FOLLOW THE MAPS: SHORT TERM WATER CONTAMINATION EXPECTED WITH FRACKING DRAFT ONLY Overview: While independent

scientists* say that long term water contamination is assured if fracking is permitted , short term safety of NYS water will be understood as a grave risk----if you follow the maps. Aquifer maps show upstate to be replete with a bountiful and interconnected system of aquifers that move under and into lakes and reservoirs. (Bugliosi et al, USGS/DEC, 1988). The SGEIS admits that fracking within Primary and Principal Aquifers pose the risk of causing significant adverse impacts to water resources. And standard mitigation measures may only partially mitigate impacts. Such partial mitigation would be unacceptable due to the potential consequences posed by such impacts. (SGEIS 6.1.3.4) Major and minor earthquake fault maps (Jacobi, 2002) indicate that many major fault lines occur in proximity to the NYC watershed. It is known from the recent earthquake in Japan that the release of energy from one fault slippage led to four domino effect earthquakes (in addition to nuclear plant meltdowns and a tsunami).good
http://freepages.genealogy.rootsweb.ancestry.com/~springport/pictures350/ NYS%20-%20JacobiTectonics.pdf See p. 78 (minor faults) and p. 86 (major faults)

Karst (networks of caves) maps show a wide band of fragile cavernous limestone running east-west throughout central NYS and north-south along the west side of the Hudson. Karst carries surface chemical spills, and storm or flood waters directly into aquifers. Interactive
USGS map at http://tin.er.usgs.gov/geology/state/state.php?state=NY (Karst = Limestone)

While SGEIS calls for a possible ban on fracking in 100 year flood plains, current floodplain maps only suggest the

locations of actual 100 year floodplains. Floodwaters transport contaminants everywhere, quickly. Any NY population map would indicate a density not compatible with fracking. Even in sparsely populated areas by NYS standards, the population of abandoned and current water and gas wells is huge, and each well is a conduit for contamination of ground and surface water. good
*Paul Rubin, Hydroquest; Mark Durand, U of Montreal; Ingraffea, Howarth, Osborn et al (www.psehealthyenergy.or)g

MISSING : EARTHQUAKE RISK ASSESSMENT Earthquake Risk and Fracking Earthquakes and seismic activity, whether naturally occurring, or induced from hydrofracking or fluid injection episodes, may shear casings and WILL crack cement sheaths used to isolate and protect freshwater aquifers from drilling contamination. Similarly, seismic activity may also degrade other vulnerable items, including dams, pipelines, bridges, reservoirs, and nuclear power plants.
(Hydro-geologist Paul Rubin, Delaware River Basin Commission Expert Fact Sheet http://hydroquest.com/Hydrofracking/)

The unexplored question in the NYS Dept. of Environmental Conservation (DEC) Supplemental Generic Environmental Impact Statement (SGEIS) is how can seismicity or earthquake probability be determined other than by past earthquakes? Robert F. Jacobi, distinguished SUNY geologist and statewide leader in the study of rock fractures and whose list of published research is astounding, studied this question of seismicity in his detailed research out of the University of Buffalo, accepted in 2002, entitled, Basement Faults and

Seismicity in the Appalachian Basin of New York State (Tectonophysics (TTP) V.353). He concludes there is a web of basement faults that crisscross NYS. and it appears that not only are there more faults than previously suspected in NYS, but also, many of these faults are seismically active. (p 75) As for the three counties bordering the NYC Watershed, he concludes that the epicenters of three seismic events in easternmost Otsego County at the border of Schoharie County could be interconnected with the nearby major fault (Sprakers Fault) in Schoharie County which, in turn, could be related to two seismic events in Delaware County (p.105 and figure 1). All this known seismic activity is just to the north, east and southeast of the NYC Watershed. Yet the DEC SGEIS, in 2011, neglects to mention this extensive earthquake fault research by Jacobi , or any other research by this geologist. This even though Dr. Jacobi had led a 2002-2007 study for our state Department of Energy, NYSERDA, on finding natural gas reserves by locating faults (Innovative Methodology for Detection of Fractured Controlled Sweet Spots in the Northern Appalachian). Nor does the SGEIS include any of Jacobis well known 2002 fault maps. Instead the DEC relies on a 1977 Isachsen/McKendree map which Jacobi described as a preliminary brittle structure map. (Basement Faults, p.101) The latter shows a very, very minimal number of faults. Based on the outdated, inaccurate map and a table/map of known quakes, the DEC states: No significant adverse impacts from induced seismicity are expected to result from HVHF [High Volume Hydrofracking] operations.(SGEIS, 6.13) This conclusion is in sharp contrast to that of Jacobi: Thus, it is vitally important to assess the maximum credible seismic event that can be expected along these faults." (Basement Faults pg 106)

