Dr. Scott Cline – PhD, Petroleum Engineering
John Krohn – Communications Director, Energy In Depth

The Environmental Working Group (EWG) and Physicians, Scientists and Engineers for Healthy Energy (PSE) released a ten point document criticizing the SGEIS.  This is the first in a two part series examining that document which serves as an example of why environmental activists are having difficulty maintaining support in New York.

They say that necessity is the mother of all invention, watching the debate over natural gas development in New York it becomes apparent anti-natural gas ideologues are at the end of the road.  Unable to gain traction on their claims, they are now recycling debunked talking points and bringing in clean-up hitters like Josh Fox in an attempt to scare Governor Cuomo like they have tried with everyone else.  Luckily, the truth always prevails and the Governor is too smart to be bullied, especially by the likes of Fox and friends.

The latest effort, put forward by Environmental Working Group and the shell group Physicians, Scientists and Engineers for Healthy Energy, both funded by the Park Foundation, is exemplified in “Ten Problems with New York’s Shale Gas Drilling Plan.”  All of the claims in this have been addressed before but they are worth revisiting.

EWG/PSE Myth #1:  Failure to use empirical scientific data to assess the risk

New York Department of Environmental Conservation Logo

Reality: The idea that empirical scientific data wasn’t utilized in formulating the draft SGEIS is laughable.  The document is one of the most comprehensive proposed regulatory structures for natural gas extraction in the United States. Spanning four years and the terms of two democratic governors, it contains 1,537 pages of proposed regulations and environmental reviews.  In fact, over 85 of those pages reflect the extensive outreach and scientific data collection conducted in developing the proposal.  Upon review it’s easy to notice a wide range of groups, and studies, consulted  by the Department of Environmental Conservation (DEC) in the formulating the SGEIS. They range from the Associated Petroleum Institute to studies conducted by the US. Department of Energy, Environmental Protection Agency, the U.S. Geological Survey and even the Environmental Defense Fund.  These are just a few examples of the diverse interests DEC examined, there are, of course, many more.

EWG and PSE would never settle on blindly declaring the SGEIS unscientific.  The groups also claim leaking natural gas wells will, without a doubt, pose an imminent danger to the Empire State. They essentially claim that most natural gas wells leak methane that will contaminate water and/or the environment.  There’s only one problem. The long history of oil and gas development in New York – which includes the world’s first commercial gas well – simply doesn’t support EWG and PSE’s assertion.

According to a report issued by Ground Water Protection Council (GWPC) in 2009 (commissioned by the U.S. Dept. of Energy), the probability of casing failure/corrosion leading to a groundwater contamination scenario is exceptionally low. Literally an order of magnitude away from what would be considered a “rounding error.”

From that report:

• “Detailed analysis was performed for those basins in which there was a possibility of casing corrosion. Risk probability analysis provided an upper bound for the probability of the fracturing fluids reaching an underground source of drinking water. Based on the values calculated, a modern horizontal well completion in which 100% of the [underground sources of drinking water] are protected by properly installed surface casings (and for geologic basins with a reasonable likelihood of corrosion), the probability that fluids injected at depth could impact a USDW would be between one well in 200,000 and one well in 200,000,000 if these wells were operated as injection wells. Other studies in the Williston basin found that the upper bound probability of injection water escaping the wellbore and reaching an underground source of drinking water is seven changes in one million well‐years where surface casings cover the drinking water aquifers.” (GWPC, DOE; p. 53)

• Accounting for advances in new technology, GWPC believes the practical risk of casing failure leading to groundwater contamination is even less than one in 200,000. From the paper: “It is expected that the probability for treatable groundwater to be impacted by the pumping of fluids during hydraulic fracture treatments of newly installed, deep shale gas wells when a high level of monitoring is being performed would be even less than the 2 x 10 (to the eighth power) estimated by API.”

• The SGEIS includes the same citation, but updates the number to reflect the capabilities of current casing technology: “Using the API analysis as an upper bound for the risk associated with the injection of hydraulic fracturing fluids, the probability of fracture fluids reaching a USDW due to failures in the casing or casing cement is estimated at less than 2 x 10-8 (fewer than 1 in 50 million wells).” (SGEIS, released Sept. 2011; page 549 of PDF)

EWG/PSE Myth #2:  Setbacks to close to sensitive water supplies

View of the Finger Lakes in New York

Reality:   New York has some of the most stringent water protections, and prohibitions, of any state hosting natural gas development.  First, the state prohibits natural gas development throughout entire watersheds, specifically the New York City and Syracuse watersheds.  This is an unprecedented action by itself.  Secondly, the state would require buffers for development occurring near the state’s primary and principle aquifers.  But even casting all this aside, if a well is properly constructed there is little to no likelihood for anything inside the well to communicate with the environment outside of it.  This is an area where the SGEIS arguably leads the nation.  Here are just a few SGEIS provisions that put in place some of the strictest well design standards in the nation.

