Публикувам един изключителен доклад за въздействието от фракинга, изготвен по поръчка на правителството на щата Ню Йорк
https://www.health.ny.gov/
https://www.health.ny.gov/
December 17, 201.
Hon. Joseph Martens Commissioner New York State Department
of Environmental Conservation 625 Broadway Albany, NY 1220.
Dear Commissioner Martens: In September 2012, you asked Dr.
Shah, then Commissioner of Health, to initiate a Public Health Review of the
Department of Environmental Conservation’s draft Supplemental Generic
Environmental Impact Statement for High Volume Hydraulic Fracturing (HVHF). I
assumed responsibility for this review when Dr. Shah left. It became clear
during this assessment that DOH’s Public Health Review needed to extend beyond
the scope of the initial request to consider, more broadly, the current state
of science regarding HVHF and public health risks. This required an evaluation
of the emerging scientific information on environmental public health and
community health effects. This also required an analysis of whether such
information was sufficient to determine the extent of potential public health impacts
of HVHF activities in New York State (NYS) and whether existing mitigation
measures implemented in other states are effectively reducing the risk for
adverse public health impacts.
As with most complex human activities in modern societies,
absolute scientific certainty regarding the relative contributions of positive
and negative impacts of HVHF on public health is unlikely to ever be attained.
In this instance, however, the overall weight of the evidence from the cumulative
body of information contained in this Public Health Review demonstrates that
there are significant uncertainties about the kinds of adverse health outcomes
that may be associated with HVHF, the likelihood of the occurrence of adverse
health outcomes, and the effectiveness of some of the mitigation measures in
reducing or preventing environmental impacts which could adversely affect public
health. Until the science provides sufficient information to determine the
level of risk to public health from HVHF to all New Yorkers and whether the
risks can be adequately managed, DOH recommends that HVHF should not proceed in
NYS.
I appreciate the opportunity to conduct this Public Health
Review. It furthers the long history of close collaboration between the two
Departments carrying out our shared responsibility to protect human health and
the environment.
Sincerely, Howard A. Zucker, M.D., J.D.
Acting Commissoner of Health 2/13/201.
Errata A Public Health Review of High Volume
Hydraulic Fracturing for Shale Gas Development It has come to the attention of
the Department of Health (DOH) that the Public Health Review document posted on
the DOH web site on December 17, 2014 contained two errors requiring
correction: 1. The following text (enclosed in ‘ ‘) was inadvertently omitted
from the beginning of page 41 and has been added back to the document to complete
the sentence started at the end of page 40: [ODNR] ‘says that it will develop
new criteria and permit conditions for new applications in light of this change
in policy. The department will also review previously issued permits for wells
that have not been drilled.’ As a consequence of the omission, the formatting
of the next section heading, beginning on page 41, was also incorrect and has
been corrected: Conclusions – Health and Environmental Literature 2.
Endnote 4 listed on page 89 referred to a web link that had been removed from
the document before it was finalized. That endnote was deleted, and all
subsequent endnotes were renumbered accordingly (i.e., original-endnote 5
became new-endnote 4, etc.).
In addition, a number of minor typographical errors have
been corrected in the amended version of the document. These include the
following changes: 1. deletion of an additional blank space character following
periods: pages 21, 25, 48, and 56; 2. addition of a missing blank space
character: pages 23, 25, 32, and 36; 3. addition of a missing period character:
pages 21 and 29; 4. correction of acronyms for US EPA and US DOL: pages 5, 7,
35, 36, 104 and, 105; 5. correction of the date from 2012 to 2014 for reference
to an IOM report: page 43; and 6. correction of the date of the reference to an
US EPA document and addition of a missing closing parenthesis in endnote 4
(originally numbered 5): page 89.
None of these corrections to the Public Health Review
document result in any substantive change to the meaning of the document or the
document’s conclusions.
Table of Contents |
Executive Summary
..........................................................................................1
Public
Health Review Process .........................................................................
15 |
Results Evaluation of Scientific Literature Relevant to the Objectives of
the Public Health Review
.............................................................................
17 HVHF
Health Outcome Studies
....................................................................... 18 Birth
Outcomes
............................................................................................
19 Case
Series and Symptom Reports
............................................................. 22 Local
Community Impacts ............................................................................
24 Cancer
Incidence
.........................................................................................
25 Non-peer-reviewed
Information
.................................................................... 26
HVHF
Environmental Studies
.......................................................................... 26
Air
Quality Impacts
.......................................................................................
26 Water
Quality Impacts ..................................................................................
35 Induced
Earthquakes
...................................................................................
39 Conclusions – Health and Environmental Literature
........................................ 4.
|
Results Information Gathered from Outside Authoritative Organizations, Public
Health Experts, and Formal Health Impact Assessments .................. 42
Health
Impact Assessments ............................................................................
42 Meetings
with Other State Agencies
................................................................ 49 California
......................................................................................................
50 Texas
...........................................................................................................
51 Illinois
...........................................................................................................
53 Public
Health Expert Consultation ...................................................................
55 |
Overall Conclusions
........................................................................................
85 |
Endnotes
..........................................................................................................
89 |
References
.......................................................................................................
92 |
Appendix 1 .....................................................................................................
109 Supplemental
Literature Considered for the Public Health Review ............... 109 |
Appendix 2 Radon Screening Analysis
..................................................... 172 Radon
from Natural Gas
............................................................................
173.
| Executive Summary The New York State Department of
Health (DOH) is charged with protecting the public health of New Yorkers. In
assessing whether public health would be adequately protected from a complex
activity such as high volume hydraulic fracturing (HVHF), a guarantee of
absolute safety is not required. However, at a minimum, there must be sufficient
information to understand what the likely public health risks will be.
Currently, that information is insufficient.
In 2012, the New York State Department of Environmental
Conservation (DEC) requested that DOH review and assess DEC’s analysis of
potential health impacts contained in DEC’s draft supplemental generic
environmental impact statement (SGEIS) for HVHF. In response to the original
request from DEC, DOH initiated an HVHF Public Health Review process. In
conducting this public health review DOH: (i) reviewed and evaluated scientific
literature to determine whether the current scientific research is sufficient
to inform questions regarding public health impacts of HVHF; (ii) sought input
from three outside public health expert consultants; (iii) engaged in field visits
and discussions with health and environmental authorities in states with HVHF activity;
and (iv) communicated with multiple local, state, federal, international, academic,
environmental, and public health stakeholders. The evaluation considered the
available information on potential pathways that connect HVHF activities and environmental
impacts to human exposure and the risk for adverse public health impacts.
Based on this review, it is apparent that the science
surrounding HVHF activity is limited, only just beginning to emerge, and
largely suggests only hypotheses about potential public health impacts that
need further evaluation. That is, many of the
.
published reports investigating both environmental impacts
that could result in human exposures and health implications of HVHF activities
are preliminary or exploratory in nature. However, the existing studies also
raise substantial questions about whether the risks of HVHF activities are
sufficiently understood so that they can be adequately managed. Furthermore,
the public health impacts from HVHF activities could be significantly broader
than just those geographic locations where the activity actually occurs, thus
expanding the potential risk to a large population of New Yorkers.
As with most complex human activities in modern societies,
absolute scientific certainty regarding the relative contributions of positive
and negative impacts of HVHF on public health is unlikely to ever be attained.
In this instance, however, the overall weight of the evidence from the
cumulative body of information contained in this Public Health Review
demonstrates that there are significant uncertainties about the kinds of
adverse health outcomes that may be associated with HVHF, the likelihood of the
occurrence of adverse health outcomes, and the effectiveness of some of the
mitigation measures in reducing or preventing environmental impacts which could
adversely affect public health. Until the science provides sufficient
information to determine the level of risk to public health from HVHF to all
New Yorkers and whether the risks can be adequately managed, DOH recommends
that HVHF should not proceed in New York State.
Scope of the Public Health Review DOH evaluated
whether the available scientific and technical information provides an adequate
basis to understand the likelihood and magnitude of risks for adverse public health
impacts from HVHF activities in New York State. DOH reviewed how HVHF activities
could result in human exposure to: (i) contaminants in air or water; (ii)
naturally occurring radiological materials that result from HVHF activities;
and (iii) the effects of
.
HVHF operations such as truck traffic, noise, and social
changes on communities. DOH also reviewed whether those exposures may result in
adverse public health outcomes.
Public Health Review Process The initial component of
the Public Health Review focused on understanding how public health concerns
were addressed in the draft SGEIS. Three nationally recognized experts
participated as consultants to the initial phase of the review process. The
expert consultants reviewed elements of the draft SGEIS and documentation
developed by DOH, and provided extensive input through multiple rounds of
communication.
As a result of this input, as well as broader consideration,
it became clear that DOH’s Public Health Review needed to extend beyond this
initial assessment to consider, more broadly, the current state of science
regarding HVHF and public health risks. This required an evaluation of the
emerging scientific information on environmental public health and community
health effects. This also required an analysis of whether such information was
sufficient to determine the extent of potential public health impact of HVHF
activities in NYS and whether existing mitigation measures implemented in other
states are effectively reducing the risk for adverse public health impacts.
In addition to evaluating published scientific literature,
former Commissioner Shah, Acting Commissioner Zucker, and DOH staff consulted
with state public health and environmental authorities to understand their
experience with HVHF. Former Commissioner Shah, Acting Commissioner Zucker, and
DOH staff also engaged in a number of discussions and meetings with researchers
from academic institutions and government agencies to learn more about planned
and ongoing studies and assessments of the public health implications of HVHF.
In total, more than 20 DOH
.
senior Research Scientists, Public Health Specialists, and
Radiological Health Specialists spent approximately 4500 hours on this Review.
Major Findings Summarized below are some of the
environmental impacts and health outcomes potentially associated with HVHF
activities: •Air impactsthat could affectrespiratory healthdue to
increased levels of particulate matter, diesel exhaust, or volatile organic
chemicals.
•Climate change impactsdue to methane and other
volatile organic chemical releases to the atmosphere.
•Drinking water impactsfrom underground migration of
methane and/or fracking chemicals associated with faulty well construction.
•Surface spills potentially resulting insoil and water
contamination.
•Surface-water contaminationresulting from inadequate
wastewater treatment.
•Earthquakesinduced during fracturing.
•Community impactsassociated with boom-town economic
effects such as increased vehicle traffic, road damage, noise, odor complaints,
increased demand for housing and medical care, and stress.
Additionally, an evaluation of the studies reveals critical
information gaps. These need to be filled to more fully understand the
connections between risk factors, such as air and water pollution, and public
health outcomes among populations living in proximity to HVHF shale gas operations
(Penning, 2014; Shonkoff, 2014; Werner, 2015).
.
Some of the most significant environmental and
health-outcome studies are briefly summarized here.
Air Impacts Studies provide evidence of uncontrolled
methane leakage, emissions of other volatile organic chemicals, and particulate
matter from well pads and natural-gas infrastructure.
State authorities in both Texas and Pennsylvania have
documented methane leakage from natural gas infrastructure by the use of
infrared cameras. A recent West Virginia study also determined that heavy
vehicle traffic and trucks idling at well pads were the likely sources of
intermittently high dust and benzene concentrations, sometimes observed at
distances of at least 625 feet from the center of the well pad (McCawley, 2012,
2013; WVDEP, 2013). These emissions have the potential to contribute to community
odor problems, respiratory health impacts such as asthma exacerbations, and
longer-term climate change impacts from methane accumulation in the atmosphere (Allen,
2013; Bunch, 2014; CDPHE, 2010; Macey, 2014; Miller, 2013; Petron, 2012; Weisel,
2010).
Water-quality Impacts Studies have found evidence for
underground migration of methane associated with faulty well construction
(Darrah, 2014; US EPA, 2011). For example, a recent study identified
groundwater contamination clusters that the authors determined were due to gas
leakage from intermediate-depth strata through failures of annulus cement,
faulty production casings, and underground gas well failure (Darrah, 2014).
Shallow methane- migration has the potential to impact private drinking water
wells, creating safety concerns due to explosions.
.
Other studies suggest additional sources of potential water
contamination, including surface spills and inadequate treatment and disposal
of radioactive wastes (Warner, 2013). A recent review paper presented published
data revealing evidence for stray gas contamination, surface water impacts, and
the accumulation of radium isotopes in some disposal and spill sites (Vengosh,
2014). One recent study also suggests that chemical signals of brine from deep
shale formations can potentially be detected in overlying groundwater aquifers
(Warner, 2012). These contaminants have the potential to affect drinking water
quality.
Seismic Impacts Recent evidence from studies in Ohio
and Oklahoma suggest that HVHF can contribute to the induction of earthquakes
during fracturing (Holland, 2014; Maxwell, 2013).
Although the potential public health consequence of these relatively
mild earthquakes is unknown, this evidence raises new concerns about this
potential HVHF impact.
Community Impacts There are numerous historical
examples of the negative impact of rapid and concentrated increases in
extractive resource development (e.g., energy, precious metals) resulting in
indirect community impacts such as interference with quality-of-life (e.g.,
noise, odors), overburdened transportation and health infrastructure, and disproportionate
increases in social problems, particularly in small isolated rural communities
where local governments and infrastructure tend to be unprepared for rapid
changes (Headwaters, 2013). Similar concerns have been raised in some communities
where HVHF activity has increased rapidly (Stedman, 2012; Texas DSHS, 2010;
Witter, 2010; WVDEP, 2013).
.
A recent study from Pennsylvania also reports that
automobile and truck accident rates in 2010–2012 from counties with heavy HVHF
activity were between 15% and 65% higher than accident rates in counties
without HVHF. Rates of traffic fatalities and major injuries were higher in
2012 in heavy drilling counties in southwestern Pennsylvania compared to
non-drilling counties (Graham, 2015).
Health Outcomes near HVHF Activity Although
well-designed, long-term health studies assessing the effect of HVHF activity on
health outcomes have not been completed, there is published health literature
that examines health outcomes in relation to residential proximity to HVHF well
pads. One peer-reviewed study and one university report have presented data
indicating statistical associations between some birth outcomes (low birth
weight and some congenital defects) and residential proximity of the mother to
well pads during pregnancy (Hill, 2012; McKenzie, 2014). Proximity to
higher-density HVHF well pad development was associated with increased
incidence of congenital heart defects and neural-tube defects in one of the
studies (McKenzie, 2014).
Several published reports present data from surveys of
health complaints among residents living near HVHF activities. Commonly
reported symptoms include skin rash or irritation, nausea or vomiting,
abdominal pain, breathing difficulties or cough, nosebleeds, anxiety/stress,
headache, dizziness, eye irritation, and throat irritation in people and farm
animals within proximity to HVHF natural gas development (Bamberger, 2012;
Finkel, 2013; Steinzor, 2012). Federal investigators have also reported that
sub-standard work practices and deficient operational controls at well pads contributed
to elevated crystalline silica exposures among workers during HVHF operations
(US DOL, 2012). While this report focused on worker exposures, it highlights
.
a possible exposure concern for residents living close to
HVHF operations if silica emissions from onsite operations are not properly
controlled.
Substantial Gaps Remain Systematic investigations
studying the effects of HVHF activity on groundwater resources, local-community
air quality, radon exposure, noise exposure, wastewater treatment, induced
seismicity, traffic, psychosocial stress, and injuries would help reduce
scientific uncertainties. While some of the on-going or proposed major study initiatives
may help close those existing data gaps, each of these alone would not adequately
address the array of complex concerns related to HVHF activities.
For example: Marcellus Shale Initiative Study Geisinger
Health System, the lead organization in the collaborative Marcellus Shale Initiative,
cares for many patients in areas where shale gas is being developed in Pennsylvania.
They began pilot studies in 2013 using well and infrastructure data to estimate
exposures to all aspects of Marcellus shale development in Pennsylvania.
According to the National Institutes of Health (NIH)
abstract, they will use these exposure estimates to evaluate whether asthma
control and pregnancy outcomes are affected by Marcellus shale development by
studying 30,000 asthma patients and 22,000 pregnancies in the Geisinger Health
System from 2006-13. Results from this study are not expected to be available
for several years.
.
University of Colorado at Boulder, Sustainability
Research Network A five-year cooperative agreement funded by the National
Science Foundation (NSF) under NSF’s Sustainability Research Network
competition, this program involves a multidisciplinary team of investigators
and is intended to address: “the conflict between natural gas extraction and
water and air resources protection with the development of a
social-ecological system framework with which to assess the conflict and
to identify needs for scientific information. Scientific investigations
will be conducted to assess and mitigate the problems. Outreach and
education efforts will focus on citizen science, public involvement, and
awareness of the science and policy issues”(Univ. Colorado, 2012;
Shonkoff, 2014).
Published research has been produced from this program
investigating associations between HVHF activity and birth outcomes and
potential for methane leakage from natural gas infrastructure. The cooperative
agreement extends to 2017.
EPA's Study of Hydraulic Fracturing and Its Potential
Impact on Drinking Water Resources Begun in 2011, the purpose of the
study is to assess the potential impacts of hydraulic fracturing on drinking
water resources, if any, and to identify the driving factors that may affect
the severity and frequency of such impacts. The research approach includes: analyses
of existing data, scenario evaluations, laboratory studies, toxicity studies,
and case studies. US EPA released a progress report on December 21, 2012 and
stated that preliminary results of the study are expected to be released as a
draft for public and
1.
peer review as soon as the end of 2014, although the full
study is not expected to be completed before 2016.
Pennsylvania Department of Environmental Protection (PA
DEP) Comprehensive Oil and Gas Development Radiation Study Started
in early 2013, PA DEP is analyzing the radioactivity levels in produced and flowback
waters, wastewater recycling, treatment sludges, and drill cuttings, as well as
issues with transportation, storage, and disposal of drilling wastes, the
levels of radon in natural gas, and potential exposures to workers and the
public. According to a July 2014 update from the PA DEP, publication of a
report could occur as soon as the end of 2014.
University of Pennsylvania Study A proposed study of
HVHF health impacts was announced several months ago. The study is led by
researchers from the University of Pennsylvania in collaboration with scientists
from Columbia University, Johns Hopkins University, and the University of North
Carolina.
Pennsylvania Department of Environmental Protection Recently
proposed community air monitoring will determine concentrations of fine and coarse
(silica-sized) particles near a transfer facility that handles hydraulic
fracturing silica sand.
These major study initiatives may eventually reduce
uncertainties regarding health impacts of HVHF and could contribute to a much
more complete knowledge base for
1.
managing HVHF risks. However, it will be years before most
of these major initiatives are completed.
Other governmental and research institutes have also
recently conducted health impact assessments of HVHF (Institute of Medicine,
2014). These include: the European Commission; University of Michigan, Graham
Sustainability Institute; Research Triangle Environmental Health Collaborative;
Nova Scotia Independent Panel on Hydraulic Fracturing; Inter-Environmental
Health Sciences Core Center Working Group on Unconventional Natural Gas
Drilling Operations funded by the National Institute of Environmental Health
Sciences; and the Maryland Institute for Applied Environmental Health, School
of Public Health, University of Maryland. While these assessments identify many
of the same potential environmental impacts mentioned above, more importantly,
they reiterate that significant gaps exist in the knowledge of potential public
health impacts from HVHF and of the effectiveness of some mitigation measures.
Conclusions HVHF is a complex activity that could
affect many communities in New York State. The number of well pads and
associated HVHF activities could be vast and spread out over wide geographic
areas where environmental conditions and populations vary. The dispersed nature
of the activity magnifies the possibility of process and equipment failures,
leading to the potential for cumulative risks for exposures and associated adverse
health outcomes. Additionally, the relationships between HVHF environmental impacts
and public health are complex and not fully understood. Comprehensive, long- term
studies, and in particular longitudinal studies, that could contribute to the understanding
of those relationships are either not yet completed or have yet to be initiated.
In this instance, however, the overall weight of the evidence from the
1.
cumulative body of information contained in this Public
Health Review demonstrates that there are significant uncertainties about the kinds
of adverse health outcomes that may be associated with HVHF, the likelihood of
the occurrence of adverse health outcomes, and the effectiveness of some of the
mitigation measures in reducing or preventing environmental impacts which could
adversely affect public health.
While a guarantee of absolute safety is not possible, an
assessment of the risk to public health must be supported by adequate
scientific information to determine with confidence that the overall risk is
sufficiently low to justify proceeding with HVHF in New York. The current
scientific information is insufficient. Furthermore, it is clear from the existing
literature and experience that HVHF activity has resulted in environmental impacts
that are potentially adverse to public health. Until the science provides
sufficient information to determine the level of risk to public health from
HVHF and whether the risks can be adequately managed, HVHF should not proceed
in New York State.
1.
| Background In 1992, the NYS Department of
Environmental Conservation (DEC) finalized the Generic Environmental Impact
Statement (1992 GEIS) on the Oil, Gas and Solution Mining Regulatory
Program.1,2Conventional natural gas development in NYS – including the use of
low-volume hydraulic fracturing – has been permitted by DEC under the GEIS
since that time. High-volume hydraulic fracturing (HVHF), which is often used in
conjunction with horizontal drilling and multi-well pad development, is an
approach to extracting natural gas that raises new, potentially significant,
adverse impacts that were not studied in the 1992 GEIS. Therefore, in 2008 DEC
began the process of developing a supplement to the GEIS (hereafter the draft
SGEIS) specifically addressing natural gas development using HVHF and directional
drilling in unconventional formations such as the Marcellus and Utica Shales
(collectively referred to here as HVHF shale-gas development).
In 2012, DEC requested that the New York State Department of
Health (DOH) review and assess DEC’s analysis of potential health impacts
contained in DEC’s draft supplemental generic environmental impact statement
(draft SGEIS3) for HVHF. In response to the original request from DEC, DOH
initiated an HVHF Public Health Review process. DOH has a long history of working
closely with DEC on all DEC programs that have public health components. DOH
has extensive expertise in environmental health, including protecting drinking
water supplies, environmental radiation protection, toxicology, environmental
exposure assessment, occupational health, and environmental epidemiology. DOH
also collects, manages, and analyzes extensive public health surveillance data
for all of New York State.
1.
DOH is charged with defending the public health of New
Yorkers. In order to meet this charge with respect to HVHF, DOH reviewed and
evaluated relevant emerging scientific literature that investigated the
environmental health and community health dimensions of HVHF. The literature
was assessed in terms of the adequacy of the current science to inform
questions regarding public health impacts of HVHF. As part of this review, DOH
also sought input from three outside public health expert consultants, engaged
in discussions and field visits with health and environmental authorities in
states with HVHF activity, and held numerous meetings with local, state,
federal, international, academic, environmental, and public health
stakeholders. The evaluation considered the available information on all
potential pathways that connect HVHF activities and environmental impacts to
human exposure and the risk for adverse public health impacts.
HVHF shale-gas development is a large-scale, complex issue
that potentially could affect a significant portion of New York State. In order
to make an informed assessment of the potential public health consequences of
HVHF in New York, the totality of available information from relevant sources
has to be evaluated collectively. A single study or isolated piece of
information will not provide a complete public health picture for such a
complex activity. In assessing whether public health would be adequately protected
when allowing a complex activity such as HVHF to go forward, a guarantee of absolute
safety is not required, but there must be sufficient information to understand what
the likely public health risks will be. Ultimately, in conducting this Public
Health Review, DOH evaluated the relevant lines of available evidence
collectively, and made a judgment on whether the scientific information was
adequate to determine the level of public health risk.
1.
Scope of the Review DOH evaluated whether the
available scientific and technical information provides an adequate basis to
understand the likelihood and magnitude of risks for adverse public health
impacts from HVHF activities in New York State. The evaluation reviewed how HVHF
activities could result in human exposure to: (i) contaminants in air or water;
(ii) naturally occurring radioactive materials that result from HVHF
activities; and (iii) the effects of HVHF operations such as truck traffic,
noise, and social changes on communities. The evaluation also reviewed whether
those exposures may result in adverse public health outcomes.
Public Health Review Process The initial component of
the Public Health Review focused on understanding how public health concerns
were addressed in the draft SGEIS. Three nationally recognized experts also
participated as consultants to the initial phase of the review process. The expert
consultants reviewed elements of the draft SGEIS and documentation developed by
DOH, and provided extensive input through multiple rounds of communication.
As a result of this input, as well as broader consideration,
it became clear that DOH’s Public Health Review needed to extend beyond this
initial assessment to consider, more broadly, the current state of science
regarding HVHF and public health risks. This required an evaluation of the
emerging scientific information on environmental public health and community
health effects. This also required an analysis of whether such information was
sufficient to determine the extent of potential public health impact of HVHF
activities in NYS and whether existing mitigation measures implemented in other
states are effectively reducing the risk for adverse public health impacts.
1.
One major component of the Public Health Review was an
objective evaluation of the emerging scientific information on environmental
impacts and public health effects of HVHF activity. Scientific studies
reporting relationships between HVHF and public health outcomes were the main
focus of this evaluation, but relevant literature that was only focused on HVHF
and effects on environmental media was also reviewed.
Additional literature was reviewed and considered
supplemental to the main Public Health Review (see Appendix 1). More than 20
DOH senior Research Scientists, Public Health Specialists, and Radiological
Health Specialists contributed to the review under the direction of former
Commissioner Shah and Acting Commissioner Zucker. The entire Public Health
Review process involved more than 4500 hours of combined effort.
In addition to evaluating published scientific literature,
former Commissioner Shah, Acting Commissioner Zucker, and DOH staff held multiple
discussions and meetings with public health and environmental authorities in
several states to understand their experience with HVHF. Former Commissioner
Shah, Acting Commissioner Zucker, and DOH staff, also engaged in a number of
discussions and meetings with researchers from academic institutions and
government agencies to learn more about planned and ongoing studies and
assessments of the public health implications of HVHF.
1.
| Results Evaluation of Scientific Literature
Relevant to the Objectives of the Public Health Review In order to
evaluate the analysis of health impacts in the draft SGEIS in a broader environmental
and public health context, DOH reviewed and evaluated relevant emerging
scientific literature investigating the environmental health and community health
dimensions of HVHF. This was not intended to be a comprehensive review of all the
published scientific literature on HVHF. Rather, the emerging literature was surveyed,
and studies with direct environmental health relevance were reviewed to better
understand the adequacy of the current science to inform questions regarding public
health impacts of HVHF.
Two major types of peer-reviewed scientific studies were the
focus of the literature review process – studies of impacts to environmental
media and studies of health outcomes. As is very often true in environmental
health science, both types of studies have limitations that make it difficult
to draw firm conclusions about environmental causation of disease from any one study
or small group of studies. Strong conclusions about disease causation in
environmental health derive from a collective assessment of the weight of
evidence from a large body of research that often takes many years to conduct..
Studies of environmental impacts investigate the effects of
HVHF activities on environmental media such as air, water and soil.
Contamination of environmental media
1.
has the potential to contribute to human health impacts if
people experience exposures to those contaminants (for example, through
breathing contaminated air or drinking contaminated water) that are large
enough to cause a biological effect. However, studies of environmental impacts
often do not attempt to directly demonstrate whether contamination of environmental
media has resulted in significant human exposure or whether a health effect
occurs as a result of an exposure. Other studies report on observed human
health outcomes potentially associated with HVHF activity (i.e., environmental
epidemiology studies). Health outcome studies related to HVHF activity focus on
health effects reported among people living near HVHF drilling sites. Most health
outcome studies can only suggest a potential statistical relationship between a
source of environmental contamination and the observed health outcomes. These studies
are limited in their ability to demonstrate that an actual exposure to the
source has occurred or that exposure to an environmental source causes a health
outcome.
Health outcome studies vary in the complexity of their
design and how rapidly they can be carried out. Some health outcome study
designs that are relatively simple and quick to conduct are often also limited
in their ability to account for other unrelated factors (usually referred to as
bias and confounding) that might contribute to the observed health effects.
Longitudinal prospective cohort studies are among the strongest study designs,
but are very expensive and take years to conduct.
HVHF Health Outcome Studies The public health science
surrounding HVHF shale-gas development is currently limited and studies are
largely exploratory in nature. Peer-reviewed epidemiologic studies were not
found that employ robust study designs addressing possible associations between
HVHF activities and adverse health outcomes while providing adequate control
for confounding and bias. Scientific studies that contain relevant information
investigating
1.
human health outcomes potentially associated with HVHF
activities are briefly summarized below.
Birth Outcomes An unpublished 2013 revision to a 2012
working paper by Hill reports results of a study using data on 2,459 natural
gas wells completed in Pennsylvania between 2006 and 2010, along with vital
records for the years 2003 through 2010. The study compared birth outcomes for
infants born to mothers living within selected fixed distances from spudded
Marcellus Shale wells (the "existing well” infant group) with outcomes for
infants born to mothers living within the same distances from future wells (the
“future well” infant group). The outcomes considered were birth weight,
gestation, five-minute APGAR (Appearance, Pulse, Grimace, Activity,
Respiration) score (a health indicator assessed immediately following birth),
small-for-gestational-age (yes/no), premature (yes/no), congenital anomalies
(yes/no) and infant death (yes/no). The investigator reported that after
specifying a fixed distance of 2.5 km from an existing or future well, and
after controlling for multiple risk factors (e.g., maternal age, race,
education, WIC status, marital status, insurance status and smoking), the
“existing well” infant group had statistically significantly lower averages for
birth weight and 5-minute APGAR score, as well as statistically significantly
higher prevalence of low birth weight and small-for-gestational age, compared
with the “future wells” infant group. No statistically significant differences
were observed for prematurity, congenital anomalies or infant death.
Hill’s conclusion that a “causal” relationship between
natural gas development and birth outcomes was established may overstate the
findings of this single study. The statistical approach used by the
investigator, the differences-in-differences method, had in the past been
employed primarily by social scientists but is increasingly used in public health
studies. In the context of this study, this statistical approach assumed that,
in the
2.
absence of drilling, average outcomes for the “existing
wells” and “future wells” infant groups would have followed parallel paths over
time. Because differences may have existed between the two study groups with
regard to potential risk factors not incorporated into the statistical analyses
(e.g., prenatal care adequacy, maternal lifestyles, pre-existing chronic
diseases, perinatal complications) it is possible that this "parallel
paths" assumption may not have been appropriate. However, the author was able
to demonstrate that, at least with regard to measured characteristics, there
were no indications that this key assumption was not met.
A similar study by McKenzie et al. (2014) evaluated
potential associations between maternal residence near natural gas wells and
birth outcomes in a retrospective cohort study of 124,842 births between 1996
and 2009 in rural Colorado. Specifically, the authors investigated associations
between natural gas well density and prevalence of congenital heart defects,
neural tube defects, oral clefts, preterm birth, and term low birth weight. The
least exposed (reference) group had no natural gas wells within a 10- mile
radius. After adjustments for maternal and infant covariates, prevalence of congenital
heart defects was significantly positively associated with increased exposure to
natural gas development, with an increase of 30% (95% CI: 20% to 50%) for the highest
exposure tertile when compared with the reference group. Prevalence of neural tube
defects was significantly positively associated with exposure to natural gas development
for the highest tertile of exposure, with an increase of 100% (95% CI: 0 to 390%)
for the most exposed group when compared with the reference group. Exposure was
associated with lower odds of preterm birth and lower odds of low birth weight
(i.e., the high exposure groups were less likely to be preterm or low birth
weight). No association was found between exposure and oral clefts.
2.
It is notable that these two birth-outcome studies used
similar study designs and observed associations between birth-outcome measures
and maternal proximity to HVHF well pads. However, there is a lack of coherence
between the observed associations in the two studies. Hill reported
associations with low birth weight and APGAR score, but no associations with
congenital defects. Conversely, McKenzie et al.
reported associations between proximity to well pads and
some congenital defects, but the highest exposure group had lower odds of
preterm birth or low birth weight than the reference group. Taken together, the
relationship between maternal proximity to HVHF well pads during pregnancy and
birth outcomes, if any, is unclear.
