Professor Tullis Onstott provides his formal evaluation to FERC

Prof. Tullis C. Onstott of the Department of Geosciences at Princeton University has been mentioned here and in people’s submissions before. He objects to the pipeline route due to the concentrations of arsenic in Hunterdon county and the amount of it that will be released into our drinking water and waterways if this pipeline is built.

Impact of Pipeline on Drinking Water
Although no specifics have been given as to the depth of the pipeline, the 3‐foot diameter pipeline will require a depth of cover of at least 3 feet below the surface, and, more likely 4 feet below the surface where the pipeline crosses many farmlands in Hunterdon County (as specified by the USDOT regulations at 49CFR192). This means the pipeline trench will need to by 7.5 feet deep and because most of the soil in Hunterdon County is less than 32 to 64 inches10, the bedrock will have to be excavated. This means that the trench construction, which will in some cases require blasting, will fracture, shatter, excavate, deposit at the surface in spoil piles and rebury arsenic‐rich shale exposing it to aerobic conditions. Horizontal Directional Drilling beneath the streams and creeks will crush the bedrock into fine‐grained sand and silt size particles and release arsenic into the drilling mud pits.

The professor goes onto to explain what this means in layman’s terms using an analogy.

To give you a better idea of the consequences of this construction phase imagine you are holding one kilogram piece of Lockatong argillite that has 100 ppm of arsenic. One kilogram is about the size of my fist. If you break it up and leach all of the arsenic from that rock and put it into a 1 liter bottle of Fiji water, the arsenic concentration of the water will be ~250 ppm. The MCL is 5 ppb, so I would have to dilute the water in that bottle with an additional 50,000 liters of Fiji water. In reality the Hunterdon County ground water is not Fiji water and already has elevated arsenic, but I’ll give PennEast a break and say that we would only need to dilute the water in that bottle with ~100,000 liters of Hunterdon County’s best well water. That is only about ~25,000 gallons of well water, which is not that much. If I poured 100,000 liters of water on to the surface of a farm in Hunterdon County, it would fill a 1,000,000 liter volume of the surficial aquifer, reasonably assuming a ~10% porosity. This is equivalent to 1,000 cubic meters. Given that the surficial aquifer is only ~1 meter deep in Hunterdon County, this corresponds to ~30 meter square patch (or ~100 feet by 100 feet) of farmland, which is really not much of an impacted area. The 100‐ foot length is about the width of the temporary ROW for the pipeline, if I understand this correctly. But how many kilograms of Lockatong argillite will be excavated, broken up, exposed to air and reburied into the trench within that ROW? How much of the Lockatong argillite around the trench will be fractured by the blasting? I will give PennEast a break here and just say that the trench is only 2 meters deep by 1 meter wide (it will certainly be larger than this), and I will assume that there is no arsenic in the upper 1 meter. This means that a ~30 meter long pipeline trench will expose ~75,000 kilograms of Lockatong argillite or about 75 metric tons. This is not a lot of rock (about three dump truck loads), but if it contains 100 ppm of arsenic, then it would have to be diluted with 75,000,000,000 liters of Hunterdon County groundwater in order for the arsenic concentration to be reduced below 5 ppb. That is a large volume of water. Another way of thinking about it is to assume that all of the arsenic was released from the 75 metric tons of Lockatong argillite into the 30 by 30 meters of 1‐meter deep surficial aquifer. The arsenic concentration would then be ~180 ppm, but I’ll give PennEast a break and say it is just 100 ppm to make the math easier. So to dilute it down to 5 ppb, you would need a 20,000x dilution factor for 100,000 liters of ground water. To visualize this volume, it would represent a 30‐meter wide strip of land extending perpendicular to the pipeline on both sides for a distance of 300 kilometers (it is just 2×10,000×30 meters), or 216 miles! The average diffusive groundwater velocities in this region are ~1 foot a day, so it would take ~2,500 years give or take a thousand, to dilute the arsenic plume by normal groundwater recharge.

Of course not all of the Lockatong and Passaic formation shale is 100 ppm and not all of the arsenic will be released during the excavation and blasting, but you can easily see that even if a mere fraction of the arsenic is released, that it will have a severe impact on the arsenic concentrations of the privately owned wells down gradient from the pipeline for more than the 30 year operational lifetime of the pipeline. We do know the range of arsenic concentrations in these two formations, but we do not know specifically what the arsenic concentration is of the bedrock along the proposed PennEast Pipeline route. We also do not know what form that arsenic is in within the bedrock along the proposed pipeline route, whether it is soluble arsenic or arsenopyrite or some other arsenic phase. But neither does PennEast know. This needs to be determined for the Environmental Impact Statement.

