Good Evening. My name is Virginia Cody. I represent the Gas Drilling Awareness Coalition. It is our contention that due to its very nature, hydraulic fracturing of the Marcellus Shale CANNOT be accomplished safely at this time. Environmental studies must be undertaken; without them, the rules concerning safe construction of the wells designed to utilize this process are, at best, a stab in the dark. Until the Environmental Protection Agency completes its latest study, we – the DEP and the public – cannot possibly know whether these rules are going to have the desired effect. We recommend the state issue a moratorium on the process until the studies are done.
That said, however, I would like to express my gratitude to the Board for the hard work they’ve put into this revision of the Oil and Gas Act, Chapter 78. I stand before you this evening after having fully read Chapter 78 and its proposed revisions to identify a number of areas which need further explanation or modification.
A copy of this statement has been provided to you.
Section 78.1 Definitions
I recommend this list include a complete explanation of hydraulic fracturing, both horizontal and vertical. This section should include, but not be limited to identification of all chemicals used in the “fracking” process so that in later years there can be no doubt as to what this process may have caused. Identification of these chemicals is critical to conforming to requirements outlined in Chapter 78.51 Protection of water supplies, 78.54 EPA Method 9090, Compatibility Test for Wastes and Membrane Liners, the Solid Waste Management Act, and Chapter 78.56 The Clean Streams Law.
Section 78.13 Permit transfers
I recommend that transfers of permits not be allowed under any circumstances. Surface landowners negotiate in good faith with individual companies, some of which are reputable, some of which are not. However, if this section is retained, I believe it should be primarily up to the discretion of the surface landowner as to which natural gas company is to have access to their land.
Section 78.17 Permit renewal
I recommend that water supply owners within 1 mile of a site be notified of a permit renewal request. I also recommend that these owners have the ability to veto such renewal if they have been impacted negatively by the natural gas companies ‘ operations.
Section 78.19 Permit application fee schedule
This fee schedule is thoroughly inadequate. In general, homeowners requesting permits to improve their properties with new windows, doors, etc. are required to pay permit fees in an amount approximately 5% of the improvement cost. The gas companies’ cost for each well is approximately $5,000,000. Gas companies should not be receiving a break on permit fees. Charge them the full 5% per well. If necessary, hold any excess in escrow in order to assist in any contamination abatement of abandoned wells which has arisen or may arise in the future.
Section 78.21 Opportunity for objections ….surface landowners
I recommend that a surface landowner be able to object to any well location for any reason. The surface land is what the surface landowner lives off of; if he is prevented from living his life the way he chooses, then the gas company is infringing on his rights. The gas company has leased the minerals, not the entire tract of land above those minerals.
Section 78.32 Recommendation by the panel.
The panel should make a recommendation as to the location of the well based on NOT the financial considerations of the parties, but on the most environmentally-sound location of that well.
Section 78.51(c) Protection of water supplies
I recommend the Department investigate a claim within 30 days.
Section 78.51-1(v)
I recommend a sentence be added to the effect that the permanent payment cannot be negated if the operating company sells its interest in the well drilling operation. Any sales agreement must stipulate this, and/or the offending operating company must place in escrow sufficient funds to pay for water in perpetuity.
Section 78.51-4
I recommend this section include a requirement to provide a water purification system to the landowner.
Section 78.52 (a) (d) Predrilling or prealteration survey
I recommend that the landowner be given the right to ask for and receive a second opinion on the results of these surveys.
Section 78.72(a)(1)
Recommend the sentence be revised to read “When drilling any well (including exploratory) that is intended…”
Section 78.72(a)(2)
Recommend the sentence read “Whether or not well head pressures or natural open flows are anticipated….”
Section 78.72(a)(5)(c)
This section states that controls must be located away from the drilling rig. I recommend a safe distance be established and included in this section.
Section 78.83[b](c)
I recommend that “freshwater based drilling fluid” NOT be an option in an alternative method.