Both birth-outcome studies used proximity to a drilling site
as an exposure surrogate, rather than actual environmental contaminant
measurements. This was a reasonable approach for an initial exploratory
investigation, as it would be difficult and expensive to characterize indoor
and outdoor exposures to all potentially relevant environmental agents (e.g.,
noise, air pollutants, groundwater pollutants, nighttime lighting) at numerous
homes and workplaces. However, studies that employ vicinity as a surrogate for
exposure cannot identify specific risk factors associated with the observed
adverse outcomes or establish how, if at all, these risk factors were related
to HVHF. For example, these studies cannot exclude the possibility that another
factor unrelated to HVHF also varied by residence proximity to drill pads and
contributed to the observed pattern of birth outcomes. The lack of coherent
associations between this exposure surrogate and comparable outcomes may
reflect weaknesses in the use of this exposure surrogate. The authors noted
that greater specificity in exposure estimates would be required to further
explore the reported associations.
2.
Case Series and Symptom Reports Bamberger and Oswald
published a study in 2012, which documents case reports of animal and human
health effects potentially resulting from nearby natural gas drilling operations.
The summary of reported human health effects lacks specificity, but mentions a
variety of symptoms such as upper respiratory, burning eyes, headache, gastrointestinal,
dermatological, and neurological. The authors acknowledge the lack of complete
testing of water, air, soil, and animal tissues that hampered more thorough analysis
of the connection between gas drilling and health. They suggest further investigation
is needed, ideally with policy changes that could assist in the collection of more
complete data sets. Bamberger and Oswald were also guest editors for a 201.
special issue on shale gas development in the same journal (New
Solutions). The articles in that special issue largely expand on potential
health concerns raised in the original Bamberger and Oswald paper, although
Bamberger and Oswald (2013) note in their introduction to the special issue
that firm conclusions about potential health concerns cannot be established
given the lack of relevant data.
Findings from an investigation done by the Earthworks’ Oil
& Gas Accountability Project were published in a non-peer-reviewed report
(Steinzor, 2012). The report summarizes the extent and types of health symptoms
experienced by 108 people from 5.
households from 14 Pennsylvania counties where HVHF is
occurring. It also has results of air sampling near 34 of the households and
water sampling from nine of the households. It is difficult to interpret the
results of this assessment. Participants report experiencing a number of
symptoms, and the results suggest that those living closer than ~½ mile from a
gas drilling facility may report symptoms in larger proportions than those
living farther than ~½ mile. However, the sample is self-selected, and there
was no systematic assessment of baseline health status or comparison with a
similar population (the report does mention a five person control group that
tended to
2.
experience fewer symptoms) unaffected by HVHF. The results
also do not adequately account for potential confounders (except smoking).
An unpublished presentation of findings from the Southwest
Pennsylvania Environmental Health Project (SWPA-EHP) was made available on the
organization’s web site. A formal report of these findings was not available;
the findings are summarized in a slide presentation.5Self-reported symptoms
were summarized for patients from one county in southwestern Pennsylvania who
sought medical care at the SWPA-EHP clinic. Self-reported symptom categories
occurring in 21 – 48 percent of individuals seeking medical care included: skin
rash or irritation, nausea or vomiting, abdominal pain, breathing difficulties
or cough, and nosebleeds. Other complaints mentioned in the presentation
include anxiety/stress, headache, dizziness, eye irritation, and throat
irritation. The presentation attributes up to 27 cases6of symptom complaints as
plausibly associated with a source of exposure in either air or water. However,
there is no environmental exposure assessment presented in support of the
claimed associations. No air or water monitoring data are presented. The
symptoms reported are common in the general population and can have many
causes. As with the Earthworks analysis, the sample is self-selected, and there
was no systematic assessment of baseline health status or comparison with a
similar non-HVHF population. There is no information presented indicating that
the analysis attempted to account for potential confounders or other existing
exposure sources.
Rabinowitz et al. (2014) conducted a preliminary
(hypothesis-generating) study in the same county in southwestern Pennsylvania
as the SWPA-EHP report described above.
The study found some evidence that residential proximity of
natural gas wells may be associated with the prevalence of certain health
symptoms, largely acute or self-limiting dermal and upper-respiratory
conditions. As the authors noted, follow-up investigations
2.
would be required before drawing any conclusions with regard
to actual disease incidence or possible causal relationships.
Results from a series of patient evaluations or symptom
reports as presented above can only be considered hypothesis generating; that
is, they can suggest possible relationships between an environmental exposure
and health effects that could be investigated systematically in epidemiology
studies designed to control for bias, confounding, temporality and chance
findings. These types of clinical reports do not allow conclusions to be drawn
about causal associations between HVHF exposures and health risks. However,
while many of the reported symptoms are common in the general population, these
reports indicate current information is not adequate to exclude the possibility
that HVHF is contributing to public health impacts.
Local Community Impacts There is a broad agreement in
the public health community that social factors such as income, education,
housing, and access to health care influence health status (i.e., so- called
social determinants of health).7Many historical examples exist of rapid and concentrated
increases in extractive resource development (e.g., energy, precious metals)
resulting in local community impacts such as interfering with quality-of-life
(e.g., noise, odors), overburdened transportation and health infrastructure,
and disproportionate increases in social problems, particularly in small
isolated rural communities where local governments and infrastructure tend to
be unprepared for rapid changes.8These impacts could indirectly result in
increased stress, which, in turn, can be associated with increased prevalence
of some health problems (for example, WHO, 2009). Similar concerns have been
raised in some communities where HVHF activity has increased rapidly (Texas
DSHS, 2010).
2.
For example, in some areas of HVHF well pad development
nearly all water used for hydraulic fracturing is hauled to the pad by truck.
One horizontal well is estimated to require about 1500 to 2000 truck trips over
the entire life of the well (NTC Consultants, 2011).
A recent study from Pennsylvania reports that automobile and
truck accident rates in 2010 - 2012 from counties with heavy HVHF activity were
between 15% and 65% higher than accident rates in counties without HVHF. Rates
of traffic fatalities and major injuries were higher in heavy drilling counties
in southwestern Pennsylvania compared to non-drilling counties in 2012 (Graham,
2015). Major potential adverse impacts from increased truck traffic include
increased traffic congestion and accidents; more damage to roads, bridges and
other infrastructure; and spills of hazardous materials during transportation..
Cancer Incidence Fryzek et al. (2013) conducted a
retrospective assessment of the potential for an association between childhood
cancer incidence and HVHF in Pennsylvania, and reported no increase in
childhood cancers after HVHF commenced. Study limitations included the
insensitivity of the methods employed, the rarity of childhood cancers, and the
absence of adequate lag time between most HVHF activities and most of the
study’s childhood cancer diagnoses. These raise some uncertainty about the
strength of the study conclusions.
2.
Non-peer-reviewed Information In addition to
investigating information in the peer-reviewed scientific literature, DOH has
maintained an ongoing effort to follow news reports and other non-peer-reviewed
sources for emerging information related to HVHF and potential public health
impacts.1.
Many findings reported through such non-peer-reviewed
sources are from informal or anecdotal health evaluations that have significant
limitations such as self-selected symptoms reports, non-specific symptoms, lack
of exposure data, lack of baseline health information, lack of unexposed
comparison groups, and lack of controls for bias and confounding. Reports of
this sort cannot be used to draw conclusions about associations between
reported health symptoms or complaints and any specific potential environmental
exposure source such as HVHF shale-gas development.
However, these types of reports suggest hypotheses for
associations between health outcomes and shale-gas activities that could be
tested with proper environmental epidemiology methods.
HVHF Environmental Studies Studies investigating HVHF
impacts on environmental media such as air or water were included in the review
if they provided information about the potential for human exposures from HVHF
activity.
Air Quality Impacts Maintaining good air quality is
obviously vital for promoting public health; poor air quality can affect large
populations of people, and therefore can contribute to significant morbidity
and mortality. DOH programs promote clean outdoor air quality by developing health
comparison values for use by DEC and by investigating and helping to correct conditions
that contribute to poor indoor air quality. NYS was the first state in the
2.
country to establish indoor smoking prohibitions in public
spaces under the NYS Clean Indoor Air Act.
The National Institute for Occupational Safety and Health
(NIOSH) has assessed potential risks to workers associated with chemical
exposure at natural gas drilling sites (NIOSH, 2012). In field studies
conducted at 11 sites, respirable crystalline silica and diesel particulates
were measured at levels with the potential to pose health hazards.
NIOSH has proposed several controls and recommended proper
use of personal protective equipment to minimize exposures. NIOSH has also
reported that the occupational fatality rate among oil and gas industry workers
is seven times higher than the average rate for all US industries (Retzer,
2011). On August 23, 2013, the federal Occupational Safety and Health
Administration (OSHA) announced that it intended to propose a revised standard
(called a permissible exposure limit) to protect workers from exposure to
respirable crystalline silica.11OSHA's Notice of Proposed Rulemaking for Occupational
Exposure to Respirable Crystalline Silica was published in the Federal Register
on September 12, 2013.12If enacted, the new regulation would reduce the permissible
exposure limit for crystalline silica and would establish certain other requirements
related to measuring levels of silica in workplace air, controlling dust, providing
respiratory protection, training of workers, and offering medical exams. While the
NIOSH assessment focused on worksite air quality, this report is suggestive
that uncontrolled silica emissions could affect the air quality of residences
or businesses near well pads.
In 2010, the Texas Department of State Health Services
collected blood and urine samples from 28 people, living in and near the town
of Dish, to determine whether people there had higher levels of volatile
organic compounds (VOCs) in their blood than 95% of the general United States
(U.S.) population. Community residents had raised
2.
concerns that they were experiencing exposure to air
contaminants from nearby gas wells and compressor stations. Measuring the
presence of chemicals in biological fluids (i.e., biomonitoring) is a technique
that can demonstrate that exposure occurred to those chemicals, but does not
necessarily identify the source of the exposure, or when exposure occurred.
Based on the pattern of VOC values found in the samples, the information
obtained from this investigation did not provide evidence that community- wide
exposures from gas wells or compressor stations were occurring in the sample population.
Other sources of exposure such as cigarette smoking, disinfectant byproducts in
drinking water and consumer or occupational/hobby related products could
explain many of the findings.
In 2010, the Colorado Department of Public Health and Environment
released a public health consultation evaluating the potential public health
hazards of ambient air pollution in areas of Garfield County in close proximity
to oil and natural gas development activities. This report summarized results
from enhanced air quality monitoring implemented following a 2008 public health
consultation13which found air concentrations near the upper end of EPA’s
acceptable range for benzene-associated cancer risk at one monitoring site. In
this study, air monitoring was used to measure concentrations of chemical
contaminants in the air near HVHF activities, and then those measured levels
were compared to health-based comparison values for the chemicals.
Health comparison values are a risk-assessment tool and are
set at levels to be protective of public health. If comparison values are
exceeded, it does not imply that adverse health impacts will occur, but it
indicates that further investigation of potential exposures is warranted.
In the 2010 report, the investigators concluded that it
could not be determined if breathing ambient air in those areas of Garfield
County that were monitored could harm
2.
people’s health. This conclusion was reached because the
cancer risks and noncancer hazards for 65 out of 86 contaminants could not be
quantitatively estimated due to the unavailability of chronic inhalation
toxicity values. Although the evaluation suggests that exposures are not likely
to result in significant cancer and noncancer effects (the levels measured are
much lower than those known to cause health effects), cumulative health effects
from synergistic interactions are unknown. Where quantitative evaluations were possible,
increased risks of cancer, long-term (chronic) noncancer hazards and short- term
(acute) noncancer hazards (where data were available) were low, although for
the latter there is uncertainty because insufficient data are available to
evaluate intermittent short-term peak exposures.
A similar risk-assessment study of air-quality monitoring in
the Barnett Shale region of Texas was published in 2014 by Bunch et al. (2014).
The study summarized air- monitoring data for volatile organic chemicals
collected at six fixed monitoring locations in Wise, Denton and Tarrant
counties in north-central Texas including areas in and around the city of Fort
Worth. The monitoring network is operated by the Texas Commission on
Environmental Quality (CEQ) and is described in the report as the most extensive
air monitoring network in place in any U.S. shale play. The network includes both
real-time monitors and 24-hour average samples analyzed in the laboratory, covers
regions of the Barnett shale producing both dry and wet gas, and spans areas of
urban and suburban development where the potential for community exposure to
any shale-gas air emissions could be significant. The analysis of these data
included assessing potential health risks of short-term and long-term exposure
to all chemicals measured by the monitoring network using existing health
comparison values (for example, Texas CEQ air monitoring comparison values or
US EPA reference concentrations). Many of the chemicals measured by the
existing network are unrelated to shale-gas development. Therefore, the authors
also conducted more refined
3.
quantitative risk assessments for a subset of volatile
organic chemicals thought to be most likely to be associated with shale gas
production.
The Bunch et al. study summarized the results of over 4.6
million data points collected over more than 10 years for up to 105 different
volatile organic chemicals per monitor.
Only one observed short-term value exceeded an applicable
odor-based comparison value.14None of the measured short-term (one hour or
24-hour average) air levels for the entire panel of chemicals exceeded an
applicable short-term health-based comparison value. Only one chemical
(1,2-dibromoethane) had any annual average concentrations that exceeded its
applicable long-term health comparison value.15The authors noted that the
analytical detection limit for 1,2-dibromoethane is substantially higher than
its chronic comparison value and about 90% of the 1,2-dibromoethane results
that contributed to the exceedances were non-detects. This suggests the true annual
average concentrations could have been substantially lower than the reported estimates.
The authors also did not consider 1,2-dibromoethane to be a chemical reasonably
expected to be associated with shale-gas production. According to the authors,
it is used as a lead-scavenger in aviation fuel. The two monitoring locations where
the 1,2-dibromoethane 2011 annual averages exceeded applicable comparison values
are located near airports. More refined deterministic and probabilistic
quantitative risk assessments for annual average concentrations found that
estimates of cumulative noncancer and cancer health risks were below levels of
concern at all monitoring locations. The authors concluded that their analysis
demonstrated that shale gas operations in the monitored region of the Barnett
play have not resulted in community- wide exposures to the measured volatile
organic chemicals at levels that would pose a health concern.
3.
Macey et al. (2014) analyzed data from grab and passive air
samples that were collected in Arkansas, Colorado, Ohio, Pennsylvania and
Wyoming by trained volunteers at locations identified through systematic
observation of industrial operations and air impacts over the course of
residents’ daily routines. The investigators reported that concentrations of
eight volatile chemicals exceeded risk-based comparison values under several
operational circumstances. Benzene, formaldehyde, and hydrogen sulfide were the
most common compounds to exceed acute and other risk-based values.
However, it was not always clear that the authors employed
appropriate risk-based comparison values given the nature of the samples that
were collected. For example, the use of comparison values based on lifetime
(long-term) cancer risk levels may have substantially overstated cancer risks
associated with exposures to short-term levels of air pollutants that were
measured. Moreover, retrospective source apportionment efforts are not possible
based on study data because the investigators did not collect the necessary
control samples, such as upwind air samples, or wind direction data. This complicates
evaluation of the study data because, at least in some urban and industrial settings,
it is not unusual for atmospheric concentrations of benzene and formaldehyde to
exceed some of the comparison values that were employed by the authors (Weisel,
2010).
The Pennsylvania Department of Environmental Protection (PA
DEP) conducted short- term, screening-level air quality sampling initiatives in
various parts of the Commonwealth where a majority of the Marcellus Shale
operations have been undertaken.16Sampling windows often captured pollutant
concentrations during the early morning hours and late evening hours, to
reflect the predominate times when complaints related to Marcellus gas
exploration activities are received by the DEP.
Following the completion of a comparative analysis, which
will consider data from
3.
separate surveys conducted in four Pennsylvania regions, the
DEP will determine whether additional, longer-term sampling is warranted.
Data from the northeastern and northcentral regions of
Pennsylvania are most relevant to New York State, since the Marcellus in those
regions produces predominantly natural gas, rather than oil. The PA DEP did not
find an immediate health risk to the general public. Certain compounds were
detected at levels that produce odors. For example, methyl mercaptan was often
detected at levels that generally produce odors. Methyl mercaptan is a
naturally occurring compound present in some shale gas formations as well as in
crude oil. Methyl mercaptan has a strong unpleasant smell that can be detected
by the human nose at very low levels. Olfactory fatigue, or the loss over time of
the ability to smell methyl mercaptan, occurs after prolonged exposure. The PA
DEP determined that the methyl mercaptan levels detected could cause violations
of PA DEP odor emission provisions in 25 Pa. Code Section 123.31 if they
persisted off the property and the Department determined that the odors were
“malodors” as defined in 25 Pa. Code Section 121. The PA DEP indicated that
prolonged or repeated exposures to strong odors may produce odor-related health
effects such as headaches and nausea.
Sampling for carbon monoxide, nitrogen dioxide, sulfur
dioxide, and ozone in northeastern Pennsylvania did not detect concentrations
above National Ambient Air Quality Standards at any of the sampling sites. With
regard to benzene, only one two- minute benzene concentration of 400 parts per
billion (ppb), reported in northcentral Pennsylvania, produced a hazard
quotient17close to 1.0 when compared to the most conservative of the three
health-based reference concentrations used in by PA DEP.
Because of where the monitoring device was located (i.e.,
next to a parking lot and road), this one benzene reading was considered most
likely due to a mobile source. The
3.
three canister samples collected during the week, which were
sited away from the parking lot, did not detect elevated levels of benzene.
Considering that this single high benzene value was measured at the background
site, the PA DEP has determined that benzene should not be considered a
pollutant of concern near Pennsylvania Marcellus Shale operations.
The PA DEP reported that the use of an infrared camera was
an effective tool in showing emissions from drilling operations that may have
impacted sampling results. At one well site, the camera documented leaks of
what is most likely methane. Although the ambient methane concentrations
detected in the air were not considered unacceptable in terms of adverse
inhalation health effects, the methane emissions represented a waste of
resources and a fractional contribution to greenhouse gas levels. The DEP
therefore determined that the camera will continue to be deployed during its
future investigative and/or sampling efforts.
Reports from other states using HVHF suggest it is common
for trucks to form lines when awaiting access to gas well pads (Gold, 2013). If
a line of idling trucks forms near a home, this could potentially increase
residents’ exposures to diesel exhaust for the duration of operations requiring
idling. A recent West Virginia study determined that vehicle traffic and engine
exhaust were the likely sources of intermittently high dust and benzene
concentrations sometimes observed at distances of 625 feet18and farther from the
center of well pads (McCawley, 2013).
Shonkoff et al. (2014) reviewed the scientific literature
related to air pollution from shale and tight gas development, and noted
differences in results obtained by different surveys. For example, McKenzie et
al. (2012) reported relatively substantial exposures
3.
to certain volatile organic compounds (e.g.,
trimethylbenzenes, xylenes, and aliphatic hydrocarbons) among residents living
≤ 0.5 mile from oil and gas wells compared with residents living > 0.5 mile
from wells. In contrast, Bunch et al. (2014) reported that shale gas production
activities in the Barnett Shale Play, Texas, did not result in community- wide
exposures to concentrations of volatile organic compounds above federal and state
health-based air comparison values. Shonkoff et al. noted that differences between
the two studies could have been due to the different sampling methods employed.
For example, McKenzie et al., but not Bunch et al., considered data from samples
collected at the local (community level) in close proximity to gas development.
Pétron et al. (2012) analyzed data collected at the National
Oceanic and Atmospheric Administration Boulder Atmospheric Observatory and
reported an alkane and benzene signature when winds blew from the direction of
the Denver-Julesburg Basin, an area of considerable oil and gas development.
Additional studies have documented substantial greenhouse gas releases and
elevated atmospheric ozone concentrations from extensive exploitation of oil
and gas deposits by various methods, including HVHF (Kemball-Cook, 2010).
Natural gas can also contain radon, a potential indoor air
contaminant. A screening analysis by DOH (see Appendix 2) suggests that radon
exposure levels from Marcellus natural gas could contribute a small fraction to
the overall indoor radon levels. However, there is substantial uncertainty
regarding radon levels in shale gas from various geographic locations and
geologic formations because of limited monitoring data, especially from the
Appalachian Basin (Rowan and Kramer, 2012), which includes the Marcellus shale.
3.
Water Quality Impacts Water quantity and quality have
obvious importance for public health in terms of having reliable sources of
water for public and private drinking-water supplies at all times.
Surface waters provide additional indirect public health
benefits related to fish resources (both recreation and for food), recreational
use (swimming and boating) and flood control in the case of wetland areas.
Maintaining adequate surface water quantity and quality helps promote these
health benefits. Under the federal Safe Drinking Water Act (SDWA), the US
Environmental Protection Agency (US EPA) established the public water system
supervision program. In New York State, the DOH has the primary responsibility
for implementing and enforcing the drinking water regulations of the SDWA for
all public water systems.19This also includes oversight and implementation of US
EPA’s Surface Water Treatment Rule.
With the promulgation of the Surface Water Treatment Rule in
the late 1980s, all drinking water taken from surface water sources must be
filtered to reduce the risk of waterborne disease. However a waiver, or
Filtration Avoidance Determination (FAD), may be granted to a water supplier if
it is able to demonstrate ongoing compliance with strict water quality criteria
and if it has a plan for the long-term control and management of its watershed.
In New York State, both the City of Syracuse and the City of
New York have been issued a FAD. The FAD for the Syracuse public water supply
system encompasses Skaneateles Lake and its 59 square mile watershed and for
New York City, the FAD encompasses the Catskill and Delaware (Cat/Del) water
supplies and its 1600 square mile watershed in the Catskills.
3.
While watershed management is important for any surface
water supply, it is critical and required for an unfiltered FAD system.
Therefore, both the NYC Cat/Del and Skaneateles Lake watersheds are unique
natural and hydrological sources of importance within the State. The importance
of these resources is highlighted, in particular, by the 1997 NYC Watershed
Memorandum of Agreement (MOA). The MOA is a landmark agreement that recognizes
both the importance of preserving high-quality drinking water and the economic
health and vitality of communities located within the watershed. It is a
legally binding 145 page contract, with 1500 pages of attachments, between NYC,
the State, US EPA, nearly 80 local governments in the watershed and environmental
groups.
The literature investigating water-related impacts of HVHF
activity is relatively extensive compared to literature on other environmental
impacts, although most studies do not directly assess the potential for human
exposure or public health impacts from water contamination. Osborne et al.
(2011) first highlighted the potential for sub-surface methane migration from
HVHF activity to affect drinking water wells in Pennsylvania, and subsequent
reports from the same group of researchers have continued to investigate this
potential source of groundwater contamination. The following summarizes a few
of the most recent water-quality investigations of HVHF that could be most
germane to understanding the potential for HVHF to contribute to human exposure
through drinking water.
Some recent publications have shed light on the potential
for and causes of occasional water pollution incidents around oil and gas wells
(for example, see: Satterfield, 2011; Sharma, 2014; Warner, 2014; Zhang, 2014).
Darrah et al. (2014) identified groundwater contamination clusters that they
determined were due to gas leakage from intermediate- depth strata through
failures of annulus cement, faulty production casings, and
3.
underground gas well failure. Vengosh et al. (2014)
identified published data revealing evidence for stray gas contamination,
surface water impacts, and the accumulation of radium isotopes in some disposal
and spill sites. Some preliminary data suggest inadequate HVHF wastewater
treatment could contribute to formation of disinfection byproducts in treated
surface waters (e.g., Chang, 2001; Parker, 2014). These and other reports
indicate that there remain data gaps and uncertainties regarding the effectiveness
of some common mitigation measures related to both well construction and
wastewater management, at least as these have been implemented in other states.
An investigation was reported by Kassotis et al. (2014)
using in vitro (i.e., cell culture) assays to assess the estrogen- and
androgen-receptor activity of HVHF chemical additives and environmental water
samples. Twelve chemicals were chosen that were considered to be known or
suspected endocrine-disrupting chemicals and were chemical additives used in
natural gas operations in Colorado.20Groundwater and surface water samples were
collected in Garfield County Colorado from areas considered “drilling dense”
near locations where natural gas “incidents” had occurred.
Reference groundwater and surface samples were collected in
areas of Garfield County considered “drilling sparse” and from the nearby
Colorado River and a non-drilling reference location in Missouri. Assay results
showed the twelve chosen chemicals showed varying degrees of anti-estrogenic
and anti-androgenic activity compared to positive control activities (17β
-estradiol and testosterone, respectively). Groundwater and surface water
samples concentrated 4-times or 40-times from their levels in the environment
had varying degrees of estrogenic, anti-estrogenic or anti-androgenic activity
in the test assays, generally with higher activities seen from samples
collected from the drilling dense sites, although differences from reference
samples were not always statistically significant.
3.
Kassotis et al. concluded that, based onin vitroassay
results of the selected chemicals and water samples from drilling dense vs.
reference locations, natural gas drilling operations may result in elevated
endocrine disrupting activity in groundwater and surface water. There are a
number of study limitations that suggest a strong conclusion attributing the
observed assay responses to natural gas drilling is questionable. For instance,
there were no chemical analyses presented of the drilling-dense water samples
that would allow an evaluation of whether the observed assay results were due to
drilling-related chemicals present in the water or to other unrelated chemicals
that could have been present from other sources. Similarly, drilling-dense
samples and reference samples were not always matched for other potentially
influential factors aside from drilling proximity such as the type (drinking
water vs. monitoring) and depth of groundwater wells, stream ecology or land
use differences adjacent to sampling locations.
Drilling-dense sampling sites were described by Kassotis et
al. as being associated with “natural gas incidents” including equipment leaks,
spills or natural gas upwelling.
However, these incidents took place at varying times from
several months to several years prior to sampling and could have involved very
different mixtures of materials (such as bulk chemical additives during a spill
or formation brine from an equipment leak). The investigators did not provide
details concerning the specific nature of any water contamination that might
have resulted from these incidents or what environmental remedial activities
may have taken place prior to collecting water samples. This information would
have been helpful in evaluating the likelihood that water contamination from
the incidents had occurred and persisted in the sampled water sources. This
information is especially important because the study report provided no
analyte concentration data for the study water samples. The proximity of water
sample collection locations to drilling activity alone does not conclusively
indicate
3.
that natural gas drilling operations result in endocrine
disrupting activity in the water.
Even if further detailed research supported drilling-related
contaminants as the source of increased endocrine disrupting activity in thein
vitroassays used in this study, the relevance of the study methods to
actual human exposure and human physiological responses are unknown. Therefore,
these results do not allow any assessment of the potential risk to human health
posed by such contamination.
A critical review of water resource issues associated with
HVHF (Vengosh, 2014) noted that treatment and disposal of HVHF solid waste and
wastewater is a significant challenge. Gas wells can bring naturally occurring
radioactive materials (NORM) to the surface in the cuttings, flowback water and
production brine. NORM consists of uranium and thorium and their decay
products. Some of those decay products, namely radium and radon, can be a
public health concern if exposure occurs at sufficiently-high levels.
Rocks and soil contain NORM at various levels, and certain
types of rock tend to have higher concentration of NORM.
NORM in flowback and production brine can plate out and
concentrate on internal surfaces of pipes and tanks (scale). NORM in pipe scale
contains predominantly radium. This can cause an external radiation exposure
risk to workers who work with this equipment.
Induced Earthquakes Although it has long been known
that some forms of underground fluid injection can increase the risk of
earthquakes,21the long-term impacts of extensive hydraulic fracturing upon the
risk of earthquakes in the Northeastern U.S. remains poorly
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understood. In contrast, some information regarding
short-term risks above the Marcellus and Utica shale plays has become available.
Holland (2014) described one of the first observed cases in
Oklahoma of earthquakes triggered by the hydraulic fracturing phase (rather than
underground wastewater injection). The earthquakes were large enough to be felt
by local residents.
In Maxwell’s (2013) description of an approach to evaluating
HVHF-related seismic events, criteria for confirming events, and existing
injection and HVHF seismicity protocols, the author described several seismic
events ranging from low to moderate energy. According to the author, during
April and May of 2011 hydraulic fracturing near Preese Hall, UK, resulted in an
event with magnitude ML=2.3 (local magnitude scale) and later another ML=1.5.
The author added that, between 2009 and 2011, 3.
earthquakes including a ML=3.8 resulted from hydraulic
fracturing in the Horn River Basin shale gas reservoir in north-east British
Columbia, Canada.
In 2014, the Ohio Department of Natural Resources (ODNR)
announced new, stronger permit conditions for drilling near faults or areas of
past seismic activity.22The new policies were developed in response to seismic
events in Poland Township (Mahoning County) that the ODNR determined were
probably connected to hydraulic fracturing near a previously unknown
“microfault.” Under the new rules, permits issued by ODNR for horizontal
drilling within three miles of a known fault or area of seismic activity greater
than a 2.0 magnitude require companies to install sensitive seismic monitors.
If those monitors detect a seismic event in excess of 1.0 magnitude, activities
must pause while the cause is investigated. If the investigation reveals a
probable connection to the hydraulic fracturing process, all well completion
operations must be suspended. ODNR
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says that it will develop new criteria and permit conditions
for new applications in light of this change in policy. The department will
also review previously issued permits for wells that have not been drilled.
Conclusions – Health and Environmental Literature The
science surrounding HVHF shale-gas development and public health risks is only just
beginning to emerge. Many of the published reports investigating environmental and
health implications of HVHF activities are preliminary or exploratory in
nature. As a result, the available science on HVHF currently is limited and
largely suggests hypotheses about potential impacts that need further
evaluation. Health impacts that have been reported to be potentially associated
with exposure to HVHF activities include a variety of acute or self-limiting
signs and symptoms such as skin rash or irritation, nausea or vomiting,
abdominal pain, breathing difficulties or cough, nosebleeds, anxiety/stress,
headache, dizziness, eye irritation, and throat irritation.
Other outcomes that have been reported as potentially
associated with HVHF exposure include low birth weight and some congenital
defects. Studies of environmental impacts have documented sub-surface methane
migration from well casings to groundwater and methane leakage to the
atmosphere from HVHF infrastructure. Other environmental impacts including
noise and dust from well pads and truck traffic, increased traffic accident rates,
inadequate wastewater treatment, and induced earthquakes have been observed.
The actual degree and extent of these environmental impacts, as well as the extent
to which they might contribute to adverse public health impacts are largely unknown.
Nevertheless, the existing studies raise substantial questions about whether the
public health risks of HVHF activities are sufficiently understood so that they
can be adequately managed.
4.
| Results Information Gathered from Outside
Authoritative Organizations, Public Health Experts, and Formal Health
Impact Assessments Other information sources were sought to provide
additional background information on public health risk of HVHF for the Public
Health Review. Former Commissioner Shah, Acting Commissioner Zucker, and DOH
staff held multiple discussions and meetings with public health and
environmental authorities in several states to understand their experience with
HVHF. Former Commissioner Shah, Acting Commissioner Zucker, and DOH staff also
engaged in a number of discussions and meetings with researchers from academic
institutions and government agencies to learn more about planned and ongoing
studies and assessments of the public health implications of HVHF. Input was sought
from three public health expert consultants regarding the potential public
health risk posed by HVHF activities. And, health impact assessments conducted
by other state, provincial and international governments were reviewed for any
additional insights regarding HVHF public health concerns.
Health Impact Assessments A health impact assessment
(HIA) is a decision tool that uses a structured assessment approach to identify
impacts of an activity or policy decision and recommend ways to lessen or
prevent adverse public health impacts under alternate decision options. The results
of these assessments tend to be based on qualitative judgments when decision alternatives
being considered involve large-scale, complex issues such as HVHF. HIAs that
examined public health risks of HVHF have recently been conducted by
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governments or academic institutions in Maryland (University
of Maryland, 2014), Michigan (University of Michigan, 2013), North Carolina
(Research Triangle Environmental Health Collaborative, 2013), Nova Scotia
(Wheeler, 2014), the National Institute of Environmental Health Sciences
(NIEHS; Penning et al, 2014), the Institute of Medicine (IOM, 2014), and the
European Commission (Broomfield, 2012).
The European Commission, which is the executive body of the
European Union, published a report (Broomfield, 2012) on the results of a
preliminary screening of potential public health and environmental risks
related to HVHF in Europe, along with risk management recommendations. For each
risk identified by the Commission, the preliminary risk screening approach
combined a subjective adverse event probability classification
("rare" to "frequent/long-term definite") with a subjective
hazard classification ("slight" to "catastrophic") to
develop a risk classification ("low" to "very high"). Using
this approach, the Commission determined that HVHF in Europe will entail "high"
cumulative risks of groundwater contamination, surface water contamination, depletion
of water resources, releases to air, increased noise, and increased traffic.
