Comment ID: 210824 Comments…

Comment ID: 210824

Comments for Otter Creek wind project, EB 013-1043 August 21, 2017 IMPACT ON WELL WATER DOVER TOWNSHIP WELLS The concern in the region about well water from wind turbine construction and operation began during the construction and operation of the turbines near Marsh Line, near Mitchell's Bay, in the former Dover Township. Problems with damage to nearby wells in this area was raised as far back as August 8, 2012, when Lambton-Kent-Middlesex MPP Monte McNaughton wrote to then Energy Minister Chris Bentley on behalf of a constituent. [1] [1] http://montemcnaughtonmpp.ca/wp-content/uploads/2012/08/August-8-2012-McNaughton-to-Bentley-re-well -water-2.pdf Some of the comments in Mr. McNaughton's letter include: “It has been brought to my attention by a constituent that recent construction of wind turbines near Mitchell's Bay south of Wallaceburg is contaminating his well water. As you are no doubt aware the construction of foundations for wind turbines in this area involves pushing steel beams deep into the soil. This action has evidently disrupted the aquifer and caused the otherwise 'sweet' well water of my constituent to turn murky and non potable.” And the very prophetic comment: “Minister, I bring this issue forward at this time to give you notice that the deep foundations required by wind turbines may be causing unforeseen problems with rural water supplies.” Several other rural residents in Dover Township have reported significant turbidity in their well water during construction of the wind project several years ago that have continued until the present. At a public meeting near Wallaceburg held by concerned citizens in August 2016, samples of well water from the Dover Township were on display. The water was visibly turbid and had the unmistakeable odour of hydrocarbons. It could not possibly be considered potable. NORTH KENT WIND PROJECT On June 29, 2016, the North Kent I wind project was granted a Renewable Energy Approval (REA) by the MOECC. Due to concerns expressed by local residents, that REA contains several requirements for a seismic survey and well water testing, as well as a commitment for the developers to provide potable water in sufficient quantities for farming operations. The North Kent proponents have commissioned a literature review [2] of the seismic issues from wind turbines by Golder Associates, a member of CanWEA, the Canadian Wind Energy Association. [2]http://northkentwind.com/files/8514/7672/1123/NKW1_Golder_Evaluation_of_GeoNorthKent1_2016_0923. pdf This report claims the turbines are unlikely to affect the nearby water wells; however, all the studies and data presented were undertaken in areas other than Dover Township, North Kent or Otter Creek project areas. Recent events in the North Kent wind project have shown that the assumptions made by Golder and their optimistic opinion were not warranted. There have been reports that 5 complaints of damage to water wells in the North Kent project area, since the start of pile driving for the turbine bases, have been submitted. At least one well on Brook Line, north of Chatham [3] was confirmed as contaminated with sediment by the MOECC. [3] http://www.chathamdailynews.ca/2017/08/02/sediment-so-thick-it-prevents-water-from-coming-through-t aps-of-chatham-township-familys-home In the Brook Line case, the sediment was enough to plug the four sediment trap filters the well owners had installed and stop the flow of water. The well owners found they had to clean the trap filters every six hours, or the flow of water would again be blocked. The North Kent developers' public response to this incident came in the form of a media statement [4] released by North Kent Project Development Manager, Jody Law, and included the following comment: “The preliminary update from AECOM’s field staff is that, with no remedial work required, they were able to run a faucet continuously with no issues. The sample was visually clear and colorless with no visible sediment. We have requested expedited analysis from the lab but, at this point, there is no empirical evidence of an issue” [4] http://www.ckreview.ca/2017/08/north-kent-wind-issues-statement-regarding-recent-water-well-complai nt/ This assessment was contradicted by the well owners and another observer [5] who commented that the water sample was obtained with difficulty. Furthermore, the well owners received a preliminary report from the MOECC stating that the sample of well water the MOECC had collected had a turbidity of 86.4 NTU's. It could not be considered “visually clear and colorless” [5] http://www.chathamdailynews.ca/2017/08/09/preliminary-results-indicate-turbidity-of-water-is-well-a bove-acceptable-level Visually inspecting the tap water and declaring “there is no empirical evidence of an issue” has resulted in the public perception of bias on the part of the consultant and developers, and an attempt to deny or minimize the problem. OTTER CREEK WIND PROJECT Given that the Otter Creek project will sit on top of the same Kettle Point bedrock formation with the same type of overburden, and on top of the same aquifer, the nearby residents are understandably concerned. The Otter Creek developers have also commissioned a study by the engineering firm, GHD Group,[6] to evaluate the Golder Report. [6] http://ottercreekwindfarm.ca/wp-content/uploads/2013/06/B5_06a_App-F.pdf This report is another review of a literature review that is