file. - Otsego County Conservation Association

York State. These rock formations are conduit bearing in nature, meaning that water in solution,
along with its toxic contaminants, can travel up to several kilometers a day. Aquifers that cooccur
with karst formations may be particularly vulnerable to surface spills as well as to
subsurface contamination caused by leaking wells. “This poses serious problems when
monitoring for water quality. Contaminants enter the ground easily through sinkholes and
sinking streams, and filtering is virtually non-existent. Even small solution conduits can transmit
groundwater and contaminants hundreds of times faster than the typical un-enlarged fracture
network. Hydrofracking-related contaminants that may enter karstic solution conduits, from
below or above, would quickly degrade groundwater and surface water quality iv .”
The DEC should ban HVHF development activities in watersheds, such as those which feed into
Otsego Lake, that overlay karstic regions.
6.1.9.1 NORM Considerations – Cuttings
We understand that the composition of Marcellus shale varies throughout the formation.
Because of this, we are concerned that naturally occurring radioactive materials (NORM)
concentrations may vary spatially and may pose a threat in certain areas while remaining benign
in others. Therefore we recommend that the DEC require that drill cuttings, flowback, and
production brine be tested prior to allowing any particular disposal method or leaving the
drilling site. We also recommend that the DEC's conclusion that NORM levels are equal to
background levels be regularly re-evaluated and updated as new information is made available.
6.2 Floodplains
The DEC did not consider the effect that fracking chemicals would have on terrestrial and aquatic
ecosystems if a well pad was flooded. This is a particular concern because of the multiple severe
flood events that have occurred in the past five years and New York’s outdated flood plain maps.
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