Karst Hydrology & Gas Drilling Concerns, Perryville, NY by 33z50F


									                                                                              January 17, 2012

Sullivan Citizens Alliance
PO Box 425
Chittenango, NY 13037

RE:    Planned Quarry Road Mine – Karst Hydrology & Gas Drilling Concerns;
       Perryville, New York

HydroQuest was retained by the Sullivan Citizens Alliance of Chittenango to address concerns
relative to the karst hydrology and potential environmental impacts associated with the proposed
Oot Quarry application. HydroQuest has prepared this report for consideration in the mine
permit application before the New York State Department of Environmental Conservation
(NYSDEC). Because significant karst features and karst aquifers are present on, beneath, and
adjacent to the subject property, a comprehensive hydrogeologic study of the site and its down
gradient groundwater and surface water receptors is necessary to address water quantity and
quality concerns of area residents. In addition, risks attendant to gas drilling in carbonate
terrains are addressed.

The focus of this report is to raise environmental issues relative to the presence of karst
hydrology on and adjacent to the Oot Quarry site and the potential that such geology carries for
adverse environmental impacts to down gradient property owner wells and surface water
resources. Specifically, mining removal of all or part of residents’ aquifer recharge area may
substantially degrade the groundwater flow regime and the quantity of groundwater currently
available to area residents (e.g., Laughlin, Osborne). In addition, mining related bedrock
particulates may become entrained in site groundwater, may flow off-site, and may potentially
degrade both groundwater and surface water quality. Also, fugitive dust from quarry operations
may pose a health risk to area residents.

HydroQuest is a hydrologic consulting firm whose principal is the undersigned Paul A. Rubin.
Paul Rubin is a hydrologist with three decades of specialized experience in both surface water
and groundwater hydrology. He has conducted work for the New York State Attorney General’s
Office (Environmental Protection Bureau), Oak Ridge National Laboratory (Environmental
Sciences Division), the New York City Department of Environmental Protection, and as an
independent environmental consultant as President of HydroQuest (see curriculum vitae and all
figures referenced in this report at: http://hydroquest.com/Laughlin/). Mr. Rubin’s experience
includes SEQRA review, research, site characterization, land-use planning, report and affidavit
preparation, testimony, and numerous professional presentations and publications related to karst
hydrology. His CV and Addendum to this letter document many of his karst related
publications, including a presentation before an international congress of karst hydrologists in
the summer of 2009.

The findings of this report are based on a combination of field survey, review of geologic
material, and hydrologic interpretation. Locations of geologic features of importance were
determined using a handheld Global Positioning System receiver and were subsequently plotted
using ESRI GIS software. Two different years of high resolution orthoimagery and digital raster
graphics (i.e., topographic data) were reviewed. The major surface drainage that flows around
much of the Perryville Plateau was then plotted on Figure 1. All springs that issue from the base
of the escarpment and hillslope areas join down gradient streams, although the exact physical
flow routes were often not plotted on the map. Photographs were also taken.

As explained in more detail below, karst geology and karst features are evident on the site and in
the surrounding area. Based on the areal extent of karst geology and hydrology, there is
substantial potential for contamination of local aquifers, wells, and down gradient surface water
resources. Assuming that state-of-the-art fueling pads are always used in the proposed quarry
and no spills occur, the most likely risk to water quality stems from the entrainment of fine
particulates that will be generated throughout the proposed quarrying process. These particulates
may move with groundwater and may result in turbid well, spring, and stream water. From a
groundwater quantity perspective, the removal and physical alteration of the aquifer recharge
area up gradient of residents wells may be a significant adverse environmental impact.

In addition to water quantity and quality risks, fugitive dust stemming from quarry operations
may also pose a significant risk that may adversely impact the health of downwind residents.
The “hard look” required by SEQRA is fully warranted.

Site Geology

In the absence of core hole data from the proposed Oot quarry site it appears that the bedrock
present throughout the northwestern portion of the Oot parcel extends throughout most of the
Manlius Formation, downward into the Rondout Formation, and below. Nearby cliffs exhibit
abundant stromatoporoids that are commonly found in the middle Olney Member of the Manlius
Formation, found below the Elmwood Member and above the Thacher Member. Thin bedded
stromatoporoid-bearing strata present in northern site cliff exposures provide further evidence
that the uppermost site strata there is the Manlius Formation vs. the Coeymans Formation that
also sometimes has stromatoporoids in portions of New York State.

Reference to a bedrock geology map of New York State available through the New York State
Museum indicates that the bedrock geology present in the southeastern portion of the site grades
upward stratigraphically, with increasing topographic elevation, into the Coeymans, Oriskany,
and Onondaga formations. Verification of the bedrock units present may have been conducted
by consulting geologists after examining bedrock core.