A 2011 Executive Order Issued by Maryland Governor Martin
O’Malley established the Maryland Marcellus Shale Safe Drilling
Initiative.23The Initiative is jointly administered by the Maryland Department
of the Environment and the Maryland Department of Natural Resources. The
Executive Order also established a Marcellus Shale Safe Drilling Initiative
Advisory Commission composed of a variety of governmental, community,
environmental and industry stakeholders. According to the Executive Order, the purpose
of the Initiative is to:
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“… assist State policymakers and regulators in
determining whether and how gas production from the Marcellus shale in
Maryland can be accomplished without unacceptable risks of adverse
impacts to public health, safety, the environment and natural
resources.” As part of the Maryland Initiative, the Maryland Department of
Health and Mental Hygiene (MDHMH) announced in September, 2013, two public
meetings to receive public input on a study of potential public health impacts
associated with possible development of the Marcellus Shale in Western
Maryland.24MDHMH then oversaw the study, which was performed by the University
of Maryland School of Public Health’s Maryland Institute for Applied
Environmental Health. The final study report, entitled “Potential Public Health
Impacts of Natural Gas Development and Production in the Marcellus Shale in
Western Maryland,” was published in July 2014.25The report identifies largely
the same types of potential health impacts of HVHF activity as those identified
in other HIAs. The report presents a hazard evaluation summary of eight potential
adverse impacts, rating four (air quality, healthcare infrastructure,
occupational health, and social determinants of health) as having a high
likelihood of negative public health impact. Three potential impacts
(cumulative exposures/risks, flowback and production water-related, and noise)
were rated as moderately high, and one (earthquakes) was rated as low.
In 2013 the University of Michigan’s Graham Sustainability
Institute released several technical reports on HVHF in the State of Michigan
that were intended to provide information for decision makers and stakeholders,
as well as to help inform the Institute’s “Hydraulic Fracturing in Michigan
Integrated Assessment,” which will evaluate policy options.26Faculty-led and
student-staffed teams provided reports on the following topics: Technology,
Geology/Hydrogeology, Environment/Ecology, Human Health,
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Policy/Law, Economics, and Public Perceptions. The Institute
noted that its technical reports should not be characterized as final products
of the integrated assessment, and that the reports do not provide a scientific
risk assessment for aspects of HVHF.
In its Public Health technical report, the Institute
preliminarily identified 18 possible public health issues related to HVHF, with
“plausibility scores” reflecting qualitative assessments of the evidence
suggesting that each issue could be considered a potential public health hazard.27Of
the 18 issues enumerated, eight were given the highest plausibility score,
reflecting the Institute’s determination that “scientific evidence exists and
is strong (e.g., many studies, good design, causality).” These eight issues were
silica exposure, intentional-use chemicals, by-product chemicals,
transportation, air quality, water quality, habitat and wildlife (impacts on
recreational opportunities, cultural/spiritual practices), and public
perceptions (causing, e.g., increased anxiety, family quarrels, depression).
The Institute discussed several “challenges and
opportunities” with regard to HVHF in Michigan, beginning with Michigan’s lack
of a public health tracking system. The Institute also called for complete
disclosure of chemicals injected during HVHF, noting that disclosure has thus
far been minimal in Michigan, with only a few facilities reporting upon a small
number of drilling events out of more than 12,000 wells that have undergone
HVHF. The Institute additionally recommended more public health outreach and
education in Michigan, particularly in potentially-impacted communities,
similar to recommendations in our review. Finally, the Institute indicated that
a health economist should be enlisted to help describe risks and benefits of
HVHF compared with alternative energy sources.
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In response to state legislation allowing the use of
horizontal drilling and hydraulic fracturing in North Carolina, a summit
meeting was convened in October, 2012, by the Research Triangle Environmental
Health Cooperative (EHC). A report presenting recommendations from the summit
was released in 2013.28According to the report, summit participants represented
diverse stakeholder groups including industry, nonprofits, governmental
organizations and academia. The report stated that: “The EHC summit aimed to
create a neutral space in which to share ideas and experiences to
identify gaps in the current knowledge of, and preparations for, the
potential impacts of hydraulic fracturing on public health in North
Carolina. The summit recommended actions and potential policies to
safeguard the health of North Carolinas citizens and environment if
hydraulic fracturing occurs in the state.” Three working groups were formed
as part of the summit – exposure pathways, health impacts, and social impacts –
and each working group made relevant recommendations for developing new
components or strengthening existing components of the state’s oil and gas
program. While each working group developed extensive specific recommendations,
major themes that were common to the working group recommendations included: •Collect
baseline data prior to oil and gas drilling. This includes data on water quality,
hydrogeological information, hydrocarbon characterization, air quality, ecosystem
information, and population health statistics.
•Develop a comprehensive water and wastewater management
plan that addresses how water is allocated among users and how oil and gas
drilling wastewater will be managed through treatment, reuse/recycling and
disposal.
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•Provide adequate and coordinated funding and administrative
oversight for oil and gas development programs. Specifically, the state should
develop a bonding and remediation program to provide adequate cleanup,
remediation, and maintenance funds. Drilling companies should pay into a
“premediation” fund financed by a permit fee to drill an oil or gas well.
Additional funding is needed to adequately address the potential environmental
and social costs of hydraulic fracturing, including collection of comprehensive
environmental and health data before, during and after the drilling process.
Local, state, and regional agencies should coordinate the administration and
oversight of hydraulic fracturing and should avoid duplication of effort.
•Develop and promote a list of best management practices
(BMPs) for drilling and hydraulic fracturing. These BMPs should focus on:
preventing contaminants from entering the environment; containing contaminants
if they do accidentally enter the environment; and monitoring for contaminants
to quickly detect releases if they occur, stop them, and begin remediation.
Effective regulations require enforcement if violations occur. Regulations must
also keep pace with the rapid technological developments in the shale gas
industry.
Another assessment was conducted in 2014 by the Nova Scotia
Independent Panel on Hydraulic Fracturing, which determined that although HVHF
would provide major economic and employment benefits to the province, Nova
Scotia does not have the necessary information required to make a final
decision on whether to allow HVHF in the province (Wheeler, 2014).29Among other
things, the review found that: many questions about fracking remain
outstanding; municipalities, citizens, Aboriginal governments, and communities
should be involved in the risk-assessment and decision- making process; and the
report should be used as a basis for informed debate on the issue of HVHF in
Nova Scotia. The report recommends that stakeholders “spend
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whatever time is necessary learning about these issues,
keeping an open mind of future developments …” The report also provides 32
recommendations “to safeguard community health, local economies, ecosystem
health, and the environment,” in the event that the province moves forward with
HVHF.
An assessment was published in 2014 by a working group
formed by Environmental Health Sciences Core Centers that are funded by the
National Institute of Environmental Health Sciences (Penning, 2014). The
Inter-Environmental Health Sciences Core Center Working Group on Unconventional
Natural Gas Drilling Operations concluded that there are data gaps and
uncertainties regarding impacts and the effectiveness of HVHF mitigation
measures. The group further concluded that a potential for water and air
pollution exists which might endanger public health, and that the social fabric
of communities could be impacted by the rapid emergence of drilling operations.
The working group recommended research to inform how potential risks could be
mitigated.
The assessment did not identify novel information or issues,
but it lends support to some of the conclusions made in this Public Health
Review with regard to data gaps and uncertainties regarding HVHF-related public
health impacts.
In 2012, a workshop convened by the Institute of Medicine
(IOM) Roundtable on Environmental Health Sciences, Research, and Medicine
discussed the human health impact of shale gas extraction through the lens of a
health impact assessment. The workshop examined the state of the science
regarding shale gas extraction, the direct and indirect environmental health
impacts of shale gas extraction, and the use of health impact assessment as a
tool that can help decision makers identify the public health consequences of
shale gas extraction (IOM, 2014).
4.
The review of HIAs for this Public Health Review focused on
identifying any public health risks different from those identified through the
scientific literature review. The review found that the public health risks and
information gaps identified in the published HIAs were qualitatively similar to
those discussed in the literature review section above.
In some cases, specific public health risks were emphasized
in these assessments: •The European Commission HIA determined that HVHF in
Europe will entail "high" cumulative risks of groundwater
contamination, surface water contamination, depletion of water resources,
releases to air, increased noise, and increased traffic.
•The University of Michigan assessment identified priority
issues including silica exposure, intentional-use chemicals, by-product
chemicals, transportation, air quality, water quality, habitat and wildlife
(impacts on recreational opportunities, cultural/spiritual practices), and public
perceptions (causing, e.g., increased anxiety, family quarrels, depression).
•The North Carolina HIA emphasized planning and monitoring
including: collecting baseline data on water quality, air quality and health
statistics; developing a comprehensive water and wastewater management plan;
adequately support coordinated enforcement; and, develop and promote best
practices.
•Both the NIEHS and IOM assessments emphasized the potential
for water and air pollution that could adversely affect public health as well
as the potential for social disruption that could result from local community
impacts caused by rapid development of HVHF activities.
Meetings with Other State Agencies Commissioner Shah
met with officials of the California Department of Public Health (CDPH) and the
California Department of Conservation (CDOC) in July, 2013. In
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August, 2013, he held separate meetings with officials in
Texas (representing the Texas Department of State Health Services (TDSHS), the
Texas Railroad Commission (TRC), and the Texas Commission on Environmental
Quality (TCEQ)) and officials in Illinois (representing the Illinois Department
of Public Health (IDPH) and the Illinois Department of Natural Resources
(IDNR)). The purpose of these meetings was to learn directly from the state
agencies about each state’s experience with oil and gas development and to evaluate
how the oil and gas regulatory programs in those states compare to the regulatory
program in New York State. The following summarizes the findings of these meetings
at the time they occurred in 2013.
California Like New York, California has a long
history of oil and gas development. As is currently the case in New York,
essentially all oil and gas wells in California are vertical wells.
Most oil wells in California are stimulated using low-volume
hydraulic fracturing. The geology in areas currently being developed in
California is very different from the Marcellus Shale formation in New York.
Most current activity in California produces oil from tight sand formations.
These formations also produce a large quantity of formation water (brine),
which is re-used for hydraulic fracturing and for enhanced oil recovery. A small
fraction of the produced brine is treated and can be used for agricultural irrigation.
The formations currently being drilled in California have
very little naturally-occurring radioactive material (NORM). The Monterey Shale
in California is a shale formation somewhat analogous to the Marcellus Shale,
although the Monterey is expected to produce primarily oil. Exploitation of the
Monterey Shale would require horizontal drilling and high-volume hydraulic
fracturing, but activity in this formation on a commercial scale has so far not
taken place because of technical challenges due to the unusual chemical and
physical properties of the formation.
5.
Unlike New York, where low-volume hydraulic fracturing has
been specifically regulated under the Generic Environmental Impact Statement
since 1992, California does not currently have formal regulations specific to
hydraulic fracturing. A discussion draft of proposed hydraulic fracturing
regulations was released by CDOC for public review and comment in December,
2012. Public feedback was obtained on the discussion draft in a series of
public hearings, and a formal proposed rule is expected to be released soon.
The discussion draft indicates that all records submitted
under the rules would be considered public records for the purposes of the
state’s public records law. The discussion draft includes provisions that would
require well operators to publicly disclose all information about chemical
additives and carrier fluids used in hydraulic fracturing fluids for a well.
This requirement would be subject to exceptions for information claimed to be
trade secrets.
California does not currently conduct public health
surveillance monitoring related specifically to oil and gas development. As is
the case in New York State, CDPH monitors water quality for public drinking
water supplies as a routine part of its drinking water regulatory program. CDPH
has reviewed 250 million individual sampling results from its regulatory water
monitoring program. Nine drinking water wells were found to have had detections
of chemicals used in hydraulic fracturing. Of those, only two wells had an oil
or gas well nearby and further investigation suggested the contaminants were most
likely related to other sources.
Texas Texas also has a long history as a major oil
and gas producer in the U.S. In 2011, Texas produced the largest quantities of
oil and natural gas of any state. Hydraulic fracturing has been used in the
state for about 60 years. Starting in 2004, Texas’ Barnett Shale formation was
one of the first locations in the United States where high-
5.
volume hydraulic fracturing and directional drilling were
used on a commercial scale to develop an unconventional shale formation. The
Barnett Shale is a shale formation underlying areas of north Texas including
the City of Fort Worth and surrounding suburban and rural counties that is
geologically somewhat similar to the Marcellus Shale. Other areas of
significant oil and gas development in unconventional shale formations in the
state include the Eagle Ford Shale in south Texas and the Haynesville-Bossier
shale in east Texas. The Cline Shale in west Texas is now also attracting
commercial attention for potential oil production.
Oil and gas development in Texas is regulated by the TRC.
Operators are required to comply with all TRC rules, which cover all aspects of
well development, such as well construction, casing and cementing, drilling
operations and flaring. Operators are required to document their compliance in
well completion forms. Well cementers are licensed in Texas, and well operators
are required to employ licensed cementers. Unlike New York regulations, the TRC
rules do not include specific separation distances from resources such as
surface water. Hydraulic fracturing chemical additive information is required
to be submitted to fracfocus.org (a publicly-available online database), with
the exception of additive information claimed as trade secrets. The TRC can
require operators to provide trade secret information to the agency if needed
to respond to emergency situations. There are essentially no oil and gas
wastewater discharges in Texas. Most oil and gas wastewater is disposed of in
Class II underground injection disposal wells. Some wastewater recycling for
use in hydraulic fracturing is now being done. The TCEQ issues permits for air
pollutant emissions from oil and gas facilities, and also conducts routine air
monitoring and enforcement monitoring. TCEQ has a large network of fixed air
monitoring stations for volatile organic chemicals, including monitoring sites
located near Barnett Shale wells. TCEQ also uses hand-held and aircraft-mounted
infra-red cameras for compliance and enforcement monitoring of oil
5.
and gas facilities such as pipelines, tanks, and
compressors. The cameras obtain direct evidence of leaks or fugitive emissions
of volatile chemicals from equipment and are considered an important
enforcement tool by TCEQ staff.
The TDSHS does not have a health surveillance program
specific to oil and gas development, but does maintain several general public
health surveillance programs similar to those in New York such as
infectious-disease reporting, birth defects registry, cancer registry, and
trauma registry. TDSHS has noted boomtown problems in some rural parts of the
state with rapid increases in oil and gas development. In particular, increased
incidence of sexually-transmitted diseases has been observed. Also, acute housing
shortages, including shortages of hotel rooms in remote locations, have been observed
to result in challenges for regulatory agencies visiting these areas and for social
services agencies attempting to place clients in temporary housing. Commonly reported
local concerns related to oil and gas development include noise, odors, and impacts
from truck traffic.
Illinois Illinois has a history of oil and gas
development similar to New York’s. As in New York, conventional vertical wells
in Illinois have been stimulated with low-volume hydraulic fracturing for many
decades. The New Albany shale formation is an unconventional shale that would
require directional drilling and HVHF stimulation for commercial oil and gas
development. Illinois convened representatives from statewide environmental organizations
and from industry to negotiate legislative language for a program to regulate
HVHF activity in the state. The bill was passed into law in 2013 and the IDNR is
the agency responsible for implementing the regulatory program.
5.
IDNR staff described several significant elements of the
Illinois program that were agreed to in the negotiations. Each well permit
application under the Illinois program will be subject to a public hearing
process (“contested case” process). Operators in Illinois will be required to
conduct water monitoring before and after drilling a well. In Illinois, operators
will be subject to a rebuttable presumption of liability, meaning that if water
contamination near a HVHF well is discovered, the operator will be assumed to
be liable for the contamination unless they can show they did not cause it. A
similar law applies to drillers in Pennsylvania, but not in New York. Operators
in Illinois will be required to provide complete information on the formula of
chemical additives used in each HVHF well to the IDNR. The information will be
made available publicly, except for information protected as trade secrets
under state law. However, IDNR will be able to share the trade secret
information with other state agencies, local emergency responders and physicians
when necessary. Operators in Illinois will be required to store HVHF wastewater
(including flowback and produced water) in above-ground storage tanks.
The draft SGEIS contains the same requirement.
The IDPH does not currently have a health surveillance
program specifically targeted at HVHF development. However, the state does maintain
similar health surveillance programs to those in New York, including cancer and
birth-defect registries and daily chief complaint reporting from emergency
departments (i.e., syndromic surveillance). As IDNR works to draft
administrative rules to implement the new HVHF law, an inter- agency workgroup
in Illinois has been formed that includes relevant state agencies including
IDPH. One issue being considered by the workgroup is the roles and responsibilities
of each agency in the implementation of the program. Enhanced public health
surveillance activities to be conducted by the IDPH is one area being
considered by this workgroup. IDPH staff on the call also suggested that health
surveillance activities focused on unconventional oil and gas development
(which includes HVHF
5.
and other technology such as directional drilling) might
ideally be coordinated at a national level by the federal Centers for Disease
Control and Prevention. However, such a national surveillance program does not
currently exist.
As is the case in New York, IDPH works as a consulting
agency to address public health issues that are raised by the environmental and
natural-resources agencies in the course of monitoring studies or complaint
investigations. IDPH is also considering providing relevant training for
HVHF-related emergency events to local physicians and emergency responders.
IDPH has been made aware of some significant public health concerns in an area
of the New Albany shale located in southwestern Ohio where HVHF development is
already active. Quality-of-life impacts were mentioned as particularly notable
in that region. Examples included rapid increases in housing costs resulting in
some renters being priced out of their homes and significant infrastructure damage
in some localities due to increased truck traffic.
Public Health Expert Consultation As part of this
Public Health Review, DOH sought additional input on public health aspects of
the draft SGEIS by consulting with three external public health experts. The consultants
were provided with DEC and DOH documents to review. Meetings were held with the
consultants by conference call and the consultants presented their final comments
and recommendations in the form of letters to former Commissioner Shah.
The public health expert consultants were given three charge
questions to help focus their review. Those charge questions were: •Are there
additional potential public health impacts of HVHF gas development that should
be considered beyond those already discussed in the SGEIS?
5.
•Are additional mitigation measures beyond those identified
in the SGEIS needed to address the potential health impacts of HVHF? If so,
what additional prevention or mitigation measures are recommended? •Are
existing and proposed environmental and health monitoring and surveillance systems
adequate to establish baseline health indicators and to measure potential
health impacts? If not, what additional monitoring is recommended? The
following letters from the public health expert consultants report their
findings and recommendations to former Commissioner Shah.
Office of the
Chair Department of Environmental and Occupational
Health Campus Box B119 13001
E. 17th Place Aurora, CO 80045 303
724 4692 office 303 724 4620 fax John.Adgate@ucdenver.edu publichealth.ucdenver.edu/environmentalhealth March
3, 2013 Nirav M. Shah, MD, MPH Commissioner New
York State Department of Health Albany, NY
Via Email Dear
Dr. Shah: Thank
you for the opportunity to review your Department’s “A Public Health Review of
the Department of Environmental
Conservation’s Supplemental Generic Environmental Impact Statement for Shale-‐-‐-‐Gas Development”
(hereafter, PHR). Your November 20, 2012 letter included the draft report and associated
materials on health outcome surveillance, existing and planned interactions between state and
local agencies under the proposed shale-‐gas program, the DEC’s SGEIS and the response to
comments on the SGEIS. Your charge to reviewers asked us to “focus
on whether additional public-‐-‐-‐health impacts should be considered in the SGEIS and whether
additional mitigation measures are needed to address potential public-‐-‐-‐health
impacts.” I provided initial comments on the November 20 draft prior to our conference call on
Monday December 3, 2012. After discussion with you, your staff, and my fellow peer reviewers,
I wrote the first version of this letter and submitted it to you on December 18, 2012. This
new version comments on the updated PHR I received in February 2013. My comments
are integrated into the earlier text, with some additional points added as an
addendum. My comments in this letter adopt the
convention of using “HVHF” or the phrase “shale gas development” to describe the entire process of
natural gas well development and production.
I do so because hydraulic fracturing is just one step in the natural gas development process and the potential public
health impacts are wide ranging and not limited
to fracturing. Lastly, since the final decision ultimately rests with New York
decision-‐ makers, these comments are
designed to address potential impacts and evaluate proposed mitigations in the event the HVHF ban in New
York State is lifted.
Adgate Letter to Dr. Shah
Page 2 of 6 My responses to the specific charge
questions are below, followed by conclusions and final comments.
Are there additional
potential public-‐-‐-‐health impacts of HVHF gas development that should be considered beyond those already
discussed in the SGEIS? If NY State decides to allow HVHF the DOH has
developed a viable approach to addressing the main public health issues associated with
shale gas development. The PHR and SGEIS describe a phased start to shale gas
development that is coupled with baseline and subsequent monitoring of potential impacts.
Although the PHR does not miss any major categories, I have highlighted potential
impacts that I believe warrant further attention. The
SGEIS acknowledges that increased traffic accidents are among the expected
impacts of HVHF. Given that local
government jurisdictions, as opposed to the state, have legal authority to designate and enforce local
traffic and road-‐-‐-‐use laws, it is important that DOH provides communities with tools to address
this issue. After our phone call it is my understanding that DOH will recommend that DEC
seek ways to strengthen the SGEIS in the area of local road-‐-‐-‐use agreements,
including development of model plans, and will develop approaches for including traffic-‐-‐-‐related
injuries in planned prospective surveillance.
The SGEIS addresses concerns
about noise and fugitive dust from pads and traffic, but it is important that DOH clearly define what is
included in “visual impairment” and address
other nuisance issues that
residents may experience. “Light pollution,” vibration, and odors can be an issue for residents living near well
pads and other production facilities. If gas development occurs in populated areas the
impact of odors (as distinct from criteria air pollutants and air toxics) is a likely common
complaint. These complaints are often the first signals of air pollution impacts. Details of
how DOH plans to work with local health departments
to formalize and coordinate systematic data collection on light, vibration, odors, noise, and other nuisance issues should
be fleshed out in the PHR and SGEIS. Development
of a database for systematic recording of inquiries and citizen complaints can help to identify sentinel events and address
community concerns about the potential impacts
on health and quality of life. The SGEIS air analysis looks at both criteria
and non-‐-‐-‐criteria air pollutants and is reasonable to the extent that emission inventories,
models, and other key assumptions are reliable.
One key uncertainty that should
be emphasized in the PHR is the lack of health-‐based standards for some of the air toxics emitted
during well development. Although it is reasonable
to use annual and short-‐term guideline concentrations, EPA provisional risk concentrations, and toxicity values from other
authoritative sources, modeling these emissions,
as described in the SGEIS, is only the first step in assessing potential air
risks. Linking these models to the
measurements included in the mitigation plans is important for assessing impacts and evaluating the
effectiveness of mitigation.
Adgate Letter to Dr. Shah
Page 3 of 6 The term “setback” largely applies to
distances to key watersheds in the PHR. I encourage broadening the use of this term in discussions
with the public to include distances from air emission sources as well. The PHR summary
notes that DEC needs to define more clearly setbacks from NYC watersheds and related
infrastructure. The rationale for setbacks for water, air, noise, and other quality of life
impacts needs to be clearer throughout the PHR and SGEIS.
The risk from HVHF near plugged
or abandoned wells is not directly addressed in the PHR. This potential hazard should also be explored
to the extent feasible. Both this hazard and potential well casing failure are scientific
uncertainties that may impact on aquifers over time. The SGEIS cites a relatively small
probability for well casing failure, but also notes that some parameters that feed into this risk
estimate are uncertain. I agree with the DOH’s assertion that the value of a highly uncertain
probabilistic risk estimate is difficult for decision-‐-‐-‐makers to evaluate.
Nonetheless, the potential for catastrophic failure should be acknowledged given the potential high
consequence of a failure. The overall impact of stress on individual
and community health is an important issue that the DOH and DEC need to acknowledge and assess
as rigorously as possible. While this concept
is implicit in some of the SGEIS text, stress needs to be more fully addressed
in the PHR and SGEIS. To help alleviate
this concern the DOH and DEC need to encourage active public participation in the permitting
process, foster community right-‐-‐-‐to-‐-‐-‐know, and make certain monitoring data is publically
available. A substantive, ongoing dialogue between State of NY officials and communities will be
needed to address this issue long term. Are additional mitigation measures beyond
those identified in the SGEIS needed to address the potential health impacts of
HVHF? If so, what additional prevention or mitigation measures are recommended? As
mentioned above, road-‐-‐-‐use agreements between operators and
municipalities are important for
reducing potential impacts from truck traffic. While this is appropriate, how this is implemented and enforced at the local
level is a key part of mitigation. It is important that DOH work with DEC to develop model
agreement language, engage local governments to minimize impacts from trucking operations,
and work to ensure this is a “funded” mandate. The
SGEIS includes environmental monitoring as mitigation in cases where the impact
of HVHF is uncertain. Continual
evaluation of monitoring data is intended to provide assessment of the effectiveness of mitigation
requirements and early detection of problems with well construction or operation. It is
important that the PHR states the frequency of these evaluations and how this information
will be disclosed to the public.
Adgate Letter to Dr. Shah
Page 4 of 6 Air monitoring of VOCs for 1 and 24 hrs is
mentioned as part of the mitigation strategies outlined in the PHR and SGEIS. It is important
to note that even a 1 hr average sample may miss short-‐term peak pollution levels nearby
residents may experience. Though there are no good solutions for real time monitoring for a
large number of air toxics, shorter term samples can be collected if done
systematically with a strong study design, quality control/assurance, and a clear plan for use of
the data. Mitigation approaches should consider
using less expensive proxy methods, such as measuring methane plumes, to obtain
emission rate estimates. This data may,
in turn, be coupled with more rigorous VOC characterization samples to estimate emissions
and/or human exposures to air toxics. This VOC characterization is done at the well head
in other states. Although the SGEIS states that NY shale is expected to yield mostly “dry”
gas, with low petroleum condensate levels, field gas sampling would be informative to help
validate existing geochemical data, assess the success of mitigations, and to characterize
these potential emission sources. If coupled with radon measurement, this data could be used to
address concerns about potential human exposure
to radon from this source. All mitigation assessments sample sizes for
baseline air, water, and health indicator measures should be specified to the extent
feasible for the proposed “phased” permitting process. While operator groundwater and air
monitoring plans proposed in the SGEIS will
be reviewed and approved by DEC
and DOH, the DEC and DOH should produce guidance on design, implementation and interpretation of
monitoring data. This guidance should also define how significant changes from baseline
will be determined. Are existing and proposed environmental
and health monitoring and surveillance systems adequate to establish baseline health
indicators and to measure potential health impacts? If not, what additional monitoring is
recommended? As a new program there are substantial
uncertainties associated with developing the health monitoring and surveillance systems through
existing health care systems. Use of “near
real time” and longer term
tracking and reporting mechanisms is good public health practice,
but acceptance of these measures as representative and informative depends on an effective communication platform. I agree
that respiratory, asthma, and neurological systems are the place to begin evaluation due
to the prevalence of these syndromes and existence of sensitive populations. Where
feasible, tracking should focus on expanded data collection in sensitive subpopulations. It
would be useful if DOH would conduct an environmental tracking exercise in as
near real time as possible to compare
baseline, local regulator, state regulator, and operator collected
data. This will require highly specific protocols so that data is collected in
ways that provide high quality exposure data that
can be explored in tandem with the health outcome data.
Adgate Letter to Dr. Shah
Page 5 of 6 Impacts of natural gas development on
community character is mentioned in the SGEIS, but formal evaluation metrics are not proposed.
While metrics for this issue are likely to be qualitative, it is important that guidance
describes how this metric will be measured and/or described prior to the initiation of
development. The potential mitigation suggested in the SGEIS, i.e., the DEC policy to abide by local
laws or ordinances prohibiting HVHF activity for the first 5 years of the program, may address
some community concerns if it is coupled with a substantive communication effort. Addendum:
Additional Comments on the PHR from February 2013 Version Review Background
and Recommendations Section: The lack of substantive research to address many of the main public health concerns is
still one of the major limitations facing both public health experts and decision-‐makers.
While this concern is front and center in this draft, the communication plan should be
highlighted here as well. This draft also identifies research by the Federal government and others
that will address important uncertainties.
It is important to highlight some
of the data the proposed monitoring and mitigation would collect and how it would address uncertainties
that are specific to HVHF in NY. Given that the final recommendation is about
the expert comments, I would also note that
it is likely that there will be
some unanticipated outcomes – history shows that even the best
prepared miss something. The DOH should reserve the option to intervene in
cases of unanticipated
consequences. Lastly, the recommendations section should
also address more clearly the issue of scale of impacts: if HVHF is allowed in NY State the
most public health relevant impacts will be at a local level. The recommendations should be
explicit that the mitigations are focused at that level. The section on water, for example,
notes that while the total amount of water used
at anticipated peak HVHF is small
compared to competing demands, there may be
“localized or transient impacts
that could affect water supplies.” The larger issue here is one of scale: both of the industry at peak
development, and the local scale where impacts
occur. This point is nicely made
in the context of water, but this “scale” of impacts point can and should also be made for air, noise, and
community quality of life impacts. Concluding Comments If
shale gas development goes forward in NY the approach outlined in the PHR
represents a viable strategy for
protecting public health. Prevention of impacts will, however, require a strong partnership between the DOH, DEC, and
the local governmental bodies engaged in land use planning, monitoring, and
enforcement. It is my belief that mitigation activities will
only be perceived as successful if the baseline and follow up monitoring data
are high quality, assessment protocols
are acceptable to all stakeholders, and the overall process is perceived as unbiased and transparent. This
will require an ongoing, substantive dialogue between the public, government, and industry
to address stakeholder concerns.
Adgate Letter to Dr. Shah
Page 6 of 6 During our conference call you asked the
reviewers if a Health Impact Assessment (HIA) should be done for shale gas development in NY
and we all said no. As someone who helped develop a HIA in Colorado I know the
benefits and shortcomings of HIA for addressing
future health impacts from natural gas development. Given the current state of the science I do not think a HIA can project
future health effects attributable to shale gas development with reasonable precision.
Furthermore, I do not think a state-‐specific HIA is the best tool for addressing issues that
transcend state borders. The impact of methane emissions during well development, for
example, is important given the realities of a changing climate. The science assessing the
cumulative effects of shale gas development on climate change is, however, still emerging,
and the implications of this work for NY-‐specific regulation unclear. For these reasons I
believe New York’s proposed prospective monitoring approach that focuses on preventing
future exposures, tracking potential health effects, and mitigation is preferable to a HIA
at this time. In closing, thank you for the opportunity to
review the DOH’s work, and please contact me if you have questions. Sincerely, John
L. Adgate, PhD, MSPH Professor and Chair Department
of Environmental and Occupational Health
Office of the
Chair Department of Environmental and Occupational
Health Campus Box B119 13001
E. 17th Place Aurora, CO 80045 303
724 4692 office 303 724 4620 fax John.Adgate@ucdenver.edu publichealth.ucdenver.edu/environmentalhealth December
18, 2012 Nirav M. Shah, MD, MPH Commissioner New
York State Department of Health Albany, NY
Via Email Dear
Dr. Shah: Thank you for the opportunity to review your
Department’s “A Public Health Review of the Department of Environmental Conservation’s
Supplemental Generic Environmental Impact Statement for Shale-‐Gas Development”
(hereafter, PHR). Your November 20, 2012 letter included the draft report and associated
materials on health outcome surveillance, existing and planned interactions between state and local
agencies under the proposed shale-‐gas program, the DEC’s SGEIS and the response to comments
on the SGEIS. Your charge to reviewers asked us to “focus
on whether additional public-‐health impacts should be considered in the SGEIS and whether
additional mitigation measures are needed to address potential public-‐health impacts.” I provided
initial comments on the November 20 draft prior to our conference call on Monday December 3,
2012. After discussion with you, your staff, and my fellow peer reviewers I have revised my
comments after receiving the updated “NY DOH Public Health Review” last week. My
comments in this letter adopt the convention of using “HVHF” or the phrase
“shale gas development” to describe the
entire process of natural gas well development and production. I do so because hydraulic fracturing is just one
step in the natural gas development process. The potential public health impacts can occur
either during the relatively intense well development phase or over the much longer production
phase. My responses to the specific charge questions
are below, followed by conclusions and final comments.
