Gas Wells in Floodplains Should Be Banned: CBF and TU

Flooded well pad next to Wyalusing Creek
Stone Energy
January 26, 2010
Photo: Susquehanna River Sentinel

February 18, 2009
Press Release

CBF and TU Call for Ban on Marcellus Gas Wells in Floodplains

Hydrofracking in Floodplains is an Environmental Disaster Waiting to Happen

(HARRISBURG, PA)—In the rush to develop the Marcellus shale formation in Pennsylvania, natural gas wells are being permitted and drilled in floodplains. Two such wells, one operated by Stone Energy along Wyalusing Creek in Rush Township, Susquehanna County, and one operated by XTO along Muncy Creek in Shrewsbury Township, Lycoming County are already experienced flooding events. The Chesapeake Bay Foundation (CBF) and Trout Unlimited (TU) call upon the Pennsylvania Department of Environmental Protection (DEP) to remedy this clear environmental and public health hazard.

"The handling of fracking chemicals and highly contaminated drilling wastewater in floodplains is an environmental disaster waiting to happen. It has to stop," said Matt Ehrhart, Executive Director of CBF's Pennsylvania Office. "Permitting well pads in floodplains causes a very serious threat of pollution. We call upon DEP to use its authority under the Clean Streams Law to order the companies operating these wells to permanently cap and abandon them, and then reclaim the sites to their natural condition."

While current regulations do not allow well pads to be located within 100 feet of streams or within the floodway without an encroachment permit, neither the Pennsylvania Oil and Gas Act nor its regulations prohibit siting wells in floodplains. Because horizontal drilling technology is used to drill into Marcellus shale, the gas underneath streams and floodplains can easily be accessed from a pad location in an upland area, avoiding risk of flooding and catastrophic pollution to Pennsylvania's rivers and streams. There is no reason to site wells in floodplains.

"This loophole must be closed immediately," said Dave Rothrock, President of the Pennsylvania Council of Trout Unlimited.

In late January, heavy rains hit northern Pennsylvania and several streams and rivers experienced flooding events, including Wyalusing and Muncy Creeks. Both the Stone Energy and the XTO sites were flooded as a result of these events.

"The risk of pollution to our streams will increase exponentially in a matter of weeks," said Rothrock. "As we head into the season of snowmelt and spring rains, there should be absolutely no more well drilling activity in floodplains anywhere in Pennsylvania."

The Stone Energy site was permitted along Wyalusing Creek by DEP without the necessary encroachment permits. While DEP issued a notice of violation to the company the week before the flood, the agency should have never issued the well drilling permit in the first place. CBF has previously highlighted serious flaws in the fast track permitting process implemented by DEP since April 2009, where permit applications do not receive careful environmental review but are instead pushed quickly out the door.

In August 2009, CBF appealed three erosion and sediment control permits issued by DEP for drilling sites in Tioga County. CBF's appeals resulted in a DEP review of the plans and revocation of all three permits because of serious deficiencies.

"The Stone Energy site is yet another example of permits being issued without the necessary review," said Ehrhart. "DEP should not have issued a drilling permit that close to the creek, plain and simple. If the agency was spending any time looking at the proposed location, it would have known that."

Governor Rendell recently announced plans to hire 68 new DEP staff to bolster inspection and environmental compliance as Marcellus shale development expands, and DEP announced plans to open a new regional office in Scranton to increase its presence in the northeast, where much drilling is already taking place.

"We are glad Pennsylvania has taken these actions," said Ehrhart. "We hope that DEP will take advantage of these new staff and resources to ensure more careful review of permits."

Credit: Don Williams
Susquehanna River Sentinel

A History of Flooding in the Susquehanna River Basin

Gas Drilling, Wildlife Don't Often Mix

The effects of natural gas drilling can have both indirect effects leading to population declines and direct mortality in wildlife. So claim the Colorado Division of Wildlife officials in an article published in the Valley-Journal last December (2008). Click here to read the original piece. John Broderick, DOW senior terrestrial bioloigist said,

...if and when intensive drilling comes to the Thompson Creek area where several gas leases have been sold, the impacts will be unmistakable.

Waterfowl suffer the greatest direct mortality rate. Ducks land in reserve pits or production pits and are coated with oily substances. Sometimes these birds can be cleaned by hand and saved. However, usually they die of respiratory failure, according to Broderick. Elk calves and deer also get into these pits to drink. But unless the animals keel over and die right in or near a pit, it is difficult to establish the cause of death in animals.

The less obvious effects of gas drilling on animal populations is more significant. The drilling and road construction that goes along with it disturb animal habitat and fragment the areas where animals live and breed. In the long term, this results in significant population declines. Raptors- hawks, owls, and eagles- are particularly vulnerable to this stress. Raptor pairs will often not mate, or they abandon eggs or even their young.

Roads are a big factor, too. They cut through unbroken habitat and expose ground areas which provided cover for the animals. This interferes with the temperature and with shelter from wind and cold. The animals, such as deer and elk, are left with less hiding cover. Roads and gravel well platforms increase runoff. Less water goes into the soil, and toxic chemicals end up in nearby streams. Roads upset the native vegetation, allowing weeds to establish themselves, thus reducing the forage for the animals. People, who would never have had access to pristine forest areas, now have easy ways to drive around. Roadkill is on the rise. With this problem of humans entering the animal habitat, poaching and other illegal activities become more common.

It is hard to come up with scientific evidence that will hold up when confronting regulatory agencies. However, Colorado officials concerned about these issues are looking to Wyoming for data. Scientists in Wyoming have discovered that, while one well per square mile may have minimal effects on mule deer populations, multiply that by 16 wells per square mile, and the detrimental effects can be measured more convincingly.

Fish can also be affected. In the Colorado River, cutthroat trout are common. Trout streams can become inhospitable to fish when sediment gets into the water, sinks to the bottom, and fills in the spaces between gravel stones. These areas provide habitat for aquatic insects which the trout love to eat. Sediment from drilling operations buries and smothers the insect larvae which normally develop and grow among the stones. Spawning is also affected. Trout lay their eggs in hallowed out places in the gravel. When the eggs are fertilized, the female sweeps the eggs into the spaces between the stones where they remain until hatched. After the baby trout are hatched, they stay in the gravel until they are old enough to feed. Ken Neubecker, president of Trout Unlimited, said,

If sediment coats the stream bottom during this time, the brood will be smothered.

Spills are another threat to fish. There are a number of ways in which industrial materials or toxic chemicals can end up where they shouldn't be. Spills from tanker trucks and leakage from holding ponds are common. Depending on where the spills originate, they can contain hydrocarbon chemicals, bentonite, and other harmful substances. Neubecker describes the result:

You get a bunch of that in a stream and it would be like lining a pond with concrete.

Some toxic hydrocarbon substances would be even worse, especially in smaller streams with low water.

It'll sterilize a stream for a long distance. A small stream would take a lifetime to recover.

Some gas leases in the Thompson Creek area in Colorado have stipulations that no roads or well pads can be placed within 350 feet of streams. While that may seem like a good thing, the gas companies can and do ask for waivers. The Bureau of Land Management often allows the gas industry to skip the restriction. Enforcement is also problematic. If a spill is reported, if it is not investigated in a timely way, the volatile chemicals evaporate before any testing is done.

Since human beings are equipped with abilities that presumably far exceed those of other animals, it behooves us to use care when extracting natural gas from the shale beneath us and to proceed in a manner that does not hurt wildlife and the habitat they depend on for their existence.

DEMAND ACCOUNTABILITY!

PROTECT OUR WILDLIFE