FOEC News - Friends of Euclid Creek (FOEC): February 2012

Here are the minutes from the February 15 steering committee meeting held at the South Euclid Library. Attending the meeting were Gary, Lou, Larry, Fran Hogg, Rick Evans, Jeanette, Ken, Frank, Barb Holtz, and Steve Albro. Frank called the meeting to order around 7PM.

March meeting - Frank Greenland will be the speaker.
April meeting - Our member to member forum will include Barb, Rick, Lou, and Connie.
FOEC newsletter - We agreed to reimburse Barb for the purchase of Publisher and discussed content, format, name, and dates for the newsletter.
Scholarship - We agreed to February 15 for receiving the scholarship from applicants and May 1 for deciding who will be the recipient. It should be a 1-2 page letter and update to PO Box 21384 and zip code of 44121-0384. Jeanette will contact Meiring to get names of contacts at high schools and develop a scoring system.
Grants - We discussed the letter to Jane Goodman. Ken is to revise and provide to Frank for signature. We are to cc Derek Schaefer on the letter. We discussed a possible WRSS grant working with Claire for the BIshop Road property. Ken noted that Metroparks did a wetlands assessment of the property. THe assessment included a naturalist and two assistants.
Dues - We discussed placing information about dues in our newsletter.
Officer elections - Larry updated us on how by May 1 he will develop a nominating committee for officer elections.
Treasurer report - We agreed to renew membership in the Ohio Environmental Council. Ken provided the February budget report.
Highland Heights gas well drilling - We discussed preparing a letter of concern in line with our role as educating the community. We can educate on the risks involved. Frank, Ken, Fran, and Jeanette can work on this with Frank and Ken beginning the draft.
Earth Day - Rick explained he plans to provide information about the watershed and FOEC at Earth Day activities at Rockwell Automation in April.
Priorities
With regard to our future priorities for land restoration, preservation, and conservation we reviewed briefly the following list, stated by geographic area in order of priority within each area.

MAIN BRANCH (Euclid, Cleveland)
1.Spillway at Neff Rd.

2. PJ playground

3. Bioswale near Dille Rd.

4. Any green space connecting Euclid Creek Reservation to Wildwood Park

EAST BRANCH (Highland Hts., Richmond Hts., Mayfield, Willoughby Hills)

1. Vacant land on Bishop Road adjacent to Hawthorne Dr. and connecting with Highland Heights Community Park. –currently for sale, Howard Hannah

2. Former Mayfair Country Club site, off of Highland Road

3. Highland Hts. Community Park/Dusty Goldenrod Meadow north of Hawthorne Dr.

4.  Richmond Rd. and White Rd. - Greenwood Farm and ravine corridor
5.  Vacant land between Belwood and Lander Rds.

WEST BRANCH (South Euclid, Lyndhurst, Beachwood)
1. Land around S. Euclid Library, "mansion" on Dorsh Rd. and Palermo property connecting to Liberty trails corridor
2. Acacia Country Club
3. Open space around Notre Dame College
4. Around St. Margaret Mary and Quarry Park
5. Easement opportunities along Ammon and Parkside Rds.

We recently presented the following information at a Highland Heights City Council meeting as part of our education role.

As advocates for the environmental health and preservation of the Euclid Creek, for the residents living within the Euclid Creek Watershed who depend upon its resources, and as owners of the Dusty Goldenrod Meadow Conservation Easement, which is an environmentally sensitive property immediate adjacent to the Highland Heights Community Park where you are currently considering to allow drilling of oil/gas wells; our organization would like to bring to your attention several concerns of which we believe you should be aware.

I. Drinking Water Contamination

It is our view that the Highland Heights Community Park and its surrounding area comprise a particularly environmentally sensitive and vital area within the Euclid Creek Watershed. Survey maps of the park readily reveal that the park property is hydrologically connected to the upper East Branch of the Euclid Creek, which empties ultimately into Lake Erie the primary source of drinking water for much of northeast Ohio. As such it would be a calamity of the first measure if fracking fluids used in the drilling process leaked out of the well and into the ground water systems flowing through and under the park. Although drilling companies are not required by law to disclose the chemical formula of their fracking fluid many companies have released information voluntarily, and the Ohio Department of Natural Resources requires companies to disclose to the department what chemical mixtures they use in case of emergency. Therefore it is known that chemicals such as hydrochloric acid, benzene, toluene, ethylbenzene and xylene are commonly used in fracking fluid and are known to be either carcinogenic or extremely toxic to humans, or both. If these chemicals were released into the ground water system of the park they could reasonably be expected to make their way gradually into the Euclid Creek and from there into Lake Erie, the source of drinking water for the residents of Cuyahoga County and much of northeast Ohio. There is no safe level for these chemicals in drinking water, and there is no way presently to remove these chemicals from water once that water is contaminated.

