NYS has three active injection disposal wells. I have requested a FOIL this spring (2012) on injectate and permitting of these wells, including the required labs and required reports for the last two years. The labs and FOILed documents are available - I will forward them electronically to anyone who is interested. (350 pp). Post script, I have Foiled 2012 and 2013 injected volumes and info also on there it for one of the wells. Write offline for info. Msmenapace@gmail.com) The documents I received include a cover letter with an outline of contents, labs of potential injectate required at permitting for all three wells, and any required labs for 2010 and 2011 on all three wells. Each well is different in mandated reporting.

Other three wells deal with brine storage I believe that they have to do with formation waters removed for gas storage v. 'brine' produced during gas development i.e. fracking. Brine a slippery term.

Maps attached, with groundwater data, depth and natural hydrological features, courtesy of Karen Edelstein, http://www.FrackTracker.org.

Notable - Two of the wells are required to test nearby residential water wells, the third not. The two that are required to test those wells run different tests. The third - Ranous/Lenape- is exempt from intermittent scans of injectate and monitoring of groundwater wells due to studies done many decades ago which indicate the wells into the strata there are less likely to have contaminates that are a concern...background on that, including documents, Are available upon request. The well is 640' deep. The wells in Ohio and TX are 4000+ ft deep generally. The Diver/Gypsum well pierces a primary aquifer. The Quill/Minard well is less than a mile from Cayuga Lake. Many injection disposal wells in Ohio were sandstone wells tapped out and re-permitted for injection. Two of the wells here were drilled for disposal - Lenape /Ranous and Gypsum/ Diver. The Quill/Minard well was drilled and produced gas for a dozen years, then re-permitted as injection well. Summary Info on each well - Using Name/Owner Diver 1A,/Gypsum well near Batavia - Queenston sandstone, 1088 ft deep. Owner US Gypsum Co. drilled and permitted for disposal in 1985, . US Gypsum owns 491 gas wells some plugged and abandoned most are active. They have not injected anything in 2010 or 2011 per the EPA records. I only requested records on the permits and 2010 and 2011.

Oversight - required to submit a Priority Pollutant Scan of potential injectate at permitting - was not from a certified lab but rather looks to be a student project. Lab results looked at sodium Calcium, magnesium, iron, aluminum, potassium, manganese, barium strontium, silica, chloride, bromide, sulfate, Sr/Ca, del D and del O-18 Is not required to run periodic priority pollutant scans. Do have to do quarterly reports, but no injection 2010 and 2011 so i have no quantities etc.

Two nearby residential water wells are monitored quarterly for pH, chloride, conductivity and specific gravity. I was sent summaries of

years 2005 thru 2011 of these results so I don't know if they were from a certified lab.

Quill 762-1/Minard well - 3/4 mile from the head of Cayuga Lake near Montezuma Wildlife Refuge- map - Queenston sandstone 1800 ft. depth drilled in 1985, produced gas until 1994. Then changed hands and permitted for disposal in 1995. Owner formerly Chesapeake, now Minard Run Oil from PA minardrunoil.com Minard now owns four hundred wells in NY acquired in March 2012 from CHK. Have fifteen thousand Marcellus leasehold acres in Bradford PA. Required to submit annual Priority Pollutant Scans, certified lab. video I shot of the site here - video here - Quill injection disposal well Cayuga county NY Three nearby residential water monitored quarterly nearby, tested for chlorides and specific conductance only, certified lab. Monthly reports include injection pressure,rate, annular pressure, volume injected, temperature, pH, chlorides, specific gravity and specific conductance. Volumes injected in 2011, yearly cumulative reported volume injected was 87,197 gallons. In 2010, 25,294 gallons reported. Ranous 1/Lenape well - approx 5 miles from Leroy near Rochester, drilled and permitted for disposal in 1985. 640' (six hundred forty) feet deep. Owned by Lenape resources, John Holko president. Lenape owns over 300 oil and gas wells. Lenape submitted a certified lab sample of potential injectate on permitting. Lenape is not required to submit priority pollutant scans nor is there required nearby ground water monitoring wells though there are homes nearby. Cumulative annual injectate volumes reported- 2010 - 114,980 gallons. 2011 - 78,100 gallons. Lenape's monthly monitoring report includes injection pressure and rate,annular pressure, volume, temp., pH and specific conductance, chlorides, specific gravity and TDS. Does not appear to be certified lab but I may just have been sent summaries. I received some background and history on this very shallow well. Write and I will send. There are studies, done many decades ago, theorizing that the produced water from wells in this area is less likely to be toxic, hence the exemptions from priority pollutant scans annually. In acover letter from Douglas McKenna, Water compliance Branch EPA office in NYC. "Per their respective permits, Chesapeake (now Minard, mine) is required to run annual priority pollutant scans. US Gypsum was required to run a priority pollutant scan prior to initiating injection but is not required to run periodic scans. Lenape is no required to run a priority pollutant scan." ALL the various labs run on all the injectate going down these wells are labs in Pennsylvannia. More- all three wells are authorized to inject only brines produced from specific formations and only from wells owned/ and or operated by the permitee. But then in next pp "In each case, the injection well may be receiving small quantities of formation fluids from hundreds of

