delivered testimony of dr. larysa dyrszka, pediatrician at hydrofracking forum (4/25/12)

8/2/2019 Delivered Testimony of Dr. Larysa Dyrszka, Pediatrician at Hydrofracking Forum (4/25/12)

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NV S S e na te D em oc ra tic C on fe re nc e H ea rin gA p ri l 2 5 , 2 0 12Larysa Dyrszka MDlarS17dy@grnai!.com

He a lt h I m p ac / a s se s sme n t is a s ys te m a ti c p ro ce ss t ha t uses a n a rra y o f d ata s ou rc es a nd a na ly ticm e th od s a n d c on sid e rs i np ut f ro m s ta ke r/ old e rs 1 0 de te lm ine !h e p ot en tia l e ffe cts o f a proposedp olic y p la n. p ro gra m . o r p ro je ct o n th e h ea llil o f a p op ula tio ll a nd th e d is tn bu lio n o f t h os e e ff e ct s

w i thm t h e p o p ul at io nH ea lth Im p ac t a ss es sm e nt p ro vid es re co mm en da tio ns o n m o nit o(m g a nd m a na gm g th os e e ffe cts .

N at io na l R es ea rc h C ou nc il, 2 01 1Throe issues for your considera tion:

The need for a Health Impact Assessment for Gas Drilling E&P in New York State Radon Social and Environmental Justice

A report (ent it led Improv ing Hea lth in the Uni ted States: The Role of Heal th Impact Assessment ') i ssued in Sep!ember 2011 by theNational Research Council of the National Academies of Science recommended the greater use of HIA in decision making In theUnited Slates, stating Ihallhe systernafic assessment of Ihll heal th consequences of pol ic ies. p rograms, p lans. and projects iscri tically important for protecting and promoting public health.2

When considering if an HIA is an appropriate process to undertake, the firsl question to answer is whether [his is important tohuman heal th and if the impacts will be significant. It is clear thallhe medical community of New York believes [hat it is imperativeto study the hea Ith impacts using this H IA 1001 belore proceeding wllh the rdSGEIS process.The SGEIS d id not consider the broad determinants or human hea lth which inf luence popu la tion hea lth. These include:

soc ial justice facto rs such as equal ity, soc ia l inc lus ion, heal th care standards. ex is ting disease burden. VUlnerablepopulationsII public services such as transportation. educaUon, security. waste management. regulationsII environment such as a ir qual ity ef fects on vulnerable populat ions, water pur ity and access, no ise. disease. soi l

con taminat ion, tox ins, food resources, I leod and f ire hazards and thei r e ffects on specif ic populat ions. par ticu la rly lhemost vulnerable

II housing safety, adequacy, aflordability, qualityII heallh behaviors such as alcoholism, diel. drug abuse, recreationlit l ivel ihood such as employment. job securi ty , wea lth, home ownership communily social support , family structure and relationships

Based on a prel iminary review of availab le I iterature , i t i s eVident f rom areas where gas dr il ling is occurr ing that these determinantsof health have been overlooked. We know that :II Gas dr ill ing frequent ly occurs in areas which have underserved and poor populat ions and near vulnerab le group act iv it iessuch as schools.II Underlying health of the population is not considered when planning such industrial act ivities.II II i s also known that unheal thy behaviors of ten accompany this industry- -behaviors such as drug abuse and crime.II Housmg is known 10 become unaffordable for Ihe residents.II Homes wilh water contammation become unmarketable and families become displaced. Residents near gas drilling operations complain about the noise. lighls, odors, diff iculty breathing and those withrespiratory problems may have exacerbations of thalr underlying breathing difficult ies.

These are just some examples related to health and weH-being and which medical professionals recognized had not beenaddressed in Ihe rdSGEIS.The potential health impacts (stressors which have been identified in other areas where gas E&P are occurring) which should beincluded in a NYS study are:1 National Research Council. Improving Health in Ihe United Stales: The Role of Health Impact Assessment. Washington. DC:The Nat ional Academies Press, 2011. pp. 4 5.

