EPA Science Advisory Board Hydraulic Fracturing Research Advisory Panel Public Teleconference February 1, 2016 Oral Statement of Larysa Dyrszka From: Larysa Dyrszka Sent: Monday, February 01, 2016 10:50 AM To: Hanlon, Edward <[email protected]> Subject: comments to EPA SAB on HF Dear Mr Hanlon, Attached please find my comments which I delivered today in abbreviated form. Also, please find the Compendium to which I referred during my comments, and also the PSE for Healthy Energy data analysis. Attached are some additional peer-reviewed articles which point to the health impacts of water contaminated during gas drilling operations. Several attachments for the Panel’s consideration are not included within this posting, due to copyright protection requirements. These attachments are noted below: 1) An evaluation of water quality in private drinking water wells near natural gas extraction sites in the Barnett Shale Formation Brian E Fontenot, Laura R Hunt, Zacariah Louis Hildenbrand, Doug D Carlton, Hyppolite Oka, Jayme L Walton, Dan Hopkins, Alexandra Osorio, Bryan Bjorndal, Qinhong Hu, and Kevin Albert Schug. Environ. Sci. Technol., Accepted Manuscript • DOI: 10.1021/es4011724 • Publication Date (Web): 25 Jul 2013 Downloaded from http://pubs.acs.org on August 9, 2013 2) Water Pollution Risk Associated with Natural Gas Extraction from the Marcellus Shale Daniel J. Rozell and Sheldon J. Reaven. Risk Analysis, Vol. 32, No. 8, 2012 DOI: 10.1111/j.1539-6924.2011.01757.x ∗ 3) Developmental and reproductive effects of chemicals associated with unconventional oil and natural gas operations Ellen Webb, Sheila Bushkin-Bedient*, Amanda Cheng, Christopher D. Kassotis, Victoria Balise and Susan C. Nagel. Rev Environ Health 2014; 29(4): 307–318 DOI 10.1515/reveh-2014-0057. 4) Toward an understanding of the environmental and public health impacts of shale gas development: an analysis of the peer-reviewed scientific literature, 2009-2015. by Jake Hays and Seth B.C. Shonkoff. Physicians scientists and engineers for healthy energy, June 16, 2015. 5) Surface and groundwater contamination associated with modern natural gas development. Physicians scientists and engineers for healthy energy. March, 2014. 6) IMPACTS OF GAS DRILLING ON HUMAN AND ANIMAL HEALTH. Michelle Bamberger & Robert E. Oswald. 2012. Published in NEW SOLUTIONS, Vol. 22(1) 51-77, 2012; published in 2012 by Baywood Publishing Co., Inc. Thank you for this opportunity, and kind regards, Larysa Dyrszka MD White lake, NY 12786 co-founder of Concerned Health Professionals of NY www.concernedhealthny.org ehp ENVIRONMENTAL HEALTH PER SPECTIVES http://www.ehponline.org Environmental Public Health Dimensions of Shale and Tight Gas Development Seth B. Shonkoff, Jake Hays, and Madelon L. Finkel http://dx.doi.org/10.1289/ehp.1307866 Received: 9 November 2013 Accepted: 2 April 2014 Advance Publication: 16 April 2014 Environmental Public Health Dimensions of Shale and Tight Gas Development Seth B. Shonkoff,1,2 Jake Hays,3,4 and Madelon L. Fin kel4 1Physicians Scientists and Engineers for Healthy Energy, Oakland, California, USA; 2Department of Environmental Science, Policy, and Management, University of California, Berkeley, Berkeley, California, USA; 3Physicians Scientists and Engineers for Healthy Energy, New York, New York, USA; 4Department of Public Health, Weill Cornell Medical College, New York, New York, USA Address correspondence to Seth B. Shonkoff, 436 14th Street, Suite 808, Oakland, CA, 94612 USA. Telephone: 510.899.9706. E-mail: [email protected] Short running title: Public Health and Shale Gas Acknowledgments: We are grateful for comments and suggestions provided by Adam Law, Weill Cornell Medical College and Rachel Morello-Frosch, University of California, Berkeley. Competing financial interests: SBS and JH are employees of Physicians Scientists and Engineers for Healthy Energy (PSE), a non-profit organization funded by private donations whose mission is to bring scientific transparency to discussions on energy sources and energy production. PSE did not receive any funding for the preparation of this manuscript. MLF has no competing financial interests to declare. 1 Abstract Background: The United States has experienced a boom in natural gas production due to recent technological innovations that have enabled this resource to be produced from shale formations. Objectives: This review discusses the body of evidence that focuses on exposure pathways to evaluate the potential environmental public health impacts of shale gas development. It highlights what is currently known and identifies data gaps and research limitations by addressing matters of toxicity, exposure pathways, air quality, and water quality. Discussion: There is evidence of potential environmental public health risks associated with shale gas development. A number of studies suggest that shale gas development contributes to levels of ambient air concentrations known to be associated with increased risk of morbidity and mortality. Similarly, an increasing body of studies suggest water contamination risks exist through a variety of environmental pathways, most notably during wastewater transport and disposal and via poor zonal isolation of gases and fluids due to structural integrity impairment of cement in gas wells. Conclusion: Despite a growing body of evidence, a number of data gaps persist. Most importantly, there is a need for more epidemiological studies to assess associations between risk factors, such as air and water pollution and health outcomes among populations living in close proximity to shale gas operations. 