Adgate Letter to Dr. Shah
Page 2 of 5
Are there additional potential
public-‐health impacts of HVHF gas development that should be considered beyond those already discussed
in the SGEIS? The DOH has developed a strong document that
is a viable approach to addressing the main public health issues associated with shale gas
development. The PHR and SGEIS describe a phased start to shale gas development that is
coupled with baseline and subsequent monitoring
of potential impacts. Although the PHR does not miss any major categories,
I have highlighted potential impacts that I
believe warrant further attention. The SGEIS acknowledges that increased traffic
accidents are among the expected impacts of HVHF. Given that local government
jurisdictions, as opposed to the state, have legal authority
to designate and enforce local traffic and road-‐use laws, it is important
that DOH provides communities with tools
to address this issue. After our phone call it is my understanding that DOH will recommend that DEC
seek ways to strengthen the SGEIS in the area of local road-‐use agreements, including
development of model plans, and will develop approaches for including traffic-‐related
injuries in planned prospective surveillance.
The SGEIS addresses concerns
about noise and fugitive dust from pads and traffic, but it is important that DOH clearly define what is
included in “visual impairment” and address
other nuisance issues that
residents may experience. “Light pollution,” vibration, and odors can be
an issue for residents living near well pads and other production facilities.
As gas development increasingly occurs
in populated areas the impact of odors (as distinct from criteria air pollutants and air toxics) is a
common complaint. These complaints are often the first signals of air pollution impacts.
Details of how DOH plans to work with local health departments to formalize and coordinate
systematic data collection on light, vibration,
odors, noise, and other nuisance
issues should be fleshed out in the PHR and SGEIS. Development of a database for systematic
recording of inquiries and citizen complaints can help to identify sentinel events and address
community concerns about the potential impacts on health and quality of life. The
SGEIS air analysis looks at both criteria and non-‐criteria air pollutants and
is reasonable to the extent that emission inventories,
models, and other key assumptions are reliable.
One key uncertainty that should
be emphasized in the PHR is the lack of health-‐based standards
for some of the air toxics emitted during well development. Although it is reasonable
to use annual and short-‐term guideline concentrations, EPA provisional risk concentrations, and toxicity values from other
authoritative sources, modeling these emissions, as described in the SGEIS, is only
the first step in assessing potential air risks. Linking
these models to the measurements included in the mitigation plans is important
for assessing impacts and evaluating the
effectiveness of mitigation.
Adgate Letter to Dr. Shah
Page 3 of 5
The term “setback” largely applies
to distances to key watersheds in the PHR. I encourage broadening the use of this term in discussions
with the public to include distances from air emission sources as well. The PHR summary
notes that DEC needs to define more clearly setbacks from NYC watersheds and related
infrastructure. The rationale for setbacks for
water, air, and noise impacts
needs to be clearer throughout the PHR and SGEIS. While
not formally part of this public health review, potential well casing failure
and its impact on aquifers over time is a key
scientific uncertainty. The SGEIS cites a relatively small probability, but also notes that some
parameters that feed into this risk estimate are inherently
uncertain. I agree that for decision-‐makers the value of a probabilistic risk
assessment is problematic when outputs
of the analysis are highly uncertain. Nonetheless, the
potential for catastrophic failure should be acknowledged given the potential
high consequence of some failures. The
overall impact of stress on individual and community health is an important
issue that the DOH and DEC need to acknowledge and assess
as rigorously as possible. While this concept is implicit in some of the SGEIS text,
stress needs to be more fully addressed in the
PHR and SGEIS. To help alleviate
this concern the DOH and DEC need to encourage active public
participation in the permitting process, foster community right-‐to-‐know,
and make certain monitoring data is
publically available. A substantive, ongoing dialogue between State
of NY officials and communities will be needed to address this issue long
term. Are additional mitigation measures beyond
those identified in the SGEIS needed to address the potential health impacts of
HVHF? If so, what additional prevention or
mitigation measures are
recommended? As mentioned above, road-‐use agreements
between operators and municipalities are important for reducing potential impacts from
truck traffic. While this is appropriate, how
this is implemented and enforced
at the local level is a key part of mitigation. It is important that DOH work with DEC to develop model
agreement language, engage local governments
to minimize impacts from trucking
operations, and work to ensure this is a “funded” mandate. The
SGEIS includes environmental monitoring as mitigation in cases where the impact
of HVHF is uncertain. Continual evaluation of
monitoring data is intended to provide assessment of the effectiveness of mitigation
requirements and early detection of problems with well construction or operation. It is
important that the PHR states the frequency of
these evaluations and how this
information will be disclosed to the public.
Air monitoring of VOCs for 1 and
24 hrs is mentioned as part of the mitigation strategies outlined in the PHR and SGEIS. It is important
to note that even a 1 hr average sample may miss short-‐term peak pollution levels nearby
residents may experience. Though there are
Adgate Letter to Dr. Shah
Page 4 of 5
no good solutions for real time
monitoring for a large number of air toxics, shorter term samples can be collected if done
systematically with a strong study design, quality control/assurance, and a clear plan for use of
the data. Mitigation approaches should consider using less expensive proxy methods,
such as measuring methane plumes, to obtain emission rate estimates. This data may, in
turn, be coupled with more rigorous VOC characterization
samples to estimate emissions and/or human exposures to air toxics. This VOC
characterization is done at the well head in other states. Although the SGEIS
states that NY shale is expected to yield mostly “dry”
gas, with low petroleum condensate levels, field gas
sampling would be informative to help validate existing geochemical data,
assess the success of mitigations, and
to characterize these potential emission sources. All
mitigation assessments sample sizes for baseline air, water, and health
indicator measures should be specified to the extent
feasible for the proposed “phased” permitting process. While operator groundwater and air
monitoring plans proposed in the SGEIS will
be reviewed and approved by DEC
and DOH, the DEC and DOH should produce guidance on design, implementation and interpretation of
monitoring data. This guidance should also
define how significant changes
from baseline will be determined. Are existing and proposed environmental
and health monitoring and surveillance systems adequate to establish baseline health
indicators and to measure potential health
impacts? If not, what
additional monitoring is recommended? As a
new program there are substantial uncertainties associated with developing the
health monitoring and surveillance
systems through existing health care systems. Use of “near real
time” and longer term tracking and reporting mechanisms is good public
health practice, but acceptance of these measures as
representative and informative depends on
an effective communication
platform. I agree that respiratory, asthma, and neurological systems are the place to begin evaluation due
to the prevalence of these syndromes and existence of sensitive populations. Where
feasible, tracking should focus on expanded data collection in sensitive subpopulations. It
would be useful if DOH would conduct a environmental tracking exercise in as
near real time as possible to compare baseline, local
regulator, state regulator, and operator
collected data. This will require
highly specific protocols so that data is collected in ways that
provide high quality exposure data that can be explored in tandem with the
health outcome data. Impacts
of natural gas development on community character is mentioned in the SGEIS,
but no formal evaluation metrics are proposed.
While metrics for this issue are likely to be qualitative, it is important that guidance
describes how this metric will be measured and/or described prior to the initiation of
development. The potential mitigation suggested in the SGEIS, i.e., the DEC policy to abide by local
laws or ordinances prohibiting HVHF activity for
Adgate Letter to Dr. Shah Page
5 of 5 the first 5
years of the program, may address some community concerns if it is coupled with
a substantive communication effort. Concluding
Comments If shale gas development goes forward in NY
the approach outlined in the PHR represents a reasonable strategy for protecting public
health. Prevention of impacts will, however,
require a strong partnership
between the DOH, DEC, and the local governmental bodies engaged in land use planning, monitoring, and
enforcement. It is my belief that mitigation activities will only be perceived as
successful if the baseline and follow up monitoring data are
high quality, assessment protocols are acceptable to all stakeholders, and the
overall process is perceived as unbiased
and transparent. This will require an ongoing, substantive dialogue between the public, government, and
industry to address stakeholder concerns.
During our conference call you
asked the reviewers if a Health Impact Assessment (HIA) should
be done for shale gas development in NY and we all said no. As someone who helped
develop a HIA in Colorado I know the benefits and shortcomings of HIA for addressing
future health impacts from natural gas development. Given the current state
of the science I do not think a HIA can project
future health effects attributable to shale gas development with reasonable precision.
Furthermore, I do not think a state-‐specific HIA is the
best tool for addressing issues that transcend state borders. The impact of
methane emissions during well
development, for example, is important given the realities of a changing
climate. The science assessing the cumulative effects of shale gas development
on climate change is, however, still
emerging, and the implications of this work for NY-‐specific regulation unclear. For these reasons I
believe New York’s proposed prospective monitoring approach that focuses on preventing
future exposures, tracking potential health effects, and mitigation is preferable to a HIA
at this time. Thank you for the opportunity to review the
DOH’s work, and please contact me if you have questions.
Sincerely, John
L. Adgate, PhD, MSPH Professor and Chair Department
of Environmental and Occupational Health
March 4,201.
Nirav R. Shah, M.D., M.P.H.
Commissioner, NY State Department of Health Corning Tower Empire
State Plaza Albany, NY 1223.
Dear Dr. Shah: I have completed my peer review of the
public-health elements of the Department of Environmental Conservation's (DEC)
supplemental generic environmental impact statement (SGEIS) for high-volume hydraulic
fracturing (HVHF). As requested, this letter summarizes my review of your
Department's effort to date.
Overview The charge was to "focus on whether
additional public-health impacts should be considered in the SGEIS and whether
additional mitigation measures are needed to address potential public-health
impacts."I also was to "consider whether existing and proposed
environmental and health monitoring and surveillance systems are adequate to
establish baseline health indicators and to measure potential health impacts."
The NY DOH specifically identified several areas of possible concern for public
health: contamination of drinking water resources; ambient air pollution;
releases of naturally-occurring radioactive materials (NORM); community impacts
related to noise and utilization of local services like transportation;
healthcare, education, housing and social services; and adequacy of existing
and proposed health surveillance and HVHF-related monitoring programs.
Specifically peer reviewers were to address three questions:
1. Are there additional potential public-health impacts of HVHF gas
development that should be considered beyond those already discussed in
the SGEIS? 2. Are additional mitigation measures beyond those identified
in the SGEIS needed to address the potential health impacts of HVHF? If
so, what additional prevention or mitigation measures are recommended? 3.
Are existing and proposed environmental, health monitoring, and surveillance
systems adequate to establish baseline health indicators and to measure
potential health impacts? If not, what additional monitoring is
recommended? In addition to the Health Review Scope and Process, you
provided a number of documents for review: 1. "NYSDOH Review of NYSDEC’s
Supplemental Generic Environmental Impact Statement", dated November
20,2012.
2. "Development
of a Health Outcome Surveillance Program for High-Volume Hydraulic Fracturing
in New York State" (markedCONFIDENTIAL INTRA-AGENCY DRAFT/FOR DELIBERATION
ONLY NOT SUBJECT TO FOIL), dated November 19, 2012.
3. "Description of Anticipated Work and
Responsibilities for Center of Environmental Health, Local Health Departments/District
Offices, and Department of Environmental Conservation Associated with HVHF Gas Well
Drilling" (markedCONFIDENTIAL INTRA-AGENCY DRAFT/FOR DELIBERATION ONLY NOT
SUBJECT TO FOIL), dated November 19, 2012.
4. "Advisory Panel on High-Volume Hydraulic Fracturing:
State Resource Needs", New York State Department of Health, Center for
Environmental Health, dated September 9, 2011.
5. A complete copy of the Interagency Confidential Draft
Final SGEIS.
6. A set of health related excerpts from the Draft Final
SGEIS prepared by the NY DOH including: (a) a second copy of the Executive
Summary from the Draft Final SGEIS; (b) Section 5.4.3.1 of the SGEIS; (c) Section
6.14 of the SGEIS; and (d) a second copy of the Appendix 34, Summary of Health
impacts, a document titled "NYSDOH and DEC Summary of Potential
Health-Related Impacts and Proposed Mitigation Measures for High-Volume
Hydraulic Fracturing".
7. A set of health-related excerpts from the DEC Document:
"Response to Comments. Final Supplemental Generic Environmental lmpact
Statement" including comments excerpted from all areas that might be health
related, not just the "Health Impacts" section.
I sent you a first draft of my review on December 2,2012.
You held a conference call with John Adgate, Richard Jackson, and I on December
3,2012. On December 7,2012, you emailed me: (1) A revised document titled
"A Public Health Review of the Department of Environmental Conservation's Supplemental
Generic Environmental lmpact Statement for Shale-Gas Development" with
changes shown in "track changes", dated December 7, 2012 and (2) a
copy of all three of the draft reviewer's comments with annotations (in track
changes) from NY DOH staff. On December 17,2012 1 sent you a letter responding
to these revised documents. In mid-February you sent me a revised confidential
draft: "Public Health Review of the Department of Environmental
Conservation's Draft Supplemental Generic Environmental lmpact Statement for
Shale-Gas Development" and requested review of this draft. Copies of my
prior responses to the charge questions with the NY DOH staff comments are
attached to this letter as Attachment A. At this time I am responding only to
the revised draft public health review.
NY State has done a credible job of thoroughly reviewing
potential environmental health impacts of HVHF.
Itis commendable that such a review has been undertaken
prior to issuing permits for such activities.
Although this process did not follow the academic model for
a Health lmpact Assessment I applaud the DOH for having used the DEC SGEIS
process to achieve the same end. In some ways this feels like a better process
in thatithas established the basis for a stronger role for DOH in working with
DEC moving forward. As noted previously, I am pleased that NY is committed to
reducing methane emissions in the context of HVHF activities. I recommend that
New York State continue and expand its efforts to develop cleaner alternative
energy sources. New York's renewable energy portfolio standard, Governor
Cuomo's NY-Sun initiative and effort to reduce electricity demand 15 percent by
2015, is a good beginning.
As I have noted previously, many of the proposed mitigation
measures are a model for other states that
are considering or
undertaking these operations. I agree with the notion embedded in the latest
review that such mitigation measures would need to be monitored over time.
Second I agree with the notion of a phased approach to HVHF gas-development
that would allow public health problems to be identified earlier, and reduce
problems resulting from overly rapid growth ("boom and bust"). Third,
I especially concur with the notion of not allowing HVHF gas-development
activity within 4000 feet of the New York City and Syracuse drinking-water
supply watersheds.
I am pleased that in this latest draft the NY DOH has
addressed a number of issues that I had flagged in my prior reports. The
revised document more strongly emphases the numerous data gaps and
uncertainties with regard to potential public health impacts of HVHF. I agree
with the notion that studies that are underway nationally (the US EPA hydraulic
fracturing study) and in Pennsylvania will be helpful in this regard. I am less
sanguine about ongoing health studies because I think these are unlikely to
capture subclinical health effects as well as effects that occur with longer
latency or lag times. I agree with the DOH recommendation to expand its
Behavioral Risk Factors Surveillance System to collect critical baseline information
in the Marcellus region. I also agree with the decision to explore approaches
for including worker and traffic-related injuries, psychosocial stress and
noise. Perhaps most important is the new recommendation that the DOH will
collaborate with the DEC in assessing new data on HVHF health and environmental
impacts as well as the effectiveness of mitigation measures. Some of the most
important information will be environmental information because of the problems
(noted above) with needing to protect the public from effects that are
subclinical or have long latencies and are difficult to detect in real- time
using epidemiology.
As noted in prior communications, I think that DOH would
require resources for public communications engagement, particularly for those
most concerned about health, for example, local health agencies, health
providers and members of the public.
Thank you very much for again having had the opportunity to
review the "Public Health Review of the Department of Environmental
Conservation's Draft Supplemental Generic Environmental Impact Statement for
Shale-Gas Development". This document as it currently stands is an
excellent review of the relevant public health issues, and attendant uncertainties
and data gaps.
Attachment: Attachment A
December 17,2012 Nirav R. Shah, MD., M.P.H. Commissioner, NY State Department of Health Corning Tower Empire State Plaza, Albany, NY 12237 Dear Dr. Shah: I have completed my peer review of the public-‐health
elements of the Department of Environmental Conservation's (DEC) supplemental generic
environmental impact statement (SGEIS) for high-‐volume hydraulic fracturing (HVHF). As requested, this letter
summarizes my review of your Department's effort to date. Overview As I understand the charge, it was to
"focus on whether additional public-‐health impacts should be considered in the SGEIS and whether additional mitigation
measures are needed to address potential public-‐health impacts. " I also was to "consider
whether existing and proposed environmental and health monitoring and surveillance systems are adequate to establish
baseline health indicators and to measure potential health impacts." The New York Department of
Health (NY DOH) specifically identified several areas of possible concern for public health: contamination of
drinking water resources; ambient air pollution; releases of naturally-‐occurring radioactive materials
(NORM); community impacts related to noise and utilization of local services like transportation; healthcare,
education, housing and social services; and adequacy of existing and proposed health surveillance and HVHF-‐related
monitoring programs. You charged peer
reviewers to address three questions: "1.
Are there additional potential public-‐health impacts of HVHF gas development
that should be considered beyond
those already discussed in the SGEIS? 2. Are additional mitigation measures
beyond those identified in the SGEIS needed to address the potential health impacts of HVHF? If so, what
additional prevention or mitigation measures are recommended? 3. Are existing and proposed environmental
and health monitoring and surveillance systems adequate to establish baseline health indicators and to
measure potential health impacts? If not, what additional monitoring is recommended?" In addition to the Health Review Scope and
Process, you provided me with a number of documents for review including: 1. "NYSDOH Review of NYSDEC’s
Supplemental Generic Environmental Impact Statement", dated November 20,
2012. 2. "Development of a Health
Outcome Surveillance Program for High-‐Volume Hydraulic Fracturing in New York
Goldman Page 2 December 17,2012 State" (marked CONFIDENTIAL INTRA-‐AGENCY
DRAFT/FOR DELIBERATION ONLY NOT SUBJECT TO FOIL), dated November 19,2012. 3. "Description of Anticipated Work and
Responsibilities for Center of Environmental Health, Local Health Departments/District Offices, and Department
of Environmental Conservation Associated with HVHF Gas Well Drilling" (marked CONFIDENTIAL INTRA-‐AGENCY
DRAFT/FOR DELIBERATION ONLY NOT SUBJECT TO FOIL), dated November 19,2012. 4. "Advisory Panel on High-‐Volume
Hydraulic Fracturing: State Resource Needs." New York State Department of Health, Center for Environmental Health.
September 9,2011. 5. A complete copy of
the Interagency Confidential Draft Final SGEIS. 6. A set of health related excerpts from the
Draft Final SGEIS prepared by the NY DOH including: (a) a second copy of the Executive Summary from the Draft
Final SGEIS; (b) Section 5.4.3.1 of the
SGEIS; (c) Section 6.14 of the SGEIS; and (d) a second copy of the Appendix 34,
Summary of Health impacts, a document
titled "NYSDOH and DEC Summary of Potential Health-‐Related Impacts and Proposed Mitigation Measures for High-‐Volume
Hydraulic Fracturing". 7. A set of
health-‐related excerpts from the DEC Document: "Response to Comments.
Final Supplemental Generic Environmental
Impact Statement" including comments excerpted from all areas that might
be health related, not just the
"Health Impacts" section. I
sent you a first draft of my review on December 2,2012. You held a conference
call with John Adgate, Richard Jackson
and I on December 3,2012, during which we discussed potential local-‐community
impacts; health and environmental
monitoring and surveillance programs; potential impacts from contamination of
air resources; potential impacts from
contamination of drinking water resources; potential impacts from naturally-‐occurring radioactive material
(NORM); and other issues that we reviewers had brought forward either in our draft reviews or in our verbal
comments and discussion. On December 7,2012, you emailed me: (1) A revised document titled "A Public
Health Review of the Department of Environmental Conservation's Supplemental Generic Environmental Impact
Statement for Shale-‐Gas Development" with changes shown in "track changes", dated December
7,2012 and (2) a copy of all three of the draft reviewer's comments with annotations (in track changes) from NY DOH
staff. The copy of my draft responses to the charge questions with the NY DOH staff comments is attached to
this letter (Attachment A); General
Comments: From the review of the
documents listed above I conclude that NY State has done a credible job of
thoroughly reviewing potential
environmental health impacts of HVHF. It is commendable that such a review has
been undertaken prior to beginning to
issue permits for such activities, and that local communities would be involved in the permitting process. The SGEIS
report has been provided to the public for review and the extensive numbers of comments that have been
received (as per the Response to Comments document) are indicative of a participatory public process.
It is also clear that involvement of the NY DOH over the last few years has helped to highlight and address a
number of potential public health concerns. In particular the draft "Description of Anticipated Work and
Responsibilities for Center of Environmental Health, Local Health
Goldman Page 3 December 17,2012 Departments/District Offices, and
Department of Environmental Conservation Associated with H VHF Gas Well Drilling" indicates a thorough and
thoughtful approach to assuring that environmental health threats are addressed collaboratively by New York's state
and local health and environmental health agencies. In my experience it often is difficult to bring
these various branches of government together in order to assure a tight environmental health safety net. This is
among the best of such frameworks that I have reviewed. While it is not a formal Health Impact Assessment
the review is, nonetheless, very thorough, and I was able to identify only a few areas that require more
review. Generally speaking, if HVHF gas
development is permitted in NYS, there are four additional aspects of the approach taken in the SGEIS that are of
critical importance for public health. First is that, the proposed mitigation measures should serve as a model
for other states that are considering or undertaking these operations. However, no number of mitigation
measures can provide one hundred percent assurance of safety and it is therefore important that the
New York DOH would have adequate funding for surveillance activities as well as follow up investigations
that would allow for identification of ways that mitigation measures need to be improved as well as
potential health impacts. Second it is important that, if NY decides to move forward with HVHF gas-‐development
that, as proposed in the SGEIS, there would be a "phased rollout approach". This not only would allow
public health problems to be identified earlier, but also reduce problems resulting from overly rapid growth
("boom and bust"). Third, I agree with the SGEIS proposal that would not allow HVHF gas-‐development
activity within 4000 feet of the New York City and Syracuse drinking water supply watersheds. Finally, it is of utmost
importance that New York would allow local input into decision-‐making about permits. In addition to specific concerns that are
described below, there are some general recommendations that I would like to put forward with regard to
provision of public information and involvement of the public moving forward: 1. Continue the Process of Assessing
Health Impacts: Regardless of when and how NY State moves forward with HVHF activities additional health
assessment activities are warranted, I recommend that the NY DOH appoint a panel of experts and citizens to
constitute a HVHF health assessment committee. Such a committee could support the DOH as well as the DEC and
local health and environmental agencies in review of health related data and other issues. Further assessment of
health impacts is needed. While the SGEIS accomplishes many of the goals of an HIA there are still
additional issues that need to be addressed. If NY State decides to lift the ban on HVHF the committee can guide
the NY DOH in its process of adaptive management as well as reviewing any additional data that may come
forward. On the other hand, if HVHF is not permitted but continues to be under consideration, NYS
should consider conducting a formal HIA an advisory panel could assist with that process. I appreciate that the
revised DOH report recommends exploring options for establishing an advisory panel to advise DOH
and DEC on health issues. One caveat is that an advisory process would require resources, and that, if NY State
moves forward with HVHF resources also should be made available for possible health investigations
or even full-‐scale studies, possibly with guidance from an advisory panel. 2. Address Right-‐To-‐Know: The CEH
DEC and local agencies are planning to develop a tremendous amount of information with regard to HVHF including,
potentially: In my draft comments I listed a number of data sets that would be relevant to HVHF-‐related
health concerns and that should be better shared among agencies, industry and the general public. Rightfully
there is a focus on information sharing among agencies but public
Goldman Page 4 December 17,2012 transparency also is important. The DOH
is recommending that DEC upgrade its existing publicly-‐available web-‐based oil and gas drilling information
to be a clearinghouse that would provide all interested parties with ready access to the breadth of HVHF
information collected under the program (e.g., well locations, monitoring data, and health surveillance findings). This
is responsive to my concern about this issue. Additionally, I would hope that there would be strong involvement of
DOH to assure that health relevant data are captured, including, as noted by DOH, "near-‐real
time monitoring and surveillance results". 3. Engage the Public: It is not
clear how the public would be engaged beyond the GEIS process. Local communities have a tremendous amount of
information that is useful for agencies, and that understanding their concerns is useful in guiding the
development of education and outreach materials. This issue is of great concern both in those communities and
statewide and public engagement activities need adequate resources to assure that the State is reaching out and
involving the public proactively. In the response to this concern, the DOH has emphasized the efforts that DEC
plans to undertake to meet periodically with industry officials and local government staff; to obtain public
comment for applications for well pads; to disclose hydraulic fracturing fluid content for each chemical
before drilling and after well completion; to post waste tracking forms on a website for view by the public; and
to provide local points of contact for disseminating information. These are good efforts. Additionally DOH
itself would require resources for public communications engagement, particularly for those most
concerned about health, for example, local health agencies, health providers and members of the public. 4. Address Greenhouse Gases: The
draft SGElS correctly identifies greenhouse gases (GHG) as potentially causing public health impacts, especially
methane and carbon dioxide. The SGElS thoroughly assesses the potential for emissions of these gases both in
development and production of HVHF wells and in "post production", i.e., transport and use of
natural gas, and highlights the requirement to comply with new EPA regulations requiring greenhouse gas
mitigation measures and performance standards for new sources in the oil and natural gas industry. However, use of
natural gas by utilities and companies to generate electricity in New York will of course emit more GHG's than
would result from the development of certain alternative energy sources. Granted, the use of natural
gas in New York State will occur regardless of the point of origin of the natural gas. Nonetheless, the draft
SGElS points to credible efforts by New York to promote the transition to cleaner sources of electricity,
including the renewable energy portfolio standard, Governor Cuomo's NY-‐Sun initiative, New York's energy
efficiency portfolio standard which seeks to reduce electricity demand 15% by 2015. 1 recommend that this
approach be strengthened in the context of cheaper natural gas, and (to date) lack of a mechanism to
internalize the costs of carbon dioxide and methane emissions to the atmosphere, nationally or in New York. Specific Comments and Recommendations: Question 1: Additional potential public-‐health
impacts of HVHF gas development that should be considered beyond those already discussed in the SGElS
Chemicals and Radionuclides: I
am pleased that in the December 7 "Public Health Review ..." you
noted my concern about the level (and
quality) of information about formaldehyde, glycol ethers/ethoxylated alcohols and microbiocides (Attachment A), and have
stated your intention to request that DEC "DEC, in collaboration with DOH, must revise the SGElS to reflect
additional available" about these chemicals. I also raised a concern with the possibility that flow-‐back and
produced waters could become contaminated by various naturally-‐
Goldman Page 5 December 17,2012 occurring metals like arsenic, cadmium,
lead, manganese, and mercury, depending on what is present naturally. NY DOH points to language in the
SGElS indicating that a number of required mitigation measures would be used. I would agree that proper
measures need to be taken to assure that such waters are properly handled, treated and disposed of. However, I
continue to think that such an approach requires information about levels and toxicity of contaminants,
including metals. As to the more
general issue of potential public health impacts of HVHF-‐related chemicals,
one of the recommendations in the DOH
report is that DEC must continue to engage DOH to evaluate potential health concerns related to any new fracturing
additive chemicals that are proposed for use as HVHF development proceeds and to develop protocols that are to
be followed for conducting alternatives assessments for HVHF chemical additive products. I strongly agree
with this recommendation. Potential
Human Health Impacts: Drinking
Water: I support DOH plans to evaluate levels of drinking water pollutants
and provide a public health
interpretation of these data. DOH would require resources for this. Air pollution: I reviewed the air pollution
models and found them to be quite complex and very dependent on conditions that could be site-‐specific which
as stack heights, placement of engines and presence of H2S or "sour" gas in sites. The model for
PM2.5 suggests that additional mitigation measures may be needed to prevent short-‐range impacts. Similarly the
model predicts the need for additional controls of benzene and formaldehyde emissions. The SGElS also
provides preliminary models for ozone formation that suggest the need to address ozone projections over time.
Although local communities may not be interested in precise quantification of emissions, permit decisions
may at least in part depend on anticipated air releases related to these operations. I appreciate that the DOH
would review and interpret air monitoring data including assessing potential health impacts. Water availability: I appreciate that in
response to my draft comments the DOH report has been revised to refer to potential health impacts related to
other water-‐quality issues, including loss of fish resources (recreationally and as a source of healthy
food), water recreational opportunities, and flood control. Also in response to my draft comments, DOH has
informed me that the DEC has promulgated water withdrawal regulations (http://www.dec.nv.nov/regulations/78258.htmI)
and that the DOH will reference these regulations in their report. Such regulatory
requirements are important, as well as carrying out monitoring activities to make sure that the cumulative
sum of water withdrawals related to HVHF does not harm downstream aquatic environments. Socioeconomic impacts: While job creation is
expected to occur, new jobs would be distributed unevenly around the state. Some areas could experience
short term labor shortages and therefore increased wages, possible negative impacts on existing industries,
and in-‐migration of new specialized workers and their families. Employment in impacted regions is
expected to peak in 20 years; income from operations in 30 years. If the additional jobs employ people in
these communities who currently are unemployed or underemployed this could increase income to
households and reduce service demands on public health. On the other hand, if prices increase rapidly
this could have a negative effect on families and increase demands for public health services.