different gas production wells each month. EPA does not require submittal of this information." This despite the EPA's 1992 Guidance letter on oversight, up front acknowledging the potential for illegal dumping of toxic waste down these wells i.e. Automotive and farm waste. They recommend i.e. chains, fences, locks, attendants, manifests, spot grab samples and spot surprise visits. The Quill well near Cauyga lake that I visited sits out in the middle of a field all alone, tanks near the road, no fence, gate nor anyone around. Maybe the wells have locking mechanisms and the nearby tanks as well, but no security apparent and all reports on monthly injecting seem to be self reported. Regarding public hearing process on these wells - not mandated. From correspondence with Frank Brock in the NYC EPA office. (He was quite helpful.) > >> - concerning new injection well permits, EPA does not post receipt of >> applications right away. Per 40 Code of Federal Regulations Part 124, >> once EPA makes a draft permit decision, a public notice is then issued on >> our website at http://www.epa.gov/region02/public_notices/index.html. This >> is after EPA has received a permit application and, usually after one or >> more back and forths with the applicant, determines the application to be >> administratively and technically complete and completes the technical >> review of the materials. The application review is 2-phased, kinda like >> assembling a jigsaw puzzle-the administrative review is making sure all >> the pieces are there. The technical review is like assembling the puzzle >> - the tech review determines if all the required info has been provided >> and meets all permitting regulatory requirements. Then EPA makes the >> draft decision to either issue a draft permit or to issue a draft permit >> application denial. In either case, that draft decision is public >> noticed. Where EPA believes there may be significant public interest, we >> may also issue a press release that will usually be published in the local >> newspapers to further ensure people in the area are aware of the draft >> permit and public notice. If there is significant public interest >> displayed during the public notice period, EPA may schedule a public >> hearing in the area to accept public comments. If a hearing is to be >> held, that is also public noticed. FOIA info for these wells - EPA - again from Frank Brock sending an e-mail FOIA is easy-just go to >> http://www.epa.gov/region02/foia/submit.htm and then click "On-Line FOIA >> Form" under Option 1 and fill out the request form. Background info from EPA and DEC: EPA has primacy over NY Class IID Injection disposal wells- not DEC - NY one of ten states that did not request primacy for oversight. http://water.epa.gov/type/groundwater/uic/Primacy.cfm Info on Class II wells - EPA http://water.epa.gov/type/groundwater/uic/class2/index.cfm

Guidance Letter for monitoring Class IID wells - EPA - http://www.epa.gov/ogwdw/uic/pdfs/guidance/guide-memo_guidance-77_op_mon_rept_guid_class2d_1992.pdf BIG discrepancy in recommendations and reality of oversight in NY , see end of this email. DEC database link on Injection Wells - NY has three injection wells for waste from O&G production - - Class IID wells - http://www.dec.ny.gov/energy/29856.html The first three wells are Class IID for injection of 'brine' from O & G production. Mary Menapace Skaneateles 315 727-9405 Msmenapace@gmail.com August 2012 June 2014