2 NRDC et al comments on the rdSGEIS January 2012


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air impactse wate r contamination soil contamination exposure to endocrine-disrupling and other chemicalswaste management

radiation exposure spills, accidents road safely social concerns such a s housing. community character . schoo ls . substance abuse economic issues such as employment. value of home. cost of heallhcare. loss of productivit y hea lth inf rastructure including avai labi lity. insurance justice concerns such as vu!nerable populat ions, eq uality cumulative ef fects of mu!Gpte stressors(and any other heal th determinants which the !ead and stakeho lders identi fy)

Lack of such discussion of these health impacts could result in more illness. increased cost to insurers and the state for health care,soc ia l instabi li ty . loss of community suppor t, and par ticular ty adversely af fectlhose who are poor. a lready ill. the underserved andvulnerable.The proposed HIA process would a im to include these determinants of heal th and identi fy stressors. Addressing them in atransparent process. and with the inc lusion of a ll stakeholders would be a key component o f this hea lth impact assessment.

Regardingliming--this is an ideat time to do Ihis study. An HIA should be done pr io r to the implementat ion of a pol icy, and shouldadvise the pol icy. not be done afterwards. The ear lier in the decis ion-making process that hea lth impacts are considered. the greaterthe l ikel ihood that such timely mformation W i l l result in better decisions by those who make them and an understanding of theconsequences 01 their decisionsOn Oclober 5.2011. heal th pro fessionals sent a lel le r to Governor Cuomo specif ically request ing that the draf t SGEISbe supplemented to include a full assessment of the public health impacts of gas E&P.3

However . s ince no H IA was iniliated by the DEC. DOH or the Governor. medical professionals again called on the Governor. andnow also on Senator Skelos and Speaker Si lver 10 include such an HIA in the budget This included the American Academy ofPediatrics of NYS. The Amer ican College of Family Physicians (NYS) , the Universi ty of Rochester Medica! Center, Hea lthy Schoo lsNetwork. the NYS Nurses Associat ion and the Medical Society of the State of New York, plus several county medical societies andmany add it ional phys ic ians. The Assembly did so, but apparent ly ne ither the Governor nor Senator Skelos agreed.To conclude about the Heal th Impact Assessmenl --without a ful l assessment and mi tiga tion of the impacts of the risks, the hea ltho f New York S la te res idents and communi ties is l ike ly 10 suf fer. We ca l ! upon you 10 continue 10 advocate for the Heallh ImpactAssessment.

Among the stressors are concerns about the radioact iv ity of Marcel lus shale. We know that Ihe Marcellus is more radioactive than other shale plays. The information in the rdSGEIS also does not include a discussion of radioactivity in pipelines. nor at th e end-point-

people's homes. Studies wh ich inctude wel l-head rad ium and radon. as wel l as along p ipel ines. f rom pigg ing operat ions,at compressor stat ions and at end-use-peop le 's homes-must be done before possib lyfprobably exposing people,particularly children, to radioactivity.

Radon (222) has a halflife of 3.8 days. tt decays by alpha and bela particle emission unt il it becomes the stable isotope oflead (206). Two decay products are the radioacllve solids. polonium (210. 214. 218) and lead (210, 214).

Raoon might have a half-life of 3.8 days. bu t i ts progeny, lead and polonium. have re la tively long ha lf -l ives of 22.6 yearsand 138 days respectively Those are loxic; lead causes neurologic and hematologic toxicity. particularly in chi ldren, anddeath; Polonium causes cancer and death

.. Radon is the leading cause of lung cancer among non-smokers and the second leading cause among smokers.

.. EPA has set the airborne action level to lrigger mitigation measures at 4 pCifL. Large areas of NYS are already at4pCilL(see map at end) ,o Radon by itself is just one part of the radioactivity issue. With chronic exposure, the isotopes 01 polon ium (214Po and

218Po) are thought to cause the majorit y of the estimated 15,00022,000 lung cancer deaths in the US every year thathave been att ributed to indoor radon. We also know that the radioactivity of What comes out of the ground is not measured in any consistent way, nor arethe dr ill cut tings and equipment tested for rad ioactivi ty , and workers are par ticular ly no t adequately pro tected. TheInternat ional A tomic Energy Agency has gu idel ines for radiat ion pro tection of workers in the o il and gas industry.4 Our

3 Physicians, Seienlists and Engineers for Healthy Energy htlp' l!www psehealthveneroy org/resources/show I is IQd /28 l roQV l Z4 IAEA hltp:/fwww-pub,jaea orglMTCDlpubHcationslPDFIPubl171 web. pdf