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Site and Area Hydrogeology Overview

The Oot parcel is situated within a broad upland karst plateau, the “Perryville Plateau”, marked
by a general lack of surface drainage (see Figures 1 and 2). The physical boundaries depicted for
the Industrial Zoning and Oot parcel were derived from outside sources and may need some
correction. Portions of this plateau drop off steeply along the edge of an escarpment, particularly
southwest and south of the Oot parcel. Instead of streams that are typically found throughout
non-carbonate terrains, site drainage is largely internal through a thin soil mantle and the
underlying fractured bedrock. Surface water infiltrates downward through dissolutionally
enlarged bedrock fractures. Some fractures are preferentially enlarged more than others,
resulting in a criss-crossed appearing ground surface where exposed (see Figure 3). This
dissolutionally enlarged fracture or joint network, referred to as karren, shunts surface water
downward into the underlying karst aquifer. Measurement of the orientation of some exposed
joints immediately east of the site reveals the following orientations: 93 to 104; 6 to 19; 68
to 78; 173 to 174. The general location of these joint orientation readings is depicted on
Figure 2. Because joint orientations are relatively consistent throughout adjacent areas, it
reasonably follows that these orientations are similar throughout the Perryville Plateau. Below
the ground surface, this network of solutionally enlarged openings is referred to as epikarst.

Surface water incident to the Perryville Plateau infiltrates downward through both the epikarst
and sinkholes. Sinkholes are closed depressions that shunt surface water downward into an
underlying karst aquifer. Several, large enough to show up on topographic maps, are present
within the Perryville Plateau, one on the Oot parcel (see Figures 1 and 2). Groundwater flow
within the plateau occurs through a continuum of intersecting joints and dissolutionally enlarged
joints and conduits that discharge to numerous springs present along the base of the plateau.
While many of these springs were located via field survey (see Figures 1 and 2), there are likely
to be others present in locations beyond the area of field reconnaissance.

What is karst and why is it important?

Karst is a term used to describe a landscape in which landforms are produced mainly by
dissolution of bedrock, most typically limestone, dolostone, and marble. Dissolution created
features; such as enlarged fractures (i.e., karren), shafts, sinkholes, and caves; form as
groundwater infiltrates into and flows through carbonate bedrock. The result is a scenic
landscape which is beautiful but fragile, and vulnerable to erosion and pollution. These features
can provide for rapid transport of contaminants with groundwater over relatively long distances
if they are exposed to a source of contamination.1

              While many excellent books on karst geology and hydrology are available, we
recommend that consulting firms, engineers, planning boards, and others interested in learning
about the subject obtain Dr. Arthur N. Palmer’s 2007 book titled Cave Geology. Dr. Palmer is
the most frequently cited karst hydrologist in the world. Paul Rubin, of HydroQuest, has
coauthored a number of karst guidebooks and papers, as well as co-led professional geological
field trips, with him. Dr. Palmer’s 454-page book is well-illustrated and brings together well his
fifty plus years of karst experience. It is available for $38.00 in hardback at:

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Some karst terrains exhibit surface features including epikarst (i.e., a solutionally enlarged
fracture network), sinkholes, sinking streams, caves, and springs, providing a relatively simple
means of identification. However, the most important aspects of karst landscapes are hidden.
For example, glacial sediments often mask karst features that would be visible in non-glaciated
regions. Only about 10% of sinkholes in a typical American karst are shown on topographic
maps. This is also true where there is a cover of glacial sediment, which tends to mask
subsidence features. Many significant karst areas, some with major cave rivers flowing beneath
them, exhibit little or no surficial evidence of karst. People unfamiliar with karst terrains may
incorrectly conclude that the absence of sinkholes on topographic maps indicates a non-karst

The most important characteristic of karst is the way groundwater behaves. Surface water in
karst areas drains underground through solution conduits. Water in these conduits can travel up
to several miles per day, and contaminants can move at the same rate with little or no natural
cleansing. Contaminants enter the ground easily through sinkholes and sinking streams, and
filtering is virtually non-existent. Stormwater discharges, pesticides, herbicides and spills
incident to karst aquifers can degrade groundwater aquifers and reservoirs within hours or days. 2
As a result of these concerns, the U.S. Environmental Protection Agency (EPA) actively supports
remedial investigations, strategy development, and conferences devoted to better understanding
karst aquifers. Even small solution conduits can transmit groundwater and contaminants
hundreds of times faster than the typical unenlarged fissure network.

http://nssbookstore.org/index.php?mode=store&category1=Cave%20Science&page=2 In this
report, we reference some of the karst characteristics cited by Dr. Palmer in his book. Such
characteristics and features will be described from observation in the vicinity of and on the Oot
property. In this manner, there will be no doubt regarding the presence of karst on the Oot
property site and no doubt relative to recommendations for completion of a DEIS should the site
ultimately be determined to be zoned for mining.
         In addition to contamination by potential fuel spills, quarry-derived particulates can be a
threat to the water quality in karst aquifer systems. Hydrocarbon contamination is particularly
serious in karst aquifers, as the likelihood of successful remediation is poor. Recker (1992)
found that hydrocarbons stemming from a gasoline spill remain in the fractured epikarst and
become a continuing source of groundwater contamination. Gasoline fumes associated with a
similar contaminant event in a Bowling Green, Kentucky karst aquifer seeped into overlying
buildings. Ewers et al. (1992) document that hydrocarbon transport in the turbulent flow of karst
conduits occurs as globules of entrained free product as well as a dissolved phase and can move
at nearly the velocity of water. Ewers et al. (1992) further illustrate that once turbulent flow
regimes become laminar (i.e., slow moving), concentrated hydrocarbons separate from water and
can collect or be trapped in high points along the conduit ceiling. Based on the results of multi-
tracer investigations of diffuse or conduit flow in karst aquifers, Quinlan and Ray (1992)
concluded that successful remediation of contamination in most karst aquifer systems would be
nearly impossible. All potential quarry-related contaminant threats require evaluation.