Jacobi further explains that most of the basement faults that extend to the surface rocks [in NYS] are seismically capable, even those that do not have historical seismicity ascribed to them. And the high number of faults means that most cultural facilities (e.g., waste disposal sites, bridges, pipelines) are not far from a potentially seismically active fault. One example he cites: in the Mohawk Valley region, the south end of the Hinckley Reservoir dam is adjacent to the Prospect Fault. Thus, it is vitally important to assess the maximum credible seismic event that can be expected along these faults. (Basement Faults p. 105-6) Another example is the impact of a seismic event on the Gilboa Dam, near the Sprakers fault (a major fault) and the NYC watershed system. A rupture of this dam in an earthquake could lead to great mortality and the flooding of several surrounding counties. Considering that the pressure released by a single earthquake can set off other quakes nearby (as exemplified recently in Japan), Indian Point nuclear power plant might also pose a huge risk. Another example is the impact of a seismic event on the Gilboa Dam, near the Sprakers fault (a major fault) and the NYC watershed system. A rupture of this dam in an earthquake could lead to great mortality and the flooding of several surrounding counties. Considering that the pressure released by a single earthquake can set off other quakes nearby (as exemplified recently in Japan), Indian Point nuclear power plant might also pose a huge risk. Duplicate paragraph Further study is needed into the seismic potential of the NYC watershed and its surrounding counties and other NY counties in the Marcellus-Utica shale gas area. Enough historical quakes exist to sound an alarm, though. For instance, according to the USGS earthquake database, there

have been 91 earthquakes up to 5.3 in magnitude between 1973 and 2011 in the Richmondville/Worcester area bordering Schoharie and Otsego Counties, just two towns removed from the NYC watershed reservoirs. But the SGEIS table 4.2 on earthquakes lists none in Otsego County and only 7 in Schoharie County for the period 1970 to 2009, while its earthquake map (fig.4.15) shows only one in the area bordering the two counties. This border area, not far from the NYC watershed, is one of the red-starred, high risk areas noted by Robert Jacobi on his 2002 major and minor fault maps. Two parallel major faults run through this area, one under East Worcester/Richmondville and the nearby aquifer that feeds into the Delaware River Basin, and one under South Worcester with its nearby aquifer that feeds into the Susquehanna River Basin. Another earthquake at this red starred area would bring fracking contaminants into the drinking water of New York City, Binghamton, and cities in Pennsylvania. Heightening the risk even more, another pair of parallel and major fault lines run north-south just east of this border. Since their direction is at an angle to the first pair, slippage of one fault could reasonably cause a domino effect, increasing the magnitude or area of the earthquake. Five fault segments failed simultaneously in Japans recent quake (which caused a tsunami and nuclear meltdown), producing a quake much larger than the model had predicted. The Japanese earthquake models predicted that only one or two faults would rupture at once and their models are based on a 400 year historical record, taking a long view, WHICH IN REALITY WAS A SHORT VIEW. IT SHOULD HAVE BEEN FOR A THOUSAND YEARS, whereas our models (as evident in the DEC and other USGS tables), cover ONLY 30 years or so. ! Seismologist Mark Peterson, who

leads the USGS project mapping seismic risk in the United States says that the his agency is now updating its model of major faults in the Western United States, based on the events in Japan. Discover Magazine , January/February 2012, page 37 We need to develop a long term geological map and in conjunction with that a computer model that has all the minor and major faults included and test it in an area that has faults with slick water to see it the model conforms to the realities observed.

Given the known history of fracking-induced earthquakes (TX, OK, AK, Alberta, UK, British Columbia), the DEC should institute a ban in a broad area around the failing NYC watershed infrastructure and the Susquehanna and Delaware River Basins, but it calls for minimal setbacks, even as it under-reports the seismic activity in the area. Add schlumberger stuff Jacobi also delineated the length of the major western NYS fault, the CLF, from Canada through Lake Ontario and through the western NYS counties of Orleans, Monroe, Genessee, Wyoming and Allegheny. His study concludes that the CLF is presently potentially seismically active. (The Southern Extension and Reactivation of the ClarendonLinden Fault System, Jacobi & Fountain, 1993, p18) In this research Jacobi sites the 1977 CLF study of Fletcher & Sykes which focused on the sharp increase in seismicity at our site near Dale [Wyoming County] following the initiation of fluid injection under high pressure (120 bars tophole) at a hydraulic mining operation nearby. This facility, which mines salt from the Vernon Formation of Silurian age, is centered near the Clarendon-Linden Fault, a major north-south trending system of high-angle thrust faults that extends for