2 Introduction Technological innovations in drilling and well stimulation techniques have led to the production of natural gas from previously inaccessible geological formations, such as shale. Proponents of modern gas development argue that it has created a unique economic and political opportunity. Some in the public health community, however, have concerns about the potential for the extraction process to negatively impact the environment and human health (Finkel et al. 2013; Goldstein et al. 2012; Saberi 2013; Witter et al. 2013). Producing natural gas from shale and tight gas formations in an economically feasible manner frequently requires a new constellation of existing technologies: high volume, slickwater, hydraulic fracturing from clustered, multi-well pads using long, directionally-drilled laterals. This method can involve drilling a well vertically thousands of feet below the surface and then directionally (horizontally) for up to two miles. An average of two to five million gallons of fluid consisting of water, proppant (often crystalline silica), and chemicals (some of which are known carcinogens or otherwise toxic) are injected into the well at a pressure high enough to fracture the shale rock (EPA 2010a). Often referred to as slickwater, chemicals are added to the fracturing fluid in order to decrease its friction. The fracturing fluid creates and expands cracks in the shale. When the pressure is released, the cracks are held open by the sand, allowing the tightly held gases to flow into the cracks and up the production casing. The gas is then collected, processed, and sent through transmission pipelines to market. In 2012, shale gas constituted nearly 40% of US gas production, up from 2% in 2000 (Hughes 2013). Natural gas has a variety of attractive attributes. In the current market, it is a relatively inexpensive and abundant fuel. When combusted for electricity generation it emits fewer health 3 damaging contaminants and approximately 50% less carbon dioxide emissions when compared to burning coal (US EIA 2013). Yet, emerging scientific evidence suggests that there may be health risks associated with the development of shale gas. In this review we discuss the body of scientific literature relevant to the environmental public health impacts of shale gas production. We highlight what is currently known and identify data gaps and research limitations. Methods Scope of review This review primarily draws upon literature directly pertinent to the human health dimensions of shale and tight gas development. Tight gas refers to natural gas produced from reservoir rocks of low permeability, such as shale or sandstone. Shale gas and other forms of tight gas are referred to as “unconventional” due to their atypical reservoirs, which require new production techniques. However, the review references some studies that do not directly evaluate unconventional natural gas operations, but that are nonetheless relevant to various aspects of the overall process (e.g., particulate matter pollution, ozone, etc.). In the case of ozone, for instance, we analyzed top down studies that measure tropospheric concentrations rather than studies that supply bottom up measurements (e.g., leakage rates). Materials included in this review are predominantly sourced from the peer-reviewed scientific literature but include, where appropriate, government reports and other grey literature. Although the production chain of gas development is far-reaching, this review focuses on the processes that begin with trucking the water, sand, chemicals, and other materials to the well pad and ends with the disposal of wastewater. Evidence suggests that these processes present the greatest risks to environmental public health and therefore have received 4 the most attention in the scientific literature (Korfmacher et al. 2013; McKenzie et al. 2012; Rozell and Reaven 2012; Witter 2013). Terminology Terminology is important when discussing modern forms of natural gas development. In part due to a lack of well-defined, uniform terminology, there has been confusion regarding which processes constitutes this type of development. The terms, “hydraulic fracturing” or “fracking” are regularly used in the popular media as umbrella terms that are colloquially used