Rough Draft of Megan’s EPA letter I am a resident of Allegany County in western New York Sate. Hydrofracking of the Marcellus Shale is a risky, dangerous process that creates huge profits for the mining companies and harms everyone else. Here are the eight reasons I believe it should be prohibited: 1. The hydrofracking process, which requires between 3 to 9 million gallons of water for each fracking episode, is a heavy user of fresh water. Streams would be emptied and the water level in lakes and rivers would be lowered. (In Pennsylvania, the Susquehanna River Basin Commission affirms that between 4 to 7 million gallons of water per well are being withdrawn from the Susquehanna River for hydrofracking. (http://wri.eas.cornell.edu/gas_wells_water_use.html) It’s conceivable that withdrawals of water for hydrofracking could compete with other regular withdrawals of water, endangering quantities required for municipal water and for cooling power plants. 2. The hydrofracking process produces toxic waste that requires special handling. The Marcellus Shale is a “highly radioactive shale” (17 OGAP Marcellus Shale Report). Drill tailings contain not only Radium 226, but acid-producing minerals that dissolve the heavy metals naturally present in the shale (arsenic, chromium, molybdenum, nickel, vanadium, and zinc) and release them into groundwater. At present, the drill tailings from well drilling in Pennsylvania are going into landfills in New York State. Testing should be done at the landfills in Angelica, New York (Hyland and the Allegany County landfill) to determine if this practice is safe. 3. The many millions of gallons of water that go down into a well for each fracking episode come back up. This frack fluid, or “produced water,” is five times saltier than sea water (“With Natural Gas Drilling Boom, Pennsylvania Faces an Onslaught of Wastewater,” Pro Publica, Oct. 4 2009) and contains the residues of a chemical cocktail the industry adds to the water/sand mixture. Many of these chemicals are highly toxic even in small amounts. They include benzene, toluene, ethylbenzene, and xylene. Though the industry says that these chemicals make up only a very small percentage of the frack fluid, that small percentage of a large amount of water is significant. For example, in the 50 million gallons of freshwater required for ten well bores, there are 250 thousand gallons of chemicals (“The Drillers are Coming”, Scientific American, July 2010). Frack fluid must be disposed of in a treatment plant that can handle such a salty brine, but such a plant doesn’t exist. So frack fluid goes to municipal water treatment plants that can’t properly process it, or it’s spread on roads and fields, or dumped into rivers and streams. 4. Hydrofracking in the Marcellus Shale in New York State will turn central and western New York into an industrialized zone. Well pads, in-ground fluid retention ponds, above-ground gas and water storage facilities will dot the landscape. Each fracking episode requires 600 to 800 truck trips to the well pad to deliver water and a percentage of that to take the flow-back or contaminated water away. Such high density truck traffic will pollute, destroy infrastructure, and create noise. And the noise of the fracking itself will make rural areas sound like a war zone. 5. Each time a well is fracked, a mini earthquake happens at depths of a mile or more below the surface. No one can predict how this man-made shock will disrupt the natural geology of the substrata or what pathways will be opened up for toxins to escape into aquifers. Problems could be complex, costly, or impossible to remedy. It is wiser not to bring them on and instead, develop much needed revenue and jobs by both investing in safer forms of energy (wind, solar, geo thermal) and creating real and lasting incentives for energy conservation. 6. With the present deficit-reduction pressure on state budgets, it is unlikely that there will be adequate regulatory oversight of an industry that has great potential to harm the health of the people living close to it. There isn’t any monetary gain large enough to sacrifice air and water quality and human, animal, and plant health. 7. In western and central New York State, the largest industries are farming, tourism, and recreation. These industries depend on clean water, clean air, healthy wildlife, and natural beauty. They are incompatible with horizontal drilling of the Marcellus shale. A density of well pads and all of the attendant industrialization they will create will destroy our established industries. 8. State income from the extraction of natural gas from the Marcellus shale could fall short of needed expenditures. The state must develop a larger regulatory presence. At present, there are not enough inspectors to oversee even the fledgling stage of the industry presence in New York. To process the huge volume of hazardous fluids produced in this process, the state must construct many high-capacity specialty waste water processing plants, and finance the repair and replacement of infrastructure that will quickly be degraded by high volume heavy truck traffic. Along with these anticipated and necessary expenditures, there would be the unanticipated ones as well. These would include a satisfactory response to accidents spills, fires, explosions, and leaks both at the mining site and on transportation routes. Furthermore, it is likely that because of devaluation of property near drilling sites, state revenues from taxes would be reduced. Respectfully yours, Megan Staffel