New York State Assemblywoman Barbara Lifton (125th Legislative District – Ithaca) recently distributed a letter to all her fellow State Senate and General Assembly members urging them to speak to Governor Andrew Cuomo against natural gas development in the state. She makes six principal assertions, all of which may be fairly described as wild exaggerations, if not outright falsehoods.
We have taken a close look and are left wondering where Lifton got her information. Her statement is, at best, a shallow exercise in demagoguery – unworthy of a state legislator. She gets nearly everything wrong and demonstrates an alarming lack of knowledge regarding an industry that is already positively affecting her district.
Let’s go through Lifton’s assertions one at a time.
Lifton Assertion No. 1:
Highly toxic, flammable and explosive Liquid Petroleum Gas (LPG) has been proposed to fracture more than 3,300 shale gas wells on 135,000 acres in Tioga County. This is reportedly a deliberate effort to skirt New York’s horizontal hydrofracturing moratorium. We request that State Environmental Quality Review (SEQR) be conducted for LPG fracturing.
While it was one company proposed this idea, it never came to fruition. Nevertheless, the suggestion the company trying to “skirt” New York’s moratorium, when they simply proposed another method of natural gas exploration that uses less water couldn’t be more unfair. Wasn’t water what the entire opposition in New York is sworn to defend? Now, suddenly a common sense approach of exploring the potential for LPG as an alternative is rejected out of hand? It just proves no matter what issues natural gas companies address – the opposition will remain opposed. “Whatever it is, (they’re) against it,” just like that famous line …
But, for those of us willing to keep an open mind, here’s what the proponents of fracturing with LPG say:
LPG fracturing is one of those rare technology breakthroughs in the oil and gas industry that can deliver both economic and environmental benefits for producers.
As much as 80% of the water that’s used in conventional methods stays in the reservoir and most of the water that does flow back has to be disposed of safely.
Using LPG allows operators to use hydrocarbons already being produced to extract more hydrocarbons while also eliminating the need for biocides required in conventional fracturing.
When gelled with our proprietary chemicals, LPG provides a consistent viscosity, does not require the costly use of CO2 or N2, nor does it require any special cool down or venting of equipment. LPG—an abundant by-product of the natural gas industry—is stored at ambient temperature.
Using LPG also reduces the need to flare production to clean up the traditional fracturing fluids, reducing CO2 emissions.
Because propane liquid is half the specific gravity of water, there is reduced trucking to the site and no trucking to transport post stimulation – which can reduce truck traffic by up to 90%. (Gasfrac.com)
Visit this link to see a case study on GasFrac. Will it work? Well, you be the judge, but dismissing it at the outset, after raising so much hysteria about the alternative, tells us everything we need to know about the opposition – some, though not all, are simply opposed, and nothing anyone says will change their minds. More than anything, it reveals the hollowness of their claims about hydraulic fracturing.
Lifton Assertion No. 2:
The New York Times recently reported the failure to conduct Environmental Impact reviews of federal mortgage lending programs involving properties with gas leases. New York’s wide variety of government mortgage lending programs must fulfill even more stringent SEQR requirements.
Attorney John Spall dealt with this issue earlier as did John Krohn and Jerry Simmons of the National Association of Royalty Owners. Natural gas exploration and real estate/mortgages are addressed differently by different lenders but we know the lending takes place and there are no significant impediments raised by either Federal or State lenders. NBT in New York is just one example of a lender that works with landowners who have gas leases and here is some background discussion indicating they are well aware of what’s involved and have addressed all the issues. Lending programs will develop even further as natural gas companies explore more of New York State. Here is even more on the exact topic raised by Lifton and it isn’t hard to see she has not researched the matter at all.
Lifton Assertion No. 3:
DEC has inexplicably granted hazardous waste regulatory exemptions for “drilling fluids, produced waters, and other wastes associated with the exploration, development or production of crude oil, natural gas or geothermal energy…” We request that this blanket exemption be immediately rescinded.
There is no reason to change anything. Natural gas companies are working with various vendors to recycle flowback water today. Take a look at Salt Water Solutions, LLC (SWS) and Aqua-Pure Ventures, for example. They treat the water, often on-site, and there is little to no waste when the process is complete.
The common practice for handling flowback and production water from natural gas wells has been to remove certain contaminants and to either dilute the waste water for reuse in other wells or to concentrate the water for reuse of the distilled portion of the fluid and to dispose of the remaining concentrate for a fee at a landfill or by deep well injection. The approach taken by SWS is to process the concentrate to create useable products without a need for disposal. SWS plans to include removal of particulates, heavy metals, and naturally occurring radioactive material (NORM) prior to processing the concentrate. The distilled water can be returned and used for hydrofracturing and the remaining materials will be processed into useable forms such as high purity salt, calcium/magnesium products, and distilled water. SWS has developed marketing relationships to sell the useable products. This approach is similar to an approach utilized by the members of the SWS team at a facility in New York. This strategy will effectively eliminate the need for disposal except for a small quantity of sludge created during the pretreatment process. (Salt Water Solutions, LLC.)
See, also, what Norse Energy has been doing and what they plan if New York State ever gets moving on developing their resources, which we reported on earlier here.
Lifton Assertion No. 4:
Natural gas drilling wastewaters are documented to be contaminated with toxic metals, petroleum hydrocarbons and radionuclides. Yet, DEC allows gas drilling wastewaters to be injected “to facilitate production of oil, gas, salt or geothermal resources” without enforcing New York’s groundwater protection standards. We request that this practice be immediately banned.
The New York State Supplemental Generic Environmental Impact Statement addresses how DEC will regulate natural gas development and flowback water disposal.
