NYS Department of Health Addresses Concerns on NYS DEC dSGEIS

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NYS Department of Health Addresses Concerns on NYS DEC dSGEIS

Edward G. Hom, Ph.D., Director
Division of Environmental Health

To: Bradley Field, Director, Division of Mineral Resources

Dear Mr. Field:

On March 10,2009 you requested that the New York State Department of Health Center for Environmental Health (CEB) review information related to the potential for public health impacts from natural gas drilling in the Marcellus shale formation in NYS. The assistance was sought as part of the development of a supplement to DEC’s 1992 Generic Environmental Impact Statement on the,Oil, Gas and Sollution Mining Regulatory Program (GElS).

CEH staff from three Bureaus -Toxic Substances Assessment (BTSA), Water Supply Protection (BWSP) and Environmental Radiation Protection (BERP) -have helped develop the information that you requested. CEH and Division of Mineral Resources (DMR) staff met in person and via telephone conference several times to define the scope of the review’ and to share relevant information. CEH was provided with confidential business information identifying the chemical composition of products used or proposed for hydraulic fracturing of gas wells in NYS and examples of fracturing fluid component mixtures for several NYS wells and wells in PA and WV. DMR also provided chemical analysis data for samples of flowback and production fluids, collected from hydraulic fractured gas wells in NYS, Pennsylvania and West Virginia.

BTSA reviewed existing toxicological data on chemicals in hydraulic fracturing products that could be used in Marcellus gas drilling operations in NYS. On April 29, 2009, Jan -Storm provided Kathy Sanford with a draft write-up of the toxicology comments. In early July, Kathy provided Jan with some additional information about some of the frac fluid additives. The, additional information included some new ingredients” but none that raise any more concern from a health perspective than those already noted in the table. BTSA has not had a chance to modify the summary table to include the new ingredients but will do so when Jan and other staff return from vacation the end of July. They also are preparing the list of references and a conclusions section. We plan to provide that information the end of the first week in August.

BWSP and BERP have also prepared comments (see attached). These are new documents, but I think you have been made aware of all of these concerns previously.

We appreciate the opportunity to review this information and help you identify possible public health concerns. Please let me know if you have any questions or reactions to our comments. As noted above, we would like to finalize our contributions to this important DGEIS during the first week in A~gust. I can be reached at 518.402.7511 or bye-mail to eghOl@health.state.ny.us.

Sincerely,
Edward G. Hom, Ph.D., Director
Division of Environmental Health
Assessment

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