Goldman Page 6 December 17,2012 Population impacts: The SGElS found that
while population impacts would be minor statewide there could be more significant impacts in particular areas,
perhaps offsetting population declines that are occurring in some of these rural areas. The SGElS notes that in
construction phases there would be many workers who live locally in temporary housing. Local health
authorities would experience increased demand for public health services from such temporary residents as well
as issues related to safety of food, drinking water and housing. In areas where populations increase quickly
there could be impacts on access to medical care and adequacy of emergency medical services. Traffic: The SGElS has considered the potential
for increased traffic impacts and there likely to would be significant impacts in many areas. In addition
to noise and air pollution impacts there are potential impacts due to traffic related injuries. NIOSH has
reported that workers in the oil and gas injury have high rates of traffic related injuries and mortality;
presumably residential vehicles and pedestrians could be at risk as well. Healthcare and public health services: I recommend consideration of potential impact
on public health systems and
healthcare services from rapid population changes. I understand, from
responses to my draft comments, that DOH
thinks that DEC's proposed phased roll out of HVHF permitting would be expected
to mitigate the possible effect of rapid
population growth and the associated increased demand for services. DOH stated
that ongoing interaction with and
monitoring of healthcare facilities would keep the agency appraised of impacts on such facilities. Likewise DOH expects that
its routine interactions with the local health departments that provide local public health would keep them
informed of potential impacts on local public health programs, and resource needs of these programs. While
the phased rollout is likely to be helpful on a statewide basis there could be relatively large changes
impacting health and public health services in local communities. I would recommend a more proactive approach that
would attempt to anticipate potential impacts on healthcare and public health systems before
there are any impacts on health in communities. Finally, DOH has noted in response to my draft comments that,
"If HVHF permitting is authorized in NYS, additional resources would be made available to local health
departments." I would agree with that approach. Injury control: In response to another one of
my recommendations in the earlier draft, the DOH states that it would address additional injury prevention and
surveillance activities by exploring mechanisms to include worker and traffic-‐related injuries/deaths
in health surveillance activities, and to enhance injury prevention activities. I would agree with that approach. Noise:
My draft comments noted that noise impacts of HVHF are greater than
conventional gas wells during the period
of time when horizontal drilling is underway, that HVHF is associated with more
noise from diesel truck traffic, and
that the SGElS did not discuss noise impacts on health. I recommend that if
HVHF activities proceed,
noise levels near operations should be monitored to determine appropriate
mitigation efforts to protect
human health. In its response the
DOH states that it "will provide DEC with additional information for the SGElS on the potential human health
effects (i.e., beyond simply annoyance) of noise". As they note, the impact analysis discussion and the mitigation
measures are targeted at human receptors. However, I think that an understanding of potential health
hazards is relevant to decision making including recommendations for local noise monitoring. Local emergency planning: The draft SGElS lays out a set of mitigations
that include a requirement for operators
of sites to respond in emergency situations (Section 7.13). I recommend consideration of potential impacts to local first responder systems. As noted above, the phased rollout would be
helpful on a statewide
Goldman Page 7 December 17,2012 basis there could be relatively large
changes in demand for emergency services impacting local communities. Psychosocial stress: I am pleased that in
response to my draft comments the DOH has indicated that their report will specifically identify stress as a
public health issue. DOH has indicated that they "will explore approaches/metrics for evaluating stress
(e.g., tracking prescription drug use)" and/or via modifications to the BRFSS. Question 2: Additional mitigation measures
beyond those identified in the SGElS needed to address the potential health impacts of HVHF Generally NY State has proposed a set of
mitigation measures that, if successful would do much to address the potential impacts of HVHF. As noted in my
general comments (above) I have broad concerns about the engagement and participation of the public in
decision making going forward, as well as how the public's rightto-‐ know can be addressed via making information
available in real-‐time. In terms of more specific recommendations, and the DOH response to these
recommendations: 1. Permitting
decisions need to be informed by information about local impacts especially in
areas that are difficult to model in the
general case, for example in estimation and control of PM2.5 emissions, which
can have serious local impacts. 2. Regional impacts on ozone formation also
would need to be addressed over time. DOH indicates that it agrees with this point and that the issue is
mentioned in the SGEIS. 3. As noted
above, DOH indicates that noise will be recognized as a health hazard,
measured, and mitigated to control
health risks. 4. DOH has indicted that
stress and stress-‐related health effects also will be identified as potential
health hazards. 5. DOH indicates that it will address local
traffic impacts as causing potential hazards, specifically, air emissions, increased noise, possibly increased
stress and increased risk of unintentional injury. 6. I continue to think that specific
communities could see local impacts on local public health and healthcare services as well as emergency medical services
and first responders, and that this needs to be addressed proactively. Question 3: Adequacy of existing and
proposed environmental and health monitoring and surveillance systems to establish baseline health indicators and
to measure potential health impacts Generally, NY State has a strong public
health surveillance system and the kind of expertise in this area that provides a strong foundation for a special
surveillance effort such as the one outlined in the draft document: "Development of a Health Outcome
Surveillance Program for High-‐Volume Hydraulic Fracturing in New York State". The basic elements of the system
-‐-‐near real-‐time surveillance, longer-‐term surveillance, and a public reporting mechanism -‐form a sound framework
for such a program. ESSS: The proposed
use of the existing Electronic Syndromic Surveillance System (ESSS) seems
appropriate. Covering hospital emergency
department visits in most of the state, it would pick up unusual upticks in a number of health conditions and I would agree
that the selection of respiratory, asthma and neurological
Goldman Page 8 December 17,2012 outcomes is a reasonable target for HVHF-‐related
outcomes. I also think that it is reasonable for NY to incorporate new "flags" related to
HVHF for detection of unusual numbers of Emergency Room (ER) visits. Additionally the plans for follow-‐up
investigations also are reasonable. I
recommend that NY consider developing and articulating more explicit
criteria for when additional actions will be taken in order to fully explicate
statements like l'ifunusual patterns or possible links are found". In response to this recommendation DOH indicates
that if HVHF permitting is authorized in NYS then they would, a priori, more specifically define what
is meant by "unusual patterns" or "possible links". In that
case I also recommend that NY DOH obtain
input both from scientific peer reviewer and stakeholders to increase the credibility and transparency of the effort. Longer Term Tracking: The proposed longer
term tracking effort is appropriate and builds on New York's existing surveillance capacity. I agree that
this longer-‐term effort should be carried out in the absence of findings from the ESSS system since many
health issues would not manifest themselves via time-‐related clusters of ER visits. I recommended (and NY DOH indicates
that they agree) an initial focus on outcomes with short latency periods, which would include birth outcomes (low
birth weight, preterm birth, and birth defects) and hospital admissions for myocardial infarction and respiratory
diseases. Cancer surveillance also is important but is a longer term effort. I
also recommend monitoring changes
in other risk factors for these outcomes, for example, downward trends in air pollution and smoking. As noted above
ideally the NY DOH would have resources for follow-‐up studies. Additional Surveillance: In addition to the
above there are some additional steps that could be taken to enhance public health surveillance. First, ER
surveillance could miss episodes where events are more spread out over time and/or where people either do not seek
emergency room care. Second, NY DOH should be able to take advantage of existing routine environmental monitoring,
especially of air and water pollutants. I also recommended (and NY DOH agreed)
systematic collection of physician and citizen reports of possible adverse health problems associated with HVHF. They
also agreed with my recommendation to link traffic injury and mortality data as well as occupational
injury data to GIS data on HVHF activities to spot opportunities to mitigate motor vehicle injury risks in association
with HVHF activities. Finally, NY DOH indicates that they have intended
that they would conduct analyses
of air and drinking water data collected by other state and local agencies and
provide surveillance summaries of
levels and trends of pollutants associated with HVHF activities. In closing, I recognize the truly impressive
quantity and quality of work that has been performed to date by the NY DOH. I also realize that the above
recommendations cannot be accomplished without the application of sufficient resources at multiple levels, from communities
through the staff at the NY DOH. Thank you very much for the opportunity to peer review the draft SGEIS and
the State DOH plans. Enclosure
Dr Nirav Shah Commissioner,
New York State Department of Health Los Angeles, CA 9009.
Dear Doctor Shah: Thank you for your request that I and two
other independent health advisors review the materials that were provided to us
on High-‐Volume Hydraulic Fracturing (HVHF) in New York State (NYS).
NYS has taken on a very difficult and important challenge.
You and your colleagues have devoted considerable resources and hard work in
confronting the health issues related to HVHF. These efforts are truly
commendable and for this reason I agreed to perform my review on voluntary non-‐paid
basis for NYS, and my comments are my own and are not those of my employer.
As noted in my Curriculum Vitae, I am a physician, a member
of the U.S. Institute of Medicine, and have more than thirty years’ experience
in environmental public health leadership at the federal and state levels.
Given the importance of energy availability and reduction of
petroleum imports, and the pervasiveness of the proponents’ advertising
campaigns and political power, HVHF is likely to continue in the United States
and worldwide. At the same time, HVHF is confounded by serious concerns about
environmental degradation and worker and community health impacts. With such
important and complex issues regarding HVHF, we are all burdened by inadequate
federal health leadership and the paucity of useful federal health research in
this area.
HVHF is at a scale and impact that the need for a national
Health Impact Assessment (HIA) has urgency.
All means of energy production have impacts on health, and
these impacts can be substantial at the global, community, and personal levels
and include risks to workers, consumers, and residential populations. This is
true for the more conventional means of energy production—hydro, coal,
petroleum, solar, natural gas. It is also true for HVHP operations.
The public is deeply concerned about HVHF as evidenced by
the 80,000 public comments received during the preparation of the NYS SGEIS.
The comments enumerated specific health concerns as well as profound worry about
the community stress from these operations and impacts to the landscape and
beauty of upstate New York.
These “quality of life” issues were mentioned but to a lesser
extent than quantified toxic exposures in the SGEIS
report. Yet such
community impacts perdure; they can be multigenerational and small impacts
multiplied by centuries become large.
Because of the unknown risks, NYS is appropriately cautious
in the decision about HVHF. The following issues are to me the most important
health questions about HVHF: • Have all negative health impacts that can be
reasonably anticipated been identified? • Are public engagement and
communication in the decision process adequate? • Is there a commitment to HVHF
process modifications based on experience in and outside NYS? • Will effects of
HVHF be recorded in real time and in ways that are publically accessible? •
Does NYS DoH possess the necessary authority to monitor HVHF? • Are there
qualified individuals and funding for the health accountability and advisory
roles for HVHF? • If NYS makes a decision to proceed with HVHF, will this occur
in a careful phased-‐in rollout with aggressive health oversight? The
following are my observations and recommendations on issues related to health
impacts and risk mitigation of HVHF: Air Contamination:Physical threats
to the environment and human health must be appropriately measured and
communicated. Placement of real time analyzers at drilling sites is an
effective way to monitor airborne threats such as hydrocarbon and greenhouse
gas (GHG) emissions and release of pollutants, carcinogens, and neurotoxins
into the air and water. At a minimum, testing for contamination of air as well
as water must occur with appropriate frequency along with timely and real time
notification of DoH and the public.
Water Contamination: On the issue of potential water
contamination, the DoH’s responsibility for drinking water protection and the
prohibition of certain drilling locations are appropriate. It does appear that
the DoH will be notified of all permits. This information should be made
available in a master information clearinghouse so all impacted parties will be
notified as information is being developed.
Noise Impacts: Noise measurement and abatement are
also necessary. In the SGEIS it appears that intermittent noise exposures are
dismissed because they are transient; yet from a health standpoint noise poses
a significant risk. For example, engine-‐brake noise from large trucks passing
a school or health facility will be intermittent but disruptive and potentially
harmful. It appears there are provisions to mitigate these exposures during the
rollout period, and noise abatement measures must be continued.
Radiation Exposure:On the issue of radiation
exposures, it appears that short term risks above background are not
particularly evident. I cannot speak to long term risks and defer to Health
Physicists. My experience as Director of CDC’s National Center for
Environmental Health and in California as the State Health Officer is that
Health Physicists are in short supply. I suspect that DoH could need additional
health physicist staffing although I defer to DoH on this.
Cumulative Risk:It appears that acute health impacts
of HVHF are well covered in the documents. The questions about chronic disease
threats are more challenging and the answers more incomplete. It seems to me that
appropriate worker and other human health protections are necessary and prudent
given the uncertainty
about long term
effects. The active monitoring of health impacts of HVHF appears to be proposed
in the documents and is essential. There must be an ongoing and transparent
“learn as we go” Health Impact Assessment.
Notification of Risk: The notification process
related to environmental monitoring is important.
While drilling firms and property owners will be notified of
measured levels, some of the documents indicate cases where the DoH and
Emergency Authorities “may” be notified or “should” be notified. From a public
health perspective, DoH notification should not be optional or permissive. DoH
will need to be involved at some point, and the sooner notification occurs the
greater the ability to protect health and mitigate impacts. My experience in other
settings such as refineries is that “real time” notification is essential.
Delays in or failure to notify health authorities and the public should merit
aggressive and increasing penalties.
Worker Safety:Workers are the persons most likely to
be more exposed. If a site operator contracts or sub-‐contracts out work, as
is often the case for some of the most dangerous work, the operator must still
bear the responsibility to protect and train the workers and bear the liability
when there are failures. I understand that enforcement authority in New York
resides in federal programs; nevertheless worker protection is of great urgency.
It is essential that DoH, the National Institute of Occupational Safety and
Health (NIOSH), the Occupational Safety and Health Administration (OSHA), and
other workplace health and safety personnel are able to carry out unannounced
inspections and to issue stop-‐work orders in the presence of imminent hazard.
Examples of imminent hazards include violations of the
silica respiratory standard, standards for other hydrocarbons, and for noise.
Community Health: Health is more than the absence of
disease as DoH staff knows well, and environmental health is more than the
absence of toxic exposures. The walkability of communities is a legitimate health
priority as is the protection of natural, scenic, and other environmental
assets that promote physical activity by community residents. Rates of obesity
and diabetes have lethally doubled in the last generation in the United States
including New York State, and any development that reduces physical activity or
encourages inactivity and unhealthy eating is a health threat. Factors that can
discourage walking and biking and other outdoor activity, such as noise, odors,
and heavy truck traffic that may be present with HVHF, present a real
measurable health threat.
Protection of Sensitive Populations:On the issue of
public protection, the DoH’s HIA now contains more explicit discussion of risks
to sensitive populations, especially children and the elderly.
Tracking documented illness:In cases of human
exposure, there must be prompt and professional medical evaluation and good
recordkeeping of workers and others with documented illness. However,
registries that track general and undocumented environmental exposures in my
own experience are rarely a good investment of limited public health resources.
These efforts quickly become financially and administratively untenable.
Health Communication: In earlier documents, there is
reflected a misunderstanding of “health communication.” A fundamental tenet of
health communication is that it is a two-‐way process involving listening as well
as speaking. Yet in the SGEIS the term communication is misused to mean merely
dispersing public information. This misunderstanding is not present in the DoH
HIA. In addition, more clarification is needed about
how communication
will occur and within what timelines. Notification should not be permissive but
required. This discussion exemplifies the need for a central clearinghouse for
collected data, including planned permits, site locations, drilling dates,
discharges, exceedances, and human exposures or illnesses. The public has a
“right to know” with appropriate confidentiality of personal protected
information.
Health Advisory Committee: The report indicates that
an external Health Advisory Committee is to be considered. I urge this most
strongly. My experience is that elected officials view Advisory Committees with
skepticism, however well-‐balanced committees of knowledgeable and respected
persons of good will and courtesy work well in highly contended situations.
Advisory Committees do require clear mission and task statements, as well as
appropriate staffing and timelines, bylaws, membership rotation, and sunset
dates.
Full Accounting of Impacts:It is important to fully
consider potential impacts to local, county and state levels on both the
positive and negative sides. “Boomtowns” have inherent social and public health
threats, and these negative effects must be mitigated. HVHF needs to create
more health benefits than health negatives. This goes back to my original
observation that all means of energy production (particularly old coal-‐fired
power plants) are associated with negative health impacts. Ongoing data to
better evaluate benefits are needed.
Sufficient Funding:I believe the resource impacts of
HVHF on DoH and local health jurisdictions will be substantial. In similar
situations of great public concern at CDC we were obliged to assign individuals
to regional offices to track concerns. Resources may include health educators,
information managers, toxicologists, chemists competent in biomonitoring,
industrial hygienists, GIS specialists, occupational health experts, syndromic
and sentinel events surveillance, local assignees and clerical staff. My
experience is that elected officials often publically promise funding and
staffing for roles while the actual funding does not occur or is quietly
redirected to other areas.
Phased Rollout with Health Impact Assessment (HIA):The
2011 report on HIA by the National Academy of Sciences Committee that I chaired
took a team of experts 18 months to develop. Our Committee asserted that
traditional Environmental Impact Assessments (EIAs) are often focused on non-‐human
impacts within an engineering and regulatory framework and too often give
little attention to personal or population health.
In general, the Committee found that large scale projects
and programs with a strong likelihood of human health impacts should be subject
to rigorous HIA that is consonant with the National Environmental Policy Act
(NEPA).
HVHF is precisely the kind of activity to which HIA should
be applied. I believe the current DoH HIA (Dec 7, 201.
version) enumerates the issues and concerns well. If the
policy decision in NYS is to proceed with HVHF, the need for an HIA is not
moot, rather what is needed is an aggressive “learn as you go” HIA during a
carefully phased rollout.
In conclusion:With the increasing pressure for HVHF
in NYS, if it is approved, it creates a need to assure long term health
benefits. The history of extraction industries with their boom and bust cycles
can be dealt with wisely if the good of the public overall is the goal and
there is strong regulation. These comments are not an endorsement of HVHF; they
reflect my belief that the NYS DoH Public Health Review that was updated and
sent to me on December 7, 2012, reflects substantial “due diligence.” Thank you
for the chance to review such an important health issue.
Respectfully
submitted, Richard J. Jackson, MD, MPH, FAAP Professor and Chair of
Environmental Health Sciences
8.
Some common themes run through the information obtained from
consultation with other state agencies, outside authorities, and the public
health expert consultants.
Common concerns include air quality impacts, truck traffic
impacts, noise, challenges with wastewater management, social disruption
associated with rapidly-escalating industrialization in communities, and the
cumulative effect of HVHF activities on stress.
The public health expert consultants particularly emphasized
that data gaps exist regarding the degree and extent to which HVHF contributes
indirectly to human health impacts due to stressors including off-site nuisance
odors and visual impacts such as nuisance light pollution (i.e., beyond simply
annoyance). All of these factors can influence stress and quality of life
perceptions that can adversely impact health. Another data gap highlighted by
the expert consultants was the need for evaluation of uncertainties regarding
the potential indirect public health impacts that could be associated with
degradation of surface waters and wetlands through impacts on fish resources
(recreationally and as a source of healthy food), other healthy recreational opportunities
(e.g., swimming, boating) and flood control.
Most of the recently-published HIAs acknowledge that there
are significant gaps in our knowledge of potential public health impacts from
HVHF and of the effectiveness to date of some mitigation measures. Other common
themes include the need for robust and constantly evolving regulatory
framework, for strong enforcement of rules designed to ensure best practices,
and for community involvement.
8.
| Overall Conclusions The DOH Public Health Review
finds that information gaps still exist regarding various aspects of HVHF
activities. Well-designed, prospective, longitudinal studies are lacking that
evaluate the overall effect of HVHF shale-gas development on public health outcomes.
The existing science investigating associations between HVHF activities and observable
adverse health outcomes is very sparse and the studies that have been published
have significant scientific limitations. Nevertheless, studies are suggestive
of potential public health risks related to HVHF activity that warrant further
careful evaluation. Additional population-based research and surveillance, and
more studies involving field investigations in locations with active HVHF
shale-gas development, would be valuable.
Systematic investigations studying the effects of HVHF
activity on groundwater resources, local-community air quality, radon exposure,
noise exposure, wastewater treatment, induced seismicity, traffic, psychosocial
stress, and injuries would help reduce scientific uncertainties. While some of
the on-going or proposed major study initiatives may help close those existing
data gaps, each of these alone would not adequately address the array of
complex concerns. For example: Marcellus Shale Initiative Study.
Geisinger Health System, the lead organization in the
collaborative Marcellus Shale Initiative, cares for many patients in areas
where shale gas is being developed in Pennsylvania. They began pilot studies in
2013 using well and infrastructure data to estimate exposures to all aspects of
Marcellus shale development in Pennsylvania.
According to the a National Institutes of Health abstract,
Geisinger will use these
8.
exposure estimates to evaluate whether asthma control and
pregnancy outcomes are affected by Marcellus shale development by studying
30,000 asthma patients and 22,000 pregnancies in the Geisinger Health System
from 2006-13. Results from this study are not expected to be available for
several years.
University of Colorado at Boulder, Sustainability Research
Network.
A five-year cooperative agreement funded by the National
Science Foundation (NSF) under NSF’s Sustainability Research Network
competition, this program involves a multi-disciplinary team of investigators
and is intended to address: “the conflict between natural gas extraction and
water and air resources protection with the development of a social-ecological
system framework with which to assess the conflict and to identify needs
for scientific information. Scientific investigations will be conducted
to assess and mitigate the problems. Outreach and education efforts will
focus on citizen science, public involvement, and awareness of the
science and policy issues.”3.
Published research has been produced from this program
investigating associations between HVHF activity and birth outcomes and
potential for methane leakage from natural gas infrastructure. The cooperative
agreement extends to 2017.
EPA's Study of Hydraulic Fracturing and Its Potential Impact
on Drinking Water Resources.
Begun in 2011, the purpose of the study is to assess the
potential impacts of hydraulic fracturing on drinking water resources, if any,
and to identify the driving factors that may affect the severity and frequency
of such impacts. The research approach includes:
8.
analyses of existing data, scenario evaluations, laboratory
studies, toxicity studies, and case studies. US EPA released a progress report
on December 21, 2012 and stated that preliminary results of the study are
expected to be released as a draft for public and peer review as soon as the
end of 2014, although the full study is not expected to be completed before
2016.
Pennsylvania Department of Environmental Protection (PA DEP)
Comprehensive Oil and Gas Development Radiation Study.
Started in early 2013, PA DEP is analyzing the radioactivity
levels in produced and flowback waters, wastewater recycling, treatment
sludges, and drill cuttings, as well as issues with transportation, storage,
and disposal of drilling wastes, the levels of radon in natural gas, and
potential exposures to workers and the public. According to a July 2014 update
from the PA DEP, publication of a report could occur as soon as the end of 2014.
University of Pennsylvania Study.
A proposed study of HVHF health impacts was announced
several months ago. The study is led by researchers from the University of
Pennsylvania in collaboration with scientists from Columbia University, Johns
Hopkins University, and the University of North Carolina.
These major study initiatives may eventually reduce
uncertainties regarding health impacts of HVHF and could contribute to a much
more complete knowledge base for managing HVHF risks. However, it will be years
before most of these major initiatives are completed.
8.
HVHF is a complex activity that could affect many
communities. The number of well pads and associated HVHF activities could be
vast and spread out over wide geographic areas where environmental conditions
and populations vary. The dispersed nature of the activity magnifies the
possibility of process and equipment failures, leading to the potential for
cumulative risks for exposures and associated adverse health outcomes.
Additionally, the relationships between HVHF environmental impacts and public
health are complex and not fully understood. Comprehensive, long-term studies, and
in particular longitudinal studies, that could contribute to the understanding
of those relationships are either not yet completed or have yet to be
initiated. In this instance, however, the overall weight of the evidence from
the cumulative body of information contained in this Public Health Review
demonstrates that there are significant uncertainties about the kinds of
adverse health outcomes that may be associated with HVHF, the likelihood of the
occurrence of adverse health outcomes, and the effectiveness of some of the
mitigation measures in reducing or preventing environmental impacts which could
adversely affect public health.
While a guarantee of absolute safety is not possible, an
assessment of the risk to public health must be supported by adequate
scientific information to determine with confidence that the overall risk is
sufficiently low to justify proceeding with HVHF in New York. The current
scientific information is insufficient. Furthermore, it is clear from the existing
literature and experience that HVHF activity has resulted in environmental impacts
that are potentially adverse to public health. Until the science provides
sufficient information to determine the level of risk to public health from
HVHF and whether the risks can be adequately managed, HVHF should not proceed in
New York State.
8.
| Endnotes .
The Generic Environmental Impact Statement (1992 GEIS) on
the Oil, Gas and Solution Mining Regulatory Program is posted on DEC’s website
athttp://www.dec.ny.gov/energy/45912.html.
The 1992 GEIS includes an analysis of impacts from gas drilling and low-volume
hydraulic fracturing. Since 1992 the Department has used the 1992 GEIS as the
basis of its State Environmental Quality Review Act (SEQRA) review for permit
applications for gas drilling in New York State.
.
All internet addresses cited in this report were confirmed
to be active as of November 20, 2014.
.
The revision of the SGEIS reviewed by DOH and the DOH expert
consultants was a newly revised draft-final SGEIS provided by DEC to DOH on
October 22, 2012 that incorporated changes by DEC in response to public
comments received on the 2009 draft SGEIS and the 2011 revised draft SGEIS.
.
For example, the broad public health consensus that a causal
relationship exists between levels of fine particulate matter in outdoor air
and many respiratory and cardiovascular health outcomes, including premature
mortality, is based on weight-of-evidence evaluations of several thousand
studies published over decades. (See U.S. Environmental Protection Agency,
(2009), Integrated Science Assessment for Particulate Matter (Final Report)).
.
As of December, 2014, the slide presentation is no longer
available on the SWPA-EHP web site. This report appears to be similar to, and
possibly a preliminary version of, the subsequent peer-reviewed study by
Rabinowitz et al. (2014) .
The total number of cases categorized by symptom type sums
up to 27, but it is not clear whether some individuals might have been counted
in more than one symptom category.
.
For example, see:http://www.cdc.gov/socialdeterminants/.
.
For a recent example, see:http://headwaterseconomics.org/energy/western-counties-fossil-fuel-
development.
.
Truck traffic also contributes to airborne emissions of
fugitive dust and truck exhaust from the well pad.
See Air Quality Impacts discussion above.
10For example, the Earthworks and Southwest Pennsylvania
Environmental Health Project reports described previously.
12The NPRM is available from the Federal Register in print
(Document number: 2013-20997) or online at https://federalregister.gov/a/2013-20997.
9.
13http://www.atsdr.cdc.gov/HAC/pha/Garfield_County_HC_3-13-08/Garfield_County_HC_3-13-08.pdf.
14The maximum 1-hour toluene concentration at one monitoring location in 2007
was 65.
micrograms/m3vs. a short-term odor comparison value of 640
micrograms/m3.
15Annual average concentrations of 1,2-dibromoethane for
2011 were 0.42 micrograms/m3and 0.3.
micrograms/m3at the Denton Airport South canister and the
Fort Worth Northwest canister, respectively vs. the chronic health-based
comparison value of 0.0167 micrograms/m3.
16http://www.portal.state.pa.us/portal/server.pt/community/oil_and_gas_related_topics/20349/air/986695.
17A hazard quotient is a comparison of an exposure level in
the environment to a risk-based comparison value. A hazard quotient at or below
1.0 generally indicates that exposures are unlikely to have significant health
risk.
18WV’s occupied dwelling structure setback is 625 ft from
the well-pad center.
19US EPA delegated primary SDWA implementation and
enforcement authority (known as primacy) to NYS DOH.
20Six of the twelve chemicals tested in Kassotis et al. are
not listed among the HVHF chemical additives submitted to DEC by drillers and
well service companies as potential additives to be used in New York State.
These include diethanolamine, diethyl glycol methyl ether,
N,N-dimethylformamide, styrene, bisphenol A, and sodium tetraborade (sic)
decahydrate. Sodium tetraborate decahydrate is listed in the draft SGEIS as a
potential HVHF chemical additive in NYS.
21See, for example, U.S. Geological Survey. 2014. Record
Number of Oklahoma Tremors Raises Possibility of Damaging Earthquakes. Updated
USGS-Oklahoma Geological Survey Joint Statement on Oklahoma Earthquakes http://earthquake.usgs.gov/regional/ceus/products/newsrelease_05022014.php.
Also see US EPA’s Underground Injection Control web pages: http://yosemite.epa.gov/r10/water.nsf/476d8e2e8829cf19882565d400706530/51bbc02148429af18825
68730082f6fa!opendocument.
22http://ohiodnr.gov/news/post/ohio-announces-tougher-permit-conditions-for-drilling-activities-near-
faults-and-areas-of-seismic-activity.
9.
25http://www.mde.state.md.us/programs/Land/mining/marcellus/Pages/Health_Study.aspx;
http://www.marcellushealth.org/final-report.html.
29http://www.novascotia.ca/nse/pollutionprevention/consultation.hydraulic.fracturing.asp(Website
includes multiple related publications.) 30Routes to Sustainability for Natural
Gas Development and Water and Air Resources in the Rocky Mountain Region.
National Science Foundation Award Abstract #1240584.
http://www.nsf.gov/news/news_summ.jsp?cntn_id=125599;Shonkoff,
S.B., et al. (2014).
Environmental Public Health Dimensions of shale and Tight
Gas Development.Environmental Health Perspectives,
122(8):787-95.;http://dx.doi.org/10.1289/ehp.1307866.
31For example, a vast literature exists on HVHF engineering, shale-gas geology,
geophysics and petrology that is outside of the scope of the Public Health
Review and outside of DOH expertise.
9.
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10.
| Appendix .
Supplemental Literature Considered for the Public Health
Review The focused literature review presented above presents and analyzes
the peer- reviewed scientific literature judged to be most relevant to
assessing the potential for adverse public health risks from HVHF activities.
The focused literature review was not intended to encompass the entirety of
published literature on HVHF.31However, DOH reviewed a broader range of
peer-reviewed studies in addition to those discussed in the main report that
investigate various aspects of HVHF, but were judged to provide supplemental
background information for the Public Health Review. This supplemental peer-reviewed
literature provided additional support for the main conclusions of the Public
Health Review. An extended bibliographic list of these peer-reviewed studies is
presented below, including the study abstracts from each of the peer-reviewed references.
Allen, D.T., Torres, V.M., Thomas, J., Sullivan, D.W.,
Harrison, M., Hendler, A., Herndon, S.C., Kolb, C.E., Fraser, M.P., Hill, A.D.,
Lamb, B.K., Miskimins, J., Sawyer, R.F., Seinfeld, J.H. Measurements of Methane
Emissions at Natural Gas Production Sites in the United States. Proc Natl Acad
Sci U S A. 2013 Oct 29;110(44):17768-73.
doi: 10.1073/pnas.1304880110. Epub 2013 Sep 16. Erratum in:
Proc Natl Acad Sci U S A. 2013 Oct 29;110(44):18023.
Abstract Engineering estimates of methane emissions from
natural gas production have led to varied projections of national emissions.
This work reports direct measurements
11.
of methane emissions at 190 onshore natural gas sites in the
United States (15.
production sites, 27 well completion flowbacks, 9 well
unloadings, and 4 workovers).
For well completion flowbacks, which clear fractured wells
of liquid to allow gas production, methane emissions ranged from 0.01 Mg to 17
Mg (mean = 1.7 Mg; 95% confidence bounds of 0.67-3.3 Mg), compared with an
average of 81 Mg per event in the 2011 EPA national emission inventory from
April 2013. Emission factors for pneumatic pumps and controllers as well as
equipment leaks were both comparable to and higher than estimates in the
national inventory. Overall, if emission factors from this work for completion
flowbacks, equipment leaks, and pneumatic pumps and controllers are assumed to
be representative of national populations and are used to estimate national
emissions, total annual emissions from these source categories are calculated
to be 957 Gg of methane (with sampling and measurement uncertainties estimated
at ± 200 Gg). The estimate for comparable source categories in the EPA national
inventory is ~1,200 Gg. Additional measurements of unloadings and workovers are
needed to produce national emission estimates for these source categories. The
957 Gg in emissions for completion flowbacks, pneumatics, and equipment leaks,
coupled with EPA national inventory estimates for other categories, leads to an
estimated 2,300 Gg of methane emissions from natural gas production (0.42% of
gross gas production).
Allen, D.T. Atmospheric Emissions and Air Quality Impacts
from Natural Gas Production and Use. Annu Rev Chem Biomol Eng. 2014;5:55-75.
doi: 10.1146/annurev- chembioeng-060713-035938. Epub 2014 Feb 5. Review.
Abstract The US Energy Information Administration projects
that hydraulic fracturing of shale formations will become a dominant source of
domestic natural gas supply over the
11.
next several decades, transforming the energy landscape in
the United States.
However, the environmental impacts associated with fracking
for shale gas have made it controversial. This review examines emissions and
impacts of air pollutants associated with shale gas production and use.
Emissions and impacts of greenhouse gases, photochemically active air
pollutants, and toxic air pollutants are described. In addition to the direct
atmospheric impacts of expanded natural gas production, indirect effects are
also described. Widespread availability of shale gas can drive down natural gas
prices, which, in turn, can impact the use patterns for natural gas. Natural
gas production and use in electricity generation are used as a case study for
examining these indirect consequences of expanded natural gas availability.
Aukema, K.G., Kasinkas, L., Aksan, A., Wackett, L.P. Use of
Silica-Encapsulated Pseudomonas Sp. Strain NCIB 9816-4 in Biodegradation of
Novel Hydrocarbon Ring Structures Found in Hydraulic Fracturing Waters. Appl
Environ Microbiol. 201.
Aug;80(16):4968-76. doi: 10.1128/AEM.01100-14. Epub 2014 Jun
6.
Abstract The most problematic hydrocarbons in hydraulic
fracturing (fracking) wastewaters consist of fused, isolated, bridged, and
spiro ring systems, and ring systems have been poorly studied with respect to
biodegradation, prompting the testing here of six major ring structural subclasses
using a well-characterized bacterium and a silica encapsulation system
previously shown to enhance biodegradation. The direct biological oxygenation
of spiro ring compounds was demonstrated here. These and other hydrocarbon ring
compounds have previously been shown to be present in flow-back waters and
waters produced from hydraulic fracturing operations.
Pseudomonas sp. strain NCIB 9816-4, containing naphthalene
dioxygenase, was
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selected for its broad substrate specificity, and it was
demonstrated here to oxidize fundamental ring structures that are common in
shale-derived waters but not previously investigated with this or related
enzymes. Pseudomonas sp. NCIB 9816-.
was tested here in the presence of a silica encasement, a
protocol that has previously been shown to protect bacteria against the
extremes of salinity present in fracking wastewaters. These studies demonstrate
the degradation of highly hydrophobic compounds by a silica-encapsulated model
bacterium, demonstrate what it may not degrade, and contribute to knowledge of
the full range of hydrocarbon ring compounds that can be oxidized using
Pseudomonas sp. NCIB 9816-4.
Bamberger, M., Oswald, R. The Shale Gas Revolution from the
Viewpoint of a Former Industry Insider. New Solutions 2014 Jul 29:1-16. [Epub
ahead of print].
Abstract This is an interview conducted with an oil and gas
worker who was employed in the industry from 1993 to 2012. He requested that
his name not be used. From 2008 to 2012, he drilled wells for a major operator
in Bradford County, Pennsylvania.