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federal government has exempted the oi l and gas industry f rom overs igh t of whatever comes up from down-ho le , There should be more auennon paid to the wolters aloog the pipelines. at processing plants and in waste/t ransportRadon and lead accumulate along the p ipes, and as the p igs ( 'Pipel ine Inspection Gauge/GizmofGadget ' l : l l l J 2 : l l~o,wik ioedia oro/wikj/Piggjng ) c lean out the pipe line . they are repositor ies for these tox ins. These pigs must be handled

by workers-the rdSGEIS does not address this aspect of worker safety ei ther. Radon can be transported into homes. schools and workplaces whiCh overlie the Marcellus--transit time would likely beless tha n the decay t ime for radon. Since radon is not removed from the gas currently-and neither is there testing for

radon. radl um, polonium and lead-radon or its daughters can enter into homes via slaves and furnaces. If ventilation isinadequate. i t wil l accumulate until converted to progeny Radon can be Iransported into homes and apartments in NYC. The Agency for Toxic Substances and Disease Registryl is ts stoves and furnaces as a source of indoor radon contaminat ion . Federal agencies5 have thus far not addressed the issue of radon risks in the oil and gas industry. and neither has thestate. Radon measurements should be taken in a ll homes, schools and workplaces as a basel ine now and moni tored throughoutthe t ime Marcellus gas is used.This is an important, but overlooked issue.

And regarding social and environmental jusUce, the county heal th rankinqs indicate that those counties currenUy slated to be dr il ledfirst are those with some of th e worst hea llh outcomes al ready.6 Broome County ranks 59th o f 62 in mor tal ity; Sul li van Countvwhere I live ranks 62nd; Chemung County is 61st in morbidity. What some of these counties share is a good physical environment,though some are already polluted, eg some of the western counties. We cannot risk further endangering our already at-risk andvulnerable populat ion any more than i ta lready is by increasing a ir pol lu tion , or exposing people to heavy tral lic and accidents,exposing them to environmental tox ins, or displac ing them,A Health lrnpact Assessment would be mindful of these important issues Thank you for Introducing the bill.

Addi tional notes:Excerpted (from C BUfger/BRSC SGEIS comments 1/2012) section on RADIOACTIV ITY1. The Marcellus shale is considered to be highly radioactive." In Onondaga County. NY, where theMarcel lus sha le is c lose 1 0 the surface, all of the homes underlain by Marcellus shale had indoor air levels of radon aboveEPA's "acuon level," with the average concentration mora Ihan twice that level. The Pennsylvania Bureau of Oil and GasManagement (BOGM) and Bureau of Radiation Protect ion found that a concentration of radon in a gas sample was 1000 timesabove the EPA's "ac lion level :2. A major concern is the radioactivity of recovered gas, but there is nc mention of radon in the Document beyond noting that it is aproduct o f radium decay.3. No ment ion has been made of the potential for contaminated gas entering our gas supply system and potential exposure thisrepresents within the home andlor work place. This poten tial needs to be assessed.4. The Document acknowledges that "No state has assessed the occurrence of NORM from longer durationdr il ling opera tions at mul ti -wel l s ites Of larger accumulat ions of shale cull ings from horizon tal dr il ling: Ini tial tests show the potent ialfor NORM build up to the extent that NORM waste may require licensing and production waste fiuid may be subject to llrnitatlons asradioactive waste.5. Rad ioactive contamlnahon ot dr il ling equ ipment and wasle is completely unexplored.6. I t i s hig hly probable thaI the sfurry in mud pits will be contaminated with radioactivit y. yet no studies have been undertake fl. TheDocument notes that someone (it does not say who, when or how) should take sampling, analysis, and surveys af ter production hasbegun and determine what radioactive mater ial li censes may be needed.7. The state will have to sort out how iIs laws for radioactive waste might apply to drilling and how the waste could impact watersuppl ies and the environment. It wi ll be important to understand the radioact ivi ty of the var ious waste streams lhat are produced(e.g. , re tuming waste f lu ids, of f-gassing. pi t/ lank s ludge and dr ill cut tings) and the gas product i tself . During dr il ling there maybe a large volume of rad ioactive sha le rock removed in the dr il l cut tings, especial ly f rom hor izontal ly dr il led we lls . It is thereforeimperative that dri ll ing wastes not be disposed of, by ei ther on-s ite burial or l and spread ing. Radioact ive wastes must be taken 10an appropriate facility that is designed to handle radioactive waste. Measures must also be taken to ensure thai the radioactive gasdoes not teak f rom wellheads, or that releases do not occur through generated fractures in the overlying rock. or from well casings,in to the water supply.