Section 78.89 Gas Migration response
This section says that “When an operator or owner is notified of…a natural gas migration…the operator shall…conduct an investigation,” if the Department says it should. It is my contention that any report of natural gas migration should be investigated immediately whether or not the Department makes that recommendation. Furthermore, while the company may initiate said investigation, it is up to the Department to fully examine the situation and order the company to take corrective action.
John Hanger has stated that he is “not pleased with the performance of the industry” and that “this industry must be tightly regulated” and “do better than it’s doing.” I, therefore, recommend that this section include a statement that “failure to comply with these requirements will result in civil and criminal charges.”
Finally, there are four items about this revision which are of concern to us.
1. While Chapter 78 addresses the construction of wells in detail, it doesn’t address elevations of well pads in relation to homes, barns, paddocks, etc. It should – the materials used in this industry are highly toxic and are liable to flow downhill.
2. Chapter 78 does not address the building of roads on well sites. The location of the necessary roads should be coordinated with and approved by the surface landowner.
3. Chapter 78 does deal with certain personnel issues such as training. In light of that fact, Chapter 78 should also contain verbiage regarding use of drugs and alcohol by well workers. Both drugs and alcohol should be explicitly forbidden, with alcohol being forbidden within 24 hours of manning any position on a well site, and well operators’ permits should be placed in jeopardy if there are violations.
4. Finally, we are very concerned as to whether adherence to the tenets of Chapter 78 by the natural gas companies can protect our aquifers. The process by which these companies extract the gas leaves horizontal bore holes in the underlying structure – the shale – that holds our aquifers in place. Will this structure be compromised? If the earth at 8000 to 12000 feet beneath our feet shifts, do we know whether vertical fissures will form? Will those aquifers collapse into the earth? Data from the US Geological Survey office indicates that this area is prone to minor earthquakes. Attached to my statement you will find a reprint of some of that data. Please allow me to read a short exerpt from one of the USGS essays; this is a report of problems associated with an earthquake here in 1954 which resulted a mine subsidence and.
“…caused damage estimated at $1 million in …Wilkes-Barre ….. Hundreds of homes were damaged, ceilings and cellar walls split and backyard fences fell over. Sidewalks were pushed sharply upward … and then collapsed. Gas and water mains snapped; methane gas rising from cracks in the earth presented a temporary emergency. Two days later a second disturbance was reported. More cracks appeared in ceilings and walls of apartment buildings. Curbs pulled away from sidewalks, and street pavements buckled. Additional water and gas mains were broken.”
If this is what can happen at the surface, can the DEP or the natural gas companies be sure that worse will not occur 8000 to 12000 feet below ground? You cannot –because there is no history of horizontal hydraulic fracturing through shale.
Thank you,
Virginia Cody
Pennsylvania
Earthquake History
Record of early earthquakes in the Northeastern United States provide limited information on effects in Pennsylvania until 1737, 55 years after the first permanent settlement was established. A very severe earthquake that centered in the St. Lawrence River region in 1663 may have been felt in Pennsylvania, but historical accounts are not definite. Likewise, a damaging shock at Newbury, Massachusetts, in 1727 probably affected towns in Pennsylvania. A strong earthquake on December 18, 1737, toppled chimneys at New York City and was reported felt at Boston, Massachusetts, Philadelphia, Pennsylvania, and New Castle, Delaware. Other shocks with origins outside the State were felt in 1758, 1783, and 1791. In 1800, two earthquakes (March 17 and November 29) were reported as "severe" at Philadelphia. On November 11 and 14, 1840, earthquakes at Philadelphia were accompanied by a great and unusual swell on the Delaware River.