to describe the entire process of shale gas and other forms of unconventional natural gas development, from land clearing and well spudding to transmission of natural gas to market. However, taken literally “hydraulic fracturing” only refers to the well stimulation processes and excludes other potentially more health and environmentally impactful processes, including but not limited to well drilling, fracturing fluid production, wastewater disposal, transportation of materials, and the processing, compression, and transmission of gas and liquids. Many of the studies cited in this review may also apply to shale (tight) oil development and other forms of oil and gas development using well stimulation techniques that include matrix acid stimulation, acid fracturing, and steam injection. However, these other techniques are beyond the focus of this review. Additionally, the term “unconventional oil and gas development” can also refer to bitumen/tar sands extraction and processing, and other types of fossil fuel development that employ novel engineering and production techniques to obtain resources from unconventional resources (e.g., coal bed methane), that are beyond the scope of this review. The majority of the environmental public health-relevant scientific literature on modern oil and gas production has focused on the development of natural gas from shale formations and so this review uses the term, shale gas development. However, this review discusses, where appropriate, 5 scientific literature on other forms of unconventional or tight gas development that include the most prominent and relevant features of shale gas development, such as high volume, horizontal, hydraulic fracturing. Identification of relevant studies The literature directly relevant to the environmental public health dimensions of shale gas development is still limited. For this reason, we adopted a broad search strategy comprised of the following: • Systematic searches in three peer-reviewed science databases across multiple disciplines: PubMed (http://www.ncbi.nlm.nih.gov/pubmed/), Web of Science (http://www.webofknowledge.com), and ScienceD irect (http://www.sciencedirect . com) • Searches in existing collections of scientific literature on this subject, such as The Marcellus Shale Initiative Publication Database at Bucknell University (http://www.bucknell.edu/script/environmentalcenter/marcellus), complemented by Google (http://www.google.com) and Google Scholar (http://scholar.google.com) • Manual searches (hand-searches) of references included in all peer-reviewed studies that pertained directly to shale gas development For bibliographic databases, this review used a combination of Medical Subject Headings (MeSH)-based and keyword strategies, which included the following terms as well as relevant combinations thereof: shale gas, shale, hydraulic fracturing, fracking, drilling, natural gas production, Marcellus, Barnett, Denver-Julesberg Basin, air pollution, methane, water pollution, public health, water contamination, fugitive emissions, air quality, epidemiology, unconventional gas development, and environmental pathways. 6 At the time of writing, this search identified a total of 211 peer-reviewed publications that pertain directly to shale gas development. This database can now be accessed online and will continue to be updated with relevant literature (http://psehealthyenergy.org/site/view/1180). Of these 211 publications, only 33 presented original data that met our inclusion criteria and which were considered relevant as primary literature. Inclusion/exclusion criteria From the studies identified through February 1, 2014, we excluded non-relevant technical papers and studies related to economics, climate change, sociology, regulation, seismicity, water usage, social stress and quality of life considerations. While we excluded commentaries from the results of this review, we cite a few to provide documentation of particular considerations among the public health community. We included studies with direct pertinence to the environmental public health and environmental exposure pathways (i.e., air and water) associated with shale and tight gas development. In this regard, we supplemented the shale gas literature with studies that evaluated particular environmental pathways and health outcomes. For instance, we included studies directly related to the health impacts of tropospheric ozone, fine particulate air pollution, and endocrine disrupting chemicals. While this review excludes the vast majority of non-peer- reviewed scientific literature, it references environmental impact statements and other government reports where appropriate. Results The environmental public health framework and possible exposure pathways The environmental exposure pathway framework is often used to describe associations between pollutant sources and health effects via emissions, environmental concentrations of pollutants, 7