Gordy Oil Company Permit Application for drilling a gas well –Wade Lively #1 in the Springfield District near Boyd Road in Monroe County.
- KARST + ANIMAL LIFE : I request the application be denied because this well site is surrounded by karst, drains into karst, and may in fact be sitting directly above karst. There are rumors of a sinkhole that has been covered in less than 100 feet from the site. There are nearby streams, waterways, and ponds. The site sits in front of a mountain ridge and the land slopes down from the field the site lives in. Water flows down – and the land down the hill from the site is perforated with sinkholes. Functionally, draining into karst is no different than drilling directly into karst from a vulnerability perspective. Two significant caves are around a mile away, while the legendary Salt Peter Cave, home to the Indiana bat (observed population 2006: 2; 2008: 12; 2010: 7) is just about 2 miles away. THIS IS DANGEROUS. Problems with fracking aside, surface spills in this area could poison the aquifer. The water from that site would drain into a network of creeks that would ultimately drain into Indian Creek – home to wild trout. The DNR keeps a count of the Indiana bat, as it is on the federal endangered species list. Water contamination = dead bats and dead trout. EPA considers karst to be an “environmentally sensitive location,” classified similar to wetlands. BAD DRILL SITE.
- GORDY CONSULT WITH USFWS ABOUT BATS : The FWS has requested that Gordy answer 9 questions about the bats. USFWS has stated that the responsibility of these bats is that of the DEP and that Gordy is supposed to comply with this request for information about the bats, the caves, the water, etc. I feel that whether the consult is REQUIRED BY LAW is not relevant – this is the right thing for Gordy to do – and the application seems incomplete without it.
- SEDIMENT & EROSION PLAN : The WV Code #22-6-6(d) states that a sediment and erosion plan shall accompany any application. This is an important requirement, especially so in karst. Application seems to be incomplete.
- DEEP WELL PERMIT : I do not find the necessary permit from the Oil and Gas Conservation Commission for drilling a deep well.
- INSUFFICIENT INSPECTORS : Randy Huffman has publicly stated that there are insufficient inspectors for the wells in WV. Based on 55K active wells and 17 inspectors, there are 0.00030909 inspectors per well. This is a crying, terrible outrage. If we know we cannot monitor/regulate our current activities, how can we embark on new business? Time to take a step back, write some new regulations and hire a couple hundred inspectors.
- INACTIVE WELLS UNCAPPED : Recent number I saw suggested that of the 12K inactive wells, some 6K are uncapped and desperately need attention. We have seen many stories of contamination from uncapped wells. Another reason to focus on cleaning up the past before moving on to the future.
- ADDITIVES DOCUMENTED : I object to the fact that the additives used in the process are not listed. Quoting from the Gazette-Mail dated November 10, 2010, “DEP wants chemical lists for Marcellus drilling permits.” The “mud company” is not applying for a permit – Gordy is, and they must be accountable for the mud company’s formula.
- INSUFFICIENT PERMITTING FEE : I object to this application because current discussions in Charleston include the possibly of a new fee schedule, which could change the fee from less than a grand to $10K or more. With a higher fee, the DEP could have more inspectors.
- DYE TESTING : Additional dye testing has been suggested by many – orgs, residents, even USFWS. This is a safety measure that needs to be addressed. Water has been documented in Monroe County to travel up to 13 miles (additional testing may show even farther) – we need to further document the path of water from the well site to better understand what sources are at the most risk.
- WASTEWATER : The application mentions that waste water will be put into injection wells. Where are they located? Will trucks be shipping the water to another site?
- 1000 FOOT IMPACT ZONE : The single biggest joke of the whole thing. Saying that only 1000 feet from the well site is considered the impact zone of a well is like saying that only the 1000 feet from the oil spill in the gulf must be tested and monitored and cleaned up. Water travels miles in karst terrain, and dye testing has proven this scientifically – showing water travelling up to 13 miles. I’d be excited to see that number moved to 5000 feet, but as that is wholly inadequate as well, I request the impact zone, the area in which Gordy must test and monitor water should be a 5 MILE RADIUS from the well site. They must be required to insert their own custom, traceable dye in their utilized frack fluids, and they must monitor for them showing up at relevant hot points within the radius.
- TRAFFIC IMPACT STUDY : I request there be a traffic impact study carried out when there are so many large and heavy trucks traveling on secondary roads. I have personally traveled these roads with friends who are truck drivers. There are many turns that will be extremely tight and will not allow traffic to pass while navigating the turn. That is a disruption!
- WETZEL COUNTY : I tend to believe that history makes a great teacher. Based on what we have seen in pictures, videos, and first hand – WHAT HAPPENED IN WETZEL CANNOT HAPPEN HERE. I mean the hillbillies (will come out of the mountains, and they will not be happy – it will not be pretty ladies and gentlemen. And this is NOT meant to be threatening in any way – but I feel it is necessary to clarify the situation – MANY of the county’s residents are NOT land rich, have not leased, and frankly, do not care about the royalties they might be able to make – and in most cases these are people who have a deep, long-standing, impenetrable cultural attachment to their land. If things proceed unchecked, and the county produces gas but things do go foul at some point (as they have many, many times many, many other places) – you’ve got a piece of the county who are making money, and you’ve got a piece whose land/water you have just destroyed – and they will be enraged, as you might imagine. If this is done WHERE it can be done safely (which means not in karst), in a WAY that can be done safely on a TIMELINE that is safe with SUFFICIENT RESOURCES and REGULATIONS in place – we can avoid a total fallout in this county.
- NOISE POLLUTION : Are there any regulations governing this? I request that drilling should be limited to daylight hours and weekdays. The inherent loss to our way of life should it proceed 24/7 will be immense.
