Testimony to NYSDEC on the SGEIS and Proposed Regulations

November 30, 2011

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Jeff Zimmerman, for Damascus Citizens for Sustainability and NYH20

I want to raise for your consideration what I believe may be the most important but so far most overlooked public health issue involved with Marcellus Shale gas. This issue is radon and the potential exposure of everyone in the New York City metropolitan area to radioactivity levels over 100 times the current exposure level.

Radon is an odorless, tasteless, colorless inert noble gas. It is produced by the radioactive decay of radium, a radioactive element with a half life of 1600 years. Radium is present in shale gas deposits in several parts of the United States. As gas is produced from these shale plays, radon is part of the gas that is transported by pipelines to areas where it is burned to produce energy.

Most of the natural gas now distributed and burned in the New York City area comes from the southern and southwestern states including Louisiana, Texas, Oklahoma, and New Mexico. The radon levels at the wellhead in these gas fields average about 4-5 picocuries per liter (pCi/l) . The travel time to get this gas to New York City is about 7 days. With a half-life of 3.8 days, the radon level once this gas gets to your kitchen stove in the City is about 1 picocurie per liter- well below EPA's action level of 4 picocuries per liter.

Marcellus Shale gas has higher radium levels and therefore higher radon levels, reaching 140 to 150 picocuries per liter. The pipeline travel time from the Marcellus areas of New York and northeastern Pennsylvania will be about 12 to 15 hours. Decay of the radon over this transit time will be approximately 10 to 15%. This will result in radon levels in apartments and houses in the range of 120 to 130 picocuries per liter, over two orders of magnitude greater than the EPA action level. On other point to be kept in mind is that radon is heavier than air and so will settle in the lowest part of a dwelling, i.e. near the floor. This will mean small children will inhale more of the radon than taller adults.

The health impact of the radon occurs in a person's lungs when it decays by radioactive emissions and the energized particles strike the tissue inside the lung. DNA is broken and cancer cells are produced. EPA has found that exposure to radon is the second leading cause of lung cancer, just behind cigarette smoking.

This is a very significant public health issue. EPA's estimate of excess cancer deaths from radon is 21,000 per year on a nationwide basis. The estimated excess radon induced cancer deaths from Marcellus Shale gas is over 13,000 per year- more than a 50% increase over the EPA national estimate, and these additional cancer deaths will be concentrated in the much smaller area of New York-New Jersey and the New England states where the Marcellus gas will be distributed. Neither the draft SGEIS nor the proposed Marcellus gas regulations addresses the radon issue in any way. This is a glaring omission in the NYSDEC analysis to date.
 

click here to read "Natural Gas from Hydrofracking in Marcellus Shale May result in High levels of Radon Gas and Lead in Homes"

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