Ohio PIRG Education Fund Policy Paper

DIRTY DRILLING:The Threat of Oil and Gas Drilling in Lake Erie

Written by Bryan M. Clark

Edited by Brad Heavner, Rose Garr, Margaux Shields, and Amy Simpson

January 2002

ACKNOWLEDGMENTS

Ohio PIRG extends our thanks to the George Gund Foundation, whose funding made the

researching and writing of this report possible. Additional thanks are due to the staff of

Ohio PIRG and the Frontier Group for their time and assistance.

Ohio Public Interest Research Group Education Fund

2460 Fairmount Blvd. 36 West Gay Street

Suite C Suite 315

Cleveland Heights, OH 44106 Columbus, OH 43215

216-791-1116 614-460-8732

www.ohiopirg.org

Ohio PIRG Education Fund is a statewide, non-profit, non-partisan organization working

on consumer, environmental, and democracy issues.

TABLE OF CONTENTS

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

AN INTRODUCTION TO OHIO’S GREATEST NATURAL RESOURCE . . . . . . . . . . . 8

OIL AND GAS DRILLING TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

THE CANADIAN DRILLING EXPERIENCE: A WARNING FOR OHIO . . . . . . . . . . 13

ECONOMIC IMPACTS OF DRILLING IN OHIO’S LAKE ERIE . . . . . . . . . . . . . . . . 19

ENVIRONMENTAL RISKS OF DRILLING IN OHIO’S LAKE ERIE . . . . . . . . . . 23

HUMAN HEALTH IMPACTS OF DRILLING IN OHIO’S LAKE ERIE . . . . . . . . . . . 29

REGULATION OF OIL AND GAS DRILLING IN THE UNITED STATES . . . . . . . . . 34

A BETTER OPTION: CLEAN ENERGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

CONCLUSION AND RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

APPENDIX ONE – DRILLING FLUID CHEMICALS . . . . . . . . . . . . . . . . . . . . . . . . . . 41

APPENDIX TWO – PETROLEUM SPILLS IN THE CANADIAN GREAT LAKES –

1990 TO 1995 (BY VOLUME) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

APPENDIX THREE – PETROLEUM SPILLS IN THE CANADIAN GREAT LAKES –

1990 TO 1995 (BY YEAR) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

APPENDIX FOUR – TOXIC CHEMICALS IN THE NATURAL GAS CYCLE . . . . . . . 45

NOTES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

DIRTY DRILLING 5

EXECUTIVE SUMMARY

With recent attempts to open Lake

Erie to oil and gas drilling in

Ohio, the Lake Erie area faces

significant new threats to its economy, envi-

ronment, and health. Both offshore and on-

shore oil and gas drilling in Lake Erie pose

unacceptable risks and hazards. This report

investigates the Canadian drilling experience

in that country’s portion of Lake Erie, as well

as the economic, environmental, and human

health threats associated with Lake Erie drill-

ing in Ohio.

Canadian Drilling

in Lake Erie

Drilling for natural gas and oil on the Cana-

dian side of Lake Erie has been neither safe

nor clean. This report finds the following:

• Fifty-one natural gas spills directly asso-

ciated with gas drilling in Canada’s por-

tion of Lake Erie were documented

between 1997 and 2001 – an average of

almost a spill a month.

• The Canadian side of Lake Erie con-

fronted eighty-three petroleum spills from

all sectors between 1990 and 1995 (the

last year for which data was made avail-

able for this report).

• Only 45% of the spill’s contaminants were

cleaned up, on average.

• Direct discharges of drilling wastes into

Lake Erie have subjected aquatic organ-

isms to immediate and long-term health

effects risks, ranging from localized fish

kills to aquatic organism developmental

impairment.

• Environmental risks are exacerbated by

the routine use of toxic chemicals during

oil and gas drilling.

• Canadian regulations that track the use and

disposal of toxic chemicals (the National

Pollutant Release Inventory) expressly ex-

clude oil and gas drilling operations from

reporting.

• There is no publicly available data regard-

ing the quantity or extent of toxic chemi-

cal release from the natural gas drilling

operations in Canada’s portion of Lake

Erie.

• The lack of available data restricts re-

search into the safety of the drilling and

hampers oversight of that industry.

Economic Impacts

of Drilling in

Ohio’s Lake Erie

Oil and gas drilling could have widespread

net negative effects on the economy of the

Lake Erie region in particular and the state

of Ohio in general. This report finds the fol-

lowing:

• The annual value of oil and gas drilling is

equal to only about three weeks of tour-

ism revenue. Drilling costs to Ohio’s $1.5

billion dollar per year tourism industry far

outweigh potential revenues from oil and

gas.

• The cost of each beach closing has been

estimated to be $3.75 million dollars dur-

ing the tourism season.

• Oil and gas drilling is a short-term job

creator that is frequently undertaken by

national companies that use non-Ohio la-

borers. As such, lost local and state rev-

enue from tourism money would not be

recouped from oil and gas drilling activi-

ties.

• The peak tourism season and the oil and

gas drilling season overlap, leading to an

increased likelihood that drilling accidents

and routine operations would have a nega-

tive effect on Lake Erie tourism.

• Beach users clearly indicate that the qual-

ity of Lake Erie waters is a significant

determinant of future visits to the lake. Oil

and gas drilling could lower water qual-

ity, both through routine operations and

accidental leaks and spills.

DIRTY DRILLING6

• Every $100 invested in charter boating

multiplies into an additional $162 dollars

for other area businesses. Each lost dol-

lar of charter boating revenue actually re-

moves $2.62 from the local economy.

Environmental

Impacts of Drilling in

Ohio’s Lake Erie

Despite industry claims to the contrary, oil

and gas drilling is still a dirty, dangerous

business. At every stage of the drilling pro-

cess the environment around the drilling site

is bombarded by toxic chemicals and threat-

ened by accidental leaks and spills. This re-

port finds the following:

• Natural gas and oil leaks and spills can

have extremely negative effects on the

natural environment, both on and off

shore. Past safety records from drilling

sites across the country indicate that such

accidents will take place – it is a matter of

when it will happen, not if it will happen.

• The potential for accidental or intentional

release of drilling wastes into the envi-

ronment is alarming. Releases can occur

though containment failure, run-off, pipe-

line accidents, and direct discharge.

• Routine drilling wastes, such as drilling

muds, cuttings, and produced waters, con-

tain both profuse and varied toxic chemi-

cals. These risks to wildlife include

developmental defects, shortened lifespan,

and numerous cancers.

• Many of the toxic chemicals associated

with oil and gas drilling can accumulate

and magnify in the food chain. This poses

a risk to aquatic organisms higher in the

food chain, such as fish and birds.

• Many of the chemicals associated with oil

and gas drilling tend to persist in the en-

vironment, leading to long-term, chronic

exposure for aquatic and terrestrial organ-

isms.

• Destruction of wildlife habitat also repre-

sents a serious threat from oil and gas drill-

ing. The land area that would be impacted

to accommodate the 2,000 wells neces-

sary to achieve peak production would be

greater than 3,000 football fields.

• The act of drilling could destroy or sig-

nificantly alter the vital natural habit nec-

essary for animals as diverse as the bald

eagle, the great blue heron and endangered

snakes.

Human Health

Impacts of Drilling

in Ohio’s Lake Erie

Oil and gas drilling in Ohio’s Lake Erie

would take place in one of the most densely

populated portions of the state. In fact, coun-

ties surrounding the Great Lakes shoreline

have the highest average population per mile

(3,835) for a major coastal area in the United

States. This report finds the following:

• Routine drilling wastes, such as drilling

muds and cuttings, contain a host of toxic

chemicals that are known to be hazard-

ous to human health.

• As pollutants from oil and gas drilling

build up in the food chain, people who

consume fish from Lake Erie will be at

serious risk of health problems such as

genetic defects and cancer.

• Routine discharges and accidental spills

of toxic chemicals from drilling sites can

also contaminate the water of Lake Erie,

thus contaminating a primary drinking

water source for millions of Ohioans.

• Some oil and gas drilling discharges, such

as air emissions and run off, are an un-

avoidable consequence of oil and gas drill-

ing. Discharge need not occur in the water

to impact the lake’s water quality.

• While the human health impacts of leaks

and spills are primarily local in nature,

placement of wells on shore puts human

DIRTY DRILLING 7

health at greater risks from accidents, as

well as from routine pollution and dis-

charges.

• Accumulation of toxic chemicals in local

and regional Lake Erie ecosystems repre-

sents one primary threat to human health.

Regulatory Oversight

of Drilling in Ohio

The Mineral Resources Management divi-

sion of the Ohio Department of Natural Re-

sources oversees oil and gas drilling in Ohio.

This report finds the following:

• At present, ODNR lacks the staffing and

mandate to implement a Lake Erie drill-

ing program.

• As Ohio continues to slash agency bud-

gets as a result of continued declines in

expected state revenues, ODNR staffing

and oversight problems will increase.

• Even with an adequately staffed oil and

gas drilling division, current regulations

that govern oil and gas drilling would fail

to protect human health and the environ-

ment in and around Lake Erie.

• Well development and placement regula-

tions in Ohio do not provide adequate

environmental or public health protec-

tions.

• While current regulations governing the

final disposal of drilling wastes and pro-

duced waters do not allow disposal in a

freshwater body, enforcement and over-

sight is insufficient to provide assurance

that these practices would not take place

in or around Lake Erie.

Policy

Recommendations

Based on the findings of this report, oil and

gas drilling in or under Lake Erie would pose

unacceptably high environmental, economic,

and public health risks. Many of these risks

are inherent to the oil and gas drilling pro-

cess and, as such, are unlikely to be miti-

gated by regulatory changes or management

practices. This report recommends the fol-

lowing:

• Ohio should permanently protect Lake

Erie from oil and gas drilling in or under

the lake.

• The Federal government should also per-

manently protect all of the Great Lakes

from oil and gas drilling in or under the

lakes.

Rather than relying on dirty drilling to meet

Ohio’s energy demands, the state should in-

vest in a cleaner, smarter energy future by

promoting energy efficiency and renewable

energy. By investing in energy efficiency

and renewable energy, Ohio can permanently

protect Lake Erie, further protect our other

environmental resources, and save Ohioans

money. This can be undertaken with the fol-

lowing:

• Tax rebates and incentives for the pur-

chase of energy efficiency appliances.

• Updated energy efficiency requirement in

Ohio’s building codes.

• Tax rebates and incentives for the instal-

lation of small-scale renewable energy

generation equipment.

• A Renewable Portfolio Standard that re-

quires 10% of the electricity sold in Ohio

come from renewable sources by 2010 and

20% by 2020.

DIRTY DRILLING8

Lake Erie is arguably Ohio’s greatest

natural resource. It is the 12th-largest

lake in the world (by area) and, to-

gether with the other Great Lakes, holds 25%

of the world’s available fresh water. The land

area that drains into Lake Erie covers 22,720

square mile (58,800 square kilometers).

Lake Erie borders four states (NY, PA, OH,

MI) and one Canadian Province (Ontario).

Counties surrounding the Great Lakes shore-

line have the highest average population per

mile (3,835) for a major coastal area in the

United States.

For years, Ohioans have recognized the

unique challenges associated with Lake Erie

protection and restoration. Ohio’s leaders

have determined that the following guiding

principle must be among the state’s highest

priorities for Lake Erie restoration and pro-

tection: “Restore the physical habitat and

chemical water quality of the watershed to

protect and restore diverse and thriving plant

and animal communities and preserve our

rare and endangered species.” Events such

as fires on the Cuyahoga River in 1952 and

1969 once exemplified the level of pollution

in and around Lake Erie. Since the mid-

1960s, Lake Erie restoration efforts have

transformed the lake from a biologically

“dead” industrial wasteland into a cleaner,

more productive ecosystem suitable for rec-

reation and tourism.

Despite these enormous restoration efforts,

Lake Erie is still in transition into a healthy,

stable ecosystem.1

Areas along the near

shore of Lake Erie cannot support healthy

biological communities. An assessment of

21 such areas yielded no areas as “excellent,”

two as “good,” 14 as “fair” and five as

“poor.”2

The legacy of toxic chemical pol-

lution, such as mercury, lead, radioactive ma-

terials, and pesticides, has also taken a toll

on sport fish in Lake Erie. In 2001, the Ohio

Department of Health issued “Do Not Eat”

or “Meal Advisory” warnings for all sport

fish caught in Lake Erie.3

These advisories

are especially relevant for at risk groups, in-

cluding infants and young children, young

women, and the elderly. As these examples

demonstrate, Lake Erie restoration still faces

challenges, while the gains of the past four

decades still need protection.

AN INTRODUCTION TO OHIO’S

GREATEST NATURAL RESOURCE

DIRTY DRILLING 9

Ohioans Support

Lake Erie Protection

For over 16 years, Ohioans have enjoyed

the benefits of a non-binding moratorium on

offshore oil and gas drilling in the Great

Lakes. While this agreement has no legal

force or standing, it has guided subsequent

natural resources policy in the state. Signed

by the Great Lakes governors (Michigan,

Wisconsin, Pennsylvania, Minnesota, Indi-

ana, Ohio, Illinois, and New York) the “State-

ment of Principle Against Oil Drilling in the

Great Lakes” stated, in part, that “this pre-

cious resource [the Great Lakes] should not

be vulnerable to oil drilling and its attendant

dangers . . . [T]his action will protect our

shared resource from an unwise risk.”4

Ev-

ery Ohio governor, both Republican and

Democrat, has echoed this stance since 1984.

US Senator and former Governor George

Voinovich has stated, “I am dismayed that

the issue [drilling in Lake Erie] would be

discussed.”5

Governor Bob Taft has also in-

dicated his support for legislation to ban drill-

ing in Lake Erie.6

While this moratorium on oil and gas drill-

ing has provided a long-standing tradition

of Lake Erie protection, Ohio has never

passed a ban on drilling. Current law could

allow oil and gas drilling if the director of

the Ohio Department of Natural Resources

obtains the approval of the director of the

Ohio Environmental Protection Agency, the

attorney general, and the governor.7

As a

result, drilling can take place at the discre-

tion of Ohio’s executive branch, affording

the lake no consistent or long-term protec-

tion from oil and gas drilling.

Ohioans are very concerned about the

health and safety of the environment. A poll

conducted in 2000 indicates that Ohioans are

highly concerned about clean water and air,

both of which rank as one of voters’ top con-

cerns.8

Clean air and water ranked higher

than taxes or the economy, indicating the

high value Ohioans place on the environ-

ment.

Ohio voters have shown a willingness to

pay for a cleaner, more productive environ-

ment. In November 2000, voters over-

whelmingly approved a bond initiative, the

Clean Ohio Fund (State Issue 1), which ear-

marks $400 million in bonds for open space

preservation and contaminated site clean up.

Despite the significant cost of the program

during a time of a declining state economy,

over 57% of Ohioans who voted, voted in

favor of the measure. This, together with

the poll data, indicates Ohio’s citizens are

strongly committed to a clean, productive

environment.

Ohioans are not alone in their commitment

to a clean environment and a healthy

economy. A recent national poll,9

which in-

cluded voters in Ohio, demonstrates that

Americans strongly support increased pro-

tection of our environment in general and our

precious natural treasures in particular.

Americans indicated their opposition to oil

or gas drilling in the Great Lakes by an al-

most two to one margin. In the same poll,

Americans also indicated their belief that

stronger environmental laws are necessary

for a healthy, productive economy.10

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DIRTY DRILLING10

Lake Erie Drilling:

Political Opportunism

at its Worst

Despite intense public opposition against

drilling in the fifties and sixties, the issue of

drilling under Lake Erie came to the fore-

front again after the unusually high natural

gas prices experienced during the 2000-01

home heating season. That price spike came

about due to a unique confluence of four fac-

tors: a lull in the natural gas market due to

recent warm winters; restricted cash flow for

natural gas producers due to low prices from

January 1998 to March 1999; unusually high

and unpredictable oil prices in 2000; and a

very cold winter in 2000-01.11

This clearly

indicates a temporary price spike, rather than

a long-term trend in natural gas prices, as

can be seen in the rapid decrease in prices

during the second half of 2001.