In recognition of this potential danger the Ohio Revised Code provides in Chapter 1509.17 Encasing Wells, in pertinent part:

(A) A well shall be constructed in a manner that is approved by the chief of the division of oil and gas resources management as specified in the permit using materials that comply with industry standards for the type and depth of the well and the anticipated fluid pressures that are associated with the well. In addition, a well shall be constructed using sufficient steel or conductor casing in a manner that supports unconsolidated sediments, that protects and isolates all underground sources of drinking water as defined by the Safe Drinking Water Act, and that provides a base for a blowout preventer or other well control equipment that is necessary to control formation pressures and fluids during the drilling of the well and other operations to complete the well. (emphasis inserted)

We believe Council should be aware of this risk to the only source of drinking water in our region, to make certain that the precautions provided by law and regulation to minimize the risk of accidental contamination of this kind, are strictly enforced. As we will explain further below, we will urge Council to require that these measures are implemented should the drilling of these wells go forward.

In addition to the risk of contaminated ground water, hydraulic fracturing of oil/gas wells requires the use of large quantities of water. While usage varies from well to well, typically hydraulic fracturing of one horizontally drilled well can consume 4.5 to 10 million gallons of fresh water. Where will that water come from? Several sources are used typically. Within municipalities drilling companies often purchase water by hooking up to fire hydrants and reimbursing the city for the water use. In other instances drilling companies may used locally available ground water including rivers, creeks, lakes or ponds. As a last resort companies will truck in water where no other source is readily available. In the case of the park, use of piped in water presents the least risk to the environment. If the water for these two wells were to be taken from the local stream running through the park, depending on the time of year, the impact on fish and animals living in and depending upon the stream and farther downstream in Euclid Creek, particularly during spawning season, could be severe. Trucking in water necessarily involves driving hundreds of truck loads into the park which while feasible, presents the separate problem of clouds of diesel fumes filling the air of the neighborhoods surrounding the park.

While the focus in hydraulic fracturing is typically on the injection portion of the fracking process, it should not be overlooked that as much as a third or more of the fracking fluid that goes into the wells typically comes back up as a highly toxic, chemically hazardous, sometimes even radioactive mess commonly known as “flowback”. Ohio regulations require the use of open pits in the management of the return flow of the fracking fluids. Given the proposed site of the wellhead and its proximity to the park stream as it flows through the park at that point, use of an overflow pit presents a very real possibility of an accidental contamination of the stream either through seepage or by overflow. Therefore the pit or pits need to be positioned so that no overflow from the wellhead can possibly flow into the stream. This is not only best practice, it is also the law. ORC 1509.17; and OAC 1501:9-1-07; 1501:9-9-(03) (F).

II. Hydrogen Sulfide Gas/Sour Gas/Air Pollutants

According to the Occupational Safety & Health Administration website on Oil and Gas Well Drilling:

Hydrogen sulfide is an extremely toxic, flammable gas that may be encountered in the production of gas well gas, high-sulfide, high sulfur content crude oil, crude oil fractions, associated gas, and waters. Since hydrogen sulfide is heavier than air, it can collect in low places. It is colorless and has a foul rotten egg odor. In low concentrations, H₂S sometimes can be detectable by its characteristic odor; however, the smell cannot be relied upon to forewarn of dangerous concentrations (greater than 100ppm) of the gas because it rapidly paralyzes the sense of smell due to paralysis of the olfactory nerve.

In addition to its extreme toxicity, because it is heavier than air, hydrogen sulfide gas has been known to travel in a cloud along the ground far from a drilling site. It will be one of the particularly unique risks of drilling in the Highland Heights Community Park that the site will be surrounded by nearby homes. Should a cloud of hydrogen sulfide escape during the drilling of the well, any number of residents could be injured or killed in a very short time. Whether hydrogen sulfide or “sour gas” as it is known in the industry exists at the proposed site for these wells is unknown, although anecdotally long time residents of Highland Height have asserted that they remember from their childhood smelling the rotten egg smell that came from the gas wells which were in the park in the 1930’s. Again, there are precautions that can be taken to prevent this type of disaster from occurring. But Council needs to be aware of the risk so that those precautionary measures can be implemented should the drilling be allowed to occur.

In addition to the possible release of hydrogen sulfide during drilling, oil and gas operations are known to release significant levels of toxic gases from storage tanks, well heads, and drilling equipment located on the wellpad after the well is in operation. According to a U.S. EPA study:

Some of the largest air emissions in the oil and gas industry occur as natural gas wells that have been fractured are being prepared for production. During a stage of well completion known as “flowback,” fracturing fluids, water, and reservoir gas come to the surface at a high velocity and volume. This mixture includes a high volume of VOCs and methane, along with air toxics such as benzene, ethylbenzene and n-hexane. The typical flowback process lasts from three to 10 days.

These gases are not captured but go directly into the air from the overflow pits. Given the location of the well in the park, in the middle of the residential heart of the city, all of the residents in the surrounding home can expect to be exposed to some level of airborne toxins. Although U.S. EPA has regulations pending, no law or regulation in Ohio protects residents from air pollution resulting from oil/gas drilling.