- AIR POLLUTION : Didn’t see anything in the application concerning air pollution. There have been many news items linking air pollution to drilling activities. I request this be addressed.
- INADEQUATE BOND : I object! The $5K bond is ridiculously inadequate. It seems the damages that could be caused by one slip-up could be worth hundreds of thousands of dollars, easily way more. Therefore I request that before any company embark on this endeavor, they thoroughly demonstrate that they have the resources to fix anything they break. A minimum of $1M bond seems appropriate to that end.
- CONTAINMENT PONDS : It seems like one of the most likely ways contamination will occur is due to a containment pond that leaks or floods or meets animal life. Again these surface spills could be catastrophic. Bats and other animals will drink from the pond. I request that containment ponds not be utilized, and all wastewater be carried from the site as it is extracted.
- WATER WITHDRAWAL : Our precious tiny little watershed cannot support hydraulic fracture. The rivers and streams have BEEN LOW REGARDLESS – I can only imagine with millions of gallons being pulled from the Greenbrier. I request strongly that stringent guidelines define the water withdrawal practices to insure the system is not maxed out and run dry.
- SUBCONTRACTORS : How are subs handled? All sub or independent contractors must meet the same regs as Gordy, and a system of accountability for those subs must be in place. I request that Gordy be held responsible for the actions of its team, both internal staff and subcontractors. Subs should also be responsible for a significant bond so we can insure they are not total fly-by-night operations.
- ADDRESSING NEARBY LANDOWNERS : The application fails to list at least two very nearby landowners, the Adkins and the Ramsey families. They are very concerned and have been forgotten. Dale and Terry Ramsey live downhill/stream from the well site. I request that these nearby landowners be addressed professionally, not left out to get their news from the papers.
- ENVIRONMENTAL ASSESSMENT : For the reasons listed above a THOROUGH assessment and investigation of the area and how it might respond to natural gas extraction activities is REQUIRED. I request, and I truly hope that you guys at the DEP will leverage your experience and wisdom to not let this proceed unchecked.
- LOSS OF LAND VALUE : So wait – this process starts, all of our land values plummet? How will this be addressed in the “reclamation” plan? I request that every landowner who loses assets (the value of their home, their land) due to the marcellus shale drilling activities should be compensated the equivalent of the lost assets, as determined by a third-party, agreed upon assessor. Our tiny little economy WILL NOT BENEFIT in the long term from the Marcellus play if when the drillers leave in a decade – everything is worth jack. Our community’s long-term financial stability DEPENDS on the value of our homes and our land.
- DEP CONDITIONS FOR DENIAL OF PERMITS : a) the proposed well work will constitute a hazard to the safety of persons, because b) the proposed well work fails to protect fresh water sources or supplies (how could this be guaranteed?); or c) habitats of rare and endangered flora and fauna or even d) bodies of water…including but not limited to wild trout streams.
- FRED ZIEGLER, Geologist
- The karst forming unit in Monroe is the Lower Carboniferous Greenbrier Limestone which covers about 70 square miles centered around Union, Pickaway and Sinks Grove, with smaller patches around Greenville and Wolf Creek.
- A count of 168 large sinkholes was determined from the central zone giving a density of four per square mile.
- No surface streams occur over much of the karst except near the margins where the flow can be shown to be underground during dryer seasons, confirming that underground flow occurs most of the time. This is true of Indian Creek and its tributaries, Laurel Creek and Hans Creek around Greenville.
- The Greenbrier Limestone has low porosity so polluted water entering the cave system would not benefit from the natural filtration effects of the groundwater table, but would pass directly into wells and beyond into the Greenbrier and New Rivers.
- The Greenbrier karst phenomenon is limited to Monroe, and adjacent Greenbrier Counties and to a smaller extent, Pocahontas County. (Caves are present in the folded rocks of the Valley and Ridge Province of the Appalachians but are mostly limited to the much older Cambro-Ordovician formations which are not subject to deep drilling.)
- Surface exposures of the Greenbrier Limestone are riddled with fissures so the general picture is of an anastomosing meshwork of large and small caves which continue to be discovered and mapped but have not been fully tested with die tracers to determine flow patterns.
- The conclusion is that the Greenbrier Limestone poses a major challenge to proposed gas drilling.
- Questions arising are:
- How could wells be adequately cased in such a formation?
- How could failures of the highly pressurized “fracking” process be avoided?
- How will the containment ponds be designed to avoid rupture?
- How will trucking accidents be avoided on the narrow, switch-back roads typical of Monroe County?
- DALE MCCUTCHEON, Sanitarian, Monroe County Health Department
Since Monroe County does not have streams with the capacity to provide for public water supply sources, almost all residents rely on groundwater for their water consumption needs. The public supplies available, which provide for about half of the county usage, primarily rely on springs or wells for their intake.
Due to the karst topography which underlies much of the county, underground streams, as indicated by numerous dye tracing activities conducted over the years, may travel for several miles. Further, unlike in other subsurface environments such as sandstone wherein natural filtration takes place, karst aquifers do not receive this benefit. This lack of filtration and substantial migration is, in the opinions of most authorities, the primary reason that about half of the water samples taken by the Monroe County Health Department over the last decade have been found unsatisfactory due to bacteriological contamination. Thus a localized contamination event, such as might occur from a drilling error, has the potential to effect a hundred or more wells over a large area.
Although, as mentioned above, a number of dye tests have been undertaken at various locales throughout the county, there is still a substantial lack of information related to our underground aquifer system. Much more testing and cataloging of results into a coordinated framework is needed to establish flow patterns and contamination potentials before we may understand the full potential of a contamination event.
- PRECAUTIONARY PRINCIPLE : “The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action.” (Wikipedia)