In response to the 2000-01 natural gas price

spike, energy companies and the Bush

administration’s National Energy Policy laid

a course towards greater reliance on new

drilling for oil and natural gas. Energy com-

panies, oil and gas lobbyists, and state and

federal legislators discussed the limited re-

serves under Lake Erie while considering

potential resources. Despite the fact that

Lake Erie drilling would not lower costs or

significantly increase supplies, oil and gas

interests became increasingly vocal in their

desire to depart with Ohio’s longstanding

tradition of Lake Erie protection and allow

drilling in Lake Erie. During testimony be-

fore the Ohio House of Representatives Pub-

lic Utilities Committee, Tom Stewart, the

executive director of the Ohio Oil and Gas

Association, stated that Ohio should re-

evaluate the current drilling moratorium.

Oil and gas interests’ desire to drill has not

been deterred by significantly lower natural

gas prices and increasing natural gas re-

serves. As a result, Lake Erie will never be

safe from oil and gas drilling until a perma-

nent drilling ban is passed at the state and

federal levels.

According to estimates in March 2001 by the Ohio De-

partment of Natural Resources, total reserves under Lake

Erie could equal about 20 billion cubic feet per year and

would take 10 to 15 years to reach peak production. That

amount is only about 8 days of natural gas per year at

Ohio’s current usage rates. Given the long lag-time be-

fore peak production could take place and the tiny amount

of natural gas available, Lake Erie drilling would do noth-

ing to help lower the gas prices seen in 2000-01.

How Much Natural Gas is Under

Ohio’s Portion of Lake Erie?

Ohioans use over 1.1 trillion cubic feet of

natural gas per year

Lake Erie could only provide 8 days worth

of natural gas per year - in 10 to 15 years

DIRTY DRILLING 11

The oil and gas industry relies on a va-

riety of tools and methods for the ex-

ploration, production, and transmis-

sion of oil and gas. Two broad categories of

drilling – offshore and directional – would

potentially impact Lake Erie, given the lo-

cation of the resources under the bed of the

lake. While both processes produce roughly

the same types of drilling wastes, other im-

pacts are quite different.

Offshore drilling is a process that uses a

rig, or large drilling platform, to drill from

the surface of a water body into underground

oil or gas reserves. Offshore drilling places

the wellhead, or top of the well, on the bot-

tom of a water body. This places the well-

head in contact with the water. Directional

drilling, on the other hand, uses land-based

drilling equipment to drill from an onshore

well under a water body. This process places

the wellhead on land within the watershed

of, or area that drains into, the water body.

Offshore Oil

and Gas Drilling

Offshore oil and gas drilling begins after the

discovery of potential oil or gas reserves

through the use of seismic testing or other

surveys. A mobile drilling platform is moved

into place and an exploratory well is drilled

into the area of potential resource reserves.

This exploratory well is used to determine

the location and accessibility of potential

reserves. During the drilling process, sup-

port vessels ferry to and from the drilling rig,

delivering pipe, chemicals, fuel, drilling flu-

ids, and other materials.

In all cases, impacts to bottomlands may

occur in the area of an offshore natural gas

well operation because the drilling takes

place in the water and takes up to 9 months

to complete. This danger arises because the

drilling takes place in the water and on the

bottom of the lake, so any negative impact

will take place directly in the water. Not only

does the actual drilling of the well require

up to nine months of operation, the explor-

atory and production drilling are only one of

many potential impacts to the bottomlands.

After completion, the wellhead must be con-

nected to pipelines that transport the natural

resources from the well to processing, stor-

age, and transportation facilities.

Directional Oil

and Gas Drilling

Also referred to as slant or horizontal drill-

ing, directional drilling begins onshore as a

traditional vertical well. The well is then

angled under a formation such as a lakebed,

allowing access to oil and gas held in deep

geologic formations. Because the wellhead

is located on land and the drilling apparatus

does not need to be in the water, this drilling

method does offer some environmental ad-

vantages over offshore drilling. As a result,

directional drilling is increasingly prevalent

in environmentally sensitive areas,13

but still

poses unacceptable levels of risk.

Water Quality Impacts

from Oil and Gas Drilling

Placing the wellhead onshore does not re-

move the threat of water contamination. Soil

and water contamination at onshore wells

OIL AND GAS DRILLING TECHNOLOGIES

Aerial overview of a typical directional drilling site. 12

DIRTY DRILLING12

within the Lake Erie watershed will lead to

contamination of the lake itself. Directional

drilling still carries with it the same blowout

risks as conventional drilling techniques, but

places that risk closer to densely populated

areas. Directional drilling sites frequently

use up to two acres for the drilling rig, well,

and support infrastructure.14

As a result, di-

rectional drilling causes significant soil ero-

sion, soil loss, and sediment contamination

of surface waters during the preparation and

development of the drilling site.

Land Use Impacts

from Oil and Gas Drilling

ODNR has estimated that peak production

from Lake Erie would require up to 2,000

natural gas wells.15

The average onshore di-

rectional well can impact up to 2 acres of

land. If all 2,000 sites reach the average on-

shore drilling impact size of two acres, the

total land affected would be over 6.25 square

miles – or an area larger than 3,000 football

fields. This wasteful land use would be un-

avoidable; would take place in a densely

populated portion of the state; and would

impact the Lake Erie shoreline, which is a

web of fragile wetlands, beaches, and other

lakefront ecosystems.

Air Quality Impacts

From Oil and Gas Drilling

Directional drilling and offshore drilling

techniques also require extensive use of gas

or oil powered drilling equipment on the

lakeshore area. In fact, the potential for air

quality degradation is higher for directional

drilling than for conventional drilling activi-

ties.16

Air quality impacts result from drill-

ing machinery, injection and production

pumps, and processing machinery. Fugitive

emissions (dust and other small particles)

from the wellhead and support infrastructure

could occur. Directional drilling along Lake

Erie would have a significant impact on lo-

cal air quality during the drilling process.

Quality of Life Impacts

from Oil and Gas Drilling

Because directional drilling sites can be very

close to populated areas, noise pollution is

also an area of concern. The pumps, drills,

generators, and support apparatuses of direc-

tional drilling all produce an unpleasant level

of noise pollution.17

The aesthetic effects of

placing directional or offshore drilling sites

in close proximity of populated areas could

also be expected to lower quality of life.

DIRTY DRILLING 13

The proponents of drilling have stated,

on innumerable occasions, that Ohio

can safely drill in Lake Erie because

the Canadians have done so with no prob-

lems for years. This claim has gone unchal-

lenged by the press largely due to the

difficulty of obtaining evidence about Ca-

nadian drilling in the lake. But, research into

the Canadian Lake Erie drilling experience

clearly shows that this has not been the case.

This report collects, for the first time, the

damning record of Canadian oil and gas sec-

tor accidents and spills in and along Lake

Erie.

While oil and gas drilling in the U.S. Great

Lakes has recently resurfaced as a signifi-

cant threat, Canadians have been actively

drilling for oil and gas in their portion of the

Great Lakes since the 1920s. Currently, drill-

ing takes place both on and offshore on the

Canadian side of Lake Erie. Talisman En-

ergy has a monopoly on offshore drilling on

the Canadian side of Lake Erie, all of which

is for natural gas. There are over 550 active

wells and 1,000 miles of pipeline under the

Canadian side of Lake Erie.

As decision-makers and the public con-

sider the pros and cons of drilling, the sub-

ject of Canadian drilling experience is

especially relevant for consideration of drill-

ing on the American side of the Great Lakes.

To provide this information, report authors

utilized Freedom of Information requests

from the Ontario Spills Action Centre, Sarnia

MCTS Centre, Ontario Ministry of Natural

Resources, and Environment Canada. The

authors also interviewed personnel at those

ministries.

Summary of Findings

• Between 1997 and 2001, there were 51

documented natural gas leaks directly as-

sociated with gas drilling operations in

Canada’s portion of Lake Erie. Lake Erie

was also impacted by 83 petroleum spills

between 1990 and 1995 (the last year for

which data was made available for this

report). In those spills, only 45% of the

contaminants were cleaned up, on aver-

age.

THE CANADIAN DRILLING EXPERIENCE:

A WARNING FOR OHIO

Offshore oil and gas drilling rig in Lake Erie.

DIRTY DRILLING14

• The routine, long-term discharge of drill-

ing waste in Canada’s portion of Lake Erie

represents a significant environmental

hazard. These direct discharges into Lake

Erie have subjected aquatic organisms to

immediate and long-term health effects

risks, ranging from localized fish kills to

damage to developing wildlife. These

risks are exacerbated by the routine us-

age of toxic chemicals during oil and gas

drilling.

• Across Canada, including the Great Lakes

area, the 26,976 petroleum sector spills

accounted for 45% of reported spills from

every sector in any given year.

• The Ontario Ministry of Natural Re-

sources, which is charged with regulatory

oversight of oil and gas drilling, has failed

to include regulated environmental con-

siderations in its permitting. The Minis-

try was severely criticized for its failure

to implement the Ontario Environmental

Bill of Rights, effectively thwarting citi-

zen access to and involvement in environ-

mental decision-making.

• The Canadian National Pollutant Release

Inventory (NPRI), which tracks the use

and disposal of toxic chemicals in Canada,

expressly excludes oil and gas drilling

operations from its reporting require-

ments. There is no publicly available in-

formation about the toxic chemicals

routinely used and discharged from

Canada’s drilling in Lake Erie.

• There is a lack of data about the cumula-

tive negative impacts of the Canadian oil

and gas drilling operations in the Great

Lakes. Neither Canadian nor American

governmental agencies have investigated

the impacts of existing drilling operations

over the past 20 years. Despite this lack

of readily accessible data, information

about the number and impact of petroleum

spills was pieced together from the Cana-

dian Coast Guard, the Ontario Ministry

of Natural Resources, and the Ontario

Ministry of Environment.

As these findings indicate, the Canadian

drilling experience has not proved to be en-

vironmentally benign, as claimed by oil and

gas industry interests. In point of fact, drill-

ing in Canada’s portion of Lake Erie has been

an accident-ridden and understudied source

of pollution.

Drilling in Canada –

Inadequate Enforcement

and Regulations

Under the Environmental Bill of Rights

(1993), Canadians in the Ontario province

obtained wide-ranging access to and inter-

vention in ministry actions that may have

environmental impacts. As a result, citizens

of Ontario can exercise oversight of poten-

tially harmful environmental actions. Part

of that requires all ministries to classify and

rank their “instruments”, which include the

Canadian equivalent of American permits to

allow actions such as petroleum operations,

according to potential environmental impact.

But according to a special report from the

Environmental Commissioner of Ontario, the

Ministry of Natural Resources failed to com-

ply with the instrument reclassification re-

quirement of the Environmental Bill of

Rights. This failure is both long-standing

and systemic in nature according to the Com-

missioner. In fact, the Commissioner con-

cluded that, “I no longer have confidence that

the ministry will carry out its legal obliga-

tion of its own accord.”18

This has far-reaching implications for the

permitting of oil and gas operations in and

under Lake Erie. As a result of the Ministry

of Natural Resource’s failure to comply with

the Environmental Bill of Rights, the

ministry’s instruments are still not subject to

public comment, review and appeal rights as

granted under the Environmental Bill of

Rights. Therefore, permits for oil and gas

drilling have little or no public comment and

oversight.

One intention of the Environmental Bill

of Rights was the provision of a tiered sys-

DIRTY DRILLING 15

tem through which Ontario’s citizens could

judge the potential environmental impacts of

oil and gas drilling. Because the Ministry of

Natural Resources has not provided that tier,

the public has no standard by which to gauge

the serious environmental impacts associated

with the M)inistry’s oil and gas drilling in-

struments. In addition, the classification of

an instrument determines the level of in-

volvement the public can expect to exercise

under the act, with greater oversight granted

for proposals that could have greater envi-

ronmental impacts.

The Ministry of Natural Resources’ lack

of a full, open permitting extends to the per-

mitting of oil and gas drilling in Lake Erie.

As a result of the Ministry’s inaction, the

public cannot access vital information con-

cerning the environmental impacts of drill-

ing. Consequently, the public cannot

intervene in the permitting of drilling or seek

to change or amend drilling instruments.

Toxic Chemicals and

Canadian Drilling

The National Pol-

lutant Release In-

ventory, the

Canadian equiva-

lent of the US Toxic

Release Inventory,

is the only compre-

hensive data source

for total toxic re-

leases into the air,

water, or soil of

Canada. However,

oil and gas well

drilling activities

are expressly ex-

cluded from NPRI

reporting require-

ments.19

As a result,

oil and gas drilling

operations in or un-

der the Canadian

portion of Lake Erie

are not required to submit any information

regarding the routine release of drilling re-

lated chemicals. This means that there is no

publicly available database for the levels of

chemicals used and discharged by drilling

companies in Lake Erie. The public and its

governments simply do not know the types,

kinds, quantities, or final fate of chemicals

routinely used by drilling operations in

Canada’s portion of Lake Erie

Natural Gas Drilling

Accidents in Canada

Lake Erie drilling proponents and the media

have regularly reported that drilling in

Canada’s Lake Erie has been “safe” and

largely problem free. The data about spills

and leaks shows that oil and gas operations

in the Great Lakes have not been environ-

mentally benign or clean. With an astound-

ing 83 reported petroleum spills during a

5-year period and 51 drilling-related natural

gas spills in the last five years, the petroleum

industry in Lake Erie has produced wide-

NOTSHIP NOTSHIP

SUBJECT DATE NUMBER SUBJECT DATE NUMBER

Gas Well Leak 23-Apr-97 C 585 Gas Leak Reported 24-Jan-00 C 75

Gas Well Leak 2-May-97 C 783 Gas Well Leak 13-Mar-00 C 204

Gas Well Leak 18-May-97 C 1081 Natural Gas Leak 13-Apr-00 C 380

Gas Well Leak 24-May-97 C 1157 Gas Well Leak 13-Apr-00 C 495

Gas Well Leak 26-May-97 C 1179 Natural Gas Leak 24-May-00 C 1034

Gas Well Leak 28-May-97 C 1204 Plugging Operation 12-Aug-00 C 2242

Gas Well Leak 3-Jun-97 C 1279 Natural Gas Leak 26-Aug-00 C 2350

Gas Well Leak 27-Jun-97 C 1698 Gas Leak 31-Oct-00 C 2931

Gas Well Leak 27-Jun-97 C 1687 Gas Leak 31-Oct-00 C 2932

Gas Well Leak 3-Aug-97 C 2201 Gas Well Leak 14-Dec-00 C 3366

Gas Well Leak 1-Sep-97 C 2593 Gas Well Leak 26-Mar-01 C 181

Gas Well Leak 1-Sep-97 C 2594 Gas Well Leak 28-Mar-01 C 223

Gas Well Leak 5-Jan-98 C 12 Gas Well Leak 11-May-01 C 815

Gas Well Leak 22-Apr-98 C 596 Gas Well Leak 14-May-01 C 838

Gas Well Leak 9-Jun-98 C 1269 Gas Well Leak 16-May-01 C 871

Gas Well Leak 18-Jul-98 C 1804 Gas Well Leak 24-Jun-01 C 1386

Gas Well Leak 2-Aug-98 C 2030 Gas Well Leak 13-Jul-01 C 1644

Gas Well Leak 21-Aug-98 C 2433 Gas Well Leak 13-Jul-01 C 1648

Gas Well Leak 11-Oct-98 C 2791 Gas Well Leak 25-Jul-01 C 1813

Gas Well Leak 29-Oct-98 C 2990 Gas Well Leak 11-Aug-01 C 2083

Gas Well Leak 5-Nov-98 C 3052 Gas Well Leak 15-Aug-01 C 2084

Gas Well Leak 26-Jun-99 C 1606 Gas Well Leak 10-Sep-01 C 2393

Gas Well Leak 15-Aug-99 C 2280 Gas Well Leak 11-Sep-01 C 2402

Gas Well Leak 22-Aug-99 C 2380 Gas Well Leak 24-Oct-01 C 2708

Gas Well Leak 20-Sep-99 C 2658 Gas Well Leak 26-Oct-01 C 2727

Gas Well Leak 20-Jan-00 C 1415

DIRTY DRILLING16

spread pollution through direct spills alone.