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As a result, sound land use planning in karst terrains requires protection of both groundwater and
surface water quality (e.g., at down gradient locations including streams, wetlands, springs,
wells, and hibernating habitat for critical species, such as certain bats). Identification of karst
terrains is essential in determining land uses protective of the environment and natural resources.

Findings: Surface Karst Features of the Oot Property Site and Surrounding Area

Dr. Palmer, in his Cave Geology book (2007), provides descriptions and pictures of many
surface karst features recognized by karst hydrologists throughout the world. His introduction

        “Most caves and surface karst features grow in close association with one another. Much
        of the water that forms caves is fed to them through karst depressions and sinking
        streams, and this water emerges at springs. These and other surface features are clues to
        the presence and patterns of caves, and they may also serve as cave entrances.” (page

In the karst aquifer beneath the Perryville Plateau, groundwater flow is influenced by a
combination of bedrock lithology and structure, karren topography, glacial processes, stream
incision, and man’s alteration of the landscape. Field investigation revealed the existence of
surface and subsurface features which provide solid documentation of karst geology and
hydrology. A brief description of these features follows.

Karst Features

        A. Karren topography and epikarst on and adjacent to the Oot property

Portions of the Oot property support no obvious surface drainageways such as streams and
gullies. In carbonate terrains where bare soluble bedrock is exposed to weathering, such as that
present on the Perryville Plateau, exposed joints or fractures are enlarged into fissures. As joints
are dissolutionally enlarged, the surrounding bedrock is left standing amidst fissures, resulting in
karren topography.       Rainwater, snowmelt, and runoff infiltrate into this network of
interconnected fissures where it flows downward, then laterally until preferentially enlarged
joints shunt this water further downward into solution conduits. Below the ground surface, this
network of dissolutionally enlarged openings is referred to as the epikarst. Figure 4 depicts
vertical joints, bedding planes, and faults present in the epikarst. Portions of the Oot property
and surrounding area exhibit extensive karren (see Figure 3).

        B. Sinkholes - topographic evidence of karst depressions

Closed depressions occur within the epikarst where sufficient groundwater flow occurs to both
carry away overlying soil and to dissolve bedrock. Subsurface streams beneath karst depressions
transport soil and any contaminants through solution conduits to springs. In America, these
closed depressions are called sinkholes. Outside of America, these closed depressions are

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referred to as dolines. Sinkholes have no surface outlet for runoff. Their sloping walls shunt
runoff and snowmelt into them and downward into an underlying solution conduit. Sinkholes
vary in size and shape from deep, vertical, shafts to broad, shallow, basins nearly filled with soil.

Shallow sinkholes commonly do not show up on USGS topographic maps where they are
properly depicted with hachured contour lines. This is for a number of reasons, including
sinkhole depth of less than the depicted map contour interval, topography not being visible under
tree cover, and relatively small size. Figures 1 and 2 depict a number of sinkholes as blue areas
with red borders that readily show up USGS topographic maps. One is on the Oot parcel.

Sinkholes provide evidence of a karst landform. In order for a sinkhole to form, subsurface
water must flow through a solution conduit, dissolving away bedrock and carrying it and any soil
away. Only when this process has occurred for a sufficiently long period of time will enough
bedrock have been removed to allow collapse into an underlying void.

Even small and shallow sinkholes provide evidence that surface water runoff is pirated into
underlying solution conduits, only to reappear or resurge at springs. Spring locations may be on-
site or, in most instances, off-site – perhaps miles away. Thus, the risk of transporting quarry
particulate material and/or fuel spill chemicals (e.g., hydrocarbons) off-site is an, as yet,
undetermined aspect of the site’s hydrogeology. Contaminants in solution conduits receive little
or no natural cleansing, thereby potentially providing unknowing down gradient receptors with
polluted water.

        C. Sinking streams

In karst terrains, entire streams can be captured by underground openings to form sinking or
disappearing streams. The sink points are called swallow holes. Some of the earliest cave
passages in karst regions are formed by sinking streams. Sinking streams typically disappear
underground directly into an open cave or through bedrock fractures or a thin soil mantle. Field
reconnaissance to date has not located any large streams sinking into the Perryville Plateau.
However, the earliest stages of surface water piracy into dissolutionally enlarged joints is evident
in places (see, for example, the center two photographs in Figure 3). Elsewhere, groundwater
has been heard and observed rapidly flowing through a dissolutionally enlarged joint upstream of
a spring (on Osborne property, see Figure 2). Several locations east of the Oot property, while
dry on the date of observation, were observed that appeared to be small stream or wetland sink

Cave streams may carry sediment, contaminants, and other debris to nearby spring resurgences
or to springs many miles away. Tracer testing is required to document subsurface groundwater
flow paths and destinations.