• Although current practices and requirements have proven effective at countless wells throughout New York State, the Department has responded to the public’s heightened concerns regarding well control and emergency response issues by including three significant revisions in the revised draft SGEIS:
  • Submission, for review in the permit application, of the operator’s proposed blowout preventer use and test plan for drilling and completion;
  • Description of the required elements of an emergency response plan (ERP); and
  • Submission and on-site availability of an ERP consistent with the SGEIS, including a list of emergency contact numbers for the community surrounding the well pad.” (page 1-11)
  • “Proposed well construction enhancements for high-volume hydraulic fracturing include:

• Requirement for fully cemented production casing or intermediate casing (if used),with the cement bond evaluated by use of a cement bond logging tool; and

• Required certification prior to hydraulic fracturing of the sufficiency of as-built wellbore construction” (page 1-11)

• “Additional well construction enhancements for high-volume hydraulic fracturing that the Department proposes to require pursuant to permit condition and/or regulation:

• Specific American Petroleum Institute (API) standards, specifications and practices would be incorporated into permit conditions related to well construction. Among these would be requirements to adhere to specifications for centralizer type and forcasing and cement quality;

• Fully cemented intermediate casing would be required unless supporting site-specific documentation to waive the requirement is presented. This directly addresses gas migration concerns by providing additional barriers (i.e., steel casing, cement) between aquifers and shallow gas-bearing zones;

• Additional measures to ensure cement strength and sufficiency would be incorporated into permit conditions, also directly addressing gas migration concerns. Compliance would continue to be tracked through site inspections and required well completion reports, and any other documentation the Department deems necessary for the operator to submit or make available for review; and minimum compressive strength requirements.”( page 1-12)

EWG/PSE Myth #3: No plan for disposing of wastewater

Here again EWG and PSE turn a blind eye towards science, facts, and history and the document itself to advance their narrative.  Their document states, “The state plan would certify that drillers certify that they can dispose of their toxic wastewater but it unclear how drilling companies would do this.”  They continue, “…it is, at best, uncertain, that any available system can treat drilling wastewater.”

Well, that’s an interesting assertion, that after 100 years of natural gas development and over 60 years of hydraulic fracturing no one knows how to treat wastewater from these operations.  It would be a mind boggling set of circumstances if only it were true.

Reality:  This provision from the SGEIS shows this claim to be patently false:

“No significant adverse impacts are identified with regard to the disposal of liquid wastes. Drilling and fracturing fluids, mud-drilled cuttings, pit liners, flowback water and produced brine, although classified as non-hazardous industrial waste, must be hauled under a New York State Part 364 waste transporter permit issued by the Department.” (Executive Summary, p. 12)

Wastewater from oil and natural gas operations will be processed in New York in the same ways it has been dealt with in other states.  The primary means of disposal will be through recycling and reuse.  In fact, one of the benefits of the continued delay here will be the adoption of recycling methods once production begins. In Pennsylvania natural gas producers are recycling nearly 100% of the water utilized in their operations.  This water is treated and re-used in multiple wells thereby reducing the need for freshwater and also reducing the need for increased disposal options. This has created a sea change in the industry.  John Hanger, former Secretary of the PA Department of Environmental Protection, succinctly delivered this message on the Diane Rehm Show last year when he stated, ”the amount of drilling wastewater now being discharged to Pennsylvania’s waters is less than before the first Marcellus well was drilled.”

In addition, operators will also use Class II underground injection wells for wastewater disposal.  The regulations for these wells were developed by EPA and are implemented by state agencies whose standards either meet, or exceed, those developed by EPA.  This is a tried and true technology utilized in the disposal of wastewater from multiple industrial process, including natural gas development drilling operations.  In fact, roughly 144,000 Class II injection wells are in operation in the United States today. On average, those wells accept more than 2 billion gallons of wastewater a day associated with oil and natural gas development. In operation in this country since the 1960’s, and in the world since the Roman Empire, you’d be hard pressed to find any environmental degradation from the disposal of wastewater in these wells. (EPA website, “What Is a Class II well”)

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