Dishes were thrown from tables (intensity V) at Allentown by a strong shock on May 31, 1884. Thirty towns from Hartford, Connecticut, to West Chester, Pennsylvania, reported fallen bricks and cracked plaster from an earthquake apparently centered near New York City on August 10, 1884. A tremor, described as lasting 10 seconds, was felt on March 8, 1889, at Harrisburg, Philadelphia, Reading, York, and other towns in that area. The intensity was estimated at V. An extremely local earthquake on May 31, 1908, at Allentown shook down a few chimneys (VI). The disturbance was not felt over more than 150 square kilometers.
On October 29, 1934, a shock of intensity V was felt at Erie. Buildings swayed, people left theaters, and dishes were thrown from cupboards. The earthquake was felt with lesser intensity at Edinboro, Girard, Mill Village, North East, and Waterford. Another shock with very localized effects occurred in southern Blair County on July 15, 1938. Broken dishes and fallen plaster (VI) were reported at Clover Creek and Henrietta. Wells were affected in Clover Creek Valley.
The area around Sinking Spring, west of Reading, experienced minor damage from an earthquake on January 7, 1954. Plaster fell from walls (VI), dishes and bottles tumbled from shelves, and furniture was upset. Other slight damage to several brick and frame buildings was reported. The tremor was felt in western Berks County and eastern Lancaster County. During the rest of the month, many smaller shocks were felt in the vicinity of Sinking Spring.
A local disturbance probably caused by subsidence of an underground coal mine caused damage estimated at $1 million in a five-block residential area of Wilkes-Barre on February 21, 1954. Occupants fled into the street. Hundreds of homes were damaged, ceilings and cellar walls split and backyard fences fell over. Sidewalks were pushed sharply upward by a heaving motion and then collapsed. Gas and water mains snapped; methane gas rising from cracks in the earth presented a temporary emergency. Two days later (February 23), a second disturbance was reported from the same section of Wilkes-Barre. More cracks appeared in ceilings and walls of apartment buildings. Curbs pulled away from sidewalks, and street pavements buckled. Additional water and gas mains were broken.
On September 14, 1961, a moderate earthquake that was centered in the Lehigh Valley shook buildings over a broad area and alarmed many residents. There was only one report of damage - loose bricks fell from a chimney at Allentown (V). However, police and newspaper switchboards throughout the area were swamped with calls from citizens. Other places with intensity V effects included Bethlehem, Catasauqua, Coplay, Egypt, Fountain Hill, Freemansburg, Hellertown, and Weaverville.
A similar disturbance occurred on December 27, 1961, in the northeast portion and suburbs of Philadelphia. Buildings shook, dishes rattled, and other objects were disturbed. Police and newspaper offices received many calls from alarmed citizens inquiring about the loud rumbling sounds (V). Several New Jersey communities across the Delaware River experienced similar effects.
A strong local shock, measured at magnitude 4.5, cracked a wall and caused some plaster to fall (VI) at Cornwall on May 12, 1964. Slight landslides were reported in the area. In one building, a radio was knocked from a table and a wall mirror moved horizontally. Workers in an iron mine about 360 meters underground were alarmed by a "quite severe jarring motion."
A small earthquake whose epicenter was in New Jersey caused intensity V effects at Darby, and Philadelphia. The December 10, 1968, shock was measured at magnitude 2.5. Although relatively minor, it broke windows at a number of places in New Jersey. Toll booths on the Benjamin Franklin and Walt Whitman Bridges in Philadelphia trembled during the earthquake.
On December 7, 1972, slight damage (V) was reported at New Holland. In addition, Akron, Penryn, and Talmage experienced intensity V effects. The total area covered approximately 1,200 square kilometers of Berks and Lancaster Counties.
Abridged from Earthquake Information Bulletin, Volume 8, Number 4, May - June 1973, by Carl A. von Hake.
Earthquake Facts and Statistics
Frequency of Occurrence of Earthquakes
Magnitude Average Annually
8 and higher 1 ¹
7 - 7.9 15 ¹
6 - 6.9 134 ²
5 - 5.9 1319 ²
4 - 4.9 13,000
(estimated)
3 - 3.9 130,000
(estimated)
2 - 2.9 1,300,000
(estimated)
¹ Based on observations since 1900.