        D. Caves in the vicinity of the site and on the site

Caves provide unequivocal evidence of underlying karst aquifers. Caves are large solution
conduits formed by bedrock dissolution. They can readily conduct contaminants into underlying

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karst aquifers. The size of a solution conduit is not important. Once it is large enough to rapidly
transport turbulent groundwater, contaminant transport can adversely impact nearby and distant

There is little doubt that caves are present within the Perryville Plateau. Caves are more
appropriately referred to as conduits because they either are or were once capable of transmitting
rapid, turbulent, groundwater flow. Conduit portions of the Perryville karst aquifer have the
highest permeabilities of all aquifer types, but random well installations would almost certainly
not intersect them. In addition, sinkholes, extensive karren, and springs provide solid evidence
of the karstic nature of the underlying aquifer. Clearly, further investigation is warranted to
characterize the site’s hydrogeology and related environmental concerns prior to any
consideration of allowing quarrying as an acceptable land use. In my experience, this is not only
important from the standpoint of protecting a Town’s best interests and environmental resources,
but also from a legal standpoint.

Using a New York State example, much of the karst hydrology of the Cobleskill Plateau in East
Central NYS, as well as of other karst systems of America, has been delineated through tracer
tests. Experienced karst hydrologists follow ASTM Standard procedures (ASTM D 5717–95) to
determine groundwater flow direction, velocity, and destination, as well as to assess contaminant
risks. Characterization of the conduit portions of karst aquifers cannot be made on the basis of a
few randomly placed wells. Instead, tracer tests are required to resolve groundwater flow paths
down gradient of quarries or projects proposed in carbonate terranes.

        E. Karst springs

The Perryville Plateau site is situated within a known karst region (see Figure 7). In karst
terrains, most underground water reappears at the surface as springs. Each karst spring
represents the resurgence of a cave stream. Springs can be small in size, ranging up to rivers in
flow. Most of the discharge at a karst spring is delivered by turbulent-flow through conduits.
Cave water moves rapidly as turbulent flow, at rates that approximate those in surface streams
(for example, 5.3 km/hr [3.3 mph] measured in Howe Caverns 3/14/07). Karst springs are
therefore highly susceptible to contamination and should never be used for water supply unless
development in the catchment area is minimal, and substantial treatment is provided. Stream and
wetland ecosystems downstream of springs are also susceptible to water quality degradation.

Numerous springs were located below the plateau and plotted (see Figures 1 and 2). Some are
supersaturated with calcite and precipitate travertine (see Figure 5). Surface runoff and
snowmelt that enters karren and sinkholes on the plateau eventually discharges as groundwater
issuing from springs. Because the proposed Oot quarry site almost certainly comprises the
recharge area of some of these springs, as well as that of residents’ wells, it is necessary to
characterize groundwater flow directions from throughout the quarry site as part of an
environmental impact analysis prior to approvals of any kind.

Determination of groundwater flow direction, pathways, and receptors in karst terranes is
accomplished via tracer testing. Tracer testing is needed to characterize karst aquifers that
underlie the proposed Oot quarry site and to document subsurface flow routes. If pathways and

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outflows are not traced, the quarry has the potential to contaminate water supplies down gradient
and some distance away, as well as surface water resources.

        F. Subsurface dissolution features - evidence of an underlying karst aquifer

Core log reports provide insight into the karstic nature of the Perryville carbonate aquifer. The
carbonate aquifer is, like most significant karst aquifers, comprised of a continuum of bedrock
fractures and dissolution conduits that range from interconnected fractures with slow, laminar,
groundwater flow to dissolutionally enlarged fractures and conduits with non-laminar, turbulent,
rapid groundwater flow. Dissolutionally enlarged fractures commonly grade into enlarged
conduits where groundwater moves rapidly until discharging at one or more spring resurgence
points. Groundwater flow in these conduits is analogous to flow in surficial streams, regardless
of whether or not they are partially or wholly water-filled. As fractures and conduits are
enlarged through time, groundwater flow within them carries dissolved bedrock, sediment,
pebbles and cobbles, and any contaminants that may enter the karst aquifer. The sapping of
surficial soils into underlying conduits, from which they are carried away, is a common
mechanism associated with sinkhole formation. As conduits grow in size, sometimes into cave
passages large enough to allow for survey, they are sometimes partially filled with sediments.
Core holes sometimes encounter what might appear to some geologists as open or sediment filled
voids, fractures, or partings in what should be continuous, unbroken, bedrock strata as is
associated with normal, uninterrupted, sediment deposition. Thus, these open or partially
sediment filled openings in bedrock represent conduits that either once were or still are actively
transmitting groundwater flow from one or more surficial water input locations to one or more
spring resurgence points. Therefore, the presence of open voids or sediment filled openings
provide hydrologic proof of karstic groundwater flow. They are not isolated vugs as one might
find when cutting a block of swiss cheese - they are part of an interconnected groundwater flow

