From:
MacDonald May [macdonald-may@ns.sympatico.ca]
Sent:
Thursday, June 05, 2014 7:05 PM
To:
HFReview
Cc:
Stephen McNeil; Randy Delorey; Allan MacMaster
Subject:
What are the interactions between unconventional gas resources
and
water resources and blah blah blah
Dear Dr.
Wheeler,
having reviewed the discussion paper “What are etc.” I decided not
to highlight every
statement that I found objectionable, examples of misdirection and bias and
focus on the most
glaring and significant.
“ Due to the compressing pressure of the weight of the soil and rock
(or lithostatic
pressure) that exists at the depth of these geological formations (such as
the Horton formation),
the fractures generated by hydraulic fracturing typically extend
approximately 100 m vertically
and approximately 200 – 300 m laterally (King, La Vergne Bryan, & Clark,
2012).” I do
appreciate the inclusion of source. “Typical” isn’t really relevant here ,
and the claim must be
taken with at least grain of salt . No one has seen the fractures , no one
really knows their
extent . We have 18 reported cases of well communication in British Columbia
, at a distances
of up to 750 meters .Quoting Dr. Anthony Ingraffea, “As soon as pressurized
fracking fluids gets
through the cracks that they have created and reaches a joint system that has
been there for
many years, the joint opens in unpredictable ways”. Not all water wells are
destroyed by
fracing , but many are in every community that hosts a shale gas industry.
“Therefore, the fractures could be hundreds of metres away from the underside
of the
aquifer.” Yes indeed they COULD , and then again they COULD destroy the
aquifer, as
happened in Pavillion Wyoming
“Due to the distance between the targeted formation and the aquifer, it is
anticipated that
fractures would not extend from the shale to the aquifer, and thus direct
contamination from
hydraulic fracturing fluids would appear unlikely.” It is that very lack of
anticipation that
creates the problem . It should be anticipated , because it has happened
elsewhere .
“Insufficient evidence exists that links hydraulic fracturing at depths
greater than 300 m to
aquifer contamination” .Insufficient for who ? There is absolutely no
evidence for the converse.
“In addition, improper well construction which allows hydraulic connection of
the drilling
aquifer and the shallower drinking water aquifer that drilling operations
pass through is
important consideration” . As noted several times in “EWI” we have no
reasonable expectation
of 100% non failure of wells, and an acknowledgement that a “small
percentage” of wells leak .
According to Dr. Ingraffea , 6 % of wells leak from day one, and eventually
they all leak .Dr.
Ingraffea highlights the places where lack of band can be lost leading to
migration . It needs to
be remembered , that shale development creates hundreds of wells, so even a
small
percentage of leaks creates significant negative impacts on an areas water
resource
“ If handled incorrectly, many of the chemicals utilized in the shale gas
industry could
contaminate water supplies. However this statement is consistent with many
industrial
processes that occur in Atlantic Canada. For example, sodium hydroxide (or
caustic soda) is a
chemical used in the shale gas industry (www.fracfocus.org) as an agent to
adjust the pH of a
fluid. Caustic soda is also used to process drinking water in some facilities
in Nova Scotia as it is
highly effective at adjusting pH and poses minimal health risks. In the case
of the drinking
water facilities, regulations and inspections are required by government to
ensure that this
chemical is safely applied and handled. Therefore, under the assumption of a
strong regulatory
framework, it would be anticipated that chemical agents could be safely
managed and applied
for hydraulic fracturing.” This is sort of misdirection in the documents is
what damages the
credibility of your panel . Shale gas industry would be imposed on rural
communities, and
comparing industrial settings to an area of mixed
residential/agricultural/tourism is
inappropriate . The inclusion of pro industry propaganda, as an act of
commission by the
authors, omission by the panel is deeply troubling
“Risk management plans need to consider the safety of the industrial process
itself and the
development of water safety plans for the protection of neighbouring
groundwater and surface
water systems.” Risk Management plans do not protect anything.
“Well infrastructure integrity was considered important across all
jurisdictions, and as such
surface casings and requirements for subsurface casings were compulsory in
all locations”, and
have failed to prevent contaminations of ground and surface waters in any
location .