based on other studies in other areas, none of which are anywhere near the North Kent, Otter Creek, or Dover Township wind projects. The conclusions in the GHD Group's study mirror the same conclusions in the Golder Report. The Summary and Conclusions in the GHD report, and quoted in Otter Creek's media [7] announcing its application for a Renewable Energy Approval includes the following statements: “Based on the similarity of geologic conditions confirmed by GHD at the Otter Creek Site and those presented in the Golder Report, GHD believes that the Golder Report conclusions are applicable to the Otter Creek Site.” “The Report concludes, and GHD concurs, that given that the typical residential well pump operational vibration intensity threshold is in the range of 3 to 9 mm/s, it is highly unlikely (nearly impossible) that vibrations induced by pile driving can cause dislodgement of sediments that would not be otherwise dislodged by existing pump vibration.” “GHD is not aware of any report or study confirming a plausible mechanism for vibrations induced by wind turbine operations to cause sediment dislodgement at distances beyond the common turbine exclusion zones.” “Based on these conclusions, Otter Creek does not anticipate that either the construction or operation of the facilities will have any negative impact on water wells.” [7] http://ottercreekwindfarm.ca/wp-content/uploads/2013/06/OCWF-Media-note-REA-submission.pdf The comment that “Otter Creek does not anticipate that either the construction or operation of the facilities will have any negative impact on water wells.” has been shown to be unwarranted and premature by the contamination of the well on Brook Line. If the Otter Creek developers and their GHD consultants believe that “the Golder Report conclusions are applicable to the Otter Creek Site.” then they must also accept that the experience with the well on Brook Line in the North Kent project zone would also be likely with a well in the Otter Creek project zone. IMPACT ON BEDROCK - FRACTURES IN THE BEDROCK The West Dover, North Kent and Otter Creek project zones are all above the Kettle Point bedrock formation consisting of black shale. The Golder Report (Reference [2] above, Section 7.4.2.1 Computer-Aided Hydrogeological Modelling) opines that bedrock fracture is limited to the possibility of fractures caused by pile driving for the turbine base supports in an area with a diameter of 24 meters, the same area contained in the perimeter of driven piles. “For the purposes of modelling and as an extreme case, it was assumed that piles driven into the shale bedrock create a fully fractured zone about half a metre thick and 24 m in diameter (within the full perimeter of driven piles) .....” Otter Creek's GHD report supports this assumption as a “conservative approach”. From Section 6. Review of Hydrogeological Numerical Modelling, Conceptual Model , page 7: “Rather than the more possible localized fracture that would occur in each pile, it was assumed that the installation of turbine piles created a fully fractured zone of 0.5 m thick and 24 m in diameter. ..... Such representation was a conservative approach as it was deliberately chosen to be biased toward the potential for more adverse fracture and flow condition in the shale bedrock.” However, neither the Golder report, nor the GHD report, present data to back up their assumption that fractures from pile driving would be limited to an area 24 meters in diameter. PRESENCE OF SHALE GAS The GHD report acknowledges that the Kettle Point black shale bedrock contains shale gas consisting mainly of methane gas: From the GHD Group report: Section 3. Review of North Kent Site Geologic and Hydrogeologic Conditions; Bedrock “The Devonian-age Kettle Point Formation is composed of black organic rich shale and siltstone. The Report indicates that the Kettle Point Formation is not considered to contain oil or water, although low pressure natural gas is found in Kent County and southwestern Lambton County. The Kettle Point Formation consists of up to 105 m of organic-rich shales (Otis, 2011). Otis (2011) documented the presence of shale gas within the Kettle Point Formation, composed primarily of methane, but did not indicate whether the shale gas may be economically viable.” No further mention is made of shale other than to acknowledge its existence in the Kettle Point bedrock. SUMMARY COMMENTS The GHD and Golder Reports are based on a series of assumptions that the conditions and observations reported in other studies, from different regions, none of which are anywhere near the Dover Township, North Kent, or Otter Creek wind projects, would also apply to the local projects. With any expert opinion or conclusions, the more assumptions that must be made, the less likely that the conclusions are correct. The Kettle Point black shale bedrock formation is rich in organic compounds and shale gas, and extends from Kettle Point on the shores of Lake Huron to the project areas for both the North Kent and Otter Creek wind projects. It also extends under the Marsh Line wind project where water from several wells is no longer potable after the nearby wind turbines were installed and operated. The experience with the water well on Brook Line in the North Kent project zone indicates that the assumptions in the Golder and GHD reports are unfounded, and their conclusions of “no damage”, or “nearly impossible” damage, to nearby wells are incorrect. Despite the seismic testing requirements for the North Kent project, there does not appear to be any protocol to respond to a well failure for the North Kent project developers, other than supplying bulk water to the residents. The continued construction activity in the North Kent project indicates the lack of any protocol requiring the project developers to address the root cause of any problems that may arise before more wells are damaged. Neither the North Kent nor the Otter Creek REA documents include any fracture trace mapping to determine the existing bedrock fractures; nor do they comment on the potential impact of pile driving on the existing fractures. Neither the Golder nor the GHD Report, nor the REA documents for the North Kent or Otter Creek projects, comment on the weight of the turbines that will be coupled to the black shale bedrock in the local projects; and none of them comment on the expected lateral vibrations at the bedrock, or the actual force that would be exerted on the bedrock by the weight and vibrations from each turbine. The manufacturer of the Enercon E-141 EP4 turbines proposed by the Otter Creek developers did not report the gross weight of the turbine and base; however, the Otter Creek construction report states that each base will use “up to 125 trucks” of concrete. Assuming a 7 cubic meters per truckload and a weight of 2400 kg per cubic meter of concrete; each turbine base will contain 875 cubic meters of concrete with a weight of more that 2100 metric tons. The potential for large scale fractures from 12 Enercon E-141 EP4 turbines that are seismically coupled to the Kettle Point black shale bedrock is unknown and has not been addressed by the developers and their consultants. The potential impact from the combination of large scale fractures and the presence of shale gas in the bedrock is unknown and has not been addressed by either the Golder report or the GHD report. One example of the potential impact from fractured bedrock and the presence of shale gas was demonstrated at the recent methane eruption at the Indian Hills golf course in Lambton Shores. https://www.youtube.com/watch?v=UdYum6v48S8 The assumption made was that this gas eruption was “naturally occurring” and a “one in a billion” event. All parties involved in the investigation have avoiding commenting on any possible relationship to the dozens of wind turbines in the area around the Indian Hills golf course. Given the experiences with wells near Marsh Line, and the Brook Line, there is enormous potential for environmental damage to the aquifer and the water wells in the Otter Creek area. RECOMMENDATIONS Recommendation 1: The Otter Creek developers should not be awarded an REA until the results of the seismic testing, and the well water analysis, both baseline and post-startup, from the North Kent wind project have been analyzed, and the cause of any damage to nearby wells has been determined. Recommendation 2: The Otter Creek developers should not be awarded an REA until the North Kent developers can provide tangible proof that pile driving or post-startup operation of the project will not cause further damage to the water wells in that project area. Recommendation 3: If or when an REA is awarded to the Otter Creek project, it should include: i) the requirement for fracture trace mapping of any existing fractures in the bedrock prior to any construction activities. ii) the requirement that no turbine bases be constructed on any existing bedrock fractures. iii) all of the sections G and H contained in the North Kent REA. iv) the requirement that the proponents install inline turbidity meters, with data loggers, at key wells within the project area prior to construction and monitor the water turbidity continuously until the turbines have been in operation for at least one year. For any wells with in-line trap filters, the water is to be monitored pre and post the trap filters. v) the requirement that any change in the well turbidity, or any damage to any of the wells, be addressed immediately and any construction activity cease until the developers can prove that further activities will not result in further damage to the wells. vi) full analysis of the water quality, both pre construction and post startup, at all wells within the project area, assuming permission is given by the well owners. Analyses are to include: total dissolved solids, total suspended solids, conductivity, nitrate, nitrites, PH, Anion/Cation, Volatile Organic compounds, isotopes for ground water age, heavy metals including arsenic, mercury, lead, uranium and radio nucleotides including radium and radon. Recommendation 4: The response of the North Kent developers to the Brook Line incident has resulted in the public's perception of bias on the part of the developers and a lack of objectivity on the part of their consultants. To regain the trust of the public, any monitoring and testing on wells in the Otter Creek project should be at the expense of the developers, but conducted by an independent laboratory reporting directly to the MOECC with all results to be shared with the well owners. Recommendation 5: If or when the Otter Creek developers are awarded an REA, and in the event that a well is damaged, the developers are to provide permanent mitigation at their expense and to the well owners satisfaction. The developers are also to provide compensation for loss of property value for any stigma resulting from the damaged well.