over 100 km from Lake Ontario to Allegheny County, New York. Although the seismic events were small (none were recorded at our station 30 km to the northwest), as many as 80 occurred per day, and many were felt locally. The marked increase in seismic activity after attaining high pressures, the closeness of these events to the bottom of the injection well, and the near cessation of activity within 48 hours of the shutdown of injection strongly suggest that this activity was caused by the triggering of tectonic strain on or near the Clarendon-Linden Fault by the high fluid pressures of the mining operation. The minimum pressure (41-48 bars) at which seismic activity occurred is consistent with predictions made by applying the Hubbert and Rubey theory of effective stress to hydrofracturing stress measurements from Alma, New York. Indeed, this decades old study implies that a specific well injection volume, pressure and depth can be ascertained in order to avoid induced earthquakes BUT DOES NOT INCLUDE A NEW VARIABLE, SLICKWATER. The contrast between the minimum pressure to induce seismic activity of 48 bars (less than 700 pounds per square inch or psi) with the average of 10,000 psi used in High Volume Slickwater HydroFracking currently is huge and the DEC should address this discrepancy. Isnt this absolutely essential information? FOR
SOME REASON I DONT LIKE THIS LAST SENTENCE.

Yet the DEC dismisses this 1977 study by saying that these induced earthquakes in Dale were lower in magnitude than a naturally occurring one in the area. And adds that Similar solution mining well operations in later years located further from the fault systemdid not create an increase in seismic activity. (p. 4-33) This is a missed opportunity by the DEC to explore future quake avoidance by understanding the pressure, volume and depth ratios of drilling, with respect to the type of injection fluid (salt water vs slickwater). This 1977 study is actually making the case for not fracking in proximity to a fault. BOLD

Also missing from the SGEIS is research to measure cumulative impacts of fracking and re-fracking several wells on a single well pad. So, where is the research that is essential to fracture, fault and earthquake knowledge? Where is the independent science? Where is the precaution to heed even the warnings by the gas industry itself? Schlumberger ---------------------------------------One might also ask, wheres the EPA ? Why werent ALL the recommendations in the EPA response to the DEC SGEIS of 2009 incorporated into 2011 revised draft? One concern that should be part of the DEC impact statement is from the EPAs 2004 study: EPA found that the volume of the space within the fracture area may not hold the volume of fluid pumped into the ground during a typical fracturing event. Therefore, EPA assumes that a greater volume of fracturing fluid must leak off to intersecting smaller fracturesor that fluid may move beyond the idealized, hypothetical edge of the fracture zone. that fracture fluids often take a stair-step transport path through the natural fracture system. (Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs, p 12.) MISSING : AQUIFERS EVERYWHERE, AND THEIR DEGRADATION Aquifer Degradation The productive life of gas wells is <20 years compared to aquifer life of about one million years. (Hydro-geologist
Paul Rubin, DRBC Expert Fact Sheet, http://hydroquest.com/Hydrofracking/)

Shale wells will last about 8 years and only about 20% of the gas is recoverable, The rock formations shattered by fracking will be thousands of times more permeable, allowing the remaining 80 per cent of shale gas and underground water, 10 times more salty than sea water, to continue circulating, bubbling to the surface through the disused gas wells. Over time, methane could leak into the groundwater and gas leaks could gush, uncontrolled, into the air. Because this happens deep below, it is not visible on the surface,
(Shale-gas extraction after-affects will threaten drinking water, could jeopardize agriculture, expert say; by Kevin Dougherty, Montreal Gazette March 4, 2011 (quoting hydro-geologist Marc Durand).