“In conclusion, this regulatory overview, while not exhaustive, demonstrates
the types of
regulatory tools and instruments that have been adopted in other
jurisdictions to protect water
quality. Clearly, the need for a strong, transparent and balanced governance
system is required
for energy development and for the protection of both water quality and
quantity” .The
numerous references to Alberta Energy Regulator , a defendant in a law suit
stemming from a
fracing incident , and widely criticized for low inspection and even lower
enforcement rates are
concerning . What we can readily learn fro the Alberta experience, is that
concern for
environmental and human health declines where the gas and oil industry
becomes established
. Regulations do not protect the environment , but serve to mislead the
public into thinking the
environment is being protected . Like the Wheeler panel , regulations , are
part of what the
Brundtland Commission Report was referring to ,as the old methods of
environmental
protection and economic development that do not work ( Our Common Future,
1987). Al
Appleton served as Commissioner of the New York City Department of
Environmental
Protection and Director of the New York City Water and Sewer System .Mr.
Appleton’s expert
opinion is that shale gas can not be regulated, owing to the negative
economics and shale gas
industry culture https://www.youtube.com/watch?v=tGTrRQAEPs4 .
“ For municipal water, all municipal drinking supplies must have a source
water
protection area that is approved by NS Environment. In many cases the
protection of
groundwater aquifers is achieved through the establishment of wellhead
protection
areas (WHPAs). WHPAs outline the areas that contribute to the well or well
field and
are used to identify and manage potential sources of contamination.” Except ,
NS
Environment did give permit to drill an exploratory well at MacIsaac’s Point
on Lake
Ainslie, Nova Scotia’s largest fresh water lake which is largely understood
to be
connected to the aquifer for the town of Inverness .
“ Environmental protection is offered under the Environment Act section 67:
“No
person shall knowingly release or permit the release into the environment of
a
substance in an amount concentration or level or at a rate of release that
causes or
may cause an adverse effect, unless authorized by an approval or the
regulations” and
“No person shall release or merit the release into the environment of a
substance in an
amount concentration or level or at a rate of release that causes or may
cause an
adverse effect unless authorized by an approval or the regulations.”
Notwithstanding ,
Fracing wastewater was released through the Windsor facility , and wastewater
from
the Triangle ponds went missing .
“ Overall, very little research has been conducted regarding wastewater
treatment for
discharge into surface water; however” , however, technologies that do not
exist should not be
considered by the review. The reliance on the imaginary , combined with a
reluctance to
examine reality has been a theme in the discussion papers and primer .
“Consistent with this EGSPA principle, Nova Scotia established the Clean
Technology Fund,
which was developed to support “the development, demonstration,
commercialization, and
implementation of innovative clean technologies”. The province has defined
Clean Technology
as “a diverse range of products, services and processes, all intended to
provide superior
performance at lower costs, while greatly reducing or eliminating negative
ecological impact,
at the same time as improving the productive and responsible use of natural
resources”
(Innovacorp 2014).
Thus, the province of Nova Scotia has several regulatory instruments in
relation to water
resources that could support an onshore petroleum resource sector” . The
Clean Technology
fund , is about developing clean technologies , not to support the
development of dirty industry
.The authors bias is again obscuring the task at hand .
“Many of the issues raised by concerned citizens can be managed in the
province.” No evidence
is offered in support of this statement, and indeed none exists
“Other issues still require further research and modelling to determine the
best course of
action.” The best course of action for protecting Nova Scotia’s environmental
, human and
animal health, is not to issue any leases for hydrocarbon development.
“Disposal of wastewater from unconventional gas operations is currently being
investigated at
institutions across North America.” Which ,means that regardless of wide
scale development of
shale resource, there is no known process that would allow produced waters
to be returned to
the environment and no known method for destroying produced waters.
“Additionally, hydrogeologic modelling of the watershed needs to be conducted
to determine
the response to the withdrawals” . The planet is currently experiencing a
climate crisis which is
disrupting traditional weather patterns and the hydrologic cycle . The
increase of deluge rain
events in Nova Scotia , presents an additional risk to the use of holding
ponds for fracing waste
water .
“ If hydraulic fracturing proceeds in the province, thorough baseline
conditions of current water
levels, flow, and quality must be established, before any withdrawals are
approved.