He goes onto explain the many, many threats there are to the pipeline’s integrity and the many, many ways arsenic can be released not just by the pipeline construction but also by its ongoing operations. I urge you to read his report in full.

The report also has a number of startling pictures to demonstrate what he’s talking about. This image shows the arsenic concentrations and the pipeline route. Sadly the route goes right through the highest arsenic concentrations in the state of NJ.

It shows the route crossing the Ramapo Fault System:

It goes right through water recharge zones – the zones are colored in blue:

The report goes on and on about the risks this pipeline poses to our health and environment, and provides a litany of things PennEast will have to do to even provide a basic measure of safety throughout the pipeline’s lifetime.

Please, go read his report below at one of these two sites:

Professor Onstott’s Statements – FERC Generated PDF

Professor Onstott’s Statements – FERC Generated PDF Alternate Site

Arsenic in our water

Debra and John from Stockton, NJ made a FERC submission today that included comments from a Prof. Tullis Onstott, from the Department of Geosciences at Princeton University. He goes into detail explaining the unique geological makeup of Hunterdon County, and how constructing a pipeline through it is a really, really bad idea for residents. He states:

My second concern, however, is far more significant. The proposed route through Hunterdon County cut right through the Triassic shales of the Passaic and Lockatong Formations. It has been long established that these formations, particularly the Lockaton argillite belt that runs through Hunterdon, are the sources of arsenic in the groundwater in this region. Several New Jersey Geological Survey reports document the high arsenic levels in the wells in Hunterdon and Mercer counties. This belt of rocks form an arsenic hot spot. The groundwater supply is known to be vulnerable in these counties, but Hunterdon county is uniquely vulnerable because the farms and rural homes all rely upon well water. They have no access to the public water utilities of their much more populated neighbors. The privately-owned wells are the source of drinking water for
the families and for their livestock. These wells tap a surficial,unconfined, fractured rock aquifer in the Lockatong, Passiac and Stockton formations. The proposed PennEast pipeline cuts right through the arsenic hot spot where it can do the most damage to the drinking water supplies of the inhabitant. The soil cover is thin, so in order to bury the 36″ diameter pipeline they have to trench or drill through the bedrock.

This excavation will aerate the rock formation and expose the arsenic-bearing pyrite to oxidation which will released the arsenic as arsenate into the groundwater. This will occur on every ridge of ever drainage divide the pipeline will cross and I am told that the proposed route crosses 87 drainage divides. These same drainage divides are the recharge zones for the groundwater used by the farmer and rural residences. This, however, is not the worst aspect of the pipeline. Once the pipeline is buried, its components and any methane that leaks from the pipeline provides

The pipeline will continue to do this throughout it operational lifetime and, if left in the ground, after its lifetime. In summary the construction phase will generate arsenic and the operational phase will mobilize arsenic. By running the pipeline through the arsenic hotspot of New Jersey, PennEast will create an arsenic pipeline that emanates into the drinking water supply along its route and there is precious little that PennEast can do about it as long as it cuts across the strike of the Triassic basin units from northwest to southeast.

Finally, I have been told that PennEast will be tunneling underneath the water drainages. In Hunterdon county these drainages all run along fracture line faults into the Delaware River. That means during the construction phase the drilling contaminants will enter the water shed. During the operational phase arsenic concentrations will likely increase in the water sheds as well. But since PennEast does not have to comply to any kind of wetland restrictions, I am not sure that they could be held accountable to this form of pollution. That is tragic, but as I said earlier, my principle concern is about the drinking water supply in this rural part of New Jersey, the arsenic hot zone.

So. A highly poisonous form of arsenic will be in everyone’s well water. And will be in run off going through our propreties. And the pipeline is going over lots and lots of ridges so the impact will be tremendous in Hunterdon county.

And on top of that it will be running into the Delaware during construction, a major source of drinking water for the whole area.

Please visit the link below to read the rest of Debra and John’s submission. It contains a fascinating description of their property (their very old home was insulated with Horse hair!) and a not-so-flattering depiction of PennEast representatives pressuring them to sign their rights away before they force the issue with eminent domain.

John and Debra of Stockton – FERC Generated PDF

John and Debra of Stockton – FERC Generated PDF Alternate Site