Additional reforences on HIA:

5 h! tp :f /Vll lWI . ! ;Ql QQ).!fradon/agency.hlml5 http://www CQlmtyhealthranl~inq5,Qr9/fankjn9s/rankjno-methQdsldQwnload-@nkjngsdata/NY


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hllp;f{www humaojmpacl gro/abQl.ltusb l tDHwww nap edu!cataloo.php?record jd=1322l;lhlto;{/w\y\'j,hiaguide,QrOimelhodsrebUo:/Iwww,healibioopac.tproiectorg/resourcesldpcument/Bhatja2011 HI8-Gujde,(wP@ctice pdfbttp-/lwww healthjmo8ctoccjecl.QrgibtllYliw w w scriM romldprJ25122126IGujde!Q-Hlhio-lhe-Ojl-and-Gas.lndu$j':cl!:IECA-2005ht!p: //wwwogo orcu !Joubsl380 pdfhttp://www.healthjmpaclprojecIQrglresQun;esfdocumenVNAHIAPrac!lce-Stds-Wrkog.Gw2010 MjQlmym-Elemen!s-and-Practice-Sl8ndardsy2 pdf

Addi tiona l references and comments on Radioactivi ty:One gram of 210Po could, in theory, poison 20 mil lion people and 10 mil lion would die hl!R:I/eo )!VjKic,eQi",Qrglwi l\ jiE2lmi !. !i ll .bl!p;ltw w w ostl Qovibridoe/servlelslpurl/64371:l94-yRoUlNI643Z394 R Q i on pg 3 ""Radon in Natural Gas Combustionof natural gas in buildings with unvented appliances may be a source of radon The concentration of radon depends onthe well head concentrat ion and transmission l ime from the well 10 the pOin t of consumption. Concentrat ions rang ingf rom 1 101500 pCi/l have been reported, In the Northeastern Stales radon from natural gas is not an important sourcebecause of considerable radioactive decay occur ring from the well -head (Texas and Louisiana] to the dist ribut ion point ."This statement ref lected gas transi ting from the western US; wi lh the exploi tat ion 01the Marcel lus sha le the gas travelsshorter distances, from PA and NY to NYC, and w i l l have a Significant health impact. hHp"l /www medi~a! joumal -ia: i.Qrq/BeIQe!enm/Belge IKhanEASOXCLQAV8alnodf . . see pg 252 here about k itchenshaving the second highest radon readings in homes in Pakis tan in this study_

hllQ !I'!! "\V-pub jaea.orqlMTCD/publicaljonsiPDFlle 1472 web pdf usee pp256-7 ,a NIgerian study; they only measuredgamma rad iat ion hence they had lower numbers than in o ther studies they c ited . However, !bey wrote thaI "The higheslmeasurements o f 10-15IJSv/h were found at pig rece iver stat ions and wel lheads (see below about PIGS) . These valuesare lower than most repor ted values elsewhere ." (and they g ive those references), The Chemung County landf ill had tha tsame f law-they measured gamma radiat ion onty"hence low numbers,

.. From the Sociely of Petroleum Engineers, 1993 ht10/fwww.opeRetro oro/ms!iblservleVooepetrQoreviaw?ig=QQQ2288Q&soc=Sel ii - - these petroleum engineers consider radioactivi ty a widespread problem... Again, from another induslry publication, the Oil and Gas Journal, 1990, h1\o;ljwww.ogi cpm1articles1pnntlvolume-881jssue-2fi/jn'!hls-issus:{Productioo/radiQilctiye-mglerjal,could-Qose-Qroblems.fQr-the-oas-jodIJstrv blml -- already thenradioactivi ty was considered a problem,

Federal regs'hllPllww)yepa,QQy/eoaWllsle/noohaZ/jndustria1ispecjalfo!llQiI-aas [){if old EPA summary 2002hlhllecfr .gooaccess Qov/cai ltftextf lext.idx?c=ecfr&rqn=div5&view=te~t&nQc!e:40;26.0.1,1 ,2&idno:040#4PZ6.Q.l .1.21 1.3 EPA2D12

