CBF: Comprehensive Study Of Marcellus Shale Drilling Impacts Needed

The Senior Scientist in Pennsylvania for the Chesapeake Bay Foundation today recommended state environmental and wildlife agencies conduct a comprehensive evaluation and assessment of the cumulative environmental and quality of life impacts from Marcellus Shale natural gas drilling in the state.
In testimony scheduled to be delivered before the House Democratic Policy Committee, Harry Campbell said, "Thirty-six of the 42 counties in Pennsylvania’s portion of the Chesapeake Bay watershed are underlain by the Marcellus Shale formation. The current pace of permitting and drilling in the watershed is high, and the projected pace will only accelerate. In fact, the Pennsylvania Department of Environmental Protection has projected over 5,000 drilling permits to be issued this year alone.
"Yet, a comprehensive evaluation and assessment of the cumulative environmental and quality of life impacts, including on recreation, of this level of drilling has not and is not being performed by any state agency(s) or commission(s).
"We believe that all of the Commonwealth’s resource agencies, including DEP, the Pennsylvania Department of Conservation and Natural Resources, the Pennsylvania Fish and Boat Commission, and the Pennsylvania Game Commission, should be required to work collaboratively to fully assess the cumulative impacts of current and long term Marcellus Shale drilling on Pennsylvania’s natural resources.
"Such an approach is absolutely necessary because to date we have not seen the careful environmental analysis of even site-specific permits required for drilling operations that we believe is necessary to ensure that land, air, and water resources are protected. If a thoughtful analysis has not occurred at even the site level, we can not purport to begin to grasp the cumulative regional impacts."
Campbell pointed to incidents last August and September last year when DEP used an expedited permit process to issue three drilling permits, including one in a State Forest, that were subsequently appealed by CBF and withdrawn by the agency when it found numerous, serious technical deficiencies with the drilling plans.
CBF recommended DEP junk the expedited permit review process in favor of one that meets the requirements of the federal Clean Water Act and gives the public and other agencies an opportunity to provide meaningful agency and public review. Specifically, they asked for--
-- Involvement of the County Conservation Districts early in the permit review process;
-- A requirement that the agency reviewing the permit application conduct a site visit as part of the permit review process;
-- Requirements for permit applicants to submit as part of the permit application complete and accurate erosion and sediment control plans, post-construction stormwater management plans, and detailed surveys of all waters of the Commonwealth in an adjacent to the permit area;
-- A requirement for the reviewing agency to conduct a full technical review of the entire permit application; and
-- A requirement for the reviewing agency to review and assess the probable cumulative impacts of all anticipated drilling within the same subwatershed, and require the permittee to undertake activities necessary to prevent adverse cumulative impacts.
CBF also recommended the state Oil and Gas Act be amended to prohibit any hydraulic fracturing activities within 100 feet of all waters of the Commonwealth, not just those depicted on topographic maps and away from a waterbody's 100-year floodplain.
Recent incidents in Susquehanna and Lycoming counties where flooding occurred on well drilling sites prompted this recommendation.
Campbell said CBF supports efforts by DEP to strengthen the discharge standard for Total Dissolved Solids which can come from drilling wastewater and other sources.
"The handling and safe disposal of wastewater from the hydrofracking process is another serious water quality challenge presented by Marcellus Shale development," Campbell said. "It can contain high levels of barium and strontium, heavy metals that can be toxic to aquatic life. Biocides, surfactants, and various toxic organic compounds, including BTEX (benzene, toluene, ethylene, xylene), that are used as additives in the hydrofracking process are present in the wastewater.
'If not handled carefully and bled through the system at proper amounts, these compounds can impair or kill the microbes in biological treatment systems many municipal wastewater treatment operations are installing to meet Chesapeake Bay requirements. And if not fully or improperly treated, these compounds can profound toxicological impacts on aquatic resources under the current conditions.
"Even with increased recycling and reuse of this wastewater by the industry, the high amount of drilling for Marcellus shale contemplated in the Commonwealth of Pennsylvania over the next several years and decades will mean that large volumes of this highly unusual and highly contaminated wastewater will have to be properly disposed.
"We believe that DEP should immediately begin analyzing the need for a permanent prohibition of surface water discharges of flowback wastewater and the development of adequate and protective nondischarge disposal alternatives, such as onsite deep well injection. Such an injection program would need to be robust and protective of surface and groundwater."
A copy of Campbell's testimony is available online.