excerpt from the following USGS paper; A Regional Perspective of the Devonian Shale and Ordovician Utica Shale Tot l Petroleum Systems of the Appalachian Basin (September 2011) Robert T. Ryder, et al. 1U.S. Geological Survey, Reston, VA 20192, rryder@usgs.gov “….For example, oil and gas generated and expelled from the Marcellus Shale in N.Y., Ohio, Pa., and W.Va. probably migrated vertically through about 1,500 to 4,000 ft of overlying shale and siltstone into Upper Devonian and Mississippian sandstone. In addition, a short time after vertical migration, large volumes of Marcellus Shale g as (from cracked oil or kerogen conversion) were expelled a short distance into underlying Lower Devonian sandstone and migrated either into adjoining anticlines or updip as far as 50 miles. Furthermore, oil and gas generated and expelled from the Utica Shale in Ohio and Pa. suggest the following migration patterns: 1) westward across  dip migration for 30 to 80 miles through a bout 1,000 ft of underlying Ordovician carbonate rocks before entrapment in Cambrian reservoirs, and 2) vertical migration through about 1,500 ft of overlying Ordovician shale followed by updip migration as far as 50 miles before entrapment in Lower Silurian sandstone.”

In addition, the NYCDEP commissioned Hazen and Sawyer Report documents migration of gases that were recorded during the construction of the NYC water tunnels – up to 7 miles through natural faults. The EPA recently documented migration of fluids containing fracking chemicals in water wells and an aquifer in Pavillion, WY. The same problems were documented in Dimmock, PA.

There are numerous detailed scientific studies on rock fracture mechanics, that prove that fluids and gases can and will predictably migrate via faults, joints and fissures, known as migration pathways in an unpredictable variety of ways, and can find their way to ground and surface fresh water resources including aquifers. The hydraulic fracturing process will (as it is designed to) stimulate movement and release of gases and fluids through existing and fracking induced pathways through the naturally fractured geology. These fluids and gases are toxic; both naturally occurring (heavy metals, deep-seated saline waters, radioactive materials and gases) and introduced toxic fracking fluids (aka slick-water).

The draft SGEIS Executive Summary Statement (above) summarily dismisses the large body of accepted scientific work on this subject or has based its conclusions on some other scientific study(s) or body of knowledge. In either case it would be valuable to the public and the scientific community if the draft SGEIS provided information or evidence that specifies what scientific research their position is based upon.

This issue is so evidently a singular crucial aspect of the ultimate safety of hydro-fracking technology that appears to be without remedy. It certainly deserves proper attention and analysis. Attached are reports from (including but not limited to) several experts and environmental engineering firms that substantiate this position. The group includes Robert D. Jacobi (whose work on mapping faults and fractures with the Geology Dept – Rock Fracture Group at The Univ of Buffalo is some of the most extensive on the subject); Hazen & Sawyer for NYC DEP, Arcadis US for the NY Watershed Inspector General, Paul Rubin, Geologist/Hydrogeologist – HydroQuest; Jeffrey Thyne, Geologist and author of the Garfield Co Hydrogeological Study; Marc Durand, geological engineering professor (Université du Québec à Montréal) whose specialty is rock mechanics and hydrogeology, among others. This compilation of reports confirms the extensive pattern of faults and fissures in NYS (Appalachian Basin). Yet the draft SGEIS fails to reference relatively well known fault and fracture information, including the existence of up to date mapping. The draft SGEIS includes an outdated map… that shows only a small fraction of the known actual faults in NYS… This lack of relevant and accurate documentation is incomprehensible and worthy of invalidating the study.

Click here for Part II, which details some of the findings of experts including Robert Jacobi.

1. RYDER, T. ROBERT, et al. A regional Perspective of the Denovian Shale and Ordovician Utica Shale Total Petroleum Systems of the Appalachian Basin. AAPG Search and Discovery Article #90131, 25-27 September 2011.