Additionally, hydrogeologic modelling of the watershed needs to be conducted
to determine the
response to the withdrawals. Baseline assessment would include taking samples
at different
times of the year and under variable weather conditions, as the
concentrations of contaminants
(including naturally occurring methane) vary throughout the year. Thorough
monitoring using
the performance, sentry, and receptor approach outlined in the Council of
Canadian Academies
report, should be adhered to and carried out by third parties (2014).
Residents must also play a
monitoring role by having their water regularly tested, beginning before any
production
activity, which should already be a best practice. It would be important for
government to
provide tools to ensure that this process is managed correctly. This will
ensure that residents
are aware of what is already present in their drinking water supply and also
provide evidence
of any contamination from industrial practices. In addition, industries and
government should
work with private well owners to establish water safety plans for wellhead
protection areas and
proactively protect groundwater wells. Water safety plans are broadly
accepted procedures
that have been originally developed by the World Health Organization and have
been applied
as regulatory documents in some jurisdictions (e.g., the province of
Alberta). It is conceivable
that a water safety plan approach could be used as a groundwater protection
step.” Another
huge cost that does nothing to protect water quality.
“Both quality and quantity of water are of great public concern and the
government has an
obligation to ensure water safety is upheld, regardless of the decision made
regarding
hydraulic fracturing.
In the case that development of hydraulic fracturing is pursued, the
following items will need to
be addressed through a robust, responsive and transparent regulatory
environment, and must
be consistent with the Nova Scotia Environment Act:
* Transparency and understanding of operations and processing chemicals used,
and
identification of any potential adverse impacts on water quality (both ground
and surface
water) due to operations;
* Detailed analysis of water demands prior to and during operations on a
case-by-case basis;
and
* Transparency and upfront detailing of procedures and requirements for
wastewater disposal
and/or treatment.” I am unaware of anything in the history of the NS
Department of the
Environment , that could be described as “robust, responsive and
transparent” . Please visit
Boat Harbour for an example of what we can expect from the Nova Scotia
Department of the
Environment .
Shale gas development begins with the deliberate contamination of
clean drinking water .
From the first day an exploratory well is drilled, water will be
intentionally polluted, and the
hope that a series of rules and “due diligence” will prevent the unintended
pollution of
additional waters. The fact is that every region to host shale gas
industries has experienced
unintended surface water pollution from produced waters. Shale wells produce
water every day
of their short lives , and the longer the water takes to return to the
surface, the greater the
concentration of radioactive materials and other naturally occurring heavy
metals . We can
only imagine the increased toxicity of the waters from capped wells, but when
the steel casing
rusts out , and it will, when the cement cracks, and it will, the produced
water will rise to the
surface over the next , 5, 10, 50, years.
Even if every necessary regulation was created , and every regulation
enforced , and every
well never leaked in operation, and there were no accidents,(conditions which
all admit don’t
exist), the “state of the art” is that a shale gas industry will create
large volumes of waste
water which will have to be warehoused at the surface for unknown years
and the inevitable
arrival of unknown quantities of far more toxic waste water. The shear
volume of produced
water would require significant numbers of holding ponds . Developing shale
gas industry in
Nova Scotia would require significant wastewater handling infrastructure, to
contain the toxic
wastewater until a solution is discovered, which may never happen, and well
monitoring for
generations to come .
If Nova Scotia chose to invest in developing regulations specific to a
shale gas industry
,where would we get inspectors that weren’t more heavily dependant on the gas
industry than
the province of Nova Scotia ? As we see in your expert panel, the
perceived need to include
gas industry insiders for their expertise has resulted in pro-industry bias
in your report . The
need for an “independent” review stemmed from the pro-industry bias of the
staff at the Nova
Scotia Department of Energy . It isn’t independence from government that is
needed , but an
independence from industry . This is not an attack on the panel’s ethics ,
but the panels
perspective , a very narrow focus with greater interest in highlighting
benefits than defining
the costs and risks, and producing documents that are at times technically
thick, and at times
oblivious to the obvious . The reports produced have been largely based on
the same use of
unfounded assumptions, wishful thinking and wilful ignorance that has damaged
human, animal
and environmental health in every community that has been occupied by shale
gas
development .
Thank You for your attention
Geoffrey May
Margaree Harbour