1.7.9 Flowback Water Disposal
Under existing regulations, before a permit is issued, the operator must disclose plans for disposal of flowback water and production brine. Further, in the SGEIS the Department proposes to use a new “Drilling and Production Waste Tracking” process, similar to the process applicable to medical waste, to monitor disposal. Under existing regulations, full analysis and approvals under state water laws and regulations are required before a water treatment facility can accept flowback from high-volume hydraulic fracturing operations. Appendix 22 includes a description and flow chart of the required approval process for discharge of flowback water or production brine from high-volume hydraulic fracturing to a Publicly-Owned Treatment Works (POTW). An applicant proposing discharge to a POTW would be required to submit a treatment capacity analysis for the receiving POTW, and, in the event that the POTW is the primary fluid disposal plan, a contingency plan. Additionally, limits would be established for NORM in POTW influent. (SGEIS, DEC, NY)
All the water will be treated and managed under the proposed regulations so as to eliminate the need for any sort of injection well. Lifton is, apparently, confusing recycling of the flowback water with injection or something – it’s pretty hard to tell with a statement such as the one she made. Again, we can refer back to Salt Water Solutions, LLC. and Aqua-Pure Adventures as examples (and there are other companies using different approaches, but none doing what Lifton suggests is happening or will happen in New York).
“We have been developing reliable membrane filtration processes for almost a decade,” said Burnett, Director of Technology for GPRI. This system is in a testing phase, currently cleaning 2 gallons of water per minute, but, once it is perfected, it will expand to larger volumes. The company hopes to produce a full scale model that will clean 100 gallons of water per minute.
Lifton Assertion No. 5:
Millions of gallons of contaminated gas drilling wastewaters are spread across New York for dust control, de-icing and roadbed stabilization. Municipal sewage treatment plants also accept contaminated gas drilling wastewaters without regulatory controls. We request that DEC ban both these practices.
No one is proposing to put untreated flowback water on to roads. It is entirely possible, however, companies will send water off to be treated such that the salt pulled out of the water may be used as a deicer. Of course, at that point the salt is no different than other forms. The companies treating the water will actually break down the composition of the waste water into different elements and then, only after they are completely safe, use them for anything else. This is no different than allowing a town to spread any other salt on its roads. From the SGEIS:
5.13.3 Flowback Water
As discussed in Section 5.12, options exist or are being developed for treatment, recycling and reuse of flowback water. Nevertheless, proper disposal is required for flowback water that is not reused. Factors which could result in a need for disposal instead of reuse include lack of reuse opportunity (i.e., no other wells being fractured within reasonable time frames or a reasonable distance), prohibitively high contaminant concentrations which render the water untreatable to usable quality, or unavailability or infeasibility of treatment options for other reasons.
Flowback water requiring disposal is considered industrial wastewater, like many other wateruse byproducts. The Department has an EPA-approved program for the control of wastewater discharges. Under New York State law, the program is called the State Pollutant Discharge Elimination System (SPDES). The program controls point source discharges to ground waters and surface waters. SPDES permits are issued to wastewater dischargers, including POTWs, and include specific discharge limitations and monitoring requirements. The effluent limitations are the maximum allowable concentrations or ranges for various physical, chemical, and/or biological parameters to ensure that there are no impacts to the receiving water body.
Road spreading for dust control and de-icing (by a Part 364 Transporter with local government approval) is also discussed in the 1992 GEIS as a general disposition method used in New York for well-related fluids, primarily production brine (not an option for flowback water). Use of existing or new private in-state waste water treatment plants and injection for enhanced resource recovery in oil fields have also been suggested. More information about each of these options is presented below and a more detailed discussion of the potential environmental impacts and how they are mitigated is presented in Chapters 6 and 7. (SGEIS, DEC, NY)
This is unregulated? Come on, read the regulations, please, before you make such wild accusations?
Lifton Assertion No. 6:
The U. S. Environmental Protection Agency as well as numerous physicians and public health professionals have repeatedly documented that DEC’s Draft and Revised Draft SGEIS proposals would fail to safeguard the health of residents in New York’s Marcellus Shale region. We request that Governor Cuomo require an independent health impact study of hydraulic fracturing for natural gas to be undertaken.
Why would New York State spend the time and money doing a health impact study, when we can all look at other states and see there are no significant health problems associated with natural gas development? I reported, in a recent post, on a woman from Canada who claimed health impacts but then couldn’t document them and resorted to claiming the government of Alberta, Canada was lying. Yet, we can look at other places where natural gas development has been occurring for decades and document there are no negative health impacts of any consequence. When one person gets sick from contaminated lettuce we hear about it in the news for weeks but there is no corroborated evidence of health issues from natural gas – only wild undocumented claims. Check out this guest post on our blog as well, it really goes in depth on the “health impacts” of natural gas development. The following table reveals pretty much the whole story of what’s happened in Denton County, Texas (Dallas/Fort Worth area) following extensive natural gas development there:
Denton County Texas Key Health Indicators 2000-2008
After several months of operation the Barnett Shale area is showing no levels of concern for any chemicals. This reinforces our conclusion that there are no immediate health concerns from air quality in the area, and that when they are properly managed and maintained, oil and gas operations do not cause harmful excess air emissions.
It’s plain to see none of the assertions made by Lifton are credible. They are presented to scare people and intimidate their elected representatives, when every single point is countered by New York State’s SGEIS and abundant evidence from other sources. The facts are the facts and there is no way around that. Lifton apparently hasn’t bothered reading the SGEIS, however. She must too busy having tea with her anti-development friends in Ithaca. It’s bitter tea to be sure, but I guess that’s how they like it.