EPA testimony on the problems with hydraulic fracking in the Marcellus Shale of PA.

Currently, certain portions of Pennsylvania are undergoing an industrial invasion that is beyond control and supervision from our DEP, and is inadequately regulated by our legislature. If there is any hope of protection for her the citizens of our Commonwealth, we look to the EPA to step up its oversight, regulation and monitoring of this industry. The history of Northeastern Pennsylvania is one of timbering, quarrying and coal mining that have left untold environmental scars, from clear-cut forests to culm banks, underground fires, air and water pollution, and boom and bust economic damage. Unfortunately, our environmental agencies set up to protect the public, are slow to respond, considerate of political and economic pressures rather than community welfare, and are inadequately staffed and informed to perform the duties necessary to protect the health and welfare of Pennsylvanians.

Some of the problems with this industrialization caused by high-volume, slick water, hydraulic fracturing through long laterals are the following:

  1. There are inadequate agency personnel to inspect the current amount of oil and gas wells in Pennsylvania, or to inspect and monitor the preponderance of newly permitted and drilled Marcellus Shale wells, (we have 150,000 active wells and 4,000 Marcellus drilled and another 8,000 Marcellus wells permitted so far this year). With 202 current DEP inspectors and 150,000 wells that is one inspector for every 742 wells and 1 per 19 Marcellus wells, if they were all pulled from every other well in PA. This is unacceptable.

  1. The current accident and violation rate for gas drilling companies in the Marcellus Shale are as follows:

As of September of 2011, on almost 4000 total wells, there have been only 508 total inspections, with 951 violations and only 142 enforcement actions. Accident rates other than administrative or paper violations that involve contamination of water or soil have been estimated at 42% in the 2.5 years on wells drilled up until the end of 2010 and 52% in the first 4 months of 2011 which have had health and safety impacts according to the DEP. We don't live in a risk-free society, but if we took the violation rate estimated by the independent investigative group ProPublica, which suggests Marcellus wells will have a 1.5-4 times the violation of conventional wells, and they estimate one in every 150 Marcellus wells will have a significant environmental impact. Some may say this is a good track record for complex industry. But if our airlines, that fly 35,000 flights per day, had that kind of accident rate we would be losing 210 flights per day. In addition to the every day, on the ground accident rate with drilling and fracking, we have had 3 major well blowouts in the past year and a half in Tioga, Clearfield, and Bradford Counties. This is unacceptable.

  1. Abandon Wells:

DEP has records of 7,500 orphan and abandoned wells. The status of 184,500 wells is unknown. All that we know about shale gas wells is that these wells are designed for a very short life span; approx. 15-20 years of the well use. After a well has been capped (cemented), there is practically nothing published which would respond to the question, what is the fate of these structures. These well bores, set in extremely corrosive saline environments, with the remaining millions of gallons of chemically laced hydraulic fracturing fluids that were left underground now acting as an eroding conduit between the deep fractured Marcellus layers and the public’s freshwater aquafers? In 20 or 30 years, how much will 150-250,000 depleted wells, which will simply have been concealed before being buried in a geographic locale, cost us per year?

There is total silence on this question, and our environmental agencies have not been proactive with the environmental impact studies necessary to estimate the long-term cumulative damage that this industry is subjecting our Commonwealth to. When the gas and oil industry has never been held accountable for what happens to the drill holes afterwards by inadequate plugging fees, the public is left cleaning up the damage. This is unacceptable.

  1. Public health hazards:

  1. Natural gas drilling produces radioactive wastewater at a level 267 times the limit safe for discharge into the environment and thousand times the limit safe for drinking water. (Scientific American-2009). The cumulative health safety impacts studies on the risks to the public from this radioactivity have not been done. Comprehensive hazard assessment studies need to be carried out on all fracture chemicals used prior to allowing this gas extraction method to continue. The Sierra Club Atlantic Chapter has received confirmation from testimony submitted by James W. Ring, Winslow Professor Emeritus of nuclear physics at Hamilton College, on the NYS DEC's revised draft Supplemental Environmental Impact Statement, regarding the dangers of inhaled radon and the likelihood that shale gas extracted from the Marcellus will deliver radon into NY state residences at point of use. According to Dr. Ring, there is an increased risk that residents will inhale radon when they turn on their stoves.

  2. Breast cancer rates which have decreased nationally are climbing in 6 North Texas counties that host the most oil and gas processing facilities related to Barnett Shale drilling.

  3. Public health effects related to air quality around compressor stations has shown increased incidence of asthma, nosebleeds, headaches, dizziness, and other serious carcinogenic, neurotoxic and leukemic effects from the known BTEX emissions. Ongoing Health impact studies on communities and populations near gas well drilling, natural gas processing, and compressor stations are necessary. Drilling sites emit hazardous air pollution from truck trips, pump engines, gases vented from wells, along with the contaminants from processing plants, and fumes evaporating from wastewater ponds.

  4. Top physicians from around the country have been calling for increased studies and regulations, on the health hazards related to gas drilling. The Dean of West Virginia University’s School of Public Health recently stated that the impact of hydraulic fracturing on the public’s health needs to be studied. The Wheeling-Ohio County health officer, also in West Virginia, stated that they are receiving complaints related to contaminated water and air. In New York State, hundreds of health professionals recently sent a letter to the Governor, calling on him to conduct a health impact assessment (HIA) of the public health impacts of gas exploration and production. Bernard Goldstein, professor emeritus at the University of Pittsburgh’s School of Public Health, said he supports the New York group’s demands because, “To me, the idea of rushing ahead basically refutes all we’ve learned in environmental health science over the last 40 years.”

  5. The health problems associated with gas well drilling does not end at the well pad borders. The study, “In the Shadow of the Marcellus Boom,” showed that more than 320 day care facilities, 67 schools and 9 hospitals across Pennsylvania are situated within two miles of an existing Marcellus Shale well site. With the drilling industry set to build thousands more wells in 2012, the problem will only grow. The Department of Environmental Protection recorded 241 environmental violations at Marcellus wells within two miles of different day care facilities and 40 violations within two miles of schools, over a recent 18-month period—not including traffic safety violations by tanker trucks.

In conclusion, I must protest that the 9 minutes allowed to present negative public health impacts related to Marcellus Shale natural gas extraction is severely inadequate and unjustifiable, if the EPA is serious about taking public input and responding accordingly in a proactive manner to protect the citizens, this agency was established to protect.

I would also like to offer into evidence our (GDAC) 10 point program for Marcellus development, public protection, and energy sustainability.

I also hereby request that this office of the EPA, take additional measures to publicly solicit further information from scientists, physicians, geologists, public health officials, psychologists, and further comments from every day community members affected on a daily basis from this activity. I would like to ask at this time, will this office of the EPA allow further written and public comment for NE Pennsylvania residents, at another forum, advertised well in advance for more attendance and for more written comment to continue this dialogue?

REFERENCES for all statements made in this testimony are available from this documents author.

Dr. Thomas Jiunta

Spokesman for the Gas Drilling Awareness Coalition