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UMD Comments On Gas Drilling
UMD Comments On Gas Drilling
UMD Comments On Gas Drilling
Table of Contents
Introduction: The state of gas drilling in Tennessee................................................................................. 1 Plans to Frack a Well with 2.4 million gallons of water............................................................................2 United Mountain Defense Position Statement...........................................................................................2 Worker and Community Safety..................................................................................................................3 Environmental impacts of gas drilling.......................................................................................................3 Public health impacts of natural gas drilling..............................................................................................6 Hydrofracking............................................................................................................................................6 Proposed rule changes................................................................................................................................7 United Mountain Defense proposes the following changes to the Oil and Gas regulations: ....................7 UMD's comments on the proposed rule changes: .....................................................................................7 In addition to the comments above, United Mountain Defense asks for:.................................................. 9
http://www.kytennoil.com/devonian.htm Horizontal drilling and fracking have been going on in Tennessee since at least 2007. According to an article in the Knoxville News Sentinel, and a presentation given by Jonathan Burr of TDEC, the type of fracking commonly done here is not the same as in Pennsylvania or other areas. In Tennessee, nitrogen gas is commonly used instead of millions of gallons of water. However, nitrogen fracking still requires the use of up to four truckloads of water (32,000 gallons) according to an Oil and Gas Board official. The energy corporations are not required to disclose the chemicals used in this process. United Mountain Defense has documentation of a well in Tennessee that was stimulated with more than 170,000 gallons of water.
quoted from the BLM document here: http://www.blm.gov/pgdata/etc/medialib/blm/es/jackson_field_office/planning/planning_pdf_tn_rfds.P ar.60098.File.dat/TN_RFDS_R3.pdf ) The Forest Service recently followed a vertical well from origin to completion in a small section of National Forest in Pennsylvania. This well was a vertical well. It was fracked, but with much less fluid than a typical Marcellus Shale hydrofracking operation. A well blowout accidentally sprayed fracking fluid onto surrounding land and trees, browning leaves and killing ground cover. After drilling was complete, Berry Energy, which owns the well, sprayed some 80,000 gallons of wastewater into the forest. The briney liquid shocked about 150 trees into shedding their leaves. A year later, half of those trees still had no foliage. This disposal method, called land application, is a legal and accepted practice in some states. The project felled or killed about 1,000 trees. It also damaged roads and eroded the land. The report said the drilling didnt appear to have a substantial effect on groundwater quality. The scientists did not monitor the forests most sensitive ecosystems, including extensive caves, and did not evaluate the operations impact on wildlife. The authors also did not test for any of the chemicals added to drilling and hydraulic fracturing fluids.
The article is here: http://www.propublica.org/article/anatomy-of-a-gas-well-what-happened-when-a-well-was-drilled-ina-national-f and the study is here: http://www.nrs.fs.fed.us/pubs/gtr/gtr_nrs76.pdf Horizontal drilling requires higher well density to fully exploit the production potential of the shale. Take a look at our google map screenshots of well activity at http://www.flickr.com/photos/60320829@N07/ Current regulations allow up to 32 vertical wells drilled per square mile. The spacing requirements for horizontal wells only take property lines into account. Horizontal drilling and fracking require much heavier vehicle traffic to move the needed equipment into place. This means heavy truck traffic on narrow rural roads and the attendant safety hazards and damage to roads.