These numbers have been recently updated, based on data from the Centennial catalog (from 1900 to 1999) and the PDE (since 2000).
² Based on observations since 1990.
Magnitude vs. Ground Motion and Energy
Magnitude Change Ground Motion Change
(Displacement) Energy Change
1.0 10.0 times about 32 times
0.5 3.2 times about 5.5 times
0.3 2.0 times about 3 times
0.1 1.3 times about 1.4 times
This table shows that a magnitude 7.2 earthquake produces 10 times more ground motion than a magnitude 6.2 earthquake, but it releases about 32 times more energy. The energy release best indicates the destructive power of an earthquake. See: How much bigger is a magnitude 8.7 earthquake than a magnitude 5.8 earthquake?
The USGS estimates that several million earthquakes occur in the world each year. Many go undetected because they hit remote areas or have very small magnitudes. The NEIC now locates about 50 earthquakes each day, or about 20,000 a year.
As more and more seismographs are installed in the world, more earthquakes can be and have been located. However, the number of large earthquakes (magnitude 6.0 and greater) has stayed relatively constant. See: Are Earthquakes Really on the Increase?
________________________________________
Number of Earthquakes Worldwide for 2000 - 2010
Located by the US Geological Survey National Earthquake Information Center
Magnitude 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
8.0 to 9.9 1 1 0 1 2 1 2 4 0 1 1
7.0 to 7.9 14 15 13 14 14 10 9 14 12 16 9
6.0 to 6.9 146 121 127 140 141 140 142 178 168 142 95
5.0 to 5.9 1344 1224 1201 1203 1515 1693 1712 2074 1768 1776 1043
4.0 to 4.9 8008 7991 8541 8462 10888 13917 12838 12078 12291 6908 5019
3.0 to 3.9 4827 6266 7068 7624 7932 9191 9990 9889 11735 2899 1957
2.0 to 2.9 3765 4164 6419 7727 6316 4636 4027 3597 3860 3009 1510
1.0 to 1.9 1026 944 1137 2506 1344 26 18 42 21 26 14
0.1 to 0.9 5 1 10 134 103 0 2 2 0 1 0
No Magnitude 3120 2807 2938 3608 2939 864 828 1807 1922 20 20
Total 22256 23534 27454 31419 31194 30478 29568 29685 31777 * 14798 * 9668
Estimated
Deaths 231 21357 1685 33819 228802 88003 6605 712 88011 1787 225510
Starting in January 2009, the USGS National Earthquake Information Center no longer locates earthquakes smaller than magnitude 4.5 outside the United States, unless we receive specific information that the earthquake was felt or caused damage.
Number of Earthquakes in the United States for 2000 - 2010
Located by the US Geological Survey National Earthquake Information Center
Magnitude 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
8.0 to 9.9 0 0 0 0 0 0 0 0 0 0 0
7.0 to 7.9 0 1 1 2 0 1 0 1 0 0 1
6.0 to 6.9 6 5 4 7 2 4 7 9 9 4 1
5.0 to 5.9 63 41 63 54 25 47 51 72 85 55 31
4.0 to 4.9 281 290 536 541 284 345 346 366 432 293 300
3.0 to 3.9 917 842 1535 1303 1362 1475 1213 1137 1486 1491 1621
2.0 to 2.9 660 646 1228 704 1336 1738 1145 1173 1573 2374 1255
1.0 to 1.9 0 2 2 2 1 2 7 11 13 26 14
0.1 to 0.9 0 0 0 0 0 0 1 0 0 1 0
No Magnitude 415 434 507 333 540 73 13 22 20 16 13
Total 2342 2261 3876 2946 3550 3685 2783 2791 3618 * 4260 * 3236
Estimated
Deaths 0 0 0 2 0 0 0 0 0 0 0
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