Core log reports from the nearby Perryville Quarry provide documentation of subsurface
conduits within the karst aquifer. For example, Boring No. DDH 6-96, in the Elmwood Member
(Unit A) of the Manlius Formation found a: “Prominent mud seam with limestone clasts at 22.5 -
22.7’. Nearly vertical weathered fracture from 24.3 - 25.1’.” Another core hole that was
completed in October 1961 (Hole 2) had only ~85 percent core recovery at a depth of 45 ft to 50
ft. The stated reason for core loss is: “probably some cavities associated with stylolites.” The 20
foot increment between 50 and 70 feet has a logged core recovery varying between only 22 and
50 percent for each five foot increment. Although not noted on the core log, the missing strata is
likely to have been as a result of encountering a solution conduit. Comments on the core log in
the 65 ft to 70 ft increment note: “small pebbles in waterline”. These pebbles are not reported as
broken clasts as might be associated with rock breakage during drilling, but rather as small
pebbles. Similarly, Worlock Stone Company core log from Hole 1 drilled in the fall of 1961
notes the presence of pebbles in the Manlius limestone at a depth of 45 ft to 50 ft. These core
log notes infer rounded, stream-worn, pebbles that would not be expected within a continuous
limestone bedrock sequence. Instead, these pebbles provide evidence of solution conduits (e.g.,
cave like conduits) that extends from surficial water input locations to spring resurgence points.

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Wells Are Not An Appropriate Method For Defining Karst Hydrology

As the hydrogeology of the Perryville karst aquifer is investigated, it is possible that the
suggestion may be made that the presence or absence of karst on the proposed quarry site could
be made based on core logs from investigative boreholes. Wells in karst terrains are rarely
suitable as a means of addressing the dynamic conduit portions of karst aquifers, unless they
intersect solution conduits with flowing groundwater.

The installation of wells in carbonate bedrock (i.e., limestone, dolomite, marble) sites as a means
of characterizing carbonate aquifers is still sometimes relied upon by some engineers, geologists,
and hydrologists who are not familiar with the literature, publications, research, and ASTM
standards specifically developed over the last forty years or so. Wells drilled at random in
carbonate bedrock rarely intersect solution conduits. These conduits commonly integrate slower
groundwater flow present in fractures to zones of lower pressure where groundwater flow and
contaminant transport are rapid. Well information alone is not sufficient to document
groundwater flow, pathways, and receptors (e.g., springs, wetlands, streams, water supplies) that
may be on or down gradient of a quarry or other project site. Tracer testing is required.

Fugitive Dust

Fugitive dust associated with quarrying operations may pose a significant health risk for
residents situated downwind of the proposed Oot quarry. Children and adults with asthma who
are exposed to dust are even more vulnerable. Figure 6 illustrates wind flow directions outward
from the rose diagram center which, in the example, illustrates the center of a proposed quarry
site. An analysis of wind speed and wind direction data, such as that presented in this figure,
should be conducted as part of the environmental impact analysis prior to considering mining or
quarrying in an area with existing nearby residences or in an area where existing zoning
contemplates additional residential development. Should mining be considered to be an
appropriate land use in an area already zoned for residential expansion, mining would in effect
be a “taking” of property rights and would directly translate into decreased land values.

Beyond the health risks associated with the inhalation of airborne particulates, quarry operations
have been documented as the source of particulate cover on yards, cars, and houses. People
living near quarries may need to keep their windows closed in warm weather to avoid dust
inhalation and deposition throughout their houses. This may directly impact people’s health and
quality of life. Data collection and interpretation, such as that illustrated, are important in health
assessments and in assessing zoning changes.

Gas Wells and Hydraulic Fracturing

It is conceivable that consideration might one day be given to leasing Oot property and
surrounding karst plateau lands to companies seeking to exploit underlying gas reserves from
gas-rich shales. Therefore, it is important to point out the associated environmental risks to karst
aquifers and conduits within them at this time. Karst terrains are particularly vulnerable to gas

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and contaminant excursions resulting from hydraulic fracturing. This is well-documented in a
January 10, 2012 HydroQuest report provided to NYSDEC as a public comment on the revised
draft Supplemental Generic Environmental Impact Statement (SGEIS) on proposed gas drilling
regulations in New York State (pages 17-25, plus figures). The many potential contaminant
transport pathways present in gas fields relative to caves are illustrated below:

                         Contaminant transport pathways illustrated in a cross-sectional
                         schematic. Here, upward hydraulic pressures drive brine and
                         contaminant-rich waters to overlying freshwater aquifers along
                         fractures, faults, and failed cement sheaths in gas wells. Where
                         caves are present, the environmental risk to groundwater and cave-
                         dwelling species is not justifiable. As illustrated, sloppy wellhead
                         practices also pose a contaminant threat to groundwater resources.