Retired DEC environmental engineering technician, Paul Hetzler: I managed scores of groundwater remediation projects in the 1990s. Ive reviewed countless hydrogeologic reports and seen thousands of lab results from contaminated wells. Hydraulic fracturing will contaminate New Yorks aquifers. If you were looking for a way to poison the drinking water supply here in the Northeast, you couldnt find a more chillingly effective and thorough method of doing so than with hydraulic fracturing.
http://www.watertowndailytimes.com/article/20111213/OPINION02/712 139975

The dangers to our waters are, in fact, extreme. The damage may not show up for years, the ruination of our water may at first be invisible and in the end irreparable. NO CLOSE QUOTE (Cyla Allison, PhD, Eight Rivers
Council, West Virginia)

The DEC has not studied in depth the many underground pathways for methane and other contaminants to reach our drinking water wells and aquifers? Migration pathways as a result of frack-induced and natural rock fractures, minor and major earthquake faults, cement casing and sealant failures, ground spills, wastewater in holding pits or future treatment facilities or streams,

hundreds of old and open abandoned wells (many unknown), and seismic episodes. Nor does it admit that all wells will fail with time and many contaminants will eventually migrate or stair-step up, reaching aquifers and surface water. The SGEIS has dismissed the peer-reviewed Duke University study Methane contamination of drinking water accompanying gas-well drilling and hydraulic fracturing which its authors, Osborn et al, claimed was the first peer-reviewed study to suggest that deep, thermogenic methane is migrating into drinking water near shale-gas wells. The DEC concludes the methane contamination was naturally occurring at the wells tested, but didnt address the scientists claim that the isotope or fingerprint of the methane found in the water wells was proof of deep source. GOOD The DEC posted its only aquifer map on the introduction page to Marcellus natural gas, a page which is not part of the 2011 SGEIS. This map shows 12 isolated and small primary aquifers only in the Marcellus area- Seventeen counties in the M shale gas area appear to be water-less as they have no primary aquifers. This DEC website map excludes the Utica shale area, which is broader extending north to Saratoga. Digging back into the 1992 GEIS of the DEC, there is one incomplete aquifer map that includes the 19 statewide primary aquifers and a handful of principal aquifers (or nonprimary, in that they dont serve populations of 10,000but, taken as a whole, serve over 2 million). But in 1992 the DEC had available its own 1988 maps depicting hundreds of principal aquifers. GOOD The DEC has not posted these 1988 DEC/USGS maps. This series of five maps show hundreds of unconsolidated aquifers, aquifers that are supported by sand and gravel, and so permeable and at risk for

contaminants to penetrate them. But these maps also give an incomplete picture of NY ground water as they do not include all the primary aquifers and many admittedly unknown unconsolidated aquifers, and all the many bedrock aquifers (those on firm, less shallow, less permeable bedrock). But, even so, they depict aquifers everywhere, often huge and resembling underground lakes and wide, elongated rivers of groundwater, and these aquifers feed into and under and flow out of our surface lakes and reservoirs, which are drawn in outline on the maps. Water is everywhere, and most of it connected. If these aquifers feed our lakes and reservoirs, they can pollute them. Adiagram in he DEC 1992 GEIS shows the connection between surface water, as rivers and marshes, draining into freshwater aquifers. It should be noted that some of the aquifers of Schoharie County are really one long and connected body of underground lakes that flow for perhaps 60 miles, finally reaching and disappearing under the Schoharie Reservoir in Gilboa, one of the NYC drinking water protected reservoirs. Again, contaminated aquifers can pollute surface reservoirs. (Potental Yields of Wells in Unconsolidated Aquifers in Upstate New York, Bugilosi, Trudell & Casey, 1988, produced by USGS and NYS DEC.) GOOD Our states prodigious amount of water is in deep contrast to the US Southwest and California where fast depleting aquifers, reservoirs, lakes and rivers are creating a water problem that is expected to soon become an emergency. No water should be squandered anywhere. Its our blue gold. GOOD

The DEC uses ambiguous and misleading language about fracking on locations above our aquifers. In the SGEIS Executive Summary it holds that only locations above primary aquifers will be exempted from fracking, with minimum setbacks at their boundaries. And that all other aquifers or principal aquifers (all non-primary aquifers, so designated because they are not sourced for larger populations) and their small setback of 500 from their boundaries, will be subject to specific site determinations. But in SGEIS 6.1.3.4 the language changes to- the Department concludes that HVHF operations within Primary and Principal Aquifers pose the risk of causing significant adverse impacts to water resources. And thatstandard mitigation measures may only partially mitigate such impacts. Such partial mitigation would be unacceptable due to the potential consequence posed by such threats. This is contradictory and confusing wording. THY MAKE THE FIRM CASE FOR NOT IMPACTING ANY ACQUIFER. Will the DEC outright ban drilling into all aquifers now that the EPA has released its three year study of aquifer contamination by fracking chemicals in Pavilion, Wyoming, where drilling through aquifers was permitted? (A glance at the comprehensive aquifer map by USGS and DEC will indicate that NY doesnt have many surface areas to frack without poisoning drinking water.) GOOD Why has the DEC only placed a 500 ft buffer from boundaries of an aquifer when horizontal fracking arms extend for a mile or more underground ? And even these small buffers or setbacks are up for site specific review and possible buffer removal after 2 years. MISSING: RISKS FROM KARST AND EXTREME FLOODING