Regarding NYS htjo' lIwww dec!W qQv{QalaldmQlrdSgeisfu\lQ911 pdf -, search for NORM references in Ihe documentAre Ihe regs in NYS adequate regarding NORM? htltr/lwww.QecDl.90vkhemica!f296.htmlBased on this NYS study, NYS DEC found li tt le reason for concern btlp '/Jwww dec ny gQvlcbemjcal/23473,blmlht!p-Wreichlerlawolfice,CQmlr1l2iahoo/QOEuranium653239.pdf 1980's paper (pre-Marcel lus) but valuable as there are

calculations for indoor radon due to natural gas being used for cooking. It' s Important to oote that radium levels in theMarce llus are higher than in other shales which Gogolak tested (daughters of rad ium are radon, then polonium and lead)o Compare current regulatory raqurrernants in the US wilh those of IAEA and the !RCP

These are the recommendations from the IAEA of which the US is a member bl!p:/t '\:Cl::-oub,iaea.oroIMTCOlpublica!joosIPDF!Pub1171 web.pdfICRP recommendations htlp;/lVtNIW jcro qro/dQcslMicha~l"&fQCQ\'Jie%2QDevelop"'meJo%20Qf%20a%2QNORM%20Maoaaement%20S1ralegy%200jl%2Qaod%20Gas6:2Q.odf

Reference from the NAS htlp:flwww,napedulopenbookphp?reoord '2"'5499&Oage-R11 on health impacts of radonexposure,

Dr Resnikoffs testimony h!!o'ljrwma cpm/newsletter radon special edWonhtmAdd it iona! references which might be useful in researching this toplc:

A . Paschoa and F Stein hausle r, Technolog ical ly Enhanced Natural Radiat ion , in: ELSEVIER, R"d lQqCl iv ity in the Envjronment.Vgluffii1:.1l, 2010,A. Pascnoa and F. Steinhausler, The Natural Radiation Environment, 8th international symposium (NRE VIII), Buzios, Rio deJaneiro, Brazi l, 7-12 October 2007, Americao Insti tute of Physics, published September 2008; ISBN 978-Q-73540559-2hllp;UWllJw,icrp.QrgldocsIAstrid%20lll11od%20Advances%2Qln%2QNQRM%20M@oaoemert%20in%20NQlWay.odf what Norway isdoing on this issueb t ! p : U w w w (QucbendocrjooloQy,comlradjplogjCllJ-jmpaCJ"21ie-ojl-and-gas-exlracliop?p9g9 =0%2C;, Paschoab.!l[)l/www IOl)chgU!lQdoas cpmlrndjological-imoacl-extractioP-a971, hlml Paschoab. tlQ' !lf li hm;,edutconferencet2Ql0docslkraemer pdf radium in water and produced waterhttp://www.proOliblic8 .Qrq/speciaWoteractlvemao-was!ewa!er -samples- frgm-qas-wells-rnd ioac!iyity-l1 09 radium in waterhllP:llwww.nvtimes.CQmDnlemctiye/20111021.7/uslnaturalg8s-map.htmlradium in produced watert lllD1 !wwy. ',ogp.Qtg ul


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hllp-fl !.WfyII ost!_Qoylbr jdgelserylelSfpurl l6437B94-yRQOsNl64~Z894 odf on pg 3 " . Radon in Natural Gas; Combustion of natural gasin bu ildings wi lh unvented appl iances may be a source of radon.b.l_tD:flwww,mediC?ljQumal-iasorgI8elgelerimlBelqeIKhan(;;A$OXCLQAY83122 pdf see P9 252 here about k itchens having thesecond highest radon readings In homes in Pakis tan in this studybtlp/!te


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EPA map ofradon zones hllo '/ lwww eDa oovlradonlslale;;/ne\Work hlm1I I t;ne 1 counne s have a predicted average Indoor radon scree mng leve I Highest Potentialgreater than 4 pClfl (picocunes per l iter) (red zones)111~one 2 count ies have a predicted average indoor radon screening level Moderate Potentialbetween 2 and 4 pCill{orange zonesl

Zone 3 count ies have a predicted average Indoor radon screening level Low Potentialless than 2 pCill (yellow zones)


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2012 Health Outcomes - New York

~ ..~ !5L _: 1 i l Rank 4762\ank17~31 Rank 3246


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M a rc eltu s S h ale F o rm a tio n2 0 09 P r od u ct io n

Legend* ftl:I!;e M" ' t ~ I '" We l l s ( 1 1mp roout b .n lClM;ne~b:tt.n:~ NYCwa:r~il i:1l8DuI(f. llr, 'Wt!itQC.I' 1

delivered testimony of dr. larysa dyrszka, pediatrician at hydrofracking forum (4/25/12)

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