5 March 2014
Response and comments to:
McCULLY PHASED ENVIRONMENTAL IMPACT ASSESSMENT PHASE III:
NATURAL GAS EXPLORATION AND
DEVELOPMENT IN McCULLY FIELD
Feb 2014 TE131040
The EIA submitted to Corridor Resources Inc. by AMEC Environment & Infrastructure is the first EIA I have ever commented upon. Being as it is premised upon the perviously approved Phase I & II submittals, the Phase III EIA will no doubt include the minimum information required by the GNB in order to grant its approval to proceed. However, I would like to go on record concerning inadequacies not included in this study that should have a bearing upon further exploration and development of unconventional gas and oil in Penobsquis as well as the province in general.
The EIA should begin by clearly acknowledging that the very nature and procedures used in the development of unconventional gas through hydraulic or propane fracturing are inherently toxic and dangerous. The EIA states the intention of Corridor Resources to meet all the minimum standards as regulated by the GNB. The potential dangers to the residents of the local community and the local ecosystems are grave and require extraordinary measures be evaluated and undertaken. The precautionary principle established by courts in Canada clearly define the responsibility of the industry and the government to protect the citizenry and the environment.
The initial exploration and development of the McCully Field was approved by the GNB prior to the findings of subsequent peer reviewed scientific studies regarding current methods and standards of unconventional gas exploration and extraction. New studies surface each day that question the efficacy of current industry methodologies and the long tern safety and sustainability of the industry in general. I would implore the GNB to review these studies prior to approval of the Phase III EIA.
As recommended by Dr. Eilish Cleary, NB Chief Medical Officer of Health, as well as the NB College of Family Physicians, base line studies of the long term health effects of the industry need to be undertaken prior to approving expansion of the industry. For example, a recent study by the Colorado School of Public Health has documented a correlation of birth defects within 10 miles of well pads. This is well beyond the 250 meter minimum setback required by NB Rules for Industry for separation of well pads from residences or the 5 km radius study area of this EIA or the public consultation by Corridor of “landowners within an 1800 meter radius of the the three well pads”. Residents of Penobsquis have persistently requested, to no avail, air monitoring by theDepartment of the Environment and the industry to safeguard their families’ health. Air monitoring is not even mentioned in the EIA. Unfortunately, the residents of Penobsquis have become the “canaries in the gas fields”.
The Phase III EIA describes the fracture treatment of existing wells using propane (LPG): two (2) treatments at the J-76 shale well; one (1) treatment at the D-67 sand well and the P-67 sand well; and two (2) treatments at the L-37 sand well. Fracture treatment using LPG has been conducted previously by Corridor. The use of LPG as a fracturing agent is new and potentially very hazardous. The health and property of the entire community could be adversely affected by an unintended accident. Are local volunteer fire fighting units trained and equipped to respond to a mishap involving large quantities of LPG and toxic materials? Dr. Anthony Ingraffea had the following comments concerning LPG fracturing:
Fracing with liquified propane, or butane (LPG):
- still needs large quantities of additional, but different chemicals to add to the LPG;
- needs HD compressor on each site to recondense returned propane/butane for reuse, and additional processing on each site for reuse;
- frac process is now nearly "robotic" because of risks to personnel on the pad;
- have been two explosions/fires in past year, one quite serious with hospitalizations;
- many truckloads of LPG needed for each frac job-these trucks are transporting hazardous material, not water;
- LPG not available in large enough volumes to make this "THE" method in any play with tens of thousands of wells projected;
- the biggies, Schlumberger, Hallliburton, et al. will not like encroachment on their turf..they have billions invested in equipment and personnel training for water based fracing, but they currently say they are "interested" in this new line of research: you make the call
- the ONLY substantive information about the process comes from the company - in effect advertising claims. There has been no independent empirical analysis of the complete life cycle of LPG fracs.
- still transports some materials from downhole just like slick water does and will be subject to the same constraints:
- communication back to surface via faults and old open wells
- communication/migration of methane and other downhole crap via casing sealing failures and leaks (cf the Pavilion/EPA study (11-10-11 released) and the "Duke" methane migration study), and
- surface spills of frac related materials that comes back up
- the added danger of propane, a heavier than air gas leaking and pooling in low spots near the well pad in large amounts and causing an explosion hazard
Bottom line: no science available to evaluate either env impact of LP frac or the safety thereof. Grasping at straws for a solution to a problem the industry claims does not exist.
A. R. Ingraffea, Ph.D., P.E.
Dwight C. Baum Professor of Engineering
Weiss Presidential Teaching Fellow
The potential dangers of further production of sand or shale gas wells in a flood plain
and in an area of known and continuing subsidence is not adequately addressed in the
Phase III EIA. Recent flooding events in Colorado are an example of what can happen
to well pads in a flood plain. Any unforeseen damages or accidents resulting form gas
development or production in a flood plain are not easily mitigated. The EIA should
clearly define mitigation measures such that they can be peer reviewed for adequacy.
Dr. Anthony Ingraffea called the locating of gas wells in a subsidence area like
Penobsquis “foolish, asking for trouble” and “Speaking as an engineer ... it’s stupid.
Don’t do it.” Since the wells of the McCully field are located in the same flood plain
above the potash mines, the EIA should also address the potential for and response
plan to a well failure or mining accident releasing methane into the the mines underlying
The inherent toxic and dangerous nature of the unconventional oil and gas industry and its history of harm to humans and natural ecosystems should make the development of this industry near existing homes and businesses unthinkable. All steel rusts, all concrete fails, all gas wells will eventually lose their well bore integrity and leak. This is a non-sustainable industry exploited on an industrial scale for short term profit at the expense of the people who live in Penobsquis.
The Premier and various ministers of the GNB have stated that unconventional gas development is essential to providing jobs and operating the potash mines in Penobsquis. The gas produced in the McCully Field is partially used by the Potash Corporation in the operation of the mines and partially to generate profits for Corridor Resources. Have the meager royalties earned by the province, after reimbursing Corridor Resources for its capital expenditures, covered the costs of damages to public infrastructure and additional health care?
Contrary to public statements made by the Premier and various ministers of the GNB, the citizens of Penobsquis have had their health, air, water and properties adversely affected by the industrialization of their rural community. When their water wells went dry or became non-potable, the GNB and the industries stonewalled for years before providing a replacement water system (at taxpayer expense). Residents of Penobsquis have persistently requested, to no avail, for air monitoring by the Department of the Environment and the industry to safeguard their families’ health. The residents have not been compensated for the loss of value in their homes under the NB Rules for Industry.
Before the GNB asks other New Brunswick families and communities to sacrifice their way of life and wellbeing to unconventional oil and gas exploration and development, the lessons learned and experienced by the citizens of Penobsquis need to be heard. They were not included in the Phase III Environmental Impact Assessment.
Consider an alternative. The Potash Corporation could have chosen to invest in a biomass boiler system and renewable power generation to generate the hot water, steam and electricity they needed to operate the mines and as a byproduct could have also offered a district hot water / home heating system to the community as a good corporate neighbor. More local jobs would have been created to operate the biomass system and to service the renewable power system meaning more income for the local economy. The $10 million spent on the water system to replace lost wells could have been avoided and/or spent in the development of the biomass and renewable systems. The corporation would have had the energy they needed, more local jobs would have been created, property values would have been protected, the community would have received the benefit of hot water and home heating, the air would have been safe to breathe and the water to drink, and a bright future could been a reality for future generations of residents in Penobsquis.
Richard Lachance & Eveline Haché