III. Blowout

One last significant risk of drilling in an urban area is the risk of blowout. It must be kept in mind that the process of drilling for oil and gas involves releasing substances deep underground and therefore under conditions of extreme pressurization. While blowouts are not common they do occur. Just last April at a Chesapeake Energy well in Bradford County, Pennsylvania, the production crew lost control of a well during the fracking process resulting in a substantial spill of hazardous flowback fluid throughout a widespread area. Although details of such accidents are routinely suppressed by energy companies and State regulators out of fear of alarming the public it is clear that thousands and thousands of gallons of flowback material gushed out of a well and spread across the Pennsylvania countryside. The accident was severe enough to cause Chesapeake to suspend drilling operations throughout the state until the cause of the accident had been determined.

But accidents during the drilling process are not the only hazard to be concerned about. After gas wells are installed failures of critical pressure values can result in gas well explosions sending hundreds and thousands of gallons of gas, oil, brine and flowback anywhere from dozens to hundreds of feet into the air and into the environment surrounding the well site. For instance, also last April a blowout of a well valve in Chester Township, in Geauga County, sent oil, gas, and brine spewing into the air for over an hour until emergency crews were able to shut down the well. Slightly less recent, in 2009 a backhoe doing restoration work near a new well on SOM Center Road in Mayfield Heights, damaged a wellhead resulting in the high pressure release of gas and oil which shot across SOM until the well was shut off. Being in an urban area surrounded by neighborhoods and the park itself, a blowout could cause extensive environmental and property damage to park property or to the homes of residents in the nearby area. There are measures that can be implemented to prevent blowouts from occurring, but even then as these incidents show, accidents do happen even where precautions have been taken.

Recommendations:

1. Water testing. The city should consider pre-drilling testing of the ground water near the proposed well site. Such testing will provide an invaluable baseline measurement of the natural state of the water in the park prior to drilling. In the event complaints arise from neighboring property owners after the well has been drilled and fracked, such a record of the water passing through the park, past the well and out of the park can be an invaluable source of evidence of contamination, or non-contamination either way. Certified water testing laboratories can readily be found on the ODNR website. http://www.ohiodnr.com/oil/watersampling_bmp/tabid/23361/Default.aspx

2. Strict Supervision and Monitoring of Cement Job. The cementing job, that is the cementing of the well hole or annulus, is absolutely critical to the prevention of blowouts and leaks. Although Ohio law and regulations provide specific stringent requirements and specifications for the completion of the cement job, including notification of a State inspector, there is no requirement that a State inspector be present during the cementing process, nor is there any requirement to have a State inspector inspect and test a cement job after it is complete. Nevertheless, an inspector can be requested to come to the job site during the cementing job and after to conduct inspections and tests. Given the environmental sensitivity of this site, it is strongly urged that a State inspector be asked to test the cement job according to the regulations for structural integrity, prior to allowing the hydraulic fracturing to proceed.

3. H2S/Methane Monitors. Given the possibility of hydrogen sulfide gas at this well site in an urbanized area, the optional requirement under State regulation for fluid drilling in such situations, should be required. Even though the regulation gives the regulator room for discretion, given the circumstances the City should insist on fluid drilling unless a better way to protect the City’s residents is put forth. Further, it is strongly recommended that H2S monitors be used at the site as the drilling process occurs. These monitors should never be turned off as a well can burp up toxic gas anytime after it is opened. If a monitor alarm is tripped the City’s special alert phone system should be utilized to notify residents of the situation as it stands. In addition, if possible, to reduce the evaporation of toxic chemicals into the air of the neighborhoods surrounding the park, the flowback pits should be covered with a tarp or other appropriate material throughout the duration of this process.

4. Pit Location, Storage Tanks. Given the location of the proposed wellhead, and the requirement of Ohio law that no ground water contamination is permissible, the flow back pits for these wells should be located at least 50 feet away from the stream bed, or separated by an earthen berm to prevent overflow and lined so as to prevent seepage of flowback into the stream. Pit liners should be regularly inspected so that there are no possible leaks. Once the wells are complete pipelines transporting the gas away, and any storage tanks for oil or brine should be required to be compliant with pending EPA regulations, and inspected for leaks on a regular basis. Air quality testing may be appropriate prior to drilling in order to have a baseline record in the event the City is presented with any air quality complaints.

5. Blowout Preventer. Given location of the proposed well and the possibility of the presence of H2S at the site, the installation of a well blowout preventer should be required. Although the Ohio regulations allow State inspectors to skip a BOP test prior to the commencement of drilling, the City should request such an inspection to be performed. Better safe than sorry. Remember the BOP did not work properly at the Deepwater Horizon.

In conclusion, while Ohio’s laws and regulations impose specific standards for oil and gas well drilling in order to protect the environment and the public, given the environmentally strategic nature of the park, and the location of the site surrounded by neighborhoods, all steps must be taken to ensure that the environment and public safety are fully protected. Failure is not an option. Furthermore, as the late President Reagan said to former Soviet President Gorbachev, “Trust but verify.” The operator will give his assurances that everything will be done to the highest standards, in this case especially, the City needs to hold him to that.