Furthermore, the reported environmental

clean up and impact levels reveal oil and gas

operations to be a source of unacceptable

pollution.

The information about the number and fre-

quency of petroleum spills in and around

Canada’s portion of Lake Erie is startling.

According to the Canadian Coast Guard,20

over 51 drilling-related natural gas spills and

leaks were reported in Canada’s portion of

Lake Erie between April 1997 and October

2001. This is an average of almost a spill

per month for five years.

A review of Canadian spills information

from 1988 to 1995 provides further cause for

alarm. As can been seen in Appendices Two

and Three, there were 83 documented petro-

leum spills in Lake Erie between 1990 and

1995. The total volume discharged was not

known for 39% of the spills, due to causes

as diverse as the source of the spill and lack

of real-time monitoring of the spill. For the

remaining spills the total volume discharged

was up to 5,000 liters of petroleum products.

To place this in perspective, one liter (roughly

1 quart) of crude oil can contaminate up to 2

million gallons of drinking water and pro-

duce an oil slick up to 2 acres in size.21

Across Canada, including the Great Lakes

area, petroleum sector spills22

account for

45% of reported spills from every sector in

any given year. This sector includes explo-

ration, production, transportation, storage,

and usage of petroleum products, including

crude oil and natural gas. The source or cause

for these spills were primarily pipeline leaks,

overflow, and unknown causes. Reasons for

petroleum sector spills range from corrosion,

equipment failure, and human error. The

majority of crude oil spills occur at the stage

where the crude is still mixed with brines –

i.e., during the exploration and production

phase of drilling. This data clearly indicates

that drilling is routinely dirty and environ-

mentally dangerous.

Spills in the production field are the most

frequent sources of pollution for four of the

top five reasons for spills: equipment fail-

ure, corrosion, material failure, human er-

ror, and storm or flood. Corrosion remains

the most significant danger related to these

spills. Pipeline spills (45%) and spills oc-

curring in the production field [which in-

cludes both mines and wells] (42%) together

account for 87% of the spills resulting from

corrosion.23

Companies and Canadian government of-

ficials have had a difficult time cleaning up

these spills. Between 1993 and 1995, only

45% of spills were fully cleaned up, while

35% were not cleaned up at all – a dismal

record. The impact of spills on the environ-

ment was also significant. Over 40% of spills

report associated property damage; over 35%

report vegetation damage; and almost 5% re-

port a fish kill.

Drilling Fluids and

Produced Waters in

Canadian Drilling

Produced waters are saline fluids that can

appear in conjunction with natural gas and

oil drilling. In Ontario, regulations prohibit

the discharge of highly saline waters directly

into any fresh water body.24

However, off-

shore drilling operations in Lake Erie utilize

lake water as the base for drilling fluids. If

the drilling operations do not encounter

brine, or salt water, during the course of well

production, regulations allow the drilling flu-

ids to be directly discharged into Lake Erie.

Petroleum Sector -- Spills by Reason

Damage by equipment

2%

Corrosion24% Equipment failure

24%

Material failure3%

Other13%

Unknown14%

Human error18%

Gasket joint2%

DIRTY DRILLING 17

These fluids can contain a whole array of

chemical additives used to lubricate the drill

bit and assure well hole stability (see Ap-

pendix One), many of which pose risks to

fish and other organisms.

On a local and regional level, spawning

fish in Lake Erie are already under consid-

erable stress and drilling has increased that

stress. For example, a sudden change in

simple physical factors such as water tem-

perature, water oxygen level, or water pH

can cause an immediate effect, such as death,

or a delayed effect, such as secondary infec-

tions or shortened lifespan.25

The continu-

ous discharge of drilling fluids and waters

can also create immediate changes in water

chemistry, such as increased pH or tempera-

ture. Additionally, they can decrease the dis-

solved oxygen levels in the lake by

contributing to nutrient loading. Nutrient

loading is the introduction of very high lev-

els of elements, such as phosphorus, which

increase the growth of algae and aquatic

plants. As these plants grow and decompose,

they remove oxygen from the water and en-

danger aquatic organisms.

Drilling Muds

and Cuttings in

Canadian Drilling

Drilling muds are the toxic semi-solid

waste produced by drilling. Drilling cuttings

are the bits of rock, soil, and debris removed

from the well hole. Together, drilling muds

and cuttings pose an extreme risk to Lake

Erie habitat. Canadian drilling operations

utilize a closed-loop drilling system, which

is designed to contain drilling muds during

the drilling process. The drilling cuttings are

separated from the muds and continuously

discharged directly to the bottom of Lake

Erie.26

A single Canadian well may produce

as much as 6000 cubic meters of cuttings and

mud discharge.27

These discharges can en-

danger an environment up to 300 meters from

the point of release. This practice poses ex-

traordinary environmental risks for bottom-

dwelling organisms. Burial of bottom-

dwelling organisms often takes place over a

long distance from the site of the drilling rig,

depending on the strength of underwater cur-

rents at the time of discharge. This burial

causes the death of aquatic species in the af-

fected area.

Because drilling muds and cuttings con-

tain a variety of toxic chemicals, direct dis-

charge of these materials into Lake Erie is of

concern. Evidence shows that the quantity

of fish on the Canadian side of Lake Erie is

noticeably smaller than their American coun-

terparts. One potential cause is the presence

of large-scale, long-term drilling operations.

No coordinated environmental assessment of

drilling effects on the aquatic environment

has been undertaken in Canada. Lack of

comprehensive data makes it difficult to

know for certain what role drilling wastes

have played. However, evidence from other

drilling sites discussed in this report indicate

that habitat disruption, immediate toxic ef-

fects, long-term toxic effects, and decreased

wildlife number and diversity are all linked

to the routine, continuous discharge of drill-

ing muds and cuttings.

Contaminated Sediments

in Canada’s Lake Erie

Offshore natural gas drilling in Lake Erie

directly disturbs the sediments of Lake Erie

because it places the wellhead and pipelines

at the bottom of the lake. There are 15 to 30

new drilling sites in Canada’s portion of Lake

Erie each year. These sites disrupt the lake’s

bottomlands for up to 9 months during the

drilling and production processes. While it

is difficult to quantify contaminated sediment

disturbance, disruption of contaminated sedi-

ments during offshore gas drilling and pro-

duction processes, as well as pipeline

development, is unavoidable.

These sediments are highly contaminated

with toxic chemicals and organisms. One

such organism, Clostridium botulinum or

DIRTY DRILLING18

Type E Botulism, is abundant in the bottom

sediments of Canadian lakes, including Lake

Erie.28

This organism was responsible for

massive fish and bird kills in the lake during

2000. While the reason for the kills has not

been positively identified, offshore drilling

can disturb the contaminated sediments and

provide a greater opportunity for the organ-

ism to gain entrance to a large segment of

the food chain. Again, it cannot be stated

that offshore drilling was the reason for the

wildlife deaths in 2000, but long-term drill-

ing cannot be ruled out as a potential reason.

Of even greater concern is the disturbance

of sediments contaminated with polychlori-

nated biphenyls (PCBs), chlorinated pesti-

cides, and heavy metals. Lake Erie bottom

sediments are extremely contaminated by

these criteria pollutants. PCBs are suspected

human carcinogens. PCBs and chlorinated

pesticides can accumulate and magnify in the

food chain. Their negative human health

impacts range from developmental disorders,

nervous system damage, and, in high con-

centrations, death. Finally, the environmen-

tal and health effects of heavy metals such

as lead and mercury are far-reaching. For

example, lead is a known developmental

toxin and has been associated with brain and

nervous system damage.

Pipeline Development

and Safety in Canada

After over 80 years of continuous oil and gas

drilling, the Canadian portion of Lake Erie

has become a dense web of underwater pipe-

lines. Over 1,000 miles of pipeline have been

laid on the bottomlands of Lake Erie in

Canada. This is enough pipeline to cross the

length of Ohio’s Lake Erie shore almost 4

times. These pipelines transfer natural gas

from, the 550 active wells in Lake Erie to

processing, storage, and distribution stations

on land.

Pipe leaks are the most common source of

spills in the seven sectors, representing 22%

of total causes.29

Of these leaks, over 65%

were a result of the petroleum sector, which

includes drilling, production, transportation,

and delivery of petroleum products. Given

the vast length of pipeline under Lake Erie,

this dubious safety record indicates that Lake

Erie drilling infrastructure unreliability poses

a risk to the lake’s environment.

Corrosion is the primary and ultimately

unavoidable cause of pipeline leaks. Corro-

sion of exposed pipelines under the lake can-

not be avoided because of the nature of

pipeline material, which will always be sus-

ceptible to the elements. For example, the

most common cause of pipeline corrosion in

Lake Erie is abrasion by gravel and sand at

the bottom of the lake. Wave movement in

the lake causes the abrasion of pipelines.

Stress corrosion cracking, tiny cracks that

develop on pipelines as a result of environ-

mental conditions, has been the subject of

Canadian governmental and private sector in-

vestigations since 1977. This type of corro-

sion is very difficult to detect, but can create

significant environmental and public health

hazards. For example, a 4-inch crack in a

Canadian-U.S. pipeline resulted in the release

of 222,000 gallons of crude oil and an unde-

termined amount of natural gas. The result-

ing natural gas leak caused the evacuation

of 400 Michigan residents.30

As this example

indicates, the environmental and public

health impacts of pipeline leaks are quite

extensive.

DIRTY DRILLING 19

While oil and gas drilling is fre-

quently viewed in terms of envi-

ronmental or public health im-

pacts, the economic impact of Lake Erie drill-

ing is also important. The environmental and

public health dangers associated with on-

shore oil and gas drilling is an impediment

to other, non-industrial Lake Erie uses. The

tourism and recreation opportunities in Lake

Erie are simply incompatible with oil and gas

drilling. The economy of the lake cannot

rely on recreational fishing, boating, or other

leisure activities and for oil and gas drilling

simultaneously. As such, oil and gas drill-

ing is an either/or issue – either Ohio pro-

tects the lake from oil and gas drilling or

existing economic uses of the lake will suf-

fer significant, long-term losses.

Summary of Findings:

• Drilling costs to Ohio’s $1.5 billion dol-

lar per year tourism industry far outweighs

potential revenues from oil and gas. The

estimated annual revenue from oil and gas

drilling is equal to about three weeks of

tourism revenue. In fact, the cost of each

beach closing has been estimated to be

$3.75 million dollars during the tourism

season.

• The potential adverse impact of oil and

gas drilling on local economies is stag-

gering. For example, every $100 invested

in charter boating multiplies into over

$162 dollars for other area businesses.

Each lost dollar of charter boating revenue

actually removes $2.62 from the local

economy.

• Oil and gas drilling is a short-term job

creator that is frequently undertaken by

national companies that use non-local la-

borers. As a consequence, lost local and

state revenue from tourism money would

not be recouped from oil and gas drilling

activities.

• Beach users clearly indicate that the qual-

ity of Lake Erie waters is a significant

determinant of future visits to the lake. Oil

and gas drilling would lower water qual-

ity, both through routine operations and

accidental leaks and spills.

Value of Lake

Erie Tourism

In Ohio, Lake Erie based tourism produces

an average of over $1.5 billion in revenue

each year.32

Lake Erie tourism produces

more revenue in three weeks than natural gas

drilling could produce in one year.33

Any new

development along the Lake Erie shoreline

will influence other uses of the lake. Pollut-

ing operations such as oil and gas drilling

would present such a conflicting and ulti-

mately incompatible lake use. By under-

standing the economic value of the current

uses of the Lake Erie ecosystem, we can be-

gin to assess the real costs associated with

new polluting industries.

Only 6.7 miles (about 3%) of Ohio’s 262

miles of Lake Erie shoreline is currently

available as publicly accessible beach and

only 15% is fully accessible to the public.34

Despite this lack of publicly accessible land,

recreational land use, such as marinas and

beaches, accounts for 23% of Ohio lakeshore

usage.35

These recreational areas are a vital

link in Ohio’s tourism industry. These rec-

reation dollars typically benefit local econo-

ECONOMIC IMPACTS OF

DRILLING IN OHIO’S LAKE ERIE

A typical summer day on Lake Erie31

DIRTY DRILLING20

mies and small business owners, while fur-

ther stimulating numerous unrelated indus-

tries in the process. The majority of tourism

revenues derive from a rather short time pe-

riod each year – roughly May through Au-

gust. This time period coincides with the oil

and gas-drilling season on Lake Erie, which

runs from April through September in

Canada. As such, adverse economic impacts

arising from oil and gas drilling would dis-

proportionately impact annual beach eco-

nomic values.

The impact of tourism along Lake Erie may

best be understood in terms of discrete local

and regional economies. According to a

beach users survey by the Ohio Sea Grant,

Lake Erie beaches are vital to the economic

vitality of local economies.36

Two beaches,

Maumee Bay State Park and Mentor Head-

lands, have an estimated annual economic

value of $87 million and $50 million respec-

tively. The study also indicates that smaller

beaches along Lake Erie could be valued,

on average, $1 million per year. These valu-

ations are based solely on the recreational

value of the area, absent any consideration

of more difficult to quantify issues such as

ecosystem valuation.

While exact figures vary according to the

beach in question, roughly 70% of annual

tourism revenues derive from the summer

season. This translates into an average daily

net, per year, of over $495,000 for a beach

like Maumee Bay State Park and over

$284,000 for an area such as Mentor Head-

lands. Pipeline leaks, toxic chemical release,

or general water quality degradation could

all lead to beach use advisories or closings.

Any beach closing due to oil or gas drilling

activities would quickly sap a local economy

of vital tourism revenues. In fact, the cost of

every tourism season Lake Erie beach advi-

sory has been estimated to equal up to $3.75

million per beach advisory each year due to

lost visitor spending.37

A second project by the Ohio Sea Grant

also considered the valuation of Lake Erie

beaches.38

While this survey represents a cal-

culation of individual motives and influ-

ences, it is important to note the striking

similarity of results across the board. As can

be seen in the following chart,39

beach visi-

tors strongly indicated water quality, shore-

line quality, and aesthetic quality as prime

factors in determining when and where to

visit along Lake Erie. Any adverse impact

upon any one factor could have a significant

impact on the recreational decisions of po-

tential Lake Erie tourists.

Put simply, drilling would adversely im-

pact Lake Erie economies even if environ-

mental and public health threats did not exist.

Americans are generally disposed to pro-en-

vironmental attitudes.40

Furthermore, the

public perceives drilling as an anti-environ-

mental enterprise. Because the value at-

tached to Lake Erie beaches is an outgrowth

of individual perceptions about the condi-

tions and qualities of a given beach, the per-

ception of the impacts of oil and gas drilling

Day Trip Day Trip Multi-day Trip Multi-day Trip

Maumee Mentor Maumee Mentor

Water quality affects my decision to go to the beach 4.14 4.25 4.17 4.38

Beach maintenance affects my decision to go to the beach 4.38 4.50 4.3 4.47

Beach cleanliness affects my decision to go to the beach 4.55 4.59 4.39 4.66

Congestion affects my decision to go to the beach 3.77 3.86 3.87 3.85

Beach facilities affects my decision to go to the beach 4.04 4.26 3.91 4.09

Lake Erie water quality affects my decision to go to the beach 3.47 3.36 4.22 3.40

Of the visitors surveyed, 47percent responded at Headlands and 54 percent responded at Maumee.

The averages reported are based on the number of survey respondents.

Scale ranged from 1 = strongly disagree to 5 = strongly agree.

DIRTY DRILLING 21

Sailboats on Lake Erie.41

may be as crucial to the vitality of local tour-

ism economies as actual environmental deg-

radation. This observation underscores the

extremely negative effects oil and gas drill-

ing would have on economies in the Lake

Erie area.

Value of Lake Erie –

Anglers, Boaters, and

Charter Boats

Not surprisingly, boating is big business for

local economies along Lake Erie. With one

of the highest number of boat owners per

capita in the nation, Ohio has a long tradi-

tion of recreational boating in Lake Erie.

One of every three Ohioans participates in

recreational boating each year. Almost 50%

of all Ohio boaters visit Lake Erie each year.

These recreational boaters are a vital link in

Ohio’s tourism industry.

Most charter boat operations are local,

small businesses with direct ties and invest-

ments in the local economy.42

As such, ev-

ery $100 invested in charter boating

multiplies into an additional $162 dollars for

other area businesses. Each lost dollar of

charter boating revenue actually removes

$2.62 from the local economy. The gross

sales of the charter boat industry in Ohio ex-

ceeded $9.2 million annually in 1990 (the

most recent year for which we have data).

Investment in boats and fishing-related

equipment almost topped $60 million in

1990.43

Though more recent data was not

available, inflation adjusted figures estimate

over $83.1 million in boating and fishing

related revenue in 2001.44

Recent concerns over Lake Erie water lev-

els serve as a useful indicator for the poten-

tial impact of oil and gas drilling on

recreational boating and fishing in the lake.

Lowered water levels,45

coupled with de-

creasing sport fish stocks,46

have adversely

impacted the recreational boating and fish-

ing industries in Lake Erie. This indicates

that environmental conditions play a central

role in determining the health of the charter

boating indus-

try. Oil and gas

drilling could

add to the

stresses experi-

enced in recent

years.

A e s t h e t i c s

and conve-

nience are also

important for

r e c r e a t i o n a l

boaters and anglers. Once again, Canada

provides a glimpse of the future of Lake Erie

if oil and gas drilling is allowed. Canadian

boaters are saddled with detailed maps of

over 1,000 miles of underwater natural gas

pipelines and 550 active wellheads on the

Canadian side of Lake Erie.47

Such maps

are provided to avoid accidental damage to

the pipelines due to anchorage, netting, or

other routine recreational and commercial

boating activities. Canadian reports48

sug-

gest that snagged nets and dropped anchors

have caused pipeline damage sufficient to

release unprocessed natural gas into the lake.

Not only do these structures pose a nuisance

to boaters, they also pose potential environ-

mental threats. Canadian boaters are also

faced with ominous radio broadcasts con-

cerning the safety of water conditions around

gas drilling and support infrastructure. Be-

tween 1997 and 2001, there were over 51

documented radio warnings issued because

of natural gas drilling alone.

According to testimony by Dr. Jeffrey M.

Reutter, director of Ohio Sea Grant, fish

stocks on the Canadian side of Lake Erie are,

on average, lower than stocks on the Ameri-

can side. While the causative agents have

not been completely identified, long-term oil

and gas drilling are considered a possible

cause.49

Additional oil and gas drilling would

pose a significant threat to future fishing ac-

tivities already endangered by decreased

fishing hauls.50

This, in turn, would have a

direct impact on the economic viability of

charter boat operators, recreational boaters,

and commercial fishing operations.

DIRTY DRILLING22

In sum, oil and gas drilling in Lake Erie

could have a significant impact on tourism,

recreational boating, and commercial fish-

ing on the lake. Risks run the gamut from

ecosystem impacts due to chronic or suble-

thal pollution levels to decreased recreational

activity due to inherently conflicting lake

uses. Given the vast revenue from recre-

ational boating and fishing in the lake, a sig-

nificant impact on local economies would

take place should these drilling risks materi-

alize.

DIRTY DRILLING 23

The Lake Erie ecosystem is a fragile

web of wetlands, beaches, aquatic en

vironments, and human develop-

ments. While the lake continues its transi-

tion from a toxic wasteland into a clean,

productive ecosystem, the negative effects

of new pollution sources are doubly impor-

tant. Despite industry claims to the contrary,

oil and gas drilling is still a dirty, dangerous

business. At every stage of the drilling pro-

cess – from exploration to production to

transportation – the environment around the

drilling site is bombarded by toxic chemi-

cals and threatened by accidental leaks and

spills. The primary environmental concerns

associated with drilling are:

• Drilling wastes, such as muds and cuttings

• Drilling fluids, such as produced waters

• Accidental leaks or spills

• Blowouts

• Intentional release

Summary of Findings

• Drilling wastes, such as drilling muds,

cuttings, and produced waters, contain

both abundant and diverse toxic chemi-

cals that pose significant risks to the en-

vironment. These risks include wildlife

developmental defects, shortened lifespan,

and physiological changes.

• The potential for accidental or routine re-

lease of drilling wastes into the environ-

ment is alarming. Releases can occur

though containment failure, run-off, and

direct discharge.

• Many of the toxic chemicals associated

with oil and gas drilling are known to ac-

cumulate and magnify in the food chain.

This poses a risk to aquatic organisms

higher in the food chain, such as fish and

birds.

• Many of the toxic chemicals used or pro-

duced during oil and gas drilling tend to

persist in the environment, leading to

long-term, chronic exposure for aquatic

and terrestrial organisms.

• Natural gas and oil leaks and spills can

have extremely negative effects on the

natural environment, both on and off

shore. Past safety records indicate that

such accidents will take place – it is a

matter of when it will happen, not if it will

happen.

Drilling Muds and

Cuttings: Unavoidable

Toxic By-products

Drilling muds are the semi-fluid mixture of

soil, water, and lubrication chemicals re-

moved from an oil or gas well. Drilling cut-

tings are the soil, rock, and other debris

“chunks” removed from an oil or gas well.

These products are toxic chemicals that can

contaminate the environment, cause environ-

ENVIRONMENTAL RISKS OF

DRILLING IN OHIO’S LAKE ERIE

A sign warns people to stay off Hunting Beach in

California after an oil spill in 1990.51

DIRTY DRILLING24

mental problems as diverse as fish and wild-

life contamination, causing developmental

abnormalities, or even death. During the

course of both directional and offshore drill-

ing, oil, water, or synthetic oil is combined

with other chemicals to form a toxic drilling

mixture that is circulated through the well

hole. These mixtures frequently contain

toxic materials such as oil and grease, sus-

pended solids, phenol, arsenic, chromium,

cadmium, lead, mercury, naturally occurring

radioactive materials, and barium.52

The

composition of drilling muds varies widely

depending on the location of the well, the

depth of the well, and the type of drilling

fluid used.53

The exact chemical composition of drill-

ing muds is generally not known to anyone

other than the oil or gas rig operator or com-

pany,54

as specific materials used may vary

according to the demands of each drilling

site. Appendix One lists the types and kinds

of chemicals routinely used in the explora-

tion and production of oil and gas wells. So

while the precise contents of drilling fluids

may differ, one thing is certain: all chemi-

cals used in drilling fluids will eventually

become drilling waste.

Three Types of Drilling Muds

Three types of drilling muds can be used in

oil and gas-drilling operations – water-based,

oil-based, and synthetic oil-based. Water

based muds are the least toxic, with toxicity

increasing from synthetic to oil based muds.55

Drilling muds enter the environment by:

• Direct discharge into a body of water

• Seepage into groundwater or other surface

water from a land-based impoundment

• Accidental release from on- or offshore

holding facilities

• Absorbtion in soils or sediments

• Vaporization of volatile components from

on- or offshore sites

Disposal and Transportation

of Drilling Muds

Type and location of drilling process deter-

mines the fate and transport of drilling muds

and cuttings. In the case of directional drill-

ing, drilling muds are frequently placed in a

holding pond or receptacle at the drilling site.

These wastes may also be disposed in a wa-

ter body like Lake Erie or a nearby stream,

or an off site disposal facility, depending

upon the chemical characteristics of the

muds.56

Drilling muds with chemical con-

centrations that exceed levels determined by

the US EPA must be disposed in a certified

hazardous waste disposal facility or injected

into a deep aquifer that cannot be used for

drinking water (a Class II injection well).

However, wastes that do not exceed those

thresholds may be disposed in a standard

landfill. Waste from offshore drilling plat-

forms is either discharged directly into the

body of water or transported to an onshore

disposal facility, depending on the toxicity

of the wastes. Again, the type of disposal

utilized depends upon the chemical charac-

teristics of the muds.

Total drilling wastes produced at a natural

gas well can be substantial. Based on infor-

mation in Estimating Externalities of Natu-

ral Gas Fuel Cycles,57

the average oil or gas

well requires 486.86 acres of land per year

for waste disposal during initial drilling and

400.02 acres per year for final drilling and

production.58

Not only does this represent a

significant amount of toxic waste, it also pre-

Drilling waste pit.

DIRTY DRILLING 25

sents a large land-based disposal problem for

Ohio.

Wildlife Impacts of Drilling

Muds and Cuttings

Environmental impacts from drilling muds

range from disruption of wildlife reproduc-

tion and accumulation of toxic materials to

wildlife habitat destruction and increased

wildlife population mortality rates. The US

EPA studies show that the routine discharge

of any drilling mud can adversely impact

bottom-dwelling species. These impacts

range from burial of species to disruption of

basic life functions, such as reproduction,

eating patterns, and life span.59

Toxic dis-

charges from drilling muds may also lead to

acute, or immediately evident, effects in

some representative marine species, such as

scallop, lobster, and a variety of fish.60

Be-

cause freshwater species are more sensitive

to these chemicals than similar saltwater or-

ganisms, the impact on Lake Erie species

would be even greater.

As the Lake Erie ecosystem transitions into

a bottom-based ecosystem,62

the impacts of

discharged drilling wastes become especially

troubling. A bottom-based ecosystem finds

the primary building blocks of the food chain

in or around the bottom of the lake, rather

than throughout the lake environment. Con-

tinual drilling mud and cuttings disposal

could negatively impact this lake in transi-

tion. For example, mayfly larvae are some-

times buried under drilling muds. This could

lead to a decrease in survival rates of these

insects. The mayfly is a primary food source

for the small fish that in turn provide food

for walleye, perch, and other larger fish. A

decrease in the size of mayfly populations

could also lower the size of fish populations

throughout the food chain.

It is important to note that Lake Erie fish

are already contaminated. As the accompa-

nying chart indicates, levels of criteria pol-

lutants such as PCBs in the Great Lakes are

still considered unsafe for wildlife. Addi-

tional pollutant loading from oil and gas drill-

ing muds and cuttings could exacerbate

existing sport fish contamination, as well as

general ecosystem contamination. Further-

more, the stressed or transitional nature of

the Lake Erie ecosystem

would intensify effects

from drilling wastes dis-

charged into the water-

shed.

Coastal land and wet-

lands could also be nega-

tively impacted by onshore

drilling mud storage and

disposal. Absent stringent

regulatory oversight and inspection, acciden-

tal release into ground or surface waters at

the drilling sites would pose a major risk to

coastal areas. In the case of oil-based drill-

ing fluids, accidental release into a coastal

marsh or wetland would have significant

impacts on fish eggs and larvae known to be

sensitive to oil and oil-based chemicals.64

Water based drilling muds have, at a low

level or greater, the following potential ef-

fects: pollution accumulation in wildlife;

magnification of pollution moving up the

food chain; contamination of the water col-

umn; damage to bottom-dwelling species;

risk of human and wildlife ingestion; occu-

pational exposure; emission of pollution into

the air through evaporation; and landfill im-

pact.65

While most pathways of risk are rated

low, the widespread usage of water based

drilling muds greatly increases the chances

of a water based mud release.

Oil based drilling muds have, at a low level

or higher, the following potential effects:

• Emission of pollution into the air through

evaporation

• Groundwater contamination

• Landfill impact

Safe for wildlife

Unsafe for wildlife

The entire Great Lakes system is rated unsafe

for wildlife due to extensive toxic pollution.63

Tumor on Great Lakes long-nose sucker61

DIRTY DRILLING26

• Threat of occupational accidents and ex-

posure66

When released into the environment, oil

based muds have been shown to inhibit the

number and diversity of bottom-dwelling

species up to 500 meters from the point of

discharge. This effect can last for several

years.67

Synthetic based drilling muds can have, at

a low level or higher, the following poten-

tial effects:

• Pollution accumulation in wildlife

• Increase in affects as pollution moves up

the food chain

• Contamination of the water column

• Damage to bottom-dwelling species

• Risk of human and wildlife ingestion

• Threat of occupational exposure

• Emission of pollution into the air through

evaporation

• Landfill impact68

As the US EPA continues to grapple with

water discharge of synthetic based drilling

muds, the potential for environmental im-

pacts may increase under future regulations.

If the agency allows water disposal of these

muds, greater environmental damage will

occur.

In summary, drilling muds and cuttings

pose a real threat to the environment, either

through accidental, intentional, or permitted

release. Because the exact composition of

different drilling muds is rarely known, the

potential risks associated with a given well

can only be estimated. What is known about

drilling muds provides ample evidence of the

real threat oil and gas drilling poses to an

ecosystem such as Lake Erie.

Produced Waters

Oil and gas drilling operations may en-

counter brines, or salt water. When this oc-

curs, it is called produced waters. These

wastewaters have high levels of dissolved

organic compounds (primarily hydrocarbons,

such as oil and propane), saline compounds,

numerous heavy metals (including lead, cad-

mium, and chromium), and radionuclides

(from naturally occurring radioactive mate-

rials).69

Like drilling muds and cuttings, the

exact composition and volume of produced

waters will vary from region to region and

from well to well.70

The US EPA has re-

ported very high toxicity in its investigation

of produced water effects on ecosystems.

Produced waters may impact the surface

water or groundwater of the Lake Erie wa-

tershed through a variety of routes. Although

produced waters are typically disposed of in

a deep aquifer (a Class II injection well),

there is still the threat of accidental release

from temporary storage. While injection

through a well into a deep aquifer (a Class II

injection well) is typically used to dispose

of produced waters,71

the threat of acciden-

tal release from temporary storage is still of

significant concern.

The following table72

provides an overview

of produced water characteristics from ar-

eas substantially similar to Ohio. The table

indicates that a broad range of toxic chemi-

cals exist in produced water from natural gas

wells and these chemicals exist in quantities

that can pose risk to the health of the envi-

ronment. The effects of these chemicals on

a given ecosystem vary based on the level of

pollution in the produced waters and the du-

ration of exposure. However, there is po-

tential for significant cumulative impacts to

Lake Erie organisms if they were to be ex-

posed to these discharges over the long term.

The high saline content of produced wa-

ters has been shown to be quite toxic to fresh-

water species used as biological monitors of

produced water’s impacts. These adverse

impacts occur regardless of the conditions

of the freshwater system.73

Under certain

conditions, the toxics in produced water may

become more bioavailable. Bioavailability

refers to the concentration of, exposure to,

and final level of a pollutant in a given spe-

cies. The toxic chemicals associated with

DIRTY DRILLING 27

produced waters remain bioavailable long

after discharges stop.74

Because wildlife ef-

fects from toxic chemicals rely on the abil-

ity of species to take up the pollutant(s), an

increase in the duration and concentration of

produced waters’ toxic components would

increase the negative effect on the Lake Erie

ecosystem.

Conditions, such as lack of oxygen at the

area of produced water discharge, can make

heavy metals more likely to become

bioavailable.75

For example, water with low

oxygen content can cause fish to “take up”

or store more mercury from produced water.

Such conditions can occur in areas where

high levels of organic nutrients, such as wa-

ter draining from lawns or farmland, lead to

a significant increase in algae growth. These

algal blooms use all the available oxygen in

the water, creating an oxygen-poor environ-

ment that can contribute to the bioavailability

of heavy metals.

Produced water discharges can have an

observable impact on the variety, number,

and amount of wildlife in and around Lake

Erie.76

Wildlife effects of heavy metals and

other toxic chemicals found in produced

water included cancer-causing effects such

as mutagenicity, or damage to genetic mate-

rial, and genotoxicity, or alteration of DNA.

Studies of long-term impacts from pro-

duced water discharge show an increase in

the abundance and diversity of species from

up to nine years after the discharge ends.

This is indicative of an ecosystem rebound-

ing from the adverse environmental effects

of produced water pollution. The data indi-

cate that the toxic chemicals frequently found

in produced waters have been absorbed into

the food chain and the pollutant’s concen-

trations and impacts increase as they move

up the ecosystem.

Because the Lake Erie ecosystem is in-

creasingly based on organisms, such as

feeder fish, and nutrients, such as phospho-

rus, on the bottom of the lake, toxic chemi-

cals such as heavy metals settling to the lake

bottom would have a great negative impact

on the lake. This is due to a sustained, long-

term, and concentrated level of exposure for

bottom-dwelling organisms. Should this

occur, the cumulative affect of heavy metals

would become much greater as one moves

up the food chain. Unfortunately, the suble-

thal or chronic impacts of produced water-

related bioaccumulation are not known for

ecosystems such as Lake Erie.

Leaks, Blowouts,

and Spills

In addition to routine pollution, drilling

sites also pose a danger of accidental leaks,

spills, and blowouts. An accidental leak or

Number of

Parameter Range Samples

pH 3.1 - 6.47 16

Specific Conductance 136,000 - 586,000 12

Pollutants (mg/L)

Alkalinity 0 - 285 13

Bromide 150 - 1149 5

Chloride 81,500 - 167,448 22

Sulfate <1.0 - 47 13

Surfactants 0.08 - 1200 13

Total dissolved solids 139,000 - 360,000 15

Total suspended solids 30895 5

Aluminum <0.50 - 83 19

Arsenic <0.005 - 1.51 5

Barium 9.65 - 1740 28

Cadmium <0.02 - 1.21 19

Calcium 9400 - 51,300 19

Copper <0.02 - 5.0 14

Iron 39.0 - 680 21

Lead <0.20 - 10.2 18

Lithium 18.6 - 235 18

Magnesium 1300 - 3900 18

Manganese 3.59 - 65 21

Nickel <0.08 - 9.2 18

Potassium 149 - 3870 16

Silver 0.047 - 7.0 4

Sodium 37,500 - 120,000 21

Zinc <0.02 - 5.0 20

Sample Characteristics

of Produced Waters

DIRTY DRILLING28

spill can occur from the rupture or contain-

ment failure from a drilling mud pit or a pipe-

line rupture. A blowout takes place when

drilling activities encounter a geologic for-

mation with abnormally high pressure, lead-

ing to the rapid discharge of the well’s

contents. The environmental threats associ-

ated with leaks and spills are the same as

those for routine discharge of drilling wastes

and produced waters. Blowouts and pipe-

line leaks, however, pose a special risk to

the environment because of the hazardous

nature of methane, the primary ingredient of

natural gas (about 85% in American natural

gas).

If a blowout occurs underwater, fish and

other aquatic organisms will come in direct

contact with a very hazardous chemical –

methane. Experience with previous natural

gas blowouts indicates the following effects

to fish: difficulty in controlling movement,

decreased muscle tone and control, organ and

tissue damage, cellular damage, and altered

cellular formation and regeneration.81

During a land-based blowout, methane will

quickly disperse in the atmosphere. How-

ever, a prolonged leak can produce both acute

(immediate) and chronic (long-term) poison-

ing of birds and other wildlife that come into

contact with the leak. Tests on the health

effects of methane exposure have produced

abnormalities of the animal’s fetal brain, in-

cluding brain hernia (extreme pressure in-

side the skull) and hydrocephalus (excessive

fluid in the brain).78

Asphyxiation, or death

due to a lack of oxygen, is also a by-product

of significant methane exposure.

Blow-out from an offshore oil drilling operation.

DIRTY DRILLING 29

Threats to human health do not take

place in a vacuum. Even permitted

emissions of pollution, while within

legal parameters, can produce cumulative

pollution concentrations that pose a risk to

human health. Such is the case with the Great

Lakes. Contaminated sediments in the lakes

continue to release chemicals over time, and

these additional pollutant inputs pose a threat

to at-risk populations, such as children, the

elderly, and young women, who rely on Lake

Erie for food sources. The introduction of a

significant new pollution source – oil and gas

drilling on the American side of the lake –

would further exacerbate existing pollution

problems.

Ingestion of contaminated sport fish or

drinking water has historically served as the

primary exposure route for Great Lakes

populations. While data for criteria pollut-

ants such as dioxin, methyl mercury, or PCBs

have received a great deal of attention from

government sources, we do not know with

certainty the possible effects of additional

pollutant loading of the type associated with

oil and gas drilling. We can know, however,

the likely risk associated with these hazards.

Summary of Findings

• Accumulation of toxic chemicals in the

Lake Erie ecosystem represents one pri-

mary threat to human health. As pollut-

ants from oil and gas drilling build up in

the food chain, people who consume fish

from Lake Erie will be at serious risk of

health problems.

• Routine discharges and accidental spills

from drilling sites can contaminate the

water of Lake Erie, thus contaminating a

primary drinking water source for millions

of Ohioans.

• Some drilling discharges, such as air emis-

sions and run off, are very difficult to

avoid.

• Placement of wells on shore puts human

health at greater risk from accidents, as

well as from routine pollution and dis-

charges.

• Routine drilling wastes, such as drilling

muds and cuttings, contain a host of toxic

chemicals that are known to be hazard-

ous to human health. Routine discharge

or accidental release of these materials

could be very dangerous in the densely

populated area of the Lake Erie watershed.

Dirty Drilling Wastes

and The Threat to

Human Health

Drilling muds, cuttings, and produced wa-

ters could impact human health via several

routes of exposure. While inhalation is an

occupational concern for drilling workers,

ingestion of contaminated food or water re-

main the primary threats to the general popu-

lation. These exposures could take place due

to the routine permitted discharge of wastes

into the lake; accidental release into the lake

or its immediate watershed; intentional re-

lease, either permitted or not permitted, into

the lake or its immediate watershed; or seep-

age from onshore storage areas into ground-

water.

If released into the environment via dis-

charge into Lake Erie, drilling muds, cut-

tings, and produced waters could be expected

HUMAN HEALTH IMPACTS

OF DRILLING IN OHIO’S LAKE ERIE

Installation of a pipeline using directional drilling.79

DIRTY DRILLING30

to contaminate the water at the area of dis-

charge. Once this contamination enters the

food chain, toxics from the waste could ac-

cumulate in the organisms and increase in

concentration as they move up the food

chain, essentially growing in toxicity. For

instance, bacteria and plankton can ingest

methyl mercury. The organisms then trans-

mit the toxic chemical to small fish or min-

nows. Predatory fish, such as walleye,

continually feed on the contaminated fish and

methyl mercury can accumulate to extremely

high levels over time. If humans ingest the

contaminated fish, they would be exposed

to extremely high levels of methyl mercury.

Ingestion of contaminated fish remains a pri-

mary route of exposure for humans.

Accidental or intentional release of drill-

ing wastes could also contaminate drinking

water. While direct impacts to Lake Erie

through offshore dumping would serve as the

greatest short-term threat, the long-term

threat of leakage into the groundwater within

the lake’s watershed is equally troubling.

Seepage of drilling wastes from onshore

impoundments into area groundwater could

have an immediate contaminating effect on

local drinking water wells. Any LNAPL, a

light liquid pollutant, introduced into ground-

water can contaminate Lake Erie water qual-

ity through transport from the aquifer to the

lake’s waters. DNAPLs, a dense liquid pol-

lutant, would be expected to exert an aqui-

fer-specific impact, but must be considered

equally troubling due to the extreme diffi-

culty of clean up and the long-term impact

of such pollution. For example, trichloroet-

hylene (TCE), a common degreaser used to

clean machine parts, has produced ground-

water contamination that can never been fully

remediated.

Acetaldehyde Causes severe eye irrita-

tion. Harmful if swallowed or inhaled. Af-

fects central nervous system, liver and

kidneys. Causes irritation to skin and res-

piratory tract. Possible cancer hazard.

Acetic acid Liquid and mist cause severe

burns to all body tissue. May be fatal if

swallowed. Harmful if inhaled. Inhalation

may cause lung and tooth damage.

Ammonium bisulfite May be fatal if swal-

lowed or inhaled. Harmful if absorbed

through skin. Causes burns to any area of

contact. Causes respiratory tract irritation.

Can liberate poisonous and flammable

hydrogen sulfide gas.

Ammonium chloride May cause irritation.

May be harmful if swallowed. Avoid con-

tact with eyes, skin, clothing.

Crotonaldehyde Harmful if swallowed,

inhaled or absorbed through the skin. Eye

contact may cause severe irritation or

burns. Respiratory, eye and skin irritant.

Dodecylbenzene sulfonic acid Contact

can irritate and burn the eyes and skin.

Can irritate the nose and throat.

Hydrochloric acid Liquid and mist cause

severe burns to all body tissue. May be

fatal if swallowed or inhaled.

Hydrofluoric acid Extremely hazardous

liquid and vapor. Causes severe burns

which may not be immediately painful or

visible. May be fatal if swallowed or in-

haled. Liquid and vapor can burn skin,

eyes and respiratory tract. Causes bone

damage.

Potassium hydroxide Causes severe

eye irritation. Harmful if swallowed or in-

haled. Affects central nervous system, liver

and kidneys. Causes irritation to skin and

respiratory tract.

Sodium hydroxide Corrosive. May be

fatal is swallowed. Harmful if inhaled.

Causes burns to any area of contact

Zinc bromide Harmful if swallowed of

inhaled. Causes severe irritation or burns

to every area of contact. Affects central

nervous system, brain and eyes.

Toxic Chemicals Associated with Natural Gas Production

DIRTY DRILLING 31

The table on the preceding pages lists haz-

ardous chemicals, as defined in 40 CFR, Part

116, that have been identified as additives in

the exploration and production of natural gas

wells in the Gulf of Mexico and can be con-

sidered a relative guide to the toxic chemi-

cals that could arise from Lake Erie drilling.80

Human health warning data has been taken

from the Occupation Safety and Health

Administration’s Material Safety Data Sheet

(MSDS) warnings.

These chemicals are the tip of the iceberg.

Drilling muds can often contain over 1,000

difference chemicals in varying volumes and

forms. As noted in the section on environ-

mental risks, drilling muds frequently con-

tain heavy metals (lead, arsenic, mercury,

cadmium, and chromium) hydrocarbons (oil,

diesel fuel, and polyaromatic hydrocarbons),

and naturally occurring radioactive materi-

als. At differing levels, each of these chemi-

Lead is a heavy metal frequently encountered in oil

and gas drilling muds. Ingestion of lead by at risk

populations, such as children, the elderly, and women

of childbearing age, can have significant impacts at

miniscule levels. In fact, the US EPA states that, “It

appears that some of these [adverse health] effects,

particularly changes in the levels of certain blood en-

zymes and in aspects of children’s neurobehavioral

development, may occur at blood lead levels so low

as to be essentially without a threshold,” (emphasis

added).81

Methyl mercury, by-product of mercury contamina-

tion in conjunction with high levels of organic mate-

rial in soils, has been associated with central nervous

system effects in humans even at the level of 0.003

mg/kg/day.82

Mercury contamination would be part

of almost any drilling waste discharge. Methyl mer-

cury is a known human neurotoxin, or nerve-destroy-

ing, compound. The chemical has also been shown

to cause mental retardation and cerebral palsy in de-

veloping fetuses.83

Given the dangers of

bioaccumulation associated with methyl mercury, as

well as the difficulty associated with removing it

through drinking water processing at municipal wa-

ter sources, additional methyl mercury contamination

would be a tremendous concern in the Lake Erie area.

Chromium, specifically chromium VI, has been given

a reference dose of .003 mg/kg-day.84

Exceeding the

reference dose can produce noncarcinogenic effects.

Existing evidence indicates the potential impacts from

chromium VI exposure are as diverse as allergic con-

tact dermatitis (skin rash), decreased fertility,

embryotoxicity (decreased birth weight and increased

mortality rate), developmental defects, and cancer.

Chromium VI is a known human carcinogen for inha-

lation exposure, but has not been assessed for its

ability to cause cancer when ingested.85

Polycyclic aromatic hydrocarbons (PAH) include

known human carcinogens such as benzene and po-

tential human carcinogens such as naphthalene.86

Numbering in the hundreds, PAHs are frequently

found in oil and gas drilling wastes. Because many

toxicologists now recognize that no safe dose exists

for carcinogenic materials,87

the introduction of PAHs

into the Lake Erie ecosystem will always pose a seri-

ous threat to human health.

Normally occurring radioactive materials in produced

waters are further cause for concern. These materi-

als have been identified as cancer-causing agents.

Because no safe exposure level exists for cancer-

causing agents, any exposure to radioactive produced

waters can cause cancer in humans and wildlife. The

levels of naturally occurring radionuclides can be ex-

pected to vary widely from area to area due to varia-

tion in geology.

Some Chemicals of Concern

cals is a known threat to human health and

the environment.

Once introduced into the drilling process,

these chemicals become an inextricable part

of the resulting drilling wastes. If chemical

concentration in the muds reaches threshold

limits (the legal level at which the mixture

must be treated as a hazardous waste or ma-

terial), the mixture is considered hazardous

and must be handled as such. Such designa-

tion does not, however, protect from acci-

dental or intentional releases of drilling muds

and cuttings into the environment.

Dirty Air and the

Toxic Emissions

from Drilling Sites

While water pollution typically comes to

mind when considering oil and gas drilling,

quite significant levels of air pollution are

DIRTY DRILLING32

also generated by these operations. In fact,

the oil and gas extraction industry leads all

other natural resource extraction industries

in the total volume of air emissions each

year.88

During routine drilling operations, very

large levels of air pollution are emitted by

the large diesel engines that power the drill-

ing equipment. These engines create signifi-

cant amounts of particulate matter that can

contain heavy metals, volatile organic com-

pounds, and polycyclic organic matter. They

also emit sulfur oxides, a chemical associ-

ated with acid rain, and oxides of nitrogen,

which contribute to smog formation. The

air pollution associated with drilling deep

wells can be increased by long-term, multi-

site drilling operations.89

The adverse human health effects of air

pollutants such as SOx (sulfur oxides), NOx

(nitrogen oxides), Hg (mercury), and particu-

late matter are well documented.90

Fine par-

ticulate matter has been

shown to result in diffi-

culty breathing and ag-

gravate existing heart

and lung disease. It may

also trigger pneumonia

or emphysema.91

Ozone

is a result, in part, of

NOx emissions on hot,

humid summer days.

Ozone alert days ad-

versely impact the res-

piratory health of

asthma suffers, at-risk

populations (children,

the elderly, and indi-

viduals with lowered immune system func-

tioning), and individuals with existing heart

and lung diseases. Mercury has been asso-

ciated with neurotoxicity (nerve destruction),

developmental toxicity (damage to fetal and

early childhood development), and renal tox-

icity (kidney damage).92

It is important to note that the Lake Erie

drilling season would coincide with the

ozone season in Ohio (roughly May through

September). As such, the increased air emis-

sions from continuous drilling activities

would add to existing poor air quality con-

ditions in areas around Lake Erie. While air

quality issues are impact human health

through inhalation, air pollution can also im-

pact human health through dermal and in-

gestion pathways when these chemicals are

deposited from the air into water.

Leaks, Blowouts,

and Spills

Natural gas pipeline leaks would signifi-

cantly impact area residents. These accidents

also happen at an alarming rate. In 2000,

nationwide natural gas pipeline incidents

topped 234, leading to 37 deaths, 77 inju-

ries, and $40,318,799 in property damage

nationwide. The charts on the opposite

page94

show the primary causes of pipeline

leaks in 2000. Corrosion was the primary

cause for transmission leaks in 2000. Dam-

age from outside forces produced the bulk

of pipeline failures for distribution lines in

2000.

Natural gas leaks are extremely dangerous,

regardless of the location. By its very na-

ture, natural gas is an extremely flammable

Air Pollution Data for Ohio, by Sector, in Tons per Year

Volatile

Carbon Nitrogen Particulate Sulfur Organic

Industry Sector Monoxide Dioxide Matter Dioxide Compounds

Oil and Gas Extraction 132,747 389,686 4,576 238,872 114,601

Metal Mining 4,951 49,252 21,732 1,202 119,761

Non-Fuel, Non-Metal Mining 31,008 21,660 44,305 9,183 138,684

Petroleum Refining 299,546 334,795 25,271 292,167 36,421

Natural gas drilling operation flare-up.93

DIRTY DRILLING 33

OFFICE OF PIPELINE SAFETY DISTRIBUTION PIPELINE INCIDENT SUMMARY BY CAUSE

1/1/2000 - 12/31/2000

Percent Percent

No. of of Total Property of Total

Cause Incidents Incidents Damages Damages Fatalities Injuries

Accidentally Caused by 0perator 7 4.54 $211,608 0.9 0 6

Construction/Operating Error 9 5.84 $1,066,000 4.55 0 6

Corrosion, External 4 2.59 $255,000 1.08 0 5

Corrosion, Internal 1 0.64 $50,000 0.21 0 0

Damage by Outside Forces 82 53.24 $10,826,204 46.26 4 17

No Data 6 3.89 $555,000 2.37 3 3

Other 45 29.22 $10,435,022 44.59 15 22

Total 154 $23,398,834 22 59

material. As such, all natural gas leaks carry

the risk of fire and explosion until the leak is

contained. Hydrogen sulfide is a toxic

chemical gas frequently found in natural gas

deposits. While Ohio regulations limit ac-

cess to sour natural gas (natural gas contami-

nated with toxic hydrogen sulfide gas), most

natural gas contracts allow hydrogen sulfide

content up to about 4 ppm.95

This is signifi-

cantly lower than the “no observable effect

dosage” set by the US EPA (30.5 ppm).96

While the allowable hydrogen sulfide lev-

els do provide adequate protection from rou-

tine natural gas pipeline leaks, they cannot

protect public health in the event of an on-

shore blowout. On average, 7 out of every

1000 exploratory wells will result in a blow-

out.97

In the event of a blowout, the pressur-

ized contents of a geologic formation literally

explode out of the new well, exposing any

contents to the environment. If a blowout

occurs in a well that has tapped into a sour

gas pocket, the uncontrolled release of hy-

drogen would take place. This release would

occur on land, where human health effects

are most likely to occur. While the risk may

be somewhat low, there is a potential for loss

of life associated with such a release.98

OFFICE OF PIPELINE SAFETY TRANSMISSION PIPELINE INCIDENT SUMMARY BY CAUSE

1/1/2000 - 12/31/2000

Percent Percent

No. of of Total Property of Total

Cause Incidents Incidents Damages Damages Fatalities Injuries

Construction/Material Defect 7 8.75 $591,043 3.49 0 0

Corrosion, External 14 17.5 $3,475,500 20.54 0 0

Corrosion, Internal 16 20 $1,686,790 9.96 12 2

Corrosion, Not Specified 1 1.25 $730,000 4.31 0 0

Damage by Outside Force 20 25 $3,164,161 18.7 3 7

Other 22 27.5 $7,272,471 42.98 0 9

Total 80 $16,919,965 15 18

DIRTY DRILLING34

As with all natural resources, the regu-

lation of oil and gas drilling has both

federal and state levels. This is more

than a casual observation, because the ques-

tion of who regulates what is at the heart of

a heated debate surrounding the Great Lakes

drilling issue. In Ohio, oil and gas drilling

has not been allowed in or under Lake Erie,

so the question of federal versus state juris-

diction has never been tested. However,

Michigan is currently embroiled in a battle

with the US Army Corp of Engineers over

the issue of permitting oil and gas drilling

along Lake Michigan. Regardless of the

outcome, it is important to understand the

history of oil and gas regulation throughout

Ohio, as well as the potential ramifications

of the jurisdictional debate.

US EPA data99

concerning the regulation

of oil and gas drilling at the national level

reveals the level of environmental damage

inflicted by oil and gas extraction. Over a

five-year period, 1 in 20 oil and gas extrac-

tion industry inspections revealed an alleged

violation of federal law and triggered an en-

forcement action by US EPA. At the same

time, inspections led to enforcement action

at an average of 1 in 6 oil and gas extraction

facilities. These startling statistics clearly

indicate the extent of the oil and gas

industry’s non-compliance with existing en-

vironmental laws, as well as the extreme

burden that this industry places upon regu-

latory agencies.

Ohio’s Regulation

of Dirty Drilling

Ohio Department of Natural Resources,

Division of Mineral Resources Management

(formerly the Division of Oil and Gas and

the Division Mines and Reclamations) has

permitting and enforcement authority for

over 215,000 land-based oil and gas wells in

Ohio, 65,000 of which are active.100

In 1999,

the Division issued 1,721 permits, including

660 permits to drill and 1,002 permits to plug

with an average turnaround of 12.6 days. The

Division’s inspectors also held over 22,000

site inspections. The Division currently

employs 21 inspectors, requiring each to in-

spect, on average, 1,047 sites per year.

Pipeline safety oversight falls to the Pub-

lic Utilities Commission of Ohio, with pri-

mary enforcement residing with the federal

Office of Pipeline Safety within the Depart-

ment of Transportation. The PUCO acts as

a conduit from the state to the federal au-

thorities in the event of a potential pipeline

accident. As such, the PUCO controls the

conveyance of pipeline safety information,

while the OPS provides primary investiga-

tive and enforcement.

Summary of Findings

• The Ohio Department of Natural Re-

sources lacks the staffing and mandate to

implement a Lake Erie drilling program.

Inspection levels and staffing are of spe-

cial concern.

• Well development and placement regula-

tions in Ohio do not provide adequate pro-

tections for human health and the

environment.

• While current regulations governing the

final disposal of drilling wastes and pro-

duced waters disallow placement in a

freshwater body, enforcement and over-

sight is insufficient to provide assurance

that these practices would not take place

in or around Lake Erie. Furthermore, pro-

duced water disposal regulations allow

discretion for testing new and unproven

disposal technologies.

Oil and Gas Well

Inspections in Ohio

In 2000, the Mineral Resources Management

division of ODNR estimates that 569 new

gas and oil wells were drilled. During the

REGULATION OF OIL AND GAS

DRILLING IN THE UNITED STATES

DIRTY DRILLING 35

same year, the division issued 825 notices

of violation to oil and gas drilling operations

in Ohio.101

In total, ODNR employs only 21

inspectors to oversee these new wells, in ad-

ditional to all other active, inactive, and aban-

doned wells.

The chart to the side summarizes one pri-

mary deficiency in ODNR’s ability to regu-

late oil and gas drilling in or under Lake Erie:

each county along Lake Erie shares a single

oil and gas well inspector with at least three

other counties and as many as 21. While the

allocation of ODNR resources does depend,

in part, on the concentration of wells in a

given geographic area, the current staffing

and allocation levels fail to provide adequate

oversight of existing wells. At current staff-

ing and inspection levels, oil and gas wells

in the state will only be inspected once ev-

ery two to three years, on average. As such,

assurance of proper waste handling and dis-

posal, as well as optimum construction and

operation of the well, falls largely within the

purview of the drilling company.

Collecting and Disposing

of Produced Waters

Produced waters may not be discharged into

waters of the state of Ohio if either of the

following exists:

• Humans or domestic animals use the wa-

ter body for consumption and the release

will exceed the standards of the Safe

Drinking Water Act.

• Damage or injury to public health or safety

or the environment will result from the

release.

These wastewaters, along with standard

well treatment fluids, may be injected into a

Class II injection well, or, in limited circum-

stances, applied to constructed surfaces.102

Brines may, however, be held in dikes or

impoundments at the drill site, prior to final

storage in an injection well. Furthermore,

the director of ODNR has the authority to

permit disposal by means other than injec-

tion. This can be done to allow for testing

or implementation of a

new disposal technol-

ogy. As a result, un-

proven technologies

could be used despite

the toxic nature of pro-

duced waters.

Because produced

waters may be stored

onsite, the risk of acci-

dental or intentional

release does exist.

Failure to provide ad-

equate staffing for an-

nual well site visits

could further exacer-

bate this potential

problem. Data on Ohio’s injection well pro-

gram seems to indicate that the ODNR oper-

ates one of the best injection well operations

in the nation. However, an extensive review

of the programs’ capacity for significant ad-

ditional waste handling would be needed in

response to potential drilling in Lake Erie.

Collecting and Disposing of

Drilling Muds and Cuttings

Regardless of the chemical make-up, the

copious amounts of drilling muds and cut-

tings produced from oil and gas wells must

be disposed. According to Ohio regulations,

drilling wastes such as muds, cuttings, and

fluids other than produced waters must not

be disposed of in violation of any solid waste

disposal rule.103

If the composition of drill-

ing wastes does not trigger hazardous waste

handling levels, the wastes can be disposed

of as a simple solid waste. While brines may

not be released into the waters of the state

(with some exceptions), Ohio laws do not

clearly indicate acceptable disposal practices

for all drilling wastes.

Based on operations in other navigable

waters of the United States, these materials

can be dumped into water bodies with the

presence of a NPDES (National Pollution

Discharge Elimination System) permit, re-

Cuyahoga, Lorain, Medina,

Summit

Lake, Ashtabula, Geauga,

Trumbull

Erie, Sandusky, Richland, Ot-

tawa, Ashland, Huron, Seneca,

Crawford

Lucas, Wood, Hancock, Putnam,

Henry, Marion, Van Wert,

Auglaize, Shelby, Delaware, De-

fiance, Paulding, Williams,

Fulton, Wyandot, Morrow, Allen,

Mercer, Logan, Union, Darke,

Hardin

Counties that Share an Oiland Gas Inspector

DIRTY DRILLING36

gardless of the drilling method employed.

EPA regulations governing the disposal of

drilling muds rely on the Best Available Tech-

nology standard.104

In addition, the EPA has

required the following of all drilling mud

disposal:105

• No release of muds or cuttings contain-

ing free oil, as determined by the static

sheen test

• No release of muds or cuttings that con-

tain diesel fuel

• 30,000 ppm 96 hour LC50 toxicity limit

for any suspended particulate matter

• No release of muds or cuttings within three

miles of the shoreline

• Stronger regulation of cadmium and mer-

cury content of barite added to drilling

fluid

Should oil or gas drilling take place in Lake

Erie, the Ohio Environmental Protection

Agency would presumably possess jurisdic-

tion over the issuance of any and all NPDES

permits for dumping in Lake Erie. To retain

authority, the requirements for the permit

must follow, at minimum, US EPA regula-

tions for disposal. However, this technical

requirement does not ensure proper imple-

mentation of the permit program in Ohio.106

Ohio’s failure to adequately implement the

Clean Water Act does not bode well for ad-

ditional permitting, especially with relation

to Lake Erie. In fact, 47.06% of Ohio’s larg-

est facilities were in violation of the Clean

Water Act for at least one of the past five

consecutive quarters.108

In addition, Ohio

ranks 5th

in the nation for percentage of ma-

jor facilities in violation of their clean water

permits and 2nd

in the nation for number of

major facilities in violation of their clean

water permits.109

Given the potential for ex-

tremely toxic drilling muds, Ohio’s failure

to adequately enforce the Clean Water Act

is of great concern for potential releases into

Lake Erie.

Natural Gas

Pipeline Safety

While the Public Utilities Commission of

Ohio maintains a conduit capacity in rela-

tion to pipeline safety,110

the federal Office

of Pipeline Safety is the primary enforcer.

As a certified state, Ohio maintains direct in-

spection authority for intrastate natural gas

pipelines, a function served by the PUCO.

In Ohio, the OPS has noted over 106 signifi-

cant natural gas pipeline accidents between

1984-1996. These accidents have resulted

in over $13,043,014 in property damage.

Furthermore, these accidents represent those

that were actually reported to the agency. In

addition, the PUCO levies an average of

$50,000 in pipeline safety-related fines per

year.

Federal administration of pipeline safety

was sharply criticized by a Government Ac-

counting Office report issued in 2000. The

report, The Office of Pipeline Safety is

Changing How it Oversees the Pipeline In-

dustry, states that pipeline accidents have

steadily increased from 1984 to 1998. At

the same time, the OPS has significantly de-

creased total fines, while also failing to pro-

vide adequate implementation and

enforcement of existing regulations.

The report indicates that the increase in

major accidents could result from the follow-The effects of run-off on Lake Erie water quality.

107

DIRTY DRILLING 37

ing: a 10% overall increase in pipeline mile-

age; growth in the volume of products trans-

ported by pipelines (due to an increase in the

nation’s energy consumption); and popula-

tion growth near pipelines.111

This is espe-

cially troubling for Ohio, as any oil and gas

drilling along Lake Erie would require ex-

tensive new pipelines to deliver gas from

production wells to processing stations. As

a point of reference, Canada utilizes over

1,000 miles of pipeline under Lake Erie, but

only delivers about 15 Bcf per year – three-

fourths of Lake Erie’s projected peak pro-

duction.

Air Emissions and Drilling

The Ohio Revised Code standards applicable

to oil and gas drilling make no reference to

the control of air emissions from drilling

sites, other than the accidental release of

natural gas or other gaseous phase hydrocar-

bons. As such, the emissions of NOx, SOx,

Hg, CO2, and particulate matter from drill-

ing machinery would be wholly unregulated.

Without regulatory oversight regarding air

emissions from oil and gas drilling sites, drill-

ing in or under Lake Erie could exacerbate

poor air quality in many northern regions of

Ohio.

Effect of Ohio regulations on

Lake Erie Drilling

Ohio’s existing regulatory and enforcement

structure would not provide oversight suffi-

cient to protect public health and the envi-

ronment should Lake Erie drilling take place.

The state does not employ oil and gas well

inspectors sufficient to ensure strict adher-

ence to the state’s existing laws and regula-

tions. While produced water disposal into

the state’s waters is forbidden, the wastes can

be stored onsite for the length of drilling –

roughly 3 to 9 months. Therefore, opportu-

nities for leaks or spills do exist. The poten-

tial for water disposal of drilling muds and

cuttings via Ohio’s NPDES permitting pro-

gram is especially troubling, given the state’s

lax enforcement of the Clean Water Act. As

pipeline accident rates continue to climb, the

potential of a major spill in or along Lake

Erie must be considered quite significant.

Finally, the state provides no mechanism for

controlling routine air pollution emissions

from drilling machinery.

Federal vs. State

Jurisdiction

As with many natural resources issues, the

question of whom the ultimate permitting

authority for Great Lakes oil and gas drill-

ing remains unanswered. Extractive activi-

ties such as oil and gas drilling always require

the presence of a governmental “O.K.” in the

form of a permit. Depending upon the loca-

tion of the resources, that permit might be

issued by any number of federal or state agen-

cies. In Ohio, for example, the Ohio De-

partment of Natural Resources maintains

permitting authority for all land-based oil and

gas drilling on private or state lands. This is

not the case for all onshore drilling. At the

Mosquito Creek Lake Project, a controver-

sial oil and gas project on federal army lands

in Northern Ohio, the US Army Corp of En-

gineers, in consultation with the Bureau of

Land Management, maintains permitting

authority.

Complicating the issue is the relative lack

of oil or gas drilling on or under the Great

Lakes in the United States. Only Michigan

has active wells on the Greats Lakes, with

the most recently completed well in 1996 and

one well still being built.112

In 1997, Gover-

nor Engler of Michigan suspended all drill-

ing, pending a Michigan Environmental

Science Board report on the potential impacts

of directional drilling on Lakes Michigan and

Huron water quality.113

No other Great

Lakes state has taken part in any oil or gas

drilling since the “Statement of Principle

Against Oil Drilling in the Great Lakes” was

signed in mid 1980s.114

In a letter issued to the Michigan Depart-

ment of Environmental Quality, the US Army

DIRTY DRILLING38

Corps of Engineers (Corps) has claimed fed-

eral jurisdiction over any directional drill-

ing activities in or under Lake Erie.115

Specifically, the Corps has made the follow-

ing claim:

“Under Section 10 of the Rivers & Har-

bors Act of 1899, the U.S. Army Corps of

Engineers has authority to require permits

for construction in navigable waters of the

U.S., and the Corps’ Detroit District exam-

ined whether this authority could apply to

the proposed drilling. It found that drilling

under the Great Lakes could fall under Corps

jurisdiction if work affected the course, lo-

cation, condition, or capacity of navigable

waters. The determination would have to be

made on a case-by-case basis and consider

geologic conditions in drilling area, such as

the potential for gas or oil to leak into

lakes.”116

Based on this evaluation of the Corps’

regulatory authority, all directional drilling

projects in or under the Great Lakes would

fall under the purview of the Corps’ permit-

ting program.

In evaluating the Corps’ claims, the actual

text of Section 10 serves as a fruitful point

of departure. The geographic jurisdiction of

the Rivers and Harbors Act of 1899 includes

all navigable waters of the United States

which are defined in 33 CFR Part 329 as,

“those waters that are subject to the ebb and

flow of the tide and/or are presently used, or

have been used in the past, or may be sus-

ceptible to use to transport interstate or for-

eign commerce.” This regulation clearly

applies to Lake Erie. Furthermore, the stat-

ute clearly indicates that, but for explicit ex-

ceptions, the Corps maintains authority over

any of the following actions: construction,

excavation, or deposition of materials in,

over, or under US navigable waters; or any

action which would affect the course, loca-

tion, condition, or capacity of those waters.

Directional drilling in or under Lake Erie

satisfies the criteria of Section 10. The lake

is considered a navigable water of the United

States and is utilized for interstate and for-

eign commerce. Furthermore, evidence pre-

sented under this report’s section dealing

with the environmental impacts of drilling

clearly indicate the significant potential for

affects to the condition and capacity of Lake

Erie’s waters. As such, the Corps’ claim of

jurisdiction over directional drilling appears

to have standing under current US laws.

Only one state has actively disputed the

claims of the Corps – Michigan. In reaction

to Corps claims regarding directional drill-

ing jurisdiction in Michigan, the Engler ad-

ministration has routinely dismissed any

assertion of Corp jurisdiction.117

Michigan

continues to assert sole authority of the per-

mitting of directional drilling in the Great

Lakes area. As such, the state relies on state

laws, notably the Natural Resources and En-

vironmental Protection Act, Act No. 451.118

To date, neither the US Army Corps of

Engineers nor the State of Michigan has

sought legal remedy for the conflicting

claims of authority. Until such time as a ju-

dicial ruling has been made or the statutory

authority of the Corp is further explained,

the question of jurisdiction will remain con-

tested. Given the multi-state and bi-national

nature reach of oil and gas drilling impacts,

the United States federal government should

have jurisdiction over all Great Lakes oil and

gas drilling. Examination of existing stat-

utes indicates a strong, long-standing basis

for that jurisdictional claim.

DIRTY DRILLING 39

Ohioans neither need the natural gas

under Lake Erie, nor want the eco-

nomic, environmental, and human

health impacts that would result from drill-

ing. To meet the need for clean, affordable

energy, the state should pursue a smarter,

cleaner energy future.

Summary of

Policy Solutions

• Provide consumers with rebates and tax

incentives for the purchase of energy effi-

cient appliances and the construction of

energy efficient buildings.

• Increase efficiency standards for building

codes in Ohio.

• Institute a Renewable Portfolio Standard

that requires 10 % of all electricity sold

in Ohio to come from renewable energy

by 2010 and 20% by 2020.

• Provide consumers with tax incentives and

rebates for the installation of renewable

energy generation equipment, such as

photovoltaic cells.

Right now, the average household in Ohio

spends over $300 a year in unneeded energy.

The total cost of wasted energy to Ohio’s

residential energy users could total almost

$900 million dollars in 2001. If the United

States had not implemented energy conser-

vation and efficiency measures in the 1970s,

those unneeded energy bills would be 40%

higher today. Energy efficiency has produced

enormous economic and environmental ben-

efits over the past three decades, however

Ohioans still have enormous energy saving

opportunities. Reliance on these opportuni-

ties, rather than dirty drilling, will provide

Ohio with sufficient energy supply levels,

economic savings, and environmental ben-

efits.

In Ohio, the potential benefits of a clean

energy future are staggering. Energy effi-

ciency investments can produce all of the

following for Ohio:119

1. Reduce net electricity costs by $1,527

million by 2020.

2. Save 72,417 GWh of electricity - equal to

about 25 large power plants - by 2020.

3. Reduce electricity demand by 17% in

2010 and 29% by 2020.

4. Cost less - at an average investment of

2.4¢/kWh - than generating, transmitting

and distributing electricity from power

plants.

Clean energy is a desirable course for Ohio.

Every $1 invested in energy efficiency pro-

duces a $1.81 return on investment. These

savings come from common sense solutions

like programmable thermostats, which allow

customers to lower energy use by tailoring

the heating and cooling of their homes. If

50% of Ohio’s residential natural gas cus-

tomers used a programmable thermostat, the

savings would be equal to 10% of Ohio’s

domestic natural gas production per year (10

Bcf) – and a savings of 65.7 million dollars

per year.120

Homeowners, commercial, and

industrial energy users can actually make

money on energy efficiency investments.

Furthermore, these savings are, in many

cases, immediate, unlike drilling for new

energy sources.

Renewable energy should be the second

part of Ohio’s clean energy equation. Re-

newable energy from solar, wind, and geo-

thermal sources holds significant

opportunities for Ohio. The Northern region

of Ohio has been rated good or very good

for wind energy generation. By one estimate,

920 MW of electricity could be provided

from wind turbine generation by 2020.121

81

MW could also be provided from photovol-

taic cells by 2020. Small-scale geothermal

heat pumps for homes and small businesses

can further supplement Ohio’s renewable

energy portfolio. As a state, Ohio should

rely on a Renewable Portfolio Standard that

requires 10% of the electricity sold in Ohio

to come from renewable sources by 2010 and

20% by 2020.

A BETTER OPTION: CLEAN ENERGY

DIRTY DRILLING40

Based on the findings of this report,

both offshore and onshore oil and gas

drilling in Lake Erie pose unaccept-

able risks and hazards. Despite industry

claims to the contrary, oil and gas drilling is

still a dirty, dangerous business. At every

stage of the drilling process the environment

around the drilling site is bombarded by toxic

chemicals and threatened by accidental leaks

and spills. Drilling for natural gas and oil

on the Canadian side of Lake Erie has been

neither safe nor clean, with 51 documented

accidents in the past 4 years. The introduc-

tion of a significant new pollution source –

oil and gas drilling on the American side of

the lake – would further exacerbate existing

public health problems. In addition to envi-

ronmental and health concerns, oil and gas

drilling could have widespread net negative

effects on the economy of the Lake Erie re-

gion in particular and the state of Ohio in

general. In Ohio, oil and gas drilling has

not been allowed in or under Lake Erie, so

the question of federal versus state jurisdic-

tion has never been tested. Even if Ohio al-

lowed oil and gas drilling, the Ohio

Department of Natural Resources lacks the

staffing and mandate to implement a Lake

Erie drilling program.

Policy Solutions

• Ohio should institute permanent protec-

tion from all oil and gas drilling in and

under Lake Erie, expressly including on

and offshore drilling.

• Federal government should institute per-

manent protection from all oil and gas

drilling in and under Lake Erie, expressly

including on and offshore drilling.

• Provide consumers with rebates and tax

incentives for the purchase of energy ef-

ficient appliances and the construction of

energy efficient buildings.

• Increase efficiency standards for building

codes in Ohio.

• Institute a Renewable Portfolio Standard

that requires 10 % of all electricity sold

in Ohio to come from renewable energy

by 2010 and 20% by 2020.

• Provide consumers with tax incentives and

rebates for the installation of renewable

energy generation equipment, such as

photovoltaic cells.

CONCLUSION AND RECOMMENDATIONS

DIRTY DRILLING 41

Functional

Code Categories Description Material Types Used

A Alkalinity, pH Controls the alkalinity or acidity of a Lime (CaO), caustic soda

control additives fluid. These factors are important in (NaOH), soda ash (Na2CO3),

controlling mud properties. bicarbonate of soda (NaHCO3),

B Bactericides Prevents bacterial degradation Aldehydes and others Soda

of organic additives. ash (Na2CO3), bicarbonate of

soda (NaHCO3), caustic

soda (NaOH) and certain

polyphosphates

CA Calcium Used to counteract the effects of Amine- and phosphate-based

reducers calcium from seawater, cement products and other specially

contamination, anhydrites, and formulated chemicals

gypsum from the formation on

CO Corrosion Controls corrosion acids Alcohol-based materials,

inhibitors and acid gases. silicone-based materials,

aluminum stearate, alkyl

phosphates

D Defoamers Used to reduce foaming action

that affects mud properties.

E Emulsifiers Used to create a heterogeneous Detergents, soaps, organic

mixture of two insoluble liquids. acids, and water based

They may be anionic (-), nonionic surfactants are used in

(no charge), or cationic (+). water-based muds

FR Filtrate Used to decrease fluid (as opposed Bentonite clays, lignite, CMC

reducers to whole mud) loss through the filter (sodium carboxymethylcellulose),

cake on the walls of the wellbore. polyacrylate, and

pregelatinized starch

FL Flocculants Used to increase viscosity, increase Inorganic salts, hydrated lime,

effectiveness of clay viscosifiers, or gypsum (calcium sulfate penta

clarify or de-water low solids fluids. hydrate), soda ash (Na2CO3),

bicarbonate of soda (NaHCO3),

sodium tetraphosphate, and

FO Foaming agents Used to create foam in water to See inventory for product

permit air or gas drilling through examples (e.g., amplifoam,

water-bearing formations. airfoam B)

APPENDIX ONE

Drilling Fluid Chemicals: Codes, Functional Categories, Descriptions,

and Material Types Used125

DIRTY DRILLING42

Functional

Code Categories Description Material Types Used

LO Lost circulation Used to plug leaks in the wellbore Nut shells, natural fibrous

materials and prevent the loss of whole materials, inorganic solids

drilling fluid to the formation.

LU Lubricants Used to reduce torque and drag Oils, synthetic liquids, graphite,

on the drill string. surfactants, glycols, and

glycerin

P Pipe-freeing Spotted at a particular point in a Detergents, soaps, oils,

agents well to prevent the drill pipe from surfactants, and other

sticking to the formation. chemicals

SH Shale control Used to control shale hydration and Soluble calcium and potassium

inhibitors subsequent wellbore enlargement, salts, other inorganic salts,

heaving and caving of and organic compounds

of water-sensitive shales.

SU Surface-active Used to modify the interfacial See inventory for product

agents tension between contacting examples (e.g., avabiowet,

surfaces. They may act as anco rope)

emulsifiers, de-emulsifiers, wetting

agents, flocculants, or deflocculants.

TE Temperature Used to increase the stability of Acrylic polymers, sulfonated

stability agents dispersions, emulsions, and polymers, copolymers, lignite,

rheological properties at high lignosulfonate, and tannin-based

temperatures. additives

TH Thinners, Used as a deflocculant to reduce Tannins, various

dispersants the attraction (flocculation) of clay polyphosphates, lignite,

particles which causes high lignosulfonates

viscosity and gel strength. That is,

they balance the effect of

viscosifiers and control mud

viscosity and gel strength.

V Viscosifiers Used to increase viscosity in muds. Bentonite, attapulgite clays,

CMC, and other polymers

W Weighting Used to increase the density of the Barite (barium sulfate), lead

materials mud and thereby enable it to compounds, iron oxides,

control formation pressures. calcium carbonate, and

similar products

DIRTY DRILLING 43

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02

9

19

90

10

-1

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43

19

90

10

0-1

00

02

7

19

90

10

00

-1

00

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13

19

90

10

00

0-1

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01

19

90

10

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+

0

19

91

0-1

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6

19

91

10

-1

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34

19

91

10

0-1

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91

10

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12

19

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1

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92

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52

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211

11

61

19

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10

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61

85

19

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10

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81

41

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73

19

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10

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82

15

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93

Un

kn

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12

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0-1

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10

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53

11

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10

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81

X2

11

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93

10

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19

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10

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51

X3

1

19

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10

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0X

APPENDIX TWO

Petroleum Spills in the Canadian Great Lakes - 1990-1995 (by volume)123

DIRTY DRILLING44

St.

Lake

St. M

arys

Geo

rg

ian

Lake

St. C

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itL

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ake

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Year

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Bay

Hu

ro

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Riv

er

Can

al

On

tario

Riv

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19

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Cru

de

19

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Ga

so

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11

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63

19

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52

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48

22

6

19

90

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11

12

19

21

4

19

90

Oth

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13

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67

29

4

19

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No

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12

2

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To

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72

12

37

13

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47

77

19

91

Cru

de

1

19

91

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33

82

19

91

Lig

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21

36

12

27

24

53

19

91

He

avy P

etro

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m O

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25

51

41

13

19

91

Oth

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18

21

15

19

91

No

n-P

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19

91

To

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l5

16

14

29

51

23

81

5

19

92

Pe

tro

leu

m O

ils (To

ta

l)5

61

32

01

411

11

47

13

19

93

Pe

tro

leu

m O

ils (To

ta

l)6

12

41

25

94

43

12

19

94

Pe

tro

leu

m O

ils (To

ta

l)2

31

89

51

42

53

76

19

95

Pe

tro

leu

m O

ils (To

ta

l)6

14

11

41

24

*3

78

APPENDIX THREE

Petroleum Spills in the Canadian Great Lakes - 1990-1995 (by year)124

DIRTY DRILLING 45

APPENDIX FOUR

Toxic Chemicals in the Natural Gas Cycle

Emissions Sources Resource Categories

Air Emissions

Carbon dioxide (CO2), Releases from drilling equipment, All impact categories

Carbon Monoxide (CO) processing plant, and power plant

stack

Nitrogen oxides/ Releases from drilling equipment, Health effect; biodiversity;

Sulfur dioxide processing plant, and power plant crop production; tree growth

stack

Acid aerosols Formation in atmosphere from Health effects; recreational

NOx and SOx; long-range transport, fishing;crop production; tree

acid deposition growth; biodiversity

Ozone Formation in the atmosphere Health effects; change in crop

from NOx and HC production

Hydrocarbons Fugitive emissions at drilling Biodiversity; recreational and

site, in pipeline, at processing commercial fishing

plant, drilling equipment, power

plant stack

Particulate, Acid aerosols Power plant emissions Health effects; recreational

use of parks

Peroxyacayl nitrate (PAN) Formation in the atmosphere Biodiversity

from NO, and HC

Water Emissions

Offshore: Emissions from offshore Commercial fisheries; recrea-

Produced Water drilling platforms tional fishing; biodiversity

Drilling Fluids

Drill Cuttings

Onshore: Discharge to coastal areas, Biodiversity; Drinking water

Produced Water underground injection, pond or

Drilling Fluids pit storage, landfill

Drill Cuttings

Wastes and wastewater Processing plant, power plant Biodiversity

Land Emissions

Drilling fluids and muds Land or pond disposal at Biodiversity; occupational

drilling sites health effects

Ash Land disposal Biodiversity; groundwater and

soil contamination impacts

Land use Production fields, processing Biodiversity

plant, power plant

Drilling platforms Construction Commercial fishing,

recreational fishing

Dredging Offshore and onshore construction Commercial fishing,

of pipelines; access to onshore biodiversity

coastal areas

Navigation, pipelines Shoreline activities associated Recreational use of

with production shoreline, biodiversity

DIRTY DRILLING46

DIRTY DRILLING 47

1. Testimony of Dr. Jeffrey M. Reutter, Director of

Ohio Sea Grant, before the Ohio State House of Rep-

resentatives, Agriculture and Natural Resources Com-

mittee. 16 May 2001.

2. Lake Erie Protection and Restoration Plan. Ohio

Lake Erie Commission. 2001.

3. Ohio Sport Fish Consumption Advisory: Year 2001

Fishing Season. Ohio Department of Health. 2001.

4. http://www.nemw.org/

5. Letter from Senator George Voinovich to Governor

Bob Taft, 12 March 2001.

6. Culp, Michael. “Taft Strives for Environmental

Legacy.” Cincinnati Enquirer. 06 August 2001.

7. Ohio Revised Code, Section 1505.7.

8. The Ohio Statewide Survey. League of Conserva-

tion Voters Ed Fund. 2000.

9. American Voters Place a High Priority On Envi-

ronmental Protections, Despite Concerns About En-

ergy and the Economy. League of Conservation Vot-

ers Ed Fund. 2001.

10. American Voters Place a High Priority On Envi-

ronmental Protections, Despite Concerns About En-

ergy and the Economy. League of Conservation Vot-

ers Ed Fund. 2001.

11. Natural Gas Prices Yesterday, Today, and Tomor-

row. Energy and Environment Analysis, Inc. 02 Feb-

ruary 2001.

12. http://www.hdiinc.com

13. “Advanced Drilling Systems.” Pierce, K.G.;

Livesay, B.J.; and Finger, J. T. Sandia National Labo-

ratories. 08 April 1996.

14. Personal interview with Lake Michigan Federa-

tion, Tanya Cabala.

15. Ohio Department of Natural Resources, as quoted

in sponsor for Senate Bill 96 by Senator Daniel Brady,

Ohio State Senate, Energy and Natural Resources

Committee.

16. Estimating Externalities of Natural Gas Fuel

Cycles. Oak Ridge National Labs and Resources for

the Future. January 1998. p. 81.

17. ibid.

18. Broken Promises: MNR’s Failure to Safeguard

Environmental Rights. Special Report to the Legis-

lative Assembly of Ontario Submitted by Gord Miller,

Environmental Commissioner of Ontario. June 21,

2001.

19. 1999 NPRI Annual Report. Environment Canada.

http://www.ec.gc.ca/pdb/npri/npri_dat_rep_e.cfm

#annual

20. Sarnia Marine Communications and Traffic Ser-

vices, Canadian Fisheries and Oceans, Canadian Coast

Guard.

21. Cabala, Tanya. “Lake Michigan Oil and Gas Drill-

ing: Worth the Risk?” Lake Michigan Federation,

2001.

22. Summary of Spill Events in Canada – 1984 to 1995.

Spills Action Centre. p. 28.

23. ibid.

24. Canada Oil and Gas Operations Act, Canada Oil

and Gas Production and Conservation Regulations.

P.C. 1990-2473 22 November, 1990.

25. Fisheries News – Lake Erie. Summer 2001.

Ontario Ministry of Natural Resources, Lake Erie Man-

agement Unit.

26. Interview with Rudy Rybansky, Ontario Ministry

of Natural Resources (19 Nov 2001).

27. http://www.ycn.library.ns.ca/georges/www/

explorat.htm

28. Fisheries News – Lake Erie. Summer 2001.

Ontario Ministry of Natural Resources, Lake Erie Man-

agement Unit.

29. Ibid

30. Lake Michigan Drilling: Worth the Risk? Lake

Michigan Federation. 2001.

31. Ohio Lake Erie Commission, 1999.

32. Ohio EPA. Lake Erie Protection & Restoration

Plan.

33. 1.5 billion/365 = 4,109,589.04 dollars per day from

tourism. Yearly natural gas revenues = 20 billion cu-

bic feet at 4.54 per thousand cubic feet = 90,800,000

dollars per year. 90,800,000/365 = 248,767.12 dol-

lars per day from drilling.

34. Lake Erie Protection and Restoration Plan. Ohio

Lake Erie Commission. 2001.

35. Herdendorf, Charles E. Ohio’s North Coast: A

resource in transition (Fact Sheet 034). Ohio Sea

Grant, The Ohio State University. 1987

36. Murray, Chris; Sohngen, Brent; Lichtkoppler,

Frank; and Bielen, Mary. “The Economics of Lake

Erie Beaches: 1998 Lake Erie Beach User Survey

Results.” Columbus, OH: Ohio Sea Grant. 1998.

37. Sohngen, Brent and Murray, Chris. “Valuing Wa-

ter Quality Advisories and Amenities in the Great

Lakes.” http://www-agecon.ag.ohio-state.edu/Faculty/

bsohngen/beach/summ_and_paper.htm

38. Sohngen, Brent; Lichtkoppler, Frank; and Bielen,

Mary. “The Value of Lake Erie Beaches.” Colum-

bus, OH: Ohio Sea Grant. 1999.

NOTES

DIRTY DRILLING48

39. ibid.

40. See, for example, the following: Uyeki, Eugene

S; and Holland, Lani J. “Diffusion of Pro-Environ-

ment Attitudes?” American Behavioral Scientist. Jan

2000, Vol. 43 Issue 4.; Clarke, Andrea; and Bell, Paul

A. “The Influence of Attitude Priming and Social Re-

sponsibility on the Valuation of Environmental Public

Goods.” Environment & Behavior. Nov 99, Vol. 31

Issue 6; and Parker, Julia Dawn; and McDonough,

Maureen H. “Environmentalism of African Ameri-

cans.” Environment & Behavior. Mar 99, Vol 31, Is-

sue 2.

41. Photo courtesy of The Ohio Lake Erie Commis-

sion.

42. Ohio Sea Grant Fact Sheet 047.

43. Ohio Sea Grant Fact Sheet 047.

44. Assumes a 3percent average rate of inflation

through 2001.

45. “Water management plan for Great Lakes signed.”

Environment, 06/19/2001. (www.boatbiz.com)

46. “A lake in transition: Erie changes not all bad, or

all good.” by Don Hopey. Pittsburgh Post-Gazette,

January 16, 2000.

47. Personal interview, Rudy Rubansky, Ontario Min-

istry of the Environment.

48. ibid. Unfortunately, to the author’s knowledge

Canadian laws do not require centralized record-keep-

ing of such incidences. However, Mr. Rubansky re-

layed a few such incidences known to him. Further

research will attempt to document Canadian pipeline

accidents such as these.

49. Testimony of Dr. Jeffrey M. Reutter before the

Ohio State House of Representatives, Agriculture and

Natural Resources Committee. 16 May 2001.

50. See previous section for discussion of ecosystem

impacts of oil and gas drilling.

51. Joseph Sohm; ChromoSohm Inc./CORBIS

52. Estimating Externalities of Natural Gas Fuel

Cycles. Oak Ridge National Labs and Resources for

the Future. January, 1998. p. 6.

53. Don’t Rig Florida’s Future. Bill Wood, Florida

PIRG. June 1993. p. 9.

54. Wills, Jonathan. Muddied Waters: A Survey of

Offshore Oilfield Drilling Wastes and Disposal Tech-

niques to Reduce the Ecological Impact of Sea Dump-

ing. Sakhalin Environment Watch, May 2000.

55. See Potential Environmental Benefits from Regu-

latory Consideration of Synthetic Drilling Muds.

Argonne National Laboratory, Environmental Assess-

ment Division. US DOE. Februrary 1995.

56. See section on regulatory oversight for US EPA

disposal limits and guidelines.

57. Estimating Externalities of Natural Gas Fuel

Cycles. Oak Ridge National Labs and Resources for

the Future. January, 1998. pp. 76-7.

58. Based on 47.36 acres per trillion Btu of energy

produced. Assumes 2,000 active wells producing 20

Bcf natural gas per year. Also assumes a Btu to Tcf

conversion of 1,028,000 to 1.

59. Duke, Thomas W.; and Parrish, Patrick R. “Project

Summary: Results of the Drilling Fluids Research

Program Sponsored by the Gulf Breeze Environmetal

Research Laboratory, 1976-1983, and Their Applica-

tion to Hazard Assessment. US EPA, Gulf Breeze,

FL. Sept. 194. pp. 2-3.

60. Cranford, P.; Querbach K.; Maillet, G.;Grant,

J.;Taggart, C.; and Lee, K. “Effects of Water Based

Drilling Mud on Early Life Stages of Haddock, Lob-

ster, and Sea Scallop.” 5 November 1998.

61. Center for Great Lakes and Aquatic Species.

62. See testimony of Dr. Jeffrey M. Reutter before the

Ohio State House of Representatives, Agriculture and

Natural Resources Committee. 16 May 2001.

63. http://www.epa.gov/glnpo/glindicators/fish/

topfish/topfisha.html

64. Cabala, Tanya. “Lake Michigan Oil and Gas Drill-

ing: Worth the Risk?” Lake Michigan Federation,

2001. p. 11.

65. Framework for a Comparative Environmental As-

sessment of Drilling Fluids. US Department of En-

ergy, Office of Fossil Energy, National Petroleum tech-

nology Office. November 1998. p. 23.

66. ibid.

67. Potential Environmental Benefits from Regulatory

Consideration of Synthetic Drilling Muds. Argonne

National Laboratory, Environmental Assessment Di-

vision. US DOE. Februrary 1995. p. 2.

68. ibid.

69. See the following: Estimating Externalities of

Natural Gas Fuel Cycles. Oak Ridge National Labs

and Resources for the Future. January, 1998; Don’t

Rig Florida’s Future. Bill Wood, Florida PIRG. June

1993; EPA Office of Compliance Sector Notebook

Project: Profile of the Oil and Gas Extraction Indus-

try. US EPA, October 2000. and Produced Water

Discharges to the Gulf of Mexico: Background Infor-

mation for Ecological Risk Assessments. Meinhold,

Anne F.; Holtzmann, Seymour; and DePhillips,

Michael P. US DOE, Bartlesville Project Office. 19

Sept 1996.

DIRTY DRILLING 49

70. Broughton, A.; Fillo, John P.; Hansotte, C.A.;

Koraido, Scott M.; and Wesolowski, D. Character-

ization of Produced Waters from Natural Gas Produc-

tion Operations: Volume I. Chicago, IL: Gas Research

Institute. 1987.

71. See Ohio Department of Natural Resources, Divi-

sion of Mineral Resources Management. “Guidance

on Disposal of Produced Waters.” See also ORC §

1509.22.

72. EPA Office of Compliance Sector Notebook

Project: Profile of the Oil and Gas Extraction Indus-

try. US EPA, October 2000. p. 55.

73. Gulley, David D.; Mount, David R.; Hockett, James

R.; and Bergman, Harold L. “Statistical Model to Pre-

dict Toxicity of Saline Produced Waters to Freshwa-

ter Organisms.” Conference paper, International Pro-

duced Water Symposium. 1992.

74. Bioavailability and Genotoxicity of Produced Wa-

ter Discharges Associated with Offshore Production

Operations: Technical Summary. Minerals Manage-

ment Service, 1995.

75. Effect of Produced-Water Discharge on Bottom

Sediment Chemistry: Technical Summary. Minerals

Management Service, 1999.

76. Long-term Effects of Contaminants from OCS Pro-

duced-water Discharges at Pelican Island Facility,

Louisiana. Minerals Management Service, 1998.

77. Patin, Slanislav. “Gas Impacts on Fish and Other

Marine Organisms.” http://www.offshore-

environment.com/gasimpact.html

78. Methane toxicological information at http://

www.toxnet.nlm.nih.gov/

79. http://www.hdiinc.com

80. Deepwater Program: Literature Review, Environ-

mental Risks of Chemical Products Used in Gulf of

Mexico Deepwater Oil and Gas Operations Volume I:

Technical Report. US Department of the Interior,

Minerals Management Service, Gulf of Mexico OCS

Region. February 2001. pp. 54-6.

81. US EPA IRIS file on lead and compounds (inor-

ganic).

82. US EPA IRIS file on methyl mercury.

83. Baker, Beth. “Mercury in fish: agencies work to

find common ground.” Bioscience. Nov 1998.

84. US EPA IRIS file on chromium VI.

85. ibid.

86. US EPA IRIS file for benzene and naphthalene.

87. Casarett & Doull’s Toxicology: The Basic Sci-

ence of Poisons (Fifth Edition). Kaassen, Curtis D.

(ed). New York: McGraw-Hill Health Professions

Division. 1996.

88. EPA Office of Compliance Sector Notebook

Project: Profile of the Oil and Gas Extraction Indus-

try. US EPA, October 2000. p. 63.

89. Estimating Externalities of Natural Gas Fuel

Cycles. Oak Ridge National Labs and Resources for

the Future. January, 1998. p. 77.

90. See Death, Disease, and Dirty Power. A report

based on research by Abt Associates, Cambridge,

Mass., 2000.

91. Ibid.

92. US EPA IRIS files for mercury, elemental.

93. Canadian-wellsite.com

94. http://ops.dot.gov/stats/NGDIST00.HTM and

http://ops.dot.gov/stats/NGTRAN00.HTM

95. Estimating Externalities of Natural Gas Fuel

Cycles. Oak Ridge National Labs and Resources for

the Future. January, 1998. p. 91.

96. US EPA IRIS file on hydrogen sulfide.

97. Cabala, Tanya. “Lake Michigan Oil and Gas Drill-

ing: Worth the Risk?” Lake Michigan Federation,

2001.

98. ibid.

99. EPA Office of Compliance Sector Notebook

Project: Profile of the Oil and Gas Extraction Indus-

try. US EPA, October 2000. p. 63

100. http://www.dnr.state.oh.us/odnr/oil+gas/

Announcement.htm

101. 2000 Annual Report. Ohio Department of Natu-

ral Resources, Division of Mineral Resources Man-

agement.

102. Section 1509.22(C), Ohio Revised Code.

103. 1509.22(B)(2), Ohio Revised Code.

104. 58 FR 12454.

105. ibid.

106. Four public interest groups in Ohio have peti-

tioned the US EPA for the removal of, among other

programs, the Ohio EPA’s Clean Water Program. The

petition alleges long-standing deficiencies in the per-

mitting and enforcement of NPDES programs in Ohio.

As such, Ohio EPA’s ability to oversee this portion of

the drilling process remains suspect at best.

107. Photo courtesy of The Ohio Lake Erie Commis-

sion.

108. Polluters’ Playground: How the Government Per-

mits Pollution. US PIRG. 2001.

DIRTY DRILLING50

109. Ibid.

110. 4905.90 to 4905.96, Ohio Revised Code.

111. The Office of Pipeline Safety is Changing How it

Oversees the Pipeline Industry. Government Account-

ing Office, May 2000.

112. Lake Michigan Oil and Gas Drilling: Worth the

Risk? Lake Michigan Federation. 2001.

113. Evaluation of Directional Drilling under the Great

Lakes. Michigan Environmental Science Board. Oc-

tober 1997.

114. For a copy of the statement, see the following:

h t tp : / /www.swee twate rv i s ions .com/Pages /

drilling.html

115. Directional Drilling Under the Great Lakes. US

Army Corp of Engineers, Detroit District. 1997.

116. ibid.

117. “House Acts to Block New Oil Drilling in Great

Lakes.” Milwaukee Journal Sentinel, 06/29/2001.

118. Lake Michigan Oil and Gas Drilling: Worth the

Risk? Lake Michigan Federation. 2001.

119. http://www.repowermidwest.org/ohiop2.php

120. 1998 data – 2.8 million residential customers,

used 97 Tcf at $625, with 70percent allocated to heat-

ing – decrease of 10percent in ½ use (source: Ohio

PIRG analysis of EIA data)

121. http://www.repowermidwest.org/ohiop3.php

122. Deepwater Program: Literature Review, Envi-

ronmental Risks of Chemical Products Used in Gulf

of Mexico Deepwater Oil and Gas Operations Vol-

ume I: Technical Report. US Department of the Inte-

rior, Minerals Management Service, Gulf of Mexico

OCS Region. February 2001.

123. Spills Action Centre, Canadian Ministry of the

Environment.

124. Ibid.

DIRTY DRILLING 51

DIRTY DRILLING52