file. - Otsego County Conservation Association

6.1.3.1 Drilling
Section 6.1.3.1 of the rdSGEIS states, “Contamination of surface water bodies and groundwater
resources during well drilling could occur as a result of failure to maintain stormwater controls,
ineffective site management and inadequate surface and subsurface fluid containment practices,
poor casing construction , or accidental spills and releases (p. 6-19).” While the DEC recognizes
that these accidents can occur, it makes no attempt to quantify the impact by estimating the
number of such accidents that New York may reasonably expect. Nor has the DEC included an
analysis of incidents in other states, such as Pennsylvania and West Virginia, which have suffered
these impacts. Such information would allow us to gain a better understanding of the prevalence
of these types of accidents, and thus assist New York State in better assessing its risk. Such an
analysis is possible and appropriate, as demonstrated by the DEC’s “Fact Sheet: What We Learned
From Pennsylvania i ” and the Ecology and Environment, Inc. analysis that estimates
socioeconomic impacts of HVHF-related activities ii . The DEC’s evaluation of environmental
impacts is inadequate without such an analysis.
6.1.3.2 Hydraulic Fracturing Additives
and
6.1.3.3 Flowback Water and Production Brine
We have two comments we wish to share with the DEC on sections 6.1.3.2 and 6.1.3.3:
1. Before water is mixed with sand and fracking chemicals to make fracking fluid, the
chemicals are stored in highly concentrated forms. High concentrations of many
chemicals can have a different effect on the environment than the same chemical in a
more diluted form. The DEC should address the impacts that surface spills of high
concentrations of fracking chemicals may have on soils, lakes, rivers, streams, wetlands
and wildlife.
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