The January 10, 2012 HydroQuest report concludes that gas drilling in karst terrains should be
banned. This report also addresses that the existing cement and steel well bore sealant material
used to protect and isolate freshwater aquifers lacks suitable durability to protect them in the
long-term. Beyond this, as discussed in the January 10, 2012 report, it is highly unlikely that
casing strings can be safely grouted through conduits. Even if this were possible, this January
17, 2012 report provides evidence that the area is seismically active. Thus, earthquakes would
almost certainly result in cracking of well bore cement sheaths and loss of sealant integrity. This
is further discussed below.

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The seismic/earthquake risk to the integrity of well sealant materials used to isolate freshwater
aquifers is great. The increased groundwater and environmental risk in karst terrains is far
greater than in non-carbonate terrains. This is well-documented in a January 10, 2012
HydroQuest report provided to NYSDEC as a public comment on the revised draft SGEIS on
proposed gas drilling regulations in New York State (pages 14-15, plus figures). The text of this
report may be reviewed at: http://hydroquest.com/Laughlin/ and all the supporting figures may
be viewed at: http://hydroquest.com/Schoharie/. The material on both these web pages, as well
as additional supportive information available at: http://hydroquest.com/Hydrofracking/, are
herewith fully incorporated by reference as part of this report. Naturally-occurring earthquakes
will almost certainly disrupt and degrade the cement sheath materials used in gas wells to protect
freshwater aquifers.

Gas production wells should not be placed within seismically active regions where ground
shaking/motion will damage the integrity of cement seals. The SGEIS draft gas drilling
regulations do not adequately address seismic risk either naturally occurring or resulting from
hydrofracking activities, nor do they identify New York State areas prone to higher seismic
activity and measures to prevent earthquake damage potentially associated with hydraulic
fracturing. The HydroQuest April 9, 2011 DRBC Comment Report (pages 41 to 46, Figures 8 to
15) details the great seismic risk and likely resultant damage to cement sheaths. Repeated
hydraulic fracturing may activate pre-existing faults or induce shifting or settlement along
lubricated fractures, as is recently indicated with underground injection of gas drilling
wastewater in Youngstown, Ohio and elsewhere.

Much of New York State is seismically active, including the Chittenango area. Excessive
lubrication of faults and fractures with highly pressurized hydraulic fracturing fluids, bolstered
by repeated hydrofracturing episodes, may result in fault activation and bedrock settlement.
This, in turn, may result in shearing of production well boreholes and casing strings even in the
absence of natural seismic activity. While assessment is warranted to establish acceptable
threshold values, appropriate maximum values for Richter magnitude and modified Mercalli
shaking-vibration intensity may be on the order of 3.0 (III) or less for both. Philadelphia, PA, for
example, recently experienced structural damage to buildings from an earthquake some 200
miles to the SW. Clearly, if the related earthquake intensity of 4.7 could damage buildings, it
was also likely to result in damage to the integrity of cement sheaths, especially with repeated
seismic events through time. Seismic hazard risk must be evaluated over the duration of the life
of aquifers – 1,000,000 plus years. Just as it would not be prudent to promulgate gas drilling
regulations without thoroughly evaluating long-term seismic risk, it would not be prudent permit
gas drilling within Chittenango – Perryville karst plateau area carbonate formations.

A series of four earthquake probability figures are presented below which show the statistical
probability of earthquakes with a magnitude of greater than 5.0 occurring within 50 kilometers of
Chittenango, New York. HydroQuest assessed the probability of earthquakes in the area using
Chittenango as a focal point. Modeling of earthquake probability was conducted using the
USGS 2009 Earthquake Probability Mapping model and related data available from the USGS
Geologic Hazards Science Center. A series of model runs were conducted to assess and
graphically display earthquake probabilities that were computed from the source model of the
2008 USGS-National Seismic Hazard Mapping Project (NSHMP) update for Chittenango, NY

HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 11 of 11
(43.05º N, -75.87º W). The four generated maps show the probability of earthquakes with
magnitudes of > 5.0 within a radius of 50 km for 500, 1000, 5,000, and 10,000-year events. The
USGS web-based model runs determined earthquake probability percents for these events to be:

                 Time Interval (yrs)               > 5.0

                   500                              4-6
                  1000                             10-12
                  5000                             40-50
                 10000                             60-80

These very real and high earthquake probabilities stem from USGS web-based model runs
conducted by HydroQuest. The probabilities for each of these events are based on known,
recorded, earthquakes. Clearly, earthquake probability and the great risk to the integrity of
cement sheaths and casing materials used to protect the integrity of freshwater aquifers must both
be addressed in a newly revised NYSDEC SGEIS and in the Perryville karst plateau should
consideration ever be given to permitting gas production in the area.

Based on the Chittenango seismic analysis presented here, it can be stated that the probability
that seismic shaking will result in cracking of cement sheaths and then massive upward release
of contaminants is great. To intentionally risk permanently jeopardizing the purity of our
freshwater aquifers by permitting gas well installations in seismically active portions of New
York State (e.g., Chittenango) would be irresponsible.

