Donald L. Hassig, November 4,2011

I have recently spoken with New York State Department of Environmental
Conservation (DEC) Deputy Commissioner Eugene Leff concerning the
health risks of high volume hydraulic fracturing (HVHF).  We discussed
the possibility of the production of a health risk assessment.  He
explained that the decision was made not to produce a health risk
assessment due to the difficulty of estimating quantities of exposure
to various pollutant releases associated with HVHF.  I believe that a
health risk assessment should nevertheless be produced because it
would be the proper document for portrayal of the complex and
impossible to quantify exposures to pollutant carcinogens associated
with HVHF.

Deputy Commissioner Leff takes the position that the best way to
proceed with HVHF in New York State is to make a firm commitment to