Air impacts:
Natural gas leaks from capped and abandoned wells are a significant contributor to atmospheric methane, a greenhouse gas 25 times more potent than carbon dioxide. The EPAs new analysis doubles its previous estimates for the amount of methane gas that leaks from loose pipe fittings and is vented from gas wells, drastically changing the picture of the nations emissions that the agency painted as recently as April. Calculations for some gas-field emissions jumped by several hundred percent. Methane levels from the hydraulic fracturing of shale gas were 9,000 times higher than previously reported. from: http://www.propublica.org/article/natural-gas-and-coal-pollution-gap-in-doubt In addition, storage tanks can leak carcinogens and volatile organic compounds (VOCs). Increased vehicular traffic and and the energy requirements of the drilling can also lead to huge levels of pollution. From a study of air pollution in the Barnett Shale drilling play in Texas: For 2009, emissions of smog-forming compounds from compressor engine exhausts and tanks [from shale gas operations in the Barnett Shale] were predicted to be approximately 96 tons per day (tpd) on an annual average, with peak summer emissions of 212 tpd.... For comparison, 2009 emission inventories recently used by state and federal regulators estimated smog forming emissions from all airports in the Dallas-Fort Worth metropolitan area to be 16 tpd. In addition, these same inventories had emission estimates for on-road motor vehicles (cars, trucks, etc.) in the 9-county Dallas-Fort Worth metropolitan area of 273 tpd. The portion of onroad motor vehicle emissions from the 5-counties in the D-FW metropolitan area with significant oil and gas production was 121 tpd, indicating that the oil and gas sector likely has greater emissions than motor vehicles in these counties. The emission rate of air toxic compounds (like benzene and formaldehyde) from Barnett Shale activities was predicted to be approximately 6 tpd on an annual average, and 17 tpd during peak summer days. The largest contributors to air toxic emissions were the condensate tanks, followed by the engine exhausts. In addition, predicted 2009 emissions of greenhouse gases like carbon dioxide and methane were approximately 33,000 tons per day of CO2 equivalent. This is roughly equivalent to the expected greenhouse gas impact from two 750 MW coal-fired power plants. The largest contributors to the Barnett Shale greenhouse gas impact were CO2 emissions from compressor engine exhausts and fugitive CH4 emissions from all source types. From the report: Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost-Effective Improvements by Al Armendariz, available here: http://www.scribd.com/doc/48254813 The economist Robert Howarth from Cornell University recently concluded that The [greenhouse gas] footprint for shale gas is greater than that for conventional gas or oil when viewed on any time frame, but particularly so over 20 years. Compared to coal, the footprint of shale gas is 1.2- to 2.1-fold greater
on the 20-year time frame and is comparable when compared over 100-years. Conventionally drilled gas did not fare much better in his assessment, see here: http://www.eeb.cornell.edu/howarth/GHG %20update%20for%20web%20--%20Jan%202011%20%282%29.pdf Other supporting sources: a climate evaluation completed by the state of New Mexico and a paper published by researchers at the University of California, Irvine
Hydrofracking
The problems outlined above apply to conventional gas drilling as well as hydraulic fracturing. Hydraulic fracturing presents a huge set of problems above and beyond those of conventional drilling. Methane can leak into drinking water supplies. For more info, see an article here: http://www.propublica.org/article/officials-in-three-states-pin-waterwoes-on-gas-drilling-426. Here is a list of some cases of water contamination linked to hydraulic fracturing: http://switchboard.nrdc.org/blogs/amall/incidents_where_hydraulic_frac.html
A major potential problem with fracking gas wells is the integrity of the cement casing that is supposed to protect drinking water supplies. According to a petroleum engineering professor at Texas A&M University, up to a quarter of all cement jobs in the oil industry fail at some point source here: http://online.wsj.com/article/SB10001424052702304879604575582693951448732.html A great deal has been written about the hazards of hydrofracking elsewhere so we are only skimming the surface here. To put it simply, while the industry claims that hydrofracking is completely safe if done properly, United Mountain Defense does not believe that any process which poisons thousands or millions of gallons of water at one time is a wise use of resources. Hydrofracking is not an acceptable or safe method of gas drilling.