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HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 14 of 14
Conclusions and Recommendations

The substantial risk of groundwater and surface water contamination via the site’s karst aquifers
has not been characterized via the SEQRA process. Public and environmental health require
assessment of the potential for groundwater transport of contaminants through and from the site.
We recommend that a Draft Environmental Impact Statement be required that addresses the
site’s karst hydrology. Hydrogeologic field work should be conducted by an experienced well-
published karst hydrologist, with subsequent public review and comment.

Should mining be determined to be a legal activity on the Oot property, we strongly recommend
that a full environmental assessment be conducted, complete with scoping and DEIS preparation.
Since the hydrologic and air quality issues raised in this report are significant and substantive, a
full EIS is warranted to ensure the protection of public health and the environment.

To protect groundwater resources, the potential risks to aquifer systems must be fully considered
when evaluating proposed quarry operations – especially in an established residential area. The
need for careful planning and water quality protection programs is particularly important when
developing in hydrologically sensitive areas like those above karst terrains, where groundwater
flow is rapid and contaminant remediation is generally impossible. For these reasons, recharge
zones for karst aquifer systems must be identified and actively protected by quarry owners and
town/community planning organizations. In general, considerations for development in karst
regions should be based upon three factors: (1) identification and hydrogeologic characterization
of regional karst aquifers (including monitoring via ASTM D 5717-95), (2) assessment of the
vulnerability of karst aquifer systems to pollutants, and (3) the design and implementation of
programs to protect underlying karst aquifers. In the specific case of assessing potential adverse
impacts associated with quarrying, potential impacts associated with the partial removal of the
aquifer recharge zone overlying the underlying aquifer must be evaluated.

The presence of karst features discussed above provides solid evidence of karst geology and
hydrology on and surrounding the Oot property. Additional field work is required, and a
thorough karst inventory should be conducted throughout the Oot parcel and nearby lands. This
is an initial step required to characterize the site’s hydrology. Based on information presented
here, it is apparent that the Oot parcel hosts karst or carbonate aquifers and, as such,
environmental concerns should be addressed.

Mining removal of part or all of the aquifer recharge area may substantially degrade the
groundwater flow regime and the quantity of groundwater currently available to area residents
(e.g., Laughlin). In addition, mining related bedrock particulates may become entrained in site
groundwater, may flow off-site, and may potentially degrade both groundwater and surface water

Airborne fugitive dust poses a health risk to area residents. In addition, quarry operations in a
residential zoned area may decrease property values and retard the natural community growth
contemplated by existing zoning law.

HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 15 of 15
Gas production below the Perryville karst plateau, should it ever be contemplated, would not be


●       Place a moratorium on any pending Perryville karst plateau quarry/mining
        approvals or zoning advancement until the site’s geology and hydrology have been
        fully characterized by professional karst hydrogeologists with extensive karst
        experience. HydroQuest has provided a technical presentation to the Town in
        support of this. Karst experience, at a minimum, should require a record of published
        karst-specific papers;

●       Require completion of a Draft Environmental Impact Statement with complete
        public review and comment should Town mining permit approval be contemplated.
        NYSDEC should have required this. The Oot quarry site should be visited and
        characterized by an experienced karst hydrologist;

●       Hydrologic characterization should include on-site and off-site spring locations,
        groundwater tracer testing with a discussion of site and area karst features, a
        comprehensive karst inventory with survey of karst features, and discussion of bedrock
        lithology, and structural and hydrologic controls on groundwater flow.3 Clearly, bedrock
        mining and potential contaminant influx to an important groundwater flow and aquifer
        system should not be permitted with no knowledge whatsoever as to where contaminants
        might go or what they might contaminate;

●       A DEIS, complete with GIS reference maps, should provide an assessment of
        contaminant risks (e.g., particulates, hydrocarbons, road salt) to groundwater, wells,
        wetlands, springs, and other potential on-site and off-site receptors;

●       Once the site’s geology and hydrology have been adequately characterized, the applicant
        should evaluate the quarry design and propose potential mitigation measures or alternate
        site uses that will provide protection of groundwater and surface water quality;

●       The DEIS should include a series of groundwater flow direction maps depicting flow
        throughout all areas of the site, with emphasis on off-site contaminant receptors;

●       The DEIS should include a comprehensive analysis of all the scoping issues to be
        identified in the early stages of SEQRA; and

●       Gas drilling should be banned along and within carbonate formations in and beyond the

         The American Society for Testing and Materials (ASTM) Standard guide for the design of ground-water
        monitoring systems in karst and fractured-rock aquifers (1995) was developed with funding from the EPA
        in response to the need for a method to characterize karst aquifer systems and their groundwater flow paths.
        A standard engineering tracer investigation should be conducted [ASTM D 5717-95] designed to determine
        groundwater flow directions, destinations, and velocities within the karst groundwater basin.

HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 16 of 16
        Town boundaries.

If you would like to discuss the issues raised in this letter, please contact me directly. Thank you.


                                                           Paul A. Rubin

References Cited:

ASTM (American Society for Testing and Materials), 1995, Standard guide for design of
    ground-water monitoring systems in karst and fractured-rock aquifers, ASTM Standard
    Guide D5717-95, Annual Book of ASTM Standards, v. 04.09, Soil and Rock (II), p. 435-

Ewers, R.O., Duda, A.J., Estes, E.K., Idstein, P.J., & Johnson, K.M., 1992, The transmission of
       Light hydrocarbon contaminants in limestone (karst) aquifers. Proceedings,
       Hydrogeology, Ecology, Monitoring, and Management of Ground Water in Karst
       Terranes Conference, National Ground Water Association, Dublin, Ohio, p. 287-306.

Palmer, A.N., 2007, Cave Geology. Published by Cave Books – the publications affiliate
       of the Cave Research Foundation, 454 p.

Palmer, A.N. and Rubin, P.A., 2007, Karst of the Silurian-Devonian Carbonates in
       Eastern New York State, with emphasis on the Cobleskill Plateau. Guidebook for the
       Hudson-Mohawk Professional Geologists’ Association Spring 2007 Field Trip,
       “Carbonate Geology of the Howes Cave Area, Schoharie County, New York”, p. 17-35,
       Trip coleader with Arthur Palmer (April 28, 2007).

Quinlan, J.F., & Ray, J.A., 1992, Ground-water remediation may be achievable in some
       karst aquifers that are contaminated, but it ranges from unlikely to impossible in most: I.
       Implications of long-term tracer tests for universal failure in goal attainment by scientists,
       consultants, and regulators. Proceedings, Hydrogeology, Ecology, Monitoring, and
       Management of Ground Water in Karst Terranes Conference. National Ground Water
       Association, Dublin, Ohio, p. 553-558.

Recker, S.A., 1992, Petroleum hydrocarbon remediation of the subcutaneous zone of a
       karst aquifer, Lexington, Kentucky, Proceedings, Hydrogeology, Ecology, Monitoring,
       and Management of Ground Water in Karst Terranes Conference, National Ground Water
       Association, Dublin, Ohio, p. 447-474.

HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 17 of 17

Figure 1: Color GIS map of Perryville, NY proposed Oot quarry area
Figure 2: Color GIS map of Perryville, NY proposed Oot quarry area – close-up
Figure 3: Karren topography
Figure 4: Bedrock geology
Figure 5: Sinkhole, springs and stream
Figure 6: Wind chart for unnamed asthmatic Quarry Town, USA
Figure 7: Eastern U.S. karst map

cc:     Sullivan's Citizens Alliance
        PO Box 425
        Chittenango, New York 13037

HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 18 of 18
Addendum: Paul A. Rubin

HydroQuest karst background and experience include (see resume for additional detail):

●       Karst field training and course work with recognized karst experts including Dr. Arthur N.
        Palmer, Dr. Stephen J. Egemeier, Dr. Peter Smart, and others;

●       Thirty years of extensive caving and karst investigation experience with recognition by the
        National Speleological Society (made a Fellow of the NSS in recognition of karst research and
        water resource protection);

●       Collaboration and publications with world recognized karst experts including Arthur N. Palmer,
        Margaret Palmer, and James Quinlan, including four lengthy technical karst guidebook papers;

●       Substantial personal research from 1973 to the present on the characterization, groundwater flow
        dynamics, and geomorphic history of assorted karst terrains in New York, Maine, Tennessee, and

●       Over 30 karst publications and conference presentations, including professional geologic
        guidebook papers and peer-reviewed papers (some papers addressed land-use planning in karst

●       Service as an expert witness in court relative to karst issues;

●       Leader or co-leader of professional karst geologic field trips for professional geologists at a New
        York State, national, and international level, including the NYS Geological Association,
        American Association of Petroleum Geologists; assorted colleges; New York State Geological
        Survey geologists including the New York State geologist; the Hudson-Mohawk Professional
        Geologists’ Association, the National Ground Water Association, the National Speleological
        Society, and the International Association of Geochemists and Cosmochemists;

●       Karst hydrologist for Howe Caverns from 2004 to 2007, plus previous karst consulting work with
        Howe Caverns;

●       Developed and documented a conceptual model of karstic groundwater flow at Oak Ridge
        National Laboratory to assess contaminated groundwater flow where the first atomic bomb was

●       Numerous consulting jobs focused heavily on environmental karst issues, land-use protection,
        and water supply in New York State and Missouri;

●       Authorship of numerous unpublished karst reports, GIS maps, and affidavits; and

●       On-going personal karst research in the Rosendale Binnewater Lakes area with emphasis on the
        hydrogeology associated with a disappearing lake, speleogenesis in a complex structural setting,
        and geomorphic interpretation.

HydroQuest RE: Perryville Plateau - Karst Hydrology & Gas Drilling Concerns 01/17/12 p. 19 of 19

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