Bradford County is the center of the Marcellus shale gas
boom in Northeastern Pennsylvania. In 2012, he formed a consulting business to
assist clients who need information on the details of gas and oil drilling
operations. In this interview, the worker describes the benefits and
difficulties of the hard work involved in drilling unconventional gas wells in
Pennsylvania. In particular, he outlines the safety procedures that were in
place and how they sometimes failed, leading to workplace injuries. He provides
a compelling view of the trade-offs between the economic opportunities of
working on a rig and the dangers and stresses of working long hours under
hazardous conditions.
11.
Bamberger, M., Oswald, R.E. Unconventional Oil and Gas
Extraction and Animal Health. Environ Sci Process Impacts. 2014
Aug;16(8):1860-5.
Abstract The extraction of hydrocarbons from shale
formations using horizontal drilling with high volume hydraulic fracturing
(unconventional shale gas and tight oil extraction), while derived from methods
that have been used for decades, is a relatively new innovation that was
introduced first in the United States and has more recently spread worldwide.
Although this has led to the availability of new sources of fossil fuels for
domestic consumption and export, important issues have been raised concerning
the safety of the process relative to public health, animal health, and our food
supply. Because of the multiple toxicants used and generated, and because of the
complexity of the drilling, hydraulic fracturing, and completion processes including
associated infrastructure such as pipelines, compressor stations and processing
plants, impacts on the health of humans and animals are difficult to assess
definitively. We discuss here findings concerning the safety of unconventional
oil and gas extraction from the perspectives of public health, veterinary
medicine, and food safety.
11.
Caulton, D.R., Shepson, P.B., Santoro, R.L., Sparks, J.P.,
Howarth, R.W., Ingraffea, A.R., Cambaliza, M.O., Sweeney, C., Karion, A.,
Davis, K.J., Stirm, B.H., Montzka, S.A., Miller, B.R. Toward a Better
Understanding and Quantification of Methane Emissions from Shale Gas
Development. Proc Natl Acad Sci U S A. 2014 Apr 29;111(17):6237-42.
doi: 10.1073/pnas.1316546111. Epub 2014 Apr 14.
Abstract The identification and quantification of methane
emissions from natural gas production has become increasingly important owing
to the increase in the natural gas component of the energy sector. An
instrumented aircraft platform was used to identify large sources of methane
and quantify emission rates in southwestern PA in June 2012. A large regional
flux, 2.0-14 g CH4 s(-1) km(-2), was quantified for a ∼ 2,800-km(2)
area, which did not differ statistically from a bottom-up inventory, 2.3- 4.6 g
CH4 s(-1) km(-2). Large emissions averaging 34 g CH4/s per well were observed
from seven well pads determined to be in the drilling phase, 2 to 3 orders of
magnitude greater than US Environmental Protection Agency estimates for this operational
phase. The emissions from these well pads, representing ∼ 1% of the total
number of wells, account for 4-30% of the observed regional flux. More work is needed
to determine all of the sources of methane emissions from natural gas production,
to ascertain why these emissions occur and to evaluate their climate and atmospheric
chemistry impacts.
11.
Chen, J., Al-Wadei, M.H., Kennedy, R.C., Terry, P.D.
Hydraulic Fracturing: Paving the Way for a Sustainable Future? J Environ Public
Health. 2014;2014:656824. doi: 10.1155/2014/656824. Epub 2014 Mar 25. PubMed
PMID: 24790614; PubMed Central PMCID: PMC3984842.
Abstract With the introduction of hydraulic fracturing
technology, the United States has become the largest natural gas producer in
the world with a substantial portion of the production coming from shale plays.
In this review, we examined current hydraulic fracturing literature including
associated wastewater management on quantity and quality of groundwater. We
conclude that proper documentation/reporting systems for wastewater discharge
and spills need to be enforced at the federal, state, and industrial level.
Furthermore, Underground Injection Control (UIC) requirements under SDWA should
be extended to hydraulic fracturing operations regardless if diesel fuel is
used as a fracturing fluid or not. One of the biggest barriers that hinder the
advancement of our knowledge on the hydraulic fracturing process is the lack of
transparency of chemicals used in the practice. Federal laws mandating
hydraulic companies to disclose fracturing fluid composition and concentration
not only to federal and state regulatory agencies but also to health care
professionals would encourage this practice. The full disclosure of fracturing
chemicals will allow future research to fill knowledge gaps for a better
understanding of the impacts of hydraulic fracturing on human health and the
environment.
11.
Cluff, M.A., Hartsock, A., MacRae, J.D., Carter, K., Mouser,
P.J. Temporal Changes in Microbial Ecology and Geochemistry in Produced Water
from Hydraulically Fractured Marcellus Shale Gas Wells. Environ Sci Technol.
2014 Jun 3;48(11):6508-17. doi: 10.1021/es501173p. Epub 2014 May 20.
Abstract Microorganisms play several important roles in
unconventional gas recovery, from biodegradation of hydrocarbons to souring of
wells and corrosion of equipment.
During and after the hydraulic fracturing process,
microorganisms are subjected to harsh physicochemical conditions within the
kilometer-deep hydrocarbon-bearing shale, including high pressures, elevated
temperatures, exposure to chemical additives and biocides, and brine-level
salinities. A portion of the injected fluid returns to the surface and may be
reused in other fracturing operations, a process that can enrich for certain
taxa. This study tracked microbial community dynamics using pyrotag sequencing
of 16S rRNA genes in water samples from three hydraulically fractured Marcellus
shale wells in Pennsylvania, USA over a 328-day period. There was a reduction
in microbial richness and diversity after fracturing, with the lowest diversity
at 49 days. Thirty-one taxa dominated injected, flowback, and produced water
communities, which took on distinct signatures as injected carbon and electron
acceptors were attenuated within the shale. The majority (>90%) of the
community in flowback and produced fluids was related to halotolerant bacteria
associated with fermentation, hydrocarbon oxidation, and sulfur-cycling metabolisms,
including heterotrophic genera Halolactibacillus, Vibrio, Marinobacter, Halanaerobium,
and Halomonas, and autotrophs belonging to Arcobacter.
Sequences related to halotolerant methanogenic genera
Methanohalophilus and Methanolobus were detected at low abundance (<2 after="" five="" fluids.="" fracturing.="" hydraulic="" in="" indicators="" insight="" into="" later="" months="" o:p="" of="" produced="" provide="" results="" several="" strong="" subsurface="" taxa="" temporal="" the="" these="" trajectory="" waters="" were="">
11.
microbial communities after "fracking" and have
important implications for the enrichment of microbes potentially detrimental
to well infrastructure and natural gas fouling during this process.
Coram, A., Moss, J., Blashki, G. Harms Unknown: Health
Uncertainties Cast Doubt on the Role of Unconventional Gas in Australia's
Energy Future. Med J Aust. 2014 Mar 3;200(4):210-3.
Abstract There is a push to increase production of
unconventional gas in Australia, which would intensify the use of the
controversial technique of hydraulic fracturing. The uncertainties surrounding
the health implications of unconventional gas, when considered together with
doubts surrounding its greenhouse gas profile and cost, weigh heavily against
proceeding with proposed future developments. The health and environmental
impacts of hydraulic fracturing have been the source of widespread public
concern. A review of available literature shows a considerable degree of
uncertainty, but an emerging consensus about the main risks. Gas is often claimed
to be a less climate-damaging alternative to coal; however, this is called into
question by the fugitive emissions produced by unconventional gas extraction
and the consequences of its export. While the health effects associated with
fracturing chemicals have attracted considerable public attention, risks posed
by wastewater, community disruption and the interaction between exposures are
of also of concern.
The health burdens of unconventional gas are likely to fall
disproportionately on rural communities, the young and the elderly. While the
health and environmental risks and benefits must be compared with other energy
choices, coal provides a poor benchmark.
11.
Edwards, P.M., Brown, S.S., Roberts, J.M., Ahmadov, R.,
Banta, R.M., deGouw, J.A., Dubé, W.P., Field, R.A., Flynn, J.H., Gilman, J.B.,
Graus, M., Helmig, D., Koss, A., Langford, A.O., Lefer, B.L., Lerner, B.M., Li,
R., Li, S.M., McKeen, S.A., Murphy, S.M., Parrish, D.D., Senff, C.J., Soltis,
J., Stutz, J., Sweeney, C., Thompson, C.R., Trainer, M.K., Tsai, C., Veres,
P.R., Washenfelder, R.A., Warneke, C., Wild, R.J., Young, C.J., Yuan, B.,
Zamora, R. High Winter Ozone Pollution from Carbonyl Photolysis in an Oil and
Gas Basin. Nature. 2014 Oct 16;514(7522):351-4. doi: 10.1038/nature13767. Epub 2014
Oct 1.
Abstract The United States is now experiencing the most
rapid expansion in oil and gas production in four decades, owing in large part
to implementation of new extraction technologies such as horizontal drilling
combined with hydraulic fracturing. The environmental impacts of this
development, from its effect on water quality to the influence of increased
methane leakage on climate, have been a matter of intense debate. Air quality
impacts are associated with emissions of nitrogen oxides (NOx = NO + NO2) and
volatile organic compounds (VOCs), whose photochemistry leads to production of
ozone, a secondary pollutant with negative health effects. Recent observations
in oil- and gas-producing basins in the western United States have identified
ozone mixing ratios well in excess of present air quality standards, but only during
winter. Understanding winter ozone production in these regions is scientifically
challenging. It occurs during cold periods of snow cover when meteorological
inversions concentrate air pollutants from oil and gas activities, but when
solar irradiance and absolute humidity, which are both required to initiate conventional
photochemistry essential for ozone production, are at a minimum.
Here, using data from a remote location in the oil and gas
basin of northeastern Utah and a box model, we provide a quantitative
assessment of the photochemistry that leads to these extreme winter ozone
pollution events, and identify key factors that
11.
control ozone production in this unique environment. We find
that ozone production occurs at lower NOx and much larger VOC concentrations
than does its summertime urban counterpart, leading to carbonyl (oxygenated
VOCs with a C = O moiety) photolysis as a dominant oxidant source. Extreme VOC
concentrations optimize the ozone production efficiency of NOx. There is
considerable potential for global growth in oil and gas extraction from shale.
This analysis could help inform strategies to monitor and mitigate air quality
impacts and provide broader insight into the response of winter ozone to
primary pollutants.
Ellsworth, W.L. Injection-Induced Earthquakes. Science. 2013
Jul 12;341(6142):1225942. doi: 10.1126/science.1225942.
Abstract Earthquakes in unusual locations have become an
important topic of discussion in both North America and Europe, owing to the
concern that industrial activity could cause damaging earthquakes. It has long
been understood that earthquakes can be induced by impoundment of reservoirs,
surface and underground mining, withdrawal of fluids and gas from the
subsurface, and injection of fluids into underground formations. Injection-induced
earthquakes have, in particular, become a focus of discussion as the
application of hydraulic fracturing to tight shale formations is enabling the
production of oil and gas from previously unproductive formations.
Earthquakes can be induced as part of the process to
stimulate the production from tight shale formations, or by disposal of
wastewater associated with stimulation and production. Here, I review recent
seismic activity that may be associated with industrial activity, with a focus
on the disposal of wastewater by injection in deep wells; assess the scientific
understanding of induced earthquakes; and discuss the key scientific challenges
to be met for assessing this hazard.
12.
Field, R.A., Soltis, J., Murphy, S. Air Quality Concerns of
Unconventional Oil and Natural Gas Production. Environ Sci Process Impacts.
2014 May;16(5):954-69. doi: 10.1039/c4em00081a.
Abstract Increased use of hydraulic fracturing
("fracking") in unconventional oil and natural gas (O & NG)
development from coal, sandstone, and shale deposits in the United States (US)
has created environmental concerns over water and air quality impacts.
In this perspective we focus on how the production of
unconventional O & NG affects air quality. We pay particular attention to
shale gas as this type of development has transformed natural gas production in
the US and is set to become important in the rest of the world. A variety of
potential emission sources can be spread over tens of thousands of acres of a
production area and this complicates assessment of local and regional air
quality impacts. We outline upstream activities including drilling, completion
and production. After contrasting the context for development activities in the
US and Europe we explore the use of inventories for determining air emissions.
Location and scale of analysis is important, as O & NG production emissions
in some US basins account for nearly 100% of the pollution burden, whereas in
other basins these activities make up less than 10% of total air emissions.
While emission inventories are beneficial to quantifying air emissions from a
particular source category, they do have limitations when determining air quality
impacts from a large area. Air monitoring is essential, not only to validate inventories,
but also to measure impacts. We describe the use of measurements, including
ground-based mobile monitoring, network stations, airborne, and satellite platforms
for measuring air quality impacts. We identify nitrogen oxides, volatile organic
compounds (VOC), ozone, hazardous air pollutants (HAP), and methane as pollutants
of concern related to O & NG activities. These pollutants can contribute to
air quality concerns and they may be regulated in ambient air, due to human
health
12.
or climate forcing concerns. Close to well pads, emissions
are concentrated and exposure to a wide range of pollutants is possible. Public
health protection is improved when emissions are controlled and facilities are
located away from where people live. Based on lessons learned in the US we
outline an approach for future unconventional O & NG development that
includes regulation, assessment and monitoring.
Finkel, M.L., Hays, J. The Implications of Unconventional
Drilling for Natural Gas: A Global Public Health Concern. Public Health. 2013
Oct;127(10):889-93. doi: 10.1016/j.puhe.2013.07.005. Epub 2013 Oct 9. Review.
Abstract Unconventional drilling for natural gas by means of
high volume horizontal hydraulic fracturing (fracking) is an important global
public health issue. Given that no sound epidemiologic study has been done to
assess the extent of exposure-related adverse health effects among populations
living in areas where natural gas extraction is going on, it is imperative that
research be conducted to quantify the potential risks to the environment and to
human health not just in the short-term, but over a longer time period since
many diseases (i.e., cancers) appear years after exposure. It should not be
concluded that an absence of data implies that no harm is being done.
12.
Flewelling, S.A., Sharma, M. Constraints on Upward Migration
of Hydraulic Fracturing Fluid and Brine. Groundwater. 2014 Jan-Feb;52(1):9-19.
doi: 10.1111/gwat.12095.
Epub 2013 Jul 29.
Abstract Recent increases in the use of hydraulic fracturing
(HF) to aid extraction of oil and gas from black shales have raised concerns
regarding potential environmental effects associated with predictions of upward
migration of HF fluid and brine. Some recent studies have suggested that such
upward migration can be large and that timescales for migration can be as short
as a few years. In this article, we discuss the physical constraints on upward
fluid migration from black shales (e.g., the Marcellus, Bakken, and Eagle Ford)
to shallow aquifers, taking into account the potential changes to the
subsurface brought about by HF. Our review of the literature indicates that HF
affects a very limited portion of the entire thickness of the overlying bedrock
and therefore, is unable to create direct hydraulic communication between black
shales and shallow aquifers via induced fractures. As a result, upward
migration of HF fluid and brine is controlled by preexisting hydraulic gradients
and bedrock permeability. We show that in cases where there is an upward
gradient, permeability is low, upward flow rates are low, and mean travel times
are long (often >10⁶ years). Consequently, the recently proposed rapid upward
migration of brine and HF fluid, predicted to occur as a result of increased HF
activity, does not appear to be physically plausible. Unrealistically high
estimates of upward flow are the result of invalid assumptions about HF and the
hydrogeology of sedimentary basins.
12.
Goldstein, B.D., Malone, S. Obfuscation does not Provide
Comfort: Response to the Article by Fryzek et al on Hydraulic Fracturing and
Childhood Cancer. J Occup Environ Med. 2013 Nov;55(11):1376-8.
No summary is available.
Goldstein, B.D., Brooks, B.W., Cohen, S.D., Gates, A.E.,
Honeycutt, M.E., Morris, J.B., Orme-Zavaleta, J., Penning, T.M., Snawder, J.
The Role of Toxicological Science in Meeting the Challenges and Opportunities
of Hydraulic Fracturing. Toxicol Sci. 201.
Jun;139(2):271-83. doi: 10.1093/toxsci/kfu061. Epub 2014 Apr
4.
Abstract We briefly describe how toxicology can inform the
discussion and debate of the merits of hydraulic fracturing by providing
information on the potential toxicity of the chemical and physical agents
associated with this process, individually and in combination. We consider
upstream activities related to bringing chemical and physical agents to the
site, on-site activities including drilling of wells and containment of agents
injected into or produced from the well, and downstream activities including
the flow/removal of hydrocarbon products and of produced water from the site. A
broad variety of chemical and physical agents are involved. As the industry
expands this has raised concern about the potential for toxicological effects on
ecosystems, workers, and the general public. Response to these concerns requires
a concerted and collaborative toxicological assessment. This assessment should
take into account the different geology in areas newly subjected to hydraulic fracturing
as well as evolving industrial practices that can alter the chemical and physical
agents of toxicological interest. The potential for ecosystem or human exposure
to mixtures of these agents presents a particular toxicological and public
12.
health challenge. These data are essential for developing a
reliable assessment of the potential risks to the environment and to human
health of the rapidly increasing use of hydraulic fracturing and deep
underground horizontal drilling techniques for tightly bound shale gas and
other fossil fuels. Input from toxicologists will be most effective when
employed early in the process, before there are unwanted consequences to the
environment and human health, or economic losses due to the need to abandon or
rework costly initiatives.
Holland, A.A. Imaging Time Dependent Crustal Deformation
Using GPS Geodesy and Induced Seismicity, Stress and Optimal Fault Orientations
in the North American Mid- Continent. Graduate Thesis. The University of
Arizona. 2014.
http://arizona.openrepository.com/arizona/handle/10150/332903.
Abstract Transient deformation has been observed in a number
of different types of tectonic environments. These transient deformation
signals are often observed using continuous GPS (CGPS) position time-series
observations. Examining transient deformation using CGPS time-series is
problematic due to the, often, low signal-to- noise ratios and variability in
duration of transient motions observed. A technique to estimate a continuous
velocity function from noisy CGPS coordinate time-series of is examined. The
resolution of this technique is dependent on the signal-to-noise ratio and the
duration or frequency content of the transient signal being modeled. Short period
signals require greater signal-to-noise ratios for effective resolution of the actual
transient signal. The technique presented here is similar to a low-pass filter but
with a number of advantages when working with CGPS data. Data gaps do not adversely
impact the technique but limit resolution near the gap epochs, if there is some
a priori knowledge of the noise contained within the time-series this
12.
information can be included in the model, and model
parameter uncertainties provide information on the uncertainty of instantaneous
velocity through time.
A large transient has been observed in the North-American
stable continental interior as a significant increase in the number and moment
release of earthquakes through time. This increase in the number of earthquakes
has been suggested to be largely related changes in oil and gas production
activities within the region as triggered or induced seismicity, primarily from
fluid injection. One of the first observed cases of triggered earthquakes from
hydraulic fracturing where the earthquakes were large enough to be felt by
local residents is documented. The multiple strong temporal and spatial
correlations between these earthquakes indicate that hydraulic fracturing in a nearby
well likely triggered the earthquake sequence. The largest magnitude earthquake
in this sequence was a magnitude 2.9 with 16 earthquakes greater than magnitude
2. The earthquakes in this sequence occurred within 2.5 km of the hydraulic
fracturing operation and focal depths are similar to the depths of hydraulic fracturing
treatment depths. In addition to the documentation of a transient earthquake
signal associated with hydraulic fracturing, the observed focal mechanisms
throughout Oklahoma are documented. These focal mechanisms were used to examine
the maximum horizontal stress orientations and active fault orientations
associated with the increased rates of seismicity observed in the region.
Generally, active-fault orientations and the stresses are
consistent through broad portions of Oklahoma with one exception, the onging
Jones earthquake sequence in central Oklahoma that started in 2009. In the
Jones earthquake sequence a bi- modal distribution of focal mechanisms are
observed. One orientation of active faults observed in the Jones earthquake
sequence would not be expected to be active in the observed regional stress
field. This unfavorably oriented set of faults appear to be pre-existing
structures and activity on these structures may suggest that pore- pressure
increases in the sub-surface due to fluid injection in the area make it
12.
possible for faults that are not optimally oriented within
the regional stress-field to reactivate.
Jackson, R.E., Gorody, A.W., Mayer, B., Roy, J.W., Ryan,
M.C., Van Stempvoort, D.R.
Groundwater Protection and Unconventional Gas Extraction:
The Critical Need for Field-Based Hydrogeological Research. Groundwater. 2013
Jul-Aug;51(4):488-510. doi: 10.1111/gwat.12074. Epub 2013 Jun 7.
Abstract Unconventional natural gas extraction from tight
sandstones, shales, and some coal- beds is typically accomplished by horizontal
drilling and hydraulic fracturing that is necessary for economic development of
these new hydrocarbon resources.
Concerns have been raised regarding the potential for
contamination of shallow groundwater by stray gases, formation waters, and
fracturing chemicals associated with unconventional gas exploration. A lack of
sound scientific hydrogeological field observations and a scarcity of published
peer-reviewed articles on the effects of both conventional and unconventional
oil and gas activities on shallow groundwater make it difficult to address
these issues. Here, we discuss several case studies related to both
conventional and unconventional oil and gas activities illustrating how under some
circumstances stray or fugitive gas from deep gas-rich formations has migrated
from the subsurface into shallow aquifers and how it has affected groundwater
quality. Examples include impacts of uncemented well annuli in areas of
historic drilling operations, effects related to poor cement bonding in both
new and old hydrocarbon wells, and ineffective cementing practices. We also
summarize studies describing how structural features influence the role of
natural and induced fractures as contaminant fluid migration pathways. On the
basis of these studies, we identify two areas where field-focused research is
urgently needed to fill current
12.
science gaps related to unconventional gas extraction: (1)
baseline geochemical mapping (with time series sampling from a sufficient
network of groundwater monitoring wells) and (2) field testing of potential
mechanisms and pathways by which hydrocarbon gases, reservoir fluids, and
fracturing chemicals might potentially invade and contaminate useable
groundwater.
Jackson, R.B., Vengosh, A., Darrah, T.H., Warner, N.R.,
Down, A., Poreda, R.J., Osborn, S.G., Zhao, K., Karr, J.D. Increased Stray Gas
Abundance in a Subset of Drinking Water Wells Near Marcellus Shale Gas
Extraction. Proc Natl Acad Sci U S A.
2013 Jul 9;110(28):11250-5. doi: 0.1073/pnas.1221635110.
Epub 2013 Jun 24.
Abstract Horizontal drilling and hydraulic fracturing are
transforming energy production, but their potential environmental effects
remain controversial. We analyzed 141 drinking water wells across the
Appalachian Plateaus physiographic province of northeastern Pennsylvania,
examining natural gas concentrations and isotopic signatures with proximity to
shale gas wells. Methane was detected in 82% of drinking water samples, with
average concentrations six times higher for homes <1 0.0006="" 0.0013="" 0.007="" 0.01="" 0.27="" 10="" 1="" 23="" a="" all="" also="" and="" appalachian="" approximately="" bottoms="" concentrations="" correlation="" deformation="" detected="" distance="" distances="" ethane="" factor="" factors="" for="" from="" front="" gas="" groundwater="" higher="" highly="" homes="" in="" influence="" km="" methane="" most="" multiple="" natural="" not="" o:p="" of="" p="0.11," pearson="" previously="" propane="" proposed="" proxy="" regression="" respectively="" shallow="" significant="" spearman="" structural="" tectonic="" the="" three="" times="" to="" valley="" was="" water="" wells="" were="" whereas="" within="">
12.
analyses (P < 0.01). For ethane concentrations, distance
to gas wells was the only statistically significant factor (P < 0.005).
Isotopic signatures (δ(13)C-CH4, δ(13)C- C2H6, and δ(2)H-CH4), hydrocarbon
ratios (methane to ethane and propane), and the ratio of the noble gas (4)He to
CH4 in groundwater were characteristic of a thermally postmature Marcellus-like
source in some cases. Overall, our data suggest that some homeowners living
<1 contaminated="" drinking="" from="" gas="" gases.="" have="" km="" o:p="" stray="" water="" wells="" with="">
Jiang, M., Hendrickson, C.T., VanBriesen, J.M. Life Cycle
Water Consumption and Wastewater Generation Impacts of a Marcellus Shale Gas
Well. Environ Sci Technol.
2014 Feb 4;48(3):1911-20. doi: 10.1021/es4047654. Epub 2014
Jan 10.
Abstract This study estimates the life cycle water
consumption and wastewater generation impacts of a Marcellus shale gas well
from its construction to end of life. Direct water consumption at the well site
was assessed by analysis of data from approximately 500 individual well
completion reports collected in 2010 by the Pennsylvania Department of
Conservation and Natural Resources. Indirect water consumption for supply chain
production at each life cycle stage of the well was estimated using the economic
input-output life cycle assessment (EIO-LCA) method. Life cycle direct and
indirect water quality pollution impacts were assessed and compared using the tool
for the reduction and assessment of chemical and other environmental impacts (TRACI).
Wastewater treatment cost was proposed as an additional indicator for water
quality pollution impacts from shale gas well wastewater. Four water management
scenarios for Marcellus shale well wastewater were assessed: current conditions
in Pennsylvania; complete discharge; direct reuse and desalination; and complete
desalination. The results show that under the current conditions, an
12.
average Marcellus shale gas well consumes 20,000 m(3) (with
a range from 6700 to 33,000 m(3)) of freshwater per well over its life cycle
excluding final gas utilization, with 65% direct water consumption at the well
site and 35% indirect water consumption across the supply chain production. If
all flowback and produced water is released into the environment without
treatment, direct wastewater from a Marcellus shale gas well is estimated to
have 300-3000 kg N-eq eutrophication potential, 900-23,000 kg 2,4D-eq
freshwater ecotoxicity potential, 0-370 kg benzene- eq carcinogenic potential,
and 2800-71,000 MT toluene-eq noncarcinogenic potential. The potential toxicity
of the chemicals in the wastewater from the well site exceeds those associated
with supply chain production, except for carcinogenic effects. If all the
Marcellus shale well wastewater is treated to surface discharge standards by
desalination, $59,000-270,000 per well would be required. The life cycle study
results indicate that when gas end use is not considered hydraulic fracturing
is the largest contributor to the life cycle water impacts of a Marcellus shale
gas well.
Kohl, C.A., Capo, R.C., Stewart, B.W., Wall, A.J.,
Schroeder, K.T., Hammack, R.W., Guthrie, G.D. Strontium Isotopes Test Long-Term
Zonal Isolation of Injected and Marcellus Formation Water After Hydraulic
Fracturing. Environ Sci Technol. 2014 Aug 19;48(16):9867-73. doi:
10.1021/es501099k. Epub 2014 Jul 28.
Abstract One concern regarding unconventional hydrocarbon
production from organic-rich shale is that hydraulic fracture stimulation could
create pathways that allow injected fluids and deep brines from the target
formation or adjacent units to migrate upward into shallow drinking water
aquifers. This study presents Sr isotope and geochemical data from a
well-constrained site in Greene County, Pennsylvania, in which samples were
collected before and after hydraulic fracturing of the Middle Devonian
13.
Marcellus Shale. Results spanning a 15-month period indicated
no significant migration of Marcellus-derived fluids into Upper Devonian/Lower
Mississippian units located 900-1200 m above the lateral Marcellus boreholes or
into groundwater sampled at a spring near the site. Monitoring the Sr isotope
ratio of water from legacy oil and gas wells or drinking water wells can
provide a sensitive early warning of upward brine migration for many years
after well stimulation.
Kondash, A.J., Warner, N.R., Lahav, O., Vengosh, A. Radium
and Barium Removal through Blending Hydraulic Fracturing Fluids with Acid Mine
Drainage. Environ Sci Technol. 2014 Jan 21;48(2):1334-42. doi:
10.1021/es403852h. Epub 2013 Dec 24.
Abstract Wastewaters generated during hydraulic fracturing
of the Marcellus Shale typically contain high concentrations of salts,
naturally occurring radioactive material (NORM), and metals, such as barium,
that pose environmental and public health risks upon inadequate treatment and
disposal. In addition, fresh water scarcity in dry regions or during periods of
drought could limit shale gas development. This paper explores the possibility
of using alternative water sources and their impact on NORM levels through
blending acid mine drainage (AMD) effluent with recycled hydraulic fracturing
flowback fluids (HFFFs). We conducted a series of laboratory experiments in
which the chemistry and NORM of different mix proportions of AMD and HFFF were
examined after reacting for 48 h. The experimental data combined with geochemical
modeling and X-ray diffraction analysis suggest that several ions, including
sulfate, iron, barium, strontium, and a large portion of radium (60-100%), precipitated
into newly formed solids composed mainly of Sr barite within the first ∼
10 h of mixing. The results imply that blending AMD and HFFF could be an
effective management practice for both remediation of the high NORM in the
Marcellus HFFF
13.
wastewater and beneficial utilization of AMD that is
currently contaminating waterways in northeastern U.S.A.
Lautz, L.K., Hoke, G.D., Lu, Z., Siegel, D.I., Christian,
K., Kessler, J.D., Teale, N.G.
Using Discriminant Analysis to Determine Sources of Salinity
in Shallow Groundwater Prior to Hydraulic Fracturing. Environ Sci Technol. 2014
Aug 19;48(16):9061-9. doi: 10.1021/es502244v. Epub 2014 Aug 1.
Abstract High-volume hydraulic fracturing (HVHF)
gas-drilling operations in the Marcellus Play have raised environmental
concerns, including the risk of groundwater contamination. Fingerprinting water
impacted by gas-drilling operations is not trivial given other potential
sources of contamination. We present a multivariate statistical modeling
framework for developing a quantitative, geochemical fingerprinting tool to distinguish
sources of high salinity in shallow groundwater. The model was developed using
new geochemical data for 204 wells in New York State (NYS), which has a HVHF
moratorium and published data for additional wells in NYS and several salinity
sources (Appalachian Basin brines, road salt, septic effluent, and animal
waste). The model incorporates a stochastic simulation to predict the geochemistry
of high salinity (>20 mg/L Cl) groundwater impacted by different salinity
sources and then employs linear discriminant analysis to classify samples from
different populations. Model results indicate Appalachian Basin brines are the primary
source of salinity in 35% of sampled NYS groundwater wells with >20 mg/L Cl.
The model provides an effective means for differentiating groundwater impacted by
basin brines versus other contaminants. Using this framework, similar discriminatory
tools can be derived for other regions from background water quality data.
13.
Mackie, P., Johnman, C., Sim, F. Hydraulic Fracturing: A New
Public Health Problem 138 Years in the Making? Public Health. 2013
Oct;127(10):887-8.
doi:10.1016/j.puhe.2013.09.009. Epub 2013 Oct 19. PubMed
PMID: 24148802.
Summary It is clear that hydraulic fracturing IS a public
health issue, just as fuel poverty and carbon reduction are public health
issues. It is also clear that it is a complex issue: there will never be all
the necessary information to make risk free choices, so governments will, as
usual, have to seek to balance the known – and suspected – risks to health on the
basis of what evidence there is, until such time as the evidence is stronger.
To do that, it is imperative to ensure a public health approach is included
when planning and decision making on this issue takes place: that cannot be too
soon.
Maguire-Boyle, S.J., Garner, D.J., Heimann, J.E., Gao, L., Orbaek,
A.W., Barron, A.R.
Automated Method for Determining the Flow of Surface
Functionalized Nanoparticles through a Hydraulically Fractured Mineral
Formation Using Plasmonic Silver Nanoparticles. Environ Sci Process Impacts.
2014 Feb;16(2):220-31. doi: 10.1039/c3em00718a.
Abstract Quantifying nanoparticle (NP) transport within
porous geological media is imperative in the design of tracers and sensors to
monitor the environmental impact of hydraulic fracturing that has seen
increasing concern over recent years, in particular the potential pollution and
contamination of aquifers. The surface chemistry of a NP defining many of its
solubility and transport properties means that there is a wide range of
functionality that it is desirable to screen for optimum transport. Most prior transport
methods are limited in determining if significant adsorption occurs of a NP over
a limited column distance, however, translating this to effects over large
13.
distances is difficult. Herein we report an automated method
that allows for the simulation of adsorption effects of a dilute nanoparticle
solution over large distances under a range of solution parameters. Using
plasmonic silver NPs and UV-visible spectroscopic detection allows for low
concentrations to be used while offering greater consistency in peak absorbance
leading to a higher degree of data reliability and statistics. As an example,
breakthrough curves were determined for mercaptosuccinic acid (MSA) and
cysteamine (CYS) functionalized Ag NPs passing through Ottawa sand (typical
proppant material) immobile phase (C) or bypassing the immobile phase (C0).