1040-02-02-.02 Drilling Permits. should include some of the prerequisites that we are asking for below recommended 1040-02-03-.01 Preparing Plats (j) Changes should read: "The plat shall also show the location of all existing or proposed access roads, the location of all dwellings, diversions, drilling pits, dikes, tanks, and all other surface disturbances, and the location of all drinking wells, streams, lakes, or other bodies of water within one-half () mile of the well site or access roads." The proposed changes want to reduce this distance to 200 feet which is ridiculous. 1040-02-04-.01 Vertical Well Spacing Conasauga shale is mentioned in this section. Is this a new potential source of shale gas? There is a complete exemption for four counties in section L: (l) Any drilling being conducted in Overton, Clay, Pickett or Fentress Counties (this is portions of Fentress County that are west of Hwy 127 and North and West of State Hwy 154) is based on 400 feet to another well and 200 feet to the unit or property line down to a depth of 2500 feet. This is an exception to the current state wide drilling requirements. This is substantially less than the statewide requirements. Why? 1040-02-06-.01 Drilling Equipment The proposed changes here are less stringent: they remove a specific set of procedures and replace it with general language: It is recommended that each operator require the drilling contractor to comply with the general rules and safe practices procedure set out in the (stricken)"Accident Prevention Manual" prepared by the SS7037 Safety Committee of the American Association of Oilwell Drilling Contractors (217 North Ervay Building, Suite 505, Dallas, Texas 75201) (replaced with) safety procedures of the industry. There is no reason to replace specific, measurable requirements with vague ones. This would be a serious step backwards in terms of safety and environmental protection. 1040-02-06-.03 Casingheads This is another weakening of the existing regs. The text: "Reconditioning shall be required on any well showing pressure on the casinghead, or leaking gas or oil between the oil string and the next larger size casing string, when, in the opinion of the Supervisor, such pressures or leakages assume hazardous proportions or indicate the existence of underground waste. Mud-laden fluid may be pumped between any two strings of casing at the top of the hole, but no cement shall be used except by special permission of the Supervisor" is to be replaced with: "Reconditioning shall be required on any well leaking gas or oil."
1040-02-06-.04 Environmental Protection This part actually gets stronger with the addition of section (2) Erosion prevention and sediment controls. Thank you for the additional protections. 1040-02-07-.02 Surface Casing Casing should run the entire length of the well. 1040-02-07-.04 Isolation of Oil, Gas and Fresh-Water-Bearing Strata, and Potential Minable Coal and Other Mineral Deposits. This section only requires 25 feet above and below the specific strata named in the title. This is significant because casing failure is speculated to be a cause of groundwater contamination. Casing should run the entire length of the well. 1040-03-03-.02 Pollution and Safety Controls (2)(g) All pits or other diversion, transport, or storage facilities shall be constructed so that waste fluids (stricken)can drain only into pits, and none can escape into the waters of the State, including ground water (replaced with)do not discharge from them. There shall be no discharge pipe, overflow weir, trickle tube, or any other device allowing any discharge (stricken) unless the operator holds a valid NPDES permit from the Department of Environment and Conservation. No pit shall be located so that any part of it, including a dike or diversion structure, is within a horizontal distance of (stricken) twenty-five (25) (replaced with) one hundred (100) feet of the normal high-water line of any stream or lake. This is an improvement. Thank you.
The new regulations should require: Pre & post chemical testing for drilling, fracking, and production fluids in down stream watershed Pre & post chemical testing for drilling, fracking, and production fracking fluids in nearby drinking wells Mandatory community & land owner notification for cited violations by the industry Mandatory community & land owner notification for supervisor granted waivers to regulated
practices Mandatory reporting of re-stimulation events, fracking events, refracking events and all chemicals used in the events A complete prohibition of wells, pits, or storage of any type in flood plains. Full advance disclosure of chemicals used in drilling and fracturing operations. Mandatory reporting of any fracking events. New requirements for plastic liner thickness of reclamation ponds. Prohibition of diesel fuel as lubricant. Expanded and improved casing and cementing requirements, with verification of casing integrity required before fracking can commence. Full public disclosure of all wells, permits, citations, and pre- and post-drilling test results. This data should be made free and easily accessible online. A complete ban on injection of water into gas wells for the purpose of fracturing underground formations to release natural gas. Revocation of corporate status and drilling license for violations. A complete ban on land application of produced water. Full testing of produced water for heavy metals, benzene and other chemicals that are associated with natural gas, and naturally occurring radioactive materials.
Prior to drilling, each applicant should submit or obtain the following: A Clean Air permit and an NPDES permit. Maps of all nearby water tables and sources and identification of source water for cement dust control, etc. before drilling. A waste management plan. Wildlife resource identification. A reclamation plan. Pre- and post-drilling water sample processes. Public water system identification. Contingency plans for spill prevention and control.
Thank you for your consideration and for your work to prevent the dangerous and irresponsible practice of hydrofracking in the state of Tennessee. Sincerely, William R. Wilson on behalf of United Mountain Defense. May 3, 2011