Risks Associated with Karst (Cavernous Limestone Formations) And Extreme Flooding Events The carbonate [limestone or calcium carbonate] aquifers should be afforded even greater protection than that contemplated for the bordering New York City watersheds, where alternate reservoirs and groundwater resources could be tapped in the event of likely extensive groundwater and surface water contamination from failed gas plays. (Paul Rubin, hydrogeologist, Hydroquest)

Karst in neither mentioned nor mapped by the DEC in its SGEIS. Another risky TOTALLY UNEEXCEPTABLE BORDERING ON CRIMINALITY omission. Karst is the fragile underground limestone or carbonate formation which contains networks of invisible sinkholes, caverns, and caves, all acting as conduits allowing storm and floodwater to rush into aquifers. The Cobleskill Plateau of east central NYS, for example, is known for its Howe Cavern and many other deep caves. Because groundwater moves rapidly through caves, much like that in surface streams, almost no natural cleansing of contaminants occurs. For this reason, conduit portions of karst aquifers are THE most hydrologically vulnerable aquifers anywhere. Contaminated karst streams resurge as springs where their adverse impact to streams, lakes, reservoirs, ecosystems, and wetland species and water quality may be rapid. (Rubin, Hydroquest) Karst is present in many parts of NYS, e.g., massed throughout the entire northern third of Schoharie County and extending in a band both to the western edge of our state, and to the east through Albany County, as well as a north/south band along the Hudson Rivers west bank, through Kingston, etc. (US Karst Map, Veni et al, 2001)

Karst aquifers are large and unconsolidated and the groundwater reacts with the acid in the limestone, breaking it down. The karst aquifers beneath much of Schoharie County are like continuous large lakes that flow east and then south to the NYC watershed in Gilboa. This is something the NYC Department of Environmental Protection (DEP) should consider in its task of protecting the watershed, especially if fracking is permitted in the state. Drilling in fragile karst is risking cave-ins and aquifer contamination, and this contamination can spread quickly in these unconfined aquifers, polluting drinking water anywhere downstream. Yet gas leases have proliferated in karst areas, and no hint of risk has been mentioned by the DEC, even though there has been national press coverage over a ban on fracking based on karst risk in Monroe County, West Virginia. GOOD Record floods upstate in karst areas and the risk to aquifers from earthquakes in karst areas are of grave consequence and warrant mention and study in a DEC statement of environmental impact? SHOULD BE A PERIOD But not a word. EXPLINATION MARK Flood plain maps should be re-drawn to reflect the reality of recent dramatic flooding, and the reality of extreme flooding events occurring more often, as predicted by government and international science/computer modeling re global warming and climate crisis. There is no point to banning fracking on floodplains if you dont realistically identify them. I HAVE RECENTLY SEEN A MAP OF INCREASED PROJECTED RAINFALL IN THIS AREA. I WILL FIND IT AND SEND IT ON. Returning to the example of Schoharie County. The long lake-like aquifers are actually high risk karst aquifers for the first half of their journey to the NYC reservoir, and much of this 75 mile journey is through 100 year floodplains.

Also noteworthy, it travels through the Cobleskill plateau where there is a history of earthquakes and within five miles of the area where 91 quakes were recorded over 35 years and where Jacobi posted the red star on his major fault map. Drinking water of the county and of NYC can be considered at risk, even without fracking. Heightening existing risks by not evaluating them carefully, by basing judgments on short term thinking only, by failing to make information available (independent science on faults, maps of karst and floodplains) and by misleading the public with outdated or incomplete sources (maps of faults and aquifers), is amoral and a threat to all living things in NYS. Researched and written by Louise Maher-Johnson, maherjohnson@gmail.com, 518 234 1942 Clark Rhoades, cjrsailor@gmail.com, 607 432 4860

Comprehensive earthquake fault maps and aquifers maps for NYS are online at www.schoharievalleywatch.org and elsewhere. For referenced documentation and questions, contact the authors.

( Bring back outsourced jobs now. Create jobs through renewable energy now. Spur the return to locally self-sufficient economies now. Prepare for continuing altered climate, now. NYS neednt become the next tar sands. Shale gas is not a bridge fuel to renewables; it is a bullet train to the next tar sands and to climate/ecosystem collapse.)