Automation allows for multiple sequences such that the absorption plateau after
each breakthrough and the rate of breakthrough can be compared for multiple
runs to provide statistical analysis. The mobility of the NPs as a function of
pH is readily determined. The stickiness (α) of the NP to the immobile phase
calculated from the C/C0 ratio shows that MSA-Ag NPs show good mobility, with a
slight decrease around neutral pH, while CYS-Ag NPs shows an almost sinusoidal
variation. The automated process described herein allows for rapid screening of
NP functionality, as a function of immobile phase (proppant versus reservoir
material), hydraulic fracturing fluid additives (guar, surfactant) and conditions
(pH, temperature).
Maguire-Boyle, S.J., Barron, A.R. Organic Compounds in
Produced Waters from Shale Gas Wells. Environ Sci Process Impacts. 2014 Sep
24;16(10):2237-48. doi: 10.1039/c4em00376d.
Abstract A detailed analysis is reported of the organic
composition of produced water samples from typical shale gas wells in the
Marcellus (PA), Eagle Ford (TX), and Barnett (NM) formations. The quality of
shale gas produced (and frac flowback)
13.
waters is a current environmental concern and disposal
problem for producers. Re- use of produced water for hydraulic fracturing is
being encouraged; however, knowledge of the organic impurities is important in
determining the method of treatment. The metal content was determined by
inductively coupled plasma optical emission spectrometry (ICP-OES). Mineral
elements are expected depending on the reservoir geology and salts used in
hydraulic fracturing; however, significant levels of other transition metals
and heavier main group elements are observed. The presence of scaling elements
(Ca and Ba) is related to the pH of the water rather than total dissolved
solids (TDS). Using gas chromatography mass spectrometry (GC/MS) analysis of
the chloroform extracts of the produced water samples, a plethora of organic
compounds were identified. In each water sample, the majority of organics are
saturated (aliphatic), and only a small fraction comes under aromatic, resin,
and asphaltene categories. Unlike coalbed methane produced water it appears
that shale oil/gas produced water does not contain significant quantities of polyaromatic
hydrocarbons reducing the potential health hazard. Marcellus and Barnett
produced waters contain predominantly C6-C16 hydrocarbons, while the Eagle Ford
produced water shows the highest concentration in the C17-C30 range.
The structures of the saturated hydrocarbons identified
generally follows the trend of linear > branched > cyclic. Heterocyclic
compounds are identified with the largest fraction being fatty alcohols,
esters, and ethers. However, the presence of various fatty acid phthalate
esters in the Barnett and Marcellus produced waters can be related to their use
in drilling fluids and breaker additives rather than their presence in connate
fluids. Halogen containing compounds are found in each of the water samples,
and although the fluorocarbon compounds identified are used as tracers, the
presence of chlorocarbons and organobromides formed as a consequence of using
chlorine containing oxidants (to remove bacteria from source water), suggests
13.
that industry should concentrate on non-chemical treatments
of frac and produced waters.
Manda, A.K., Heath, J.L., Klein, W.A., Griffin, M.T., Montz,
B.E. Evolution of Multi-Well Pad Development and Influence of Well Pads on
Environmental Violations and Wastewater Volumes in the Marcellus Shale (USA). J
Environ Manage. 2014 Sep 1;142:36-45. doi: 0.1016/j.jenvman.2014.04.011. Epub
2014 May 8.
Abstract A majority of well pads for unconventional gas
wells that are drilled into the Marcellus shale (northeastern USA) consist of
multiple wells (in some cases as many as 12 wells per pad), yet the influence
of the evolution of well pad development on the extent of environmental
violations and wastewater production is unknown. Although the development of
multi-well pads (MWP) at the expense of single well pads (SWP) has been mostly
driven by economic factors, the concentrated nature of drilling activities from
hydraulic fracturing and horizontal drilling operations on MWP suggests that
MWP may create less surface disturbance, produce more volumes of wastewater,
and generate more environmental violations than SWP. To explore these
hypotheses, we use geospatial techniques and statistical analyses (i.e.,
regression and Mann-Whitney tests) to assess development of unconventional
shale gas wells, and quantify environmental violations and wastewater volumes
on SWP and MWP in Pennsylvania. The analyses include assessments of the
influence of different types of well pads on potential, minor and major
environmental events. Results reveal that (a) in recent years, a majority of pads
on which new wells for unconventional gas were drilled are MWP, (b) on average,
MWP have about five wells located on each pad and thus, had the transition to
MWP not occurred, between two and four times as much land surface
13.
disturbance would have occurred per year if drilling was
relegated to SWP, (c) there were more environmental violations on MWP than SWP,
but when the number of wells were taken into account, fewer environmental
violations per well were observed on MWP than on SWP, (d) there were more
wastewater and recycled wastewater volumes per pad and per well produced on MWP
than on SWP, and (e) the proportion of wastewater that was recycled was higher
on MWP than SWP. This study sheds light on how the evolution from SWP to MWP
has influenced environmental violations and wastewater production in a field
that has undergone rapid development in recent years.
Mash, R., Minnaar, J., Mash, B. Health and Fracking: Should
the Medical Profession be Concerned? S Afr Med J. 2014 Feb 26;104(5):332-5.
doi: 10.7196/samj.7860.
Abstract The use of natural gas that is obtained from
high-volume hydraulic fracturing (fracking) may reduce carbon emissions
relative to the use of coal and have substantial economic benefits for South
Africa. However, concerns have been raised regarding the health and
environmental impacts. The drilling and fracking processes use hundreds of
chemicals as well as silica sand. Additional elements are either released from
or formed in the shale during drilling. These substances can enter the environment
in various ways: through failures in the well casing; via alternative underground
pathways; as wastewater, spills and leaks on the wellpad; through transportation
accidents; and as air pollution. Although many of these chemicals and elements
have known adverse health effects, there is little evidence available on the health
impacts of fracking. These health concerns have not yet been fully addressed in
policy making, and the authors recommend that the voice of health professionals
13.
should be part of the public debate on fracking and that a
full health impact assessment be required before companies are given the
go-ahead to drill.
Mazur, A. How did the Fracking Controversy Emerge in the
Period 2010-2012? Public Underst Sci. 2014 Aug 8. pii: 0963662514545311. [Epub
ahead of print] Abstract In 2010-2012, the controversy over fracking grew rapidly,
first in the United States, and then internationally. An important step was the
anti-fracking documentary film Gasland. With help from celebrity sources, the
film was produced and won a prize at the Sundance Film Festival by early 2010
and had an Oscar nomination by early 2011, in the meantime popularizing potent
images of hazard including tainted aquifers and ignitable water running from
kitchen faucets. During this period, major US news organizations paid little
attention to the issue. The offshore Deepwater Horizon disaster of April 2010
spurred The New York Times to prolific reporting on potential risks of the new
onshore technique for extracting shale gas. With flagship news coverage, the
controversy had by 2012 gained wide media attention that evoked public concern
and opposition, spreading from the United States to other nations.
13.
McJeon, H., Edmonds, J., Bauer, N., Clarke, L., Fisher, B.,
Flannery, B.P., Hilaire, J., Krey, V., Marangoni, G., Mi, R., Riahi, K.,
Rogner, H., Tavoni, M. Limited Impact on Decadal-Scale Climate Change from
Increased Use of Natural Gas. Nature. 2014 Oct 23;514(7523):482-5. doi:
10.1038/nature13837. Epub 2014 Oct 15.
Abstract The most important energy development of the past
decade has been the wide deployment of hydraulic fracturing technologies that
enable the production of previously uneconomic shale gas resources in North
America. If these advanced gas production technologies were to be deployed
globally, the energy market could see a large influx of economically
competitive unconventional gas resources. The climate implications of such
abundant natural gas have been hotly debated. Some researchers have observed
that abundant natural gas substituting for coal could reduce carbon dioxide
(CO2) emissions. Others have reported that the non-CO.
greenhouse gas emissions associated with shale gas
production make its lifecycle emissions higher than those of coal. Assessment
of the full impact of abundant gas on climate change requires an integrated
approach to the global energy-economy- climate systems, but the literature has
been limited in either its geographic scope or its coverage of greenhouse
gases. Here we show that market-driven increases in global supplies of
unconventional natural gas do not discernibly reduce the trajectory of
greenhouse gas emissions or climate forcing. Our results, based on simulations from
five state-of-the-art integrated assessment models of energy-economy-climate systems
independently forced by an abundant gas scenario, project large additional natural
gas consumption of up to +170 per cent by 2050. The impact on CO.
emissions, however, is found to be much smaller (from -2 per
cent to +11 per cent), and a majority of the models reported a small increase
in climate forcing (from -0..
per cent to +7 per cent) associated with the increased use
of abundant gas. Our results show that although market penetration of globally
abundant gas may
13.
substantially change the future energy system, it is not
necessarily an effective substitute for climate change mitigation policy.
Mohan, A.M., Bibby, K.J., Lipus, D., Hammack, R.W., Gregory,
K.B. The Functional Potential of Microbial Communities in Hydraulic Fracturing
Source Water and Produced Water from Natural Gas Extraction Characterized By
Metagenomic Sequencing. PLoS One. 2014 Oct 22;9(10):e107682. doi:
10.1371/journal.pone.0107682. eCollection 2014.
Abstract Microbial activity in produced water from hydraulic
fracturing operations can lead to undesired environmental impacts and increase
gas production costs. However, the metabolic profile of these microbial
communities is not well understood. Here, for the first time, we present
results from a shotgun metagenome of microbial communities in both hydraulic
fracturing source water and wastewater produced by hydraulic fracturing.
Taxonomic analyses showed an increase in anaerobic/facultative anaerobic
classes related to Clostridia, Gammaproteobacteria, Bacteroidia and Epsilonproteobacteria
in produced water as compared to predominantly aerobic Alphaproteobacteria in
the fracturing source water. The metabolic profile revealed a relative increase
in genes responsible for carbohydrate metabolism, respiration, sporulation and
dormancy, iron acquisition and metabolism, stress response and sulfur
metabolism in the produced water samples. These results suggest that microbial
communities in produced water have an increased genetic ability to handle stress,
which has significant implications for produced water management, such as disinfection.
14.
Murali Mohan, A., Hartsock, A., Hammack, R.W., Vidic, R.D.,
Gregory, K.B. Microbial Communities In Flowback Water Impoundments from
Hydraulic Fracturing for Recovery of Shale Gas. FEMS Microbiol Ecol. 2013
Dec;86(3):567-80. doi: 10.1111/1574- 6941.12183. Epub 2013 Aug 13.
Abstract Hydraulic fracturing for natural gas extraction
from shale produces waste brine known as flowback that is impounded at the
surface prior to reuse and/or disposal.
During impoundment, microbial activity can alter the fate of
metals including radionuclides, give rise to odorous compounds, and result in
biocorrosion that complicates water and waste management and increases
production costs. Here, we describe the microbial ecology at multiple depths of
three flowback impoundments from the Marcellus shale that were managed
differently. 16S rRNA gene clone libraries revealed that bacterial communities
in the untreated and biocide-amended impoundments were depth dependent,
diverse, and most similar to species within the taxa γ-proteobacteria,
α-proteobacteria, δ-proteobacteria, Clostridia, Synergistetes, Thermotogae,
Spirochetes, and Bacteroidetes. The bacterial community in the pretreated and
aerated impoundment was uniform with depth, less diverse, and most similar to
known iodide-oxidizing bacteria in the α- proteobacteria. Archaea were
identified only in the untreated and biocide-amended impoundments and were
affiliated to the Methanomicrobia class. This is the first study of microbial
communities in flowback water impoundments from hydraulic fracturing. The
findings expand our knowledge of microbial diversity of an emergent and
unexplored environment and may guide the management of flowback impoundments.
14.
Murali Mohan, A., Hartsock, A., Bibby, K.J., Hammack, R.W.,
Vidic, R.D., Gregory, K.B.
Microbial Community Changes in Hydraulic Fracturing Fluids
and Produced Water from Shale Gas Extraction. Environ Sci Technol. 2013 Nov
19;47(22):13141-50. doi: 10.1021/es402928b. Epub 2013 Oct 31.
Abstract Microbial communities associated with produced
water from hydraulic fracturing are not well understood, and their deleterious
activity can lead to significant increases in production costs and adverse
environmental impacts. In this study, we compared the microbial ecology in
prefracturing fluids (fracturing source water and fracturing fluid) and
produced water at multiple time points from a natural gas well in southwestern Pennsylvania
using 16S rRNA gene-based clone libraries, pyrosequencing, and quantitative
PCR. The majority of the bacterial community in prefracturing fluids constituted
aerobic species affiliated with the class Alphaproteobacteria. However, their
relative abundance decreased in produced water with an increase in halotolerant,
anaerobic/facultative anaerobic species affiliated with the classes Clostridia,
Bacilli, Gammaproteobacteria, Epsilonproteobacteria, Bacteroidia, and Fusobacteria.
Produced water collected at the last time point (day 187) consisted almost
entirely of sequences similar to Clostridia and showed a decrease in bacterial abundance
by 3 orders of magnitude compared to the prefracturing fluids and produced
water samplesfrom earlier time points. Geochemical analysis showed that produced
water contained higher concentrations of salts and total radioactivity compared
to prefracturing fluids. This study provides evidence of long-term subsurface
selection of the microbial community introduced through hydraulic fracturing,
which may include significant implications for disinfection as well as reuse of
produced water in future fracturing operations.
14.
Rafferty, M.A., Limonik, E. Is Shale Gas Drilling an Energy
Solution or Public Health Crisis? Public Health Nurs. 2013
Sep-Oct;30(5):454-62. doi: 10.1111/phn.12036. Epub 2013 Apr 22.
Abstract High-volume horizontal hydraulic fracturing, a
controversial new mining technique used to drill for shale gas, is being
implemented worldwide. Chemicals used in the process are known neurotoxins,
carcinogens, and endocrine disruptors. People who live near shale gas drilling
sites report symptoms that they attribute to contaminated air and water. When
they seek help from clinicians, a diagnosis is often elusive because the
chemicals to which the patients have been exposed are a closely guarded trade
secret. Many nurses have voiced grave concern about shale gas drilling safety.
Full disclosure of the chemicals used in the process is necessary in order for
nurses and other health professionals to effectively care for patients. The economic
exuberance surrounding natural gas has resulted in insufficient scrutiny into
the health implications. Nursing research aimed at determining what effect unconventional
drilling has on human health could help fill that gap. Public health nurses
using the precautionary principle should advocate for a more concerted transition
from fossil fuels to sustainable energy. Any initiation or further expansion of
unconventional gas drilling must be preceded by a comprehensive Health Impact Assessment
(HIA).
Ren, L., Zhao, J., Hu, Y. Hydraulic Fracture Extending into
Network in Shale: Reviewing Influence Factors and their Mechanism.
ScientificWorldJournal. 2014;2014:847107. doi: 0.1155/2014/847107. Epub 2014
Jun 15.
Abstract Hydraulic fracture in shale reservoir presents
complex network propagation, which has essential difference with traditional
plane biwing fracture at forming mechanism.
14.
Based on the research results of experiments, field
fracturing practice, theory analysis, and numerical simulation, the influence
factors and their mechanism of hydraulic fracture extending into network in
shale have been systematically analyzed and discussed. Research results show
that the fracture propagation in shale reservoir is influenced by the
geological and the engineering factors, which includes rock mineral
composition, rock mechanical properties, horizontal stress field, natural fractures,
treating net pressure, fracturing fluid viscosity, and fracturing scale. This study
has important theoretical value and practical significance to understand fracture
network propagation mechanism in shale reservoir and contributes to improving
the science and efficiency of shale reservoir fracturing design.
Rich, A.L., Crosby, E.C. Analysis of Reserve Pit Sludge from
Unconventional Natural Gas Hydraulic Fracturing and Drilling Operations for the
Presence of Technologically Enhanced Naturally Occurring Radioactive Material
(TENORM). New Solut.
2013;23(1):117-35.
Abstract Soil and water (sludge) obtained from reserve pits
used in unconventional natural gas mining was analyzed for the presence of
technologically enhanced naturally occurring radioactive material (TENORM).
Samples were analyzed for total gamma, alpha, and beta radiation, and specific
radionuclides: beryllium, potassium, scandium, cobalt, cesium, thallium,
lead-210 and -214, bismuth-212 and -214, radium-226 and -228, thorium, uranium,
and strontium-89 and -90. Laboratory analysis confirmed elevated beta readings
recorded at 1329 ± 311 pCi/g. Specific radionuclides present in an active
reserve pit and the soil of a leveled, vacated reserve pit included 232Thorium
decay series (228Ra, 228Th, 208Tl), and 226Radium decay series (214Pb, 214Bi,
210Pb) radionuclides. The potential for
14.
impact of TENORM to the environment, occupational workers,
and the general public is presented with potential health effects of individual
radionuclides. Current oversight, exemption of TENORM in federal and state
regulations, and complexity in reporting are discussed.
Roundtable on Environmental Health Sciences, Research, and
Medicine, Board on Population Health and Public Health Practice, Institute of
Medicine. Health Impact Assessment of Shale Gas Extraction: Workshop Summary.
Washington (DC): National Academies Press (US); 2014 Dec 30.
Excerpt Natural gas extraction from shale formations, which
includes hydraulic fracturing, is increasingly in the news as the use of
extraction technologies has expanded, rural communities have been transformed
seemingly overnight, public awareness has increased, and regulations have been
developed. The governmental public health system, which retains primary
responsibility for health, was not an early participant in discussions about
shale gas extraction; thus public health is lacking critical information about
environmental health impacts of these technologies and is limited in its
ability to address concerns raised by regulators at the federal and state
levels, communities, and workers employed in the shale gas extraction industry.
Health Impact Assessment of Shale Gas Extraction is the summary of a workshop convened
in 2012 by the Institute of Medicine (IOM) Roundtable on Environmental Health
Sciences, Research, and Medicine to discuss the human health impact of shale
gas extraction through the lens of a health impact assessment. Eminent scientists,
physicians, public health experts, and representatives from government agencies
at federal and state levels, from nongovernment organizations, from the business
sector, and from interest groups representing the interests of the citizens
14.
met to exchange ideas and to inform on hydraulic fracturing
as a means of extraction of natural gas. This report examines the state of the
science regarding shale gas extraction, the direct and indirect environmental
health impacts of shale gas extraction, and the use of health impact assessment
as a tool that can help decision makers identify the public health consequences
of shale gas extraction.
Roy, A.A., Adams, P.J., Robinson, A.L. Air Pollutant
Emissions from the Development, Production, and Processing of Marcellus Shale
Natural Gas. J Air Waste Manag Assoc.
2014 Jan;64(1):19-37. PubMed PMID: 24620400.
Abstract The Marcellus Shale is one of the largest natural
gas reserves in the United States; it has recently been the focus of intense
drilling and leasing activity. This paper describes an air emissions inventory
for the development, production, and processing of natural gas in the Marcellus
Shale region for 2009 and 2020. It includes estimates of the emissions of
oxides of nitrogen (NOx), volatile organic compounds (VOCs), and primary fine
particulate matter (< or = 2.5 microm aerodynamic diameter; PM2.5) from
major activities such as drilling, hydraulic fracturing, compressor stations, and
completion venting. The inventory is constructed using a process-level
approach; a Monte Carlo analysis is used to explicitly account for the
uncertainty. Emissions were estimated for 2009 and projected to 2020,
accounting for the effects of existing and potential additional regulations. In
2020, Marcellus activities are predicted to contribute 6-18% (95% confidence
interval) of the NOx emissions in the Marcellus region, with an average contribution
of 12% (129 tons/day). In 2020, the predicted contribution of Marcellus activities
to the regional anthropogenic VOC emissions ranged between 7% and 28% (95%
confidence interval), with an average contribution of 12% (100 tons/day).
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These estimates account for the implementation of recently
promulgated regulations such as the Tier 4 off-road diesel engine regulation
and the US. Environmental Protection Agency's (EPA) Oil and Gas Rule. These
regulations significantly reduce the Marcellus VOC and NOx emissions, but there
are significant opportunities for further reduction in these emissions using
existing technologies.
Implications The Marcellus Shale is one of the largest
natural gas reserves in United States. The development and production of this
gas may emit substantial amounts of oxides of nitrogen and volatile organic
compounds. These emissions may have special significance because Marcellus
development is occurring close to areas that have been designated nonattainment
for the ozone standard. Control technologies exist to substantially reduce
these impacts. PM2.5 emissions are predicted to be negligible in a regional
context, but elemental carbon emissions from diesel powered equipment may be
important.
Rozell, D.J. "Constraints on Upward Migration of
Hydraulic Fracturing Fluid and Brine" by S.A. Flewelling and M. Sharma.
Groundwater. 2014 Jul-Aug;52(4):491-2. doi: 10.1111/gwat.12229. Epub 2014 Jun
27.
No summary is available.
14.
Sang, W., Stoof, C.R., Zhang,W., Morales, V.L., Gao, B.,
Kay, R.W., Liu, L., Zhang, Y., Steenhuis, T.S. Effect of Hydrofracking Fluid on
Colloid Transport in the Unsaturated Zone. Environ Sci Technol. 2014 Jul
15;48(14):8266-74. doi: 10.1021/es501441e. Epub 2014 Jun 25.
Abstract Hydraulic fracturing is expanding rapidly in the US
to meet increasing energy demand and requires high volumes of hydrofracking
fluid to displace natural gas from shale. Accidental spills and deliberate land
application of hydrofracking fluids, which return to the surface during
hydrofracking, are common causes of environmental contamination. Since the
chemistry of hydrofracking fluids favors transport of colloids and mineral
particles through rock cracks, it may also facilitate transport of in situ
colloids and associated pollutants in unsaturated soils. We investigated this by
subsequently injecting deionized water and flowback fluid at increasing flow
rates into unsaturated sand columns containing colloids. Colloid retention and
mobilization was measured in the column effluent and visualized in situ with
bright field microscopy. While <5 1="" 2="" 32-36="" 36="" additional="" also="" an="" and="" breakthrough="" by="" colloid="" colloidal="" colloids="" contaminate="" deionized="" disaggregation="" distinct="" due="" existing="" expansion="" filled="" flocs.="" flow="" flowback="" fluid="" flushing="" from="" groundwater="" hydrofracking="" in="" increasing="" indirectly="" initial="" kinetic="" may="" mobilized="" o:p="" of="" peaks.="" peaks="" pollutants.="" pore="" rate="" reduction="" released="" remobilizing="" repulsion="" resulted="" slow="" space.="" steric="" study="" suggests="" surface="" tension="" that="" the="" these="" this="" to="" two="" water="" were="" with="">
Sommariva, R., Blake, R.S., Cuss, R.J., Cordell, R.L.,
Harrington, J.F., White, I.R., Monks, P.S. Observations of the Release of
Non-Methane Hydrocarbons from
14.
Fractured Shale. Environ Sci Technol. 2014 Aug
5;48(15):8891-6. doi: 10.1021/es502508w. Epub 2014 Jul 14.
Abstract The organic content of shale has become of
commercial interest as a source of hydrocarbons, owing to the development of
hydraulic fracturing ("fracking"). While the main focus is on the
extraction of methane, shale also contains significant amounts of non-methane
hydrocarbons (NMHCs). We describe the first real-time observations of the
release of NMHCs from a fractured shale. Samples from the Bowland-Hodder formation
(England) were analyzed under different conditions using mass spectrometry,
with the objective of understanding the dynamic process of gas release upon
fracturing of the shale. A wide range of NMHCs (alkanes, cycloalkanes,
aromatics, and bicyclic hydrocarbons) are released at parts per million or
parts per billion level with temperature- and humidity-dependent release rates,
which can be rationalized in terms of the physicochemical characteristics of
different hydrocarbon classes. Our results indicate that higher energy inputs
(i.e., temperatures) significantly increase the amount of NMHCs released from
shale, while humidity tends to suppress it; additionally, a large fraction of
the gas is released within the first hour after the shale has been fractured.
These findings suggest that other hydrocarbons of commercial interest may be
extracted from shale and open the possibility to optimize the
"fracking" process, improving gas yields and reducing environmental
impacts.
14.
Stephens, D.B. Analysis of the Groundwater Monitoring
Controversy at the Pavillion, Wyoming Natural Gas Field. Groundwater. 2014 Sep
17. doi: 10.1111/gwat.12272.
[Epub ahead of print].
Abstract The U.S. Environmental Protection Agency (EPA) was
contacted by citizens of Pavillion, Wyoming 6 years ago regarding taste and
odor in their water wells in an area where hydraulic fracturing operations were
occurring. EPA conducted a field investigation, including drilling two deep
monitor wells, and concluded in a draft report that constituents associated
with hydraulic fracturing had impacted the drinking water aquifer. Following
extensive media coverage, pressure from state and other federal agencies, and
extensive technical criticism from industry, EPA stated the draft report would
not undergo peer review, that it would not rely on the conclusions, and that it
had relinquished its lead role in the investigation to the State of Wyoming for
further investigation without resolving the source of the taste and odor
problem. Review of the events leading up to EPA's decision suggests that much
of the criticism could have been avoided through improved preproject planning with
clear objectives. Such planning would have identified the high national significance
and potential implications of the proposed work. Expanded stakeholder involvement
and technical input could have eliminated some of the difficulties that plagued
the investigation. However, collecting baseline groundwater quality data prior
to initiating hydraulic fracturing likely would have been an effective way to evaluate
potential impacts. The Pavillion groundwater investigation provides an excellent
opportunity for improving field methods, report transparency, clarity of communication,
and the peer review process in future investigations of the impacts of
hydraulic fracturing on groundwater.
15.
Stringfellow, W.T., Domen, J.K., Camarillo, M.K., Sandelin,
W.L., Borglin, S. Physical, Chemical, and Biological Characteristics of
Compounds Used in Hydraulic Fracturing. J Hazard Mater. 2014 Jun 30;275:37-54.
doi: 10.1016/j.jhazmat.2014.04.040. Epub 201.
Apr 25.
Abstract Hydraulic fracturing (HF), a method to enhance oil
and gas production, has become increasingly common throughout the U.S. As such,
it is important to characterize the chemicals found in HF fluids to evaluate
potential environmental fate, including fate in treatment systems, and human
health impacts. Eighty-one common HF chemical additives were identified and
categorized according to their functions. Physical and chemical characteristics
of these additives were determined using publicly available chemical
information databases. Fifty-five of the compounds are organic and twenty- seven
of these are considered readily or inherently biodegradable. Seventeen chemicals
have high theoretical chemical oxygen demand and are used in concentrations
that present potential treatment challenges. Most of the HF chemicals evaluated
are non-toxic or of low toxicity and only three are classified as Category 2
oral toxins according to standards in the Globally Harmonized System of Classification
and Labeling of Chemicals; however, toxicity information was not located for
thirty of the HF chemicals evaluated. Volatilization is not expected to be a significant
exposure pathway for most HF chemicals. Gaps in toxicity and other chemical
properties suggest deficiencies in the current state of knowledge, highlighting
the need for further assessment to understand potential issues associated with
HF chemicals in the environment.
15.
Sun, M., Lowry, G.V., Gregory, K.B. Selective Oxidation of
Bromide in Wastewater Brines from Hydraulic Fracturing. Water Res. 2013 Jul
1;47(11):3723-31.
doi:10.1016/j.watres.2013.04.041. Epub 2013 Apr 30.
Abstract Brines generated from oil and natural gas
production, including flowback water and produced water from hydraulic
fracturing of shale gas, may contain elevated concentrations of bromide (~1
g/L). Bromide is a broad concern due to the potential for forming brominated
disinfection byproducts (DBPs) during drinking water treatment. Conventional
treatment processes for bromide removal is costly and not specific. Selective
bromide removal is technically challenging due to the presence of other ions in
the brine, especially chloride as high as 30-200 g/L. This study evaluates the
ability of solid graphite electrodes to selectively oxidize bromide to bromine
in flowback water and produced water from a shale gas operation in Southwestern
PA. The bromine can then be outgassed from the solution and recovered, as a
process well understood in the bromine industry. This study revealed that
bromide may be selectively and rapidly removed from oil and gas brines (~10
h(-1) m(-2) for produced water and ~60 h(-1) m(-2) for flowback water).
The electrolysis occurs with a current efficiency between 60
and 90%, and the estimated energy cost is ~6 kJ/g Br. These data are similar to
those for the chlor- alkali process that is commonly used for chlorine gas and
sodium hydroxide production. The results demonstrate that bromide may be
selectively removed from oil and gas brines to create an opportunity for
environmental protection and resource recovery.
15.
Thurman, E.M., Ferrer, I., Blotevogel, J., Borch, T.
Analysis of Hydraulic Fracturing Flowback and Produced Waters Using Accurate
Mass: Identification of Ethoxylated Surfactants. Anal Chem. 2014 Oct
7;86(19):9653-61. doi: 10.1021/ac502163k. Epub 2014 Sep 16.
Abstract Two series of ethylene oxide (EO) surfactants,
polyethylene glycols (PEGs from EO3 to EO33) and linear alkyl ethoxylates (LAEs
C-9 to C-15 with EO3-EO28), were identified in hydraulic fracturing flowback
and produced water using a new application of the Kendrick mass defect and
liquid chromatography/quadrupole-time- of-flight mass spectrometry. The
Kendrick mass defect differentiates the proton, ammonium, and sodium adducts in
both singly and doubly charged forms. A structural model of adduct formation is
presented, and binding constants are calculated, which is based on a spherical
cagelike conformation, where the central cation (NH4(+) or Na(+)) is
coordinated with ether oxygens. A major purpose of the study was the
identification of the ethylene oxide (EO) surfactants and the construction of a
database with accurate masses and retention times in order to unravel the mass
spectral complexity of surfactant mixtures used in hydraulic fracturing fluids.
For example, over 500 accurate mass assignments are made in a few seconds of
computer time, which then is used as a fingerprint chromatogram of the water
samples. This technique is applied to a series of flowback and produced water
samples to illustrate the usefulness of ethoxylate "fingerprinting",
in a first application to monitor water quality that results from fluids used
in hydraulic fracturing.
15.
Vikram, A., Lipus, D., Bibby, K. Produced Water Exposure
Alters Bacterial Response to Biocides. Environ Sci Technol. 2014 Oct 22. [Epub
ahead of print].
Abstract Microbial activity during the holding and reuse of
wastewater from hydraulic fracturing operations, termed produced water, may
lead to issues with corrosion, sulfide release, and fouling. Biocides are
applied to control biological activity, often with limited efficacy, which is
typically attributed to chemical interactions with the produced water. However,
it is unknown whether there is a biologically driven mechanism to biocide
tolerance in produced water. Here, we demonstrate that produced water exposure
results in an enhanced tolerance against the typically used biocide
glutaraldehyde and increased susceptibility to the oxidative biocide hypochlorite
in a native and a model bacteria and that this altered resistance is due to the
salinity of the produced water. In addition, we elucidate the genetic response of
the model organism Pseudomonas fluorescens to produced water exposure to provide
a mechanistic interpretation of the altered biocide resistance. The RNA-seq data
demonstrated the induction of genes involved in osmotic stress, energy production
and conversion, membrane integrity, and protein transport following produced
water exposure, which facilitates bacterial survival and alters biocide tolerance.
Efforts to fundamentally understand biocide resistance mechanisms, which enable
the optimization of biocide application, hold significant implications for greening
of the fracturing process through encouraging produced water recycling.
Specifically, these results suggest the necessity of
optimizing biocide application at the level of individual shale plays, rather
than historical experience, based upon produced water characteristics and
salinity.
15.
Webb, E., Bushkin-Bedient, S., et al. 2014. Developmental
and Reproductive Effects of Chemicals Associated with Unconventional Oil and
Natural Gas Operations. Rev.
Environ. Health. 29: 307-318.
Abstract Abstract Unconventional oil and gas (UOG)
operations have the potential to increase air and water pollution in
communities located near UOG operations. Every stage of UOG operation from well
construction to extraction, operations, transportation, and distribution can
lead to air and water contamination. Hundreds of chemicals are associated with
the process of unconventional oil and natural gas production. In this work, we
review the scientific literature providing evidence that adult and early life exposure
to chemicals associated with UOG operations can result in adverse reproductive
health and developmental effects in humans. Volatile organic compounds (VOCs)
[including benzene, toluene, ethyl benzene, and xylene (BTEX) and formaldehyde]
and heavy metals (including arsenic, cadmium and lead) are just a few of the
known contributors to reduced air and water quality that pose a threat to human
developmental and reproductive health. The developing fetus is particularly sensitive
to environmental factors, which include air and water pollution. Research shows
that there are critical windows of vulnerability during prenatal and early postnatal
development, during which chemical exposures can cause potentially permanent damage
to the growing embryo and fetus. Many of the air and water pollutants found
near UOG operation sites are recognized as being developmental and reproductive
toxicants; therefore there is a compelling need to increase our knowledge of
the potential health consequences for adults, infants, and children from these
chemicals through rapid and thorough health research investigation.
15.
Weber, B.A., Geigle, J., Barkdull, C. 2014. Rural North
Dakota's Oil Boom and its Impact on Social Services. Soc Work. Jan; 59(1):62-72.
Abstract Over the last five years, North Dakota has
experienced an oil boom based on high oil prices and hydraulic fracturing
technologies. This has brought economic expansion and population growth to
rural communities that had previously experienced decades of depopulation and
economic struggle. Although the state has enjoyed many benefits--especially in
juxtaposition to a sluggish national economy-- the boom has also meant the
arrival of economic refugees and dramatic impacts on largely rural social
service systems. In the midst of a rapidly changing situation, available
information tends to swing between euphoria over economic success and hysteria
about rising crime and shifting cultures. In response, the authors used a primary
focus group with county social service directors from across the state and a followup
focus group with social workers operating on the edge of oil activity.
Grounded in resilience theory, qualitative analysis of the
primary focus group, and triangulation of data from other sources, this study
provides a more objective report of the housing and social challenges, the
benefits of the boom, and the challenges to solutions.
15.
Zhang, T., Gregory, K., Hammack, R.W., Vidic, R.D.
Co-precipitation of Radium with Barium and Strontium Sulfate and its Impact on
the Fate of Radium During Treatment of Produced Water from Unconventional Gas
Extraction. Environ Sci Technol. 2014 Apr 15;48(8):4596-603. doi:
10.1021/es405168b. Epub 2014 Apr 7.
Abstract Radium occurs in flowback and produced waters from
hydraulic fracturing for unconventional gas extraction along with high
concentrations of barium and strontium and elevated salinity. Radium is often
removed from this wastewater by co-precipitation with barium or other alkaline
earth metals. The distribution equation for Ra in the precipitate is derived
from the equilibrium of the lattice replacement reaction (inclusion) between
the Ra(2+) ion and the carrier ions (e.g., Ba(2+) and Sr(2+)) in aqueous and
solid phases and is often applied to describe the fate of radium in these
systems. Although the theoretical distribution coefficient for Ra- SrSO4 (Kd =
237) is much larger than that for Ra-BaSO4 (Kd = 1.54), previous studies have
focused on Ra-BaSO4 equilibrium. This study evaluates the equilibria and
kinetics of co-precipitation reactions in Ra-Ba-SO4 and Ra-Sr-SO4 binary systems
and the Ra-Ba-Sr-SO4 ternary system under varying ionic strength (IS) conditions
that are representative of brines generated during unconventional gas extraction.
Results show that radium removal generally follows the theoretical distribution
law in binary systems and is enhanced in the Ra-Ba-SO4 system and restrained in
the Ra-Sr-SO4 system by high IS. However, the experimental distribution
coefficient (Kd') varies widely and cannot be accurately described by the distribution
equation, which depends on IS, kinetics of carrier precipitation and does not
account for radium removal by adsorption. Radium removal in the ternary system is
controlled by the co-precipitation of Ra-Ba-SO4, which is attributed to the
rapid BaSO4 nucleation rate and closer ionic radii of Ra(2+) with Ba(2+) than
with Sr(2+).
Carrier (i.e., barite) recycling during water treatment was
shown to be effective in
15.
enhancing radium removal even after co-precipitation was
completed. Calculations based on experimental results show that Ra levels in
the precipitate generated in centralized waste treatment facilities far exceed
regulatory limits for disposal in municipal sanitary landfills and require
careful monitoring of allowed source term loading (ASTL) for technically
enhanced naturally occurring materials (TENORM) in these landfills. Several
alternatives for sustainable management of TENORM are discussed.
Zvala-Araiza, D., Sullivan, D.W., Allen, D.T. 2014.
Atmospheric Hydrocarbon Emissions and Concentrations in the Barnett Shale
Natural Gas Production Region. EnvSciTech.
48:5314−5321.
Abstract Hourly ambient hydrocarbon concentration data were
collected, in the Barnett Shale Natural Gas Production Region, using automated
gas chromatography (auto-GC), for the period from April 2010 to December 2011.
Data for three sites were compared: a site in the geographical center of the
natural gas production region (Eagle Mountain Lake (EML)); a rural/suburban
site at the periphery of the production region (Flower Mound Shiloh), and an
urban site (Hinton). The dominant hydrocarbon species observed in the Barnett
Shale region were light alkanes.
Analyses of daily, monthly, and hourly patterns showed
little variation in relative composition. Observed concentrations were compared
to concentrations predicted using a dispersion model (AERMOD) and a spatially
resolved inventory of volatile organic compounds (VOC) emissions from natural
gas production (Barnett Shale Special Emissions Inventory) prepared by the
Texas Commission on Environmental Quality (TCEQ), and other emissions
information. The predicted concentrations of VOC due to natural gas production
were 0-40% lower than background corrected
15.
measurements, after accounting for potential
under-estimation of certain emission categories. Hourly and daily variations in
observed, background corrected concentrations were primarily explained by
variability in meteorology, suggesting that episodic emission events had little
impact on hourly averaged concentrations.
Total emissions for VOC from natural gas production sources
are estimated to be approximately 25,300 tons/yr, when accounting for potential
under-estimation of certain emission categories. This region produced, in 2011,
approximately 5 bcf/d of natural gas (100 Gg/d) for a VOC to natural gas
production ratio (mass basis) of 0.0006.
In addition to studies published in the peer-reviewed
scientific literature, there are many documents produced by governmental
organizations on all aspects of HVHF activities.
The following reports also provided additional background
information for the Public Health Review.
Colorado’s Air Quality Control Commission. REGULATION NUMBER
3, STATIONARY SOURCE PERMITTING AND AIR POLLUTANT EMISSION NOTICE, REQUIREMENTS
5 CCR 1001-5 http://perma.cc/TEP5-T7TM Rulemaking Summary On February 23, 2014,
Colorado’s Air Quality Control Commission (“Commission”) fully adopted EPA’s Standards
of Performance for Crude Oil and Natural Gas Production, Transmission, and
Distribution found in 40 C.F.R. Part 60, Subpart OOOO (“NSPS OOOO”) into Regulation
Number 6, Part A; adopted corresponding revisions to its emissions reporting
and permitting framework in Regulation Number 3, Parts A, B, and C; and adopted
complementary oil and gas control measures in Regulation Number 7. This rulemaking
was the culmination of the Commission’s October 2012, directive to
15.
consider full adoption of EPA’s NSPS OOOO. These oil and gas
control measures revisions focus on identifying and repairing leaks in the oil
and gas sector, but also contain some recordkeeping and reporting requirements.
This rulemaking received support from environmental groups and some companies
within the oil and gas industry. In addition to extensive VOC reductions, the
Regulation Number .
revisions also regulate methane emissions from the oil and
gas industry.
These oil and gas control measures are estimated to reduce
VOC emissions by approximately 93,500 tons per year and methane/ethane
emissions by approximately 65,000 tons per year, at a cost of approximately $42.5
million per year.
US EPA. 2014. Advance notice of proposed rulemaking under 40
CFR Chapter I [EPA– HQ–OPPT–2011–1019; FRL–9909–13] Hydraulic Fracturing
Chemicals and Mixtures.
Summary In its response to a citizen petition submitted
under section 21 of the Toxic Substances Control Act (TSCA), EPA indicated that
as a first step, it would convene a stakeholder process to develop an approach
to obtain information on chemical substances and mixtures used in hydraulic
fracturing. To gather information to inform EPA’s proposal, the Agency is
issuing this advance notice of proposed rulemaking (ANPR) and initiating a
public participation process to seek comment on the information that should be
reported or disclosed for hydraulic fracturing chemical substances and mixtures
and the mechanism for obtaining this information. This mechanism could be
regulatory (under TSCA section 8(a) and/or section 8(d)), voluntary, or a
combination of both and could include best management practices, third-party
certification and collection, and incentives for disclosure of this
16.
information. In addition, the Agency is seeking comment on
ways of minimizing reporting burdens and costs and of avoiding the duplication
of state and other federal agency information collections, while at the same
time maximizing data available for EPA risk characterization, external
transparency, and public understanding. Also, EPA is soliciting comments on
incentives and recognition programs that could be used to support the
development and use of safer chemicals in hydraulic fracturing.
Dusseault, M. & Jackson, R. Seepage Pathway Assessment
for Natural Gas to Shallow Groundwater During Well Stimulation, Production and
After Abandonment. GeoMontréal 2013 [66th Canadian Geotechnical Conference and
the 11th Joint CGS/IAH-CNC Groundwater Conference].
Abstract Hydraulic fracture stimulation (HFS) of
unconventional oil and gas reservoirs has become the focus of public concern
with respect to fugitive gas emissions, fracture height growth, induced
seismicity and groundwater pollution. We evaluate the potential pathways of
fugitive gas seepage during stimulation and production and conclude that the
quality of surface casing and deeper casing installations is a major concern
with respect to future gas migration. The pathway outside the casing is of greatest
concern, and likely leads to many wells leaking natural gas upwards from intermediate,
non-depleted thin gas zones, rather than from the deeper target reservoirs
which are depleted during production. We substantiate this argument with isotopic
data from the Western Canada Sedimentary Basin. These paths must be understood
and the probability of leakage addressed by mitigating methods such as casing
perforation and squeeze, expanding packers of long life and controlled leak- off
into saline aquifers. With a few exceptions, hydraulic fracture stimulation
itself
16.
appears not to be a significant risk. These exceptions
include situations involving fluids during the high pressure stage of HFS when
(1) old well casings are intersected by fracturing fluids and (2) when these
fluids pressurize nearby offset wells that have not been shut in, and
particularly offset wells in the same formation that are surrounded by a region
of pressure depletion where the horizontal stresses have also been diminished.
Ellsworth, W.l., Hickman, S,H., Lleons, A.l., Mcgarr, A.,
Michael, A.J., Rubinstein, J.l.
2012. Are Seismicity Rate Changes in the Midcontinent
Natural Or Manmade? SSA 2012 Abstract # 12-137.
Summary A remarkable increase in the rate of M 3 and greater
earthquakes is currently in progress in the US midcontinent. The average number
of M >= 3 earthquakes/year increased starting in 2001, culminating in a
six-fold increase over 20th century levels in 2011. Is this increase natural or
manmade? To address this question, we take a regional approach to explore
changes in the rate of earthquake occurrence in the midcontinent (defined here
as 85° to 108° West, 25° to 50° North) using the USGS Preliminary Determination
of Epicenters and National Seismic Hazard Map catalogs.
These catalogs appear to be complete for M >= 3 since
1970. From 1970 through 2000, the rate of M >= 3 events averaged 21 +-
7.6/year in the entire region. This rate increased to 29 +- 3.5 from 2001
through 2008. In 2009, 2010 and 2011, 50, 8.
and 134 events occurred, respectively. The modest increase
that began in 2001 is due to increased seismicity in the coal bed methane field
of the Raton Basin along the Colorado-New Mexico border west of Trinidad, CO.
The acceleration in activity that began in 2009 appears to involve a
combination of source regions of oil and gas production, including the Guy,
Arkansas region, and in central and southern
16.
Oklahoma. Horton, et al. (2012) provided strong evidence linking
the Guy, AR activity to deep waste water injection wells. In Oklahoma, the rate
of M >= 3 events abruptly increased in 2009 from 1.2/year in the previous
half-century to over 25/year.
This rate increase is exclusive of the November 2011 M 5.6
earthquake and its aftershocks. A naturally-occurring rate change of this
magnitude is unprecedented outside of volcanic settings or in the absence of a
main shock, of which there were neither in this region. While the seismicity
rate changes described here are almost certainly manmade, it remains to be
determined how they are related to either changes in extraction methodologies
or the rate of oil and gas production.
Hammack, R., Harbert, W., Sharma, S., Stewart, B., Capo, R.,
Wall, A., Wells, A., Diehl, R., Blaushild, D., Sams, J., Veloski, G. 2014. An
Evaluation of Fracture Growth and Gas/Fluid Migration as Horizontal Marcellus
Shale Gas Wells are Hydraulically Fractured in Greene County, Pennsylvania;
NETL-TRS-3-2014; EPAct Technical Report Series; U.S. Department of Energy,
National Energy Technology Laboratory: Pittsburgh, PA.
Executive Summary This field study monitored the induced
fracturing of six horizontal Marcellus Shale gas wells in Greene County,
Pennsylvania. The study had two research objectives: 1) to determine the
maximum height of fractures created by hydraulic fracturing at this location;
and 2) to determine if natural gas or fluids from the hydraulically fractured
Marcellus Shale had migrated 3,800 ft upward to an overlying Upper Devonian/Lower
Mississippian gas field during or after hydraulic fracturing.
The Tully Limestone occurs about 280 ft above the Marcellus
Shale at this location and is considered to be a barrier to upward fracture
growth when intact.
16.
Microseismic monitoring using vertical geophone arrays
located 10,28.
microseismic events during hydraulic fracturing; about 40%
of the events were above the Tully Limestone, but all events were at least
2,000 ft below producing zones in the overlying Upper Devonian/Lower
Mississippian gas field, and more than 5,000 ft below drinking water aquifers.
Monitoring for evidence of fluid and gas migration was
performed during and after the hydraulic fracturing of six horizontal Marcellus
Shale gas wells. This monitoring program included: 1) gas pressure and
production histories of three Upper Devonian/Lower Mississippian wells; 2)
chemical and isotopic analysis of the gas produced from seven Upper
Devonian/Lower Mississippian wells; 3) chemical and isotopic analysis of water
produced from five Upper Devonian/Lower Mississippian wells; and 4) monitoring
for perfluorocarbon tracers in gas produced from two Upper Devonian/Lower
Mississippian wells.
Gas production and pressure histories from three Upper
Devonian/Lower Mississippian gas wells that directly overlie stimulated,
horizontal Marcellus Shale gas wells recorded no production or pressure
increase in the 12-month period after hydraulic fracturing. An increase would
imply communication with the over- pressured Marcellus Formation below.
Sampling to detect possible migration of fluid and gas from the underlying
hydraulically fractured Marcellus Shale gas wells commenced 2 months prior to
hydraulic fracturing to establish background conditions. Analyses have been
completed for gas samples collected up to 8 months after hydraulic fracturing
and for produced water samples collected up to 5 months after hydraulic
fracturing. Samples of gas and produced water continue to be collected monthly
(produced water) and bimonthly (gas) from seven Upper Devonian/Lower
Mississippian gas wells.
16.
Current findings are: 1) no evidence of gas migration from
the Marcellus Shale; and 2) no evidence of brine migration from the Marcellus
Shale. Four perfluorocarbon tracers were injected with hydraulic fracturing
fluids into 10 stages of a 14-stage, horizontal Marcellus Shale gas well during
stimulation. Gas samples collected from two Upper Devonian/Lower Mississippian
wells that directly overlie the tracer injection well were analyzed for
presence of the tracer. No tracer was found in 1.
gas samples taken from each of the two wells during the
2-month period after completion of the hydraulic fracturing.
Pennsylvania DEP. Regional Determination Letters.
http://files.dep.state.pa.us/OilGas/BOGM/BOGMPortalFiles/OilGasReports/Determinatio
n_Letters/Regional_Determination_Letters.pdf.
Summary The following list identifies cases where DEP
determined that a private water supply was impacted by oil and gas activities.
The oil and gas activities referenced in the list below include operations
associated with both conventional and unconventional drilling activities that
either resulted in a water diminution event or an increase in constituents
above background conditions. This list is intended to identify historic water
supply impacts and does not necessarily represent ongoing impacts. Many of the
water supply complaints listed below have either returned to background conditions,
have been mitigated through the installation of water treatment controls or
have been addressed through the replacement of the original water supply. This list
is dynamic in nature and will be updated to reflect new water supply impacts as
they are reported to DEP and a determination is made; however, the list will
retain cases of water supply impacts even after the impact has been resolved.
16.
Public Health Association Australia (2014) Submission to
Northern Territory Legislative Assembly Inquiry into Hydraulic Fracturing. PHAA
NT Branch, ACT, Australia.
No summary is available.
Schumacher B, Griggs J, Askren D, Litman B, Shannon B,
Mehrhoff M, Nelson A, Schultz MK. 2014. Development of Rapid Radiochemical
Method for Gross Alpha and Gross Beta Activity Concentration in Flowback and
Produced Waters from Hydraulic Fracturing Operations (EPA Report).
Summary and Conclusions Three parts of The Gross Alpha and
Gross Beta Method in FPWHFO were tested using a matrix based on the composition
of a FPWHFO sample received from the EPA to determine whether they would
satisfy method development guidelines outlined in the Method Validation Guide
for Qualifying Methods Used by Radiological Laboratories Participating in
Incident Response Activities (EPA, 2009). Two of the three parts comprise measurements
of alpha emitters in the sample while the third is designed to measure beta
emitters.
The MQOs for each of the three parts differed based on the
matrix complexity, the instruments used for analyses, and the nuclear constants
associated with the principal radionuclides used for the development process,
and variation associated with preparation of the test samples. The as-tested
MQOs and measured results are presented in Table 3. The final method with flow
diagram used in this method development study is presented in Attachment III.
Each of the three parts of the method validated met all of
the acceptance criteria for method uncertainty as shown in Tables 6A, 6B, and
6C. A summary of the observed
16.
levels of uncertainty at each of three activity levels is
summarized in Tables 7A, 7B, and 7C. Detectable levels of bias were observed
across the activity levels for each of the three measurements as summarized in
Table 10. The levels of bias, however, were so large that they compromised the
determinatoin of method uncertainty. The detection capability for each of the
three parts was successfully verified as summarized in 9A, 9B, and 9C.
Although all testing criteria were met as described in this
report, the complexity of the matrix prevented development of a
single-measurement method for gross alpha and beta in FPWHFO samples that will
be simple, economical, and sufficiently rugged in matrices beyond the one used
for the testing. Performing this analysis required a level of effort that was
much different from previous analytical methods in other water matrices for
alpha or beta emitters. Several unique approaches were attempted in order to
identify an analytical approach that would accommodate this particularly
challenging matrix. Section 11 provides a brief synopsis of development activities
and Attachment 1 provides additional detail supporting the method development
activities preliminary to final testing.
The final approach for gross alpha requires two
measurements. The first measurement involves gross alpha by liquid
scintillation counting following chemical separation to isolate thorium,
uranium and polonium from the matrix. Method testing in the surrogate matrix
indicates that a measureable bias is associated with the technique. Average
recovery were 74±11% (k=1) of the known concentration of 230Th. Recoveries
ranged from 57–104%. Although all of the testing criteria were met, the
observed low bias raises possible questions about the ruggedness of the technique,
especially with regard to use of the method for analyzing of FPWHFO of different
compositions, from different regions or different times in the hydraulic fracturing
life cycle. Possible future work should be done to improve the ruggedness
16.
of the method and to develop estimates of uncertainty and
decision criteria that would protect against decision errors using this
screening technique.17 See Section 11 for recommendations for possible future
work in this area.
The second measurement for alpha activity associated with
226Ra is performed by gamma spectrometry. The gamma spectrometry measurement is
used to simultaneously determine the activity of longer-lived members of the
thorium and uranium decay chains for calculation of gross beta activity.
Although the development process detected bias in the gamma spectrometry
measurements at some levels, the magnitude of the bias is lower than that
observed for the alpha and there is no need for concern about the ruggedness of
the non-destructive measurement technique since there are no variables such
chemical separations that will introduce variable levels of bias into the
method. Section 11 suggests the possibility of future work to improve the
sensitivity of the gamma spectrometry measurement.
Due to the physics of the measurement technologies,
radionuclide determinations performed by gamma spectrometry are generally less
sensitive and have higher uncertainty that those performed by the liquid
scintillation counting. This complicates the reporting process, the determination
of uncertainty, and prevents calculation of a single meaningful value for gross
alpha detection capability. Section 11 recommends that measurements of gross
alpha by LSC and of 226Ra be reported and interpreted separately and suggests
the possibility of future work that would improve the sensitivity of the gamma
spectrometry measurement thereby minimize the disparity in the sensitivity of
the two techniques.
Finally, as mentioned in the introduction in Section 1, all
gross alpha and beta measurements are limited by the complexities of
radioactive decay and ingrowth in the uranium and thorium decay chains which
causes the alpha and beta activity
16.
physically present in the sample to change over time. Thus
gross alpha and beta measurements are often not (inter-) comparable from
measurement to measurement or laboratory to laboratory. This significantly
complicated the interpretation of gross alpha and beta results. Section 11
recommends that future work explore the impact of timing on the performance of
the method and the interpretation of results, a project that would benefit
gross alpha and beta measurements of natural products in all water matrices.
Stinson, R.J., Townsend, I., Donley, T.L., Chirenje, T.,
Patrick, D. 2014. Heavy Metal Distribution in Surficial Water: A Possible Link
to Hydrocarbon Exploration and Extraction, Middle Susquehanna River Sub-Basin,
Pennsylvania. Northeastern Section – Geological Society of America,
Northeastern Section, 49th Annual Meeting (23–2.
March, 2014), Lancaster, Pennsylvania.
Summary Several environmental and human health concerns have
emerged in the past few years due to the recent boom of hydrocarbon exploration
and the new hydraulic fracturing methods involved. Although many different
concerns exist, groundwater contamination has continually been the focal point
of water issues relating to hydraulic fracturing. Surficial water has a fast
residence time in the hydrologic cycle and does not directly impact humans as
much as groundwater; therefore, it tends to be overlooked. For a chance to
better understand the interaction between surface water and hydraulic
fracturing, this project helps to determine if hydraulic fracturing is
influencing the local watershed. Water samples were collected from tributaries leading
into the Susquehanna River, from Bradford and Wyoming Counties, PA, to measure
the concentrations of potential pollutants. Concentrations of heavy metals, such
as arsenic, strontium, selenium, barium, nickel, cadmium, lead, copper, and
16.
zinc, were measured by means of atomic absorption
spectrophotometry. On-site measurements, comprising of temperature, pH,
dissolved oxygen, conductivity, and turbidity, were also measured. A
statistical analysis of the collected data was interpreted and graphical
representations were produced to portray the results.
Results of the analyzed data showing a trend in increased
concentration levels of pollutants with distinct distribution patterns could be
considered a link to hydraulic fracturing. Effluence in surficial water can be
acquired via runoff, which can originate from different phases of the hydraulic
fracturing process; specifically, the handling and disposal of all fluids. This
project holds the groundwork for additional research to understand the
relationship between surficial water and hydraulic fracturing. Further investigation
and modeling can be attempted to recognize the following: how the pollutants
are deposited and transported, watershed quality and impacts (negative or positive),
if the pollutants found are at levels that can endanger human health, and, most
importantly, whether hydraulic fracturing can be labeled as a point-source or
not.
US EPA. 2014. Advance notice of proposed rulemaking under 40
CFR Chapter I [EPA– HQ–OPPT–2011–1019; FRL–9909–13] Hydraulic Fracturing
Chemicals and Mixtures.
Summary In its response to a citizen petition submitted
under section 21 of the Toxic Substances Control Act (TSCA), EPA indicated that
as a first step, it would convene a stakeholder process to develop an approach
to obtain information on chemical substances and mixtures used in hydraulic
fracturing. To gather information to inform EPA’s proposal, the Agency is
issuing this advance notice of proposed rulemaking (ANPR) and initiating a
public participation process to seek comment on the information that should be
reported or disclosed for hydraulic fracturing chemical
17.
substances and mixtures and the mechanism for obtaining this
information. This mechanism could be regulatory (under TSCA section 8(a) and/or
section 8(d)), voluntary, or a combination of both and could include best
management practices, third-party certification and collection, and incentives
for disclosure of this information.
In addition, the Agency is seeking comment on ways of
minimizing reporting burdens and costs and of avoiding the duplication of state
and other federal agency information collections, while at the same time
maximizing data available for EPA risk characterization, external transparency,
and public understanding. Also, EPA is soliciting comments on incentives and
recognition programs that could be used to support the development and use of
safer chemicals in hydraulic fracturing.
USGS. 2014. Record Number of Oklahoma Tremors Raises
Possibility of Damaging Earthquakes. Updated USGS-Oklahoma Geological Survey
Joint Statement on Oklahoma Earthquakes. Originally Released: 10/22/2013
1:07:59 PM; Updated May 2, 2014.http://earthquake.usgs.gov/regional/ceus/products/newsrelease_05022014.php.
Summary The rate of earthquakes in Oklahoma has increased by
about 50 percent since October 2013, significantly increasing the chance for a
damaging quake in central Oklahoma. In a new joint statement by the U.S.
Geological Survey and Oklahoma Geological Survey, the agencies reported that
183 earthquakes of magnitude 3.0 or greater occurred in Oklahoma from October
2013 through April 14, 2014. This compares with a long-term average from 1978
to 2008 of only two magnitude 3.0 or larger earthquakes per year. As a result
of the increased number of small and moderate shocks, the likelihood of future,
damaging earthquakes has increased for central and north-central Oklahoma.
17.
“We hope that this new advisory of increased hazard will
become a crucial consideration in earthquake preparedness for residents,
schools and businesses in the central Oklahoma area,” said Dr. Bill Leith, USGS
Senior Science Advisor for Earthquakes and Geologic Hazards. “Building owners
and government officials should have a special concern for older, unreinforced
brick structures, which are vulnerable to serious damage during sufficient
shaking.” The joint statement indicates that a likely contributing factor to
the increase in earthquakes is wastewater disposal by injection into deep
geologic formations. The water injection can increase underground pressures,
lubricate faults and cause earthquakes – a process known as injection-induced
seismicity. Much of this wastewater is a byproduct of oil and gas production
and is routinely disposed of by injection into wells specifically designed and
approved for this purpose. The recent earthquake rate changes are not due to
typical, random fluctuations in natural seismicity rates.
Oklahoma’s heightened earthquake activity since 2009
includes 20 magnitude 4..
to 4.8 quakes, plus one of the two largest recorded
earthquakes in Oklahoma’s history – a magnitude 5.6 earthquake that occurred
near Prague on Nov. 5, 2011, which damaged a number of homes and the historic
Benedictine Hall at St.
Gregory's University in Shawnee.
As a result of the increased seismicity, the Oklahoma
Geological Survey has increased the number of monitoring stations and now
operates a seismograph network of 15 permanent stations and 17 temporary
stations. Both agencies are actively involved in research to determine the
cause of the increased earthquake rate and to quantify the increased hazard in
central Oklahoma.
17.
| Appendix .
Radon Screening Analysis Radon is a naturally
occurring, radioactive gas found in soil and rock. It seeps into homes through
cracks in the foundation, walls, and joints. Radon comes from the natural
(radioactive) breakdown of uranium in soil, rock and water and gets into the
air.
The amount of uranium in soil, rock and water varies across
New York State. Radon from soil is the primary source of elevated levels in
homes. Radon is a potential public health concern because elevated radon levels
in the home can increase the risk of lung cancer for residents. This risk is
greatly increased among smokers living in homes with elevated radon levels.
The New York State Department of Health has been collecting
radon data since 1987.
The data come from New York residents who choose to test
their homes through the DOH radon program (Figures A and B).The information
contained in the database is posted on the DOH website (http://www.health.ny.gov/environmental/radiological/radon/radon.htm)
and contains basement radon results for about 70,000 homes. The information is
listed by county and town and is updated semi-annually. DOH has a radon
outreach and education program that promotes testing and mitigation in high
risk radon areas and encourages testing by providing low-cost radon test kits
to residents across the state.
17.
Radon from Natural Gas Natural gas contains radon
from the decay of naturally occurring radium. The amount of radon will vary
depending on the source of natural gas. Radon undergoes radioactive decay with
a 3.8 day half-life. This means that the amount of radon in the natural gas decreases
by 50% every 3.8 days. Transport of the natural gas through gathering and distribution
lines provides time for radon gas to decay resulting in a lower concentration of
radon when delivered to the customer.
Published estimates of indoor radon concentrations due to
the use of natural gas in homes (US EPA, 1973) suggest that radon from natural
gas use is typically a very small contributor to the total indoor radon levels
in the home, compared to radon levels in the soil gas. Most gas appliances are
vented, therefore only unvented appliances (mostly gas ranges) are assumed to
contribute radon to indoor air.
A 1973 US EPA study found an average radon level in US
natural gas wells of 3.
picocuries per liter (pCi/L) (range: 0.2 to 1,450 pCi/L).
The highest radon concentrations are from natural gas that originates in Texas,
Oklahoma and Kansas. Similar estimates have been reported for natural gas from
other parts of the world. A more recent study of radon in Pennsylvania natural
gas wells conducted by the US Geological Survey (Rowan and Kramer, 2012) showed
a radon concentration range of 1-79 pCi/L.
To determine whether radon in natural gas contributes to the
overall indoor radon levels in the home, EPA made the following assumptions:
home size (8000 ft3), gas usage (2.
ft3/day) and number of air exchanges (1 per hour). Based on
the above assumptions and an average radon concentration of 20 pCi/L (in gas at
the burner) in an unvented kitchen range, the contribution from radon in
natural gas results in an indoor radon
17.
concentration of about of 0.0028 pCi/L. Using the highest
reported US radon concentration (1450 pCi/L) in an unvented kitchen range shows
an increase of about 0.2 pCi/L. For comparison, the average outdoor radon
concentration in the US is 0..
pCi/L, and according to the NYSDOH radon database, the
average indoor radon concentration in New York State in homes that have been
tested, mostly located in high radon areas, is 6.2 pCi/L. The nationwide
average indoor radon concentration is 1..
pCi/L.
The assumptions used to estimate indoor radon contribution
from burning natural gas were established in 1973 and may not represent present
kitchen stove usage. Current data on gas use states that a typical home uses
from 4.5-12.5 ft3/day (rather than the 2.
ft3/day used above) depending on whether or not the gas
range has a pilot light (US DOE, 2009). Using these revised gas consumption
values, a radon concentration of 2.
pCi/L and keeping all the other parameter values the same,
the contribution from an unvented gas appliance falls to 0.00046 to
0.0011pCi/L. If instead of the average radon concentration of 20 pCi/L we use
the maximum measured concentration of 1450 pCi/L, the contribution to the
indoor radon level from natural gas will range from 0.03 – 0.0.
pCi/L. Assuming a smaller dwelling of 4,000 ft3the radon
concentration could increase to 0.16 pCi/l from natural gas.
In summary, it is generally accepted that sources other than
soil such as groundwater, consumer products (e.g., granite counter tops) and
natural gas are not considered significant contributors to indoor radon
concentrations. The above calculation demonstrate that natural gas has the
potential to contribute a small amount of radon to the indoor air of homes from
the use of unvented gas ranges. Based on the EPA methodologies, this
contribution could be as high 0.16 pCi/L using the most recent data on gas
consumption in a small dwelling. This contribution should be considered in the
17.
context of what we know about radon concentrations in the
environment which is that the average outdoor radon concentration in the US is
0.4 pCi/L, the nationwide average indoor is 1.3 pCi/L and according to the
NYSDOH radon database, the average indoor radon concentration in New York State
is 6.2 pCi/L.
17.
Figure A New York State short-term indoor radon levels by
county.
Figure B New York State long-term indoor radon levels by
county.
Department of Health
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