Thank you.
It is reasonable to expect that water will drain from an upper freshwater formation into the lower saltwater formations due to depressurization from previous conventional gas and oil production. To my knowledge, there has never been a study done to determine the probable effect of having 8- to 16-million vertical conduits installed that are capable of transferring potable groundwater to deep saline zones. That water is gone forever.
The new regulations do not require the industry to repair surface casings or leaks on conventional wells. All that is required is to connect the surface casing vent to the gas sales pipeline. There is no requirement to identify how much water is flowing down the old well bore and into deep saline conventional zones. This water will be lost forever, and it will certainly never reach Hudson Bay.
The new regulations allow for unrestricted injection of formation stimulants such as benzene, toluene, xylene, synthetic olifins, and methanol into freshwater zones below 600 metres. This is achieved by a process called “fraccing”. Tons of these chemicals are currently being used. This contaminated groundwater will eventually surface as river flow. Based on a 30-year-old incomplete database, the base of groundwater protection is actually set at less than 600 metres in many areas. In other words, these toxins are now being injected into freshwater formations as shallow as 200 metres.
The industry-inspired new regulations do not protect groundwater at all below 600 metres from chemical injection, even though we have known areas of pristine groundwater in the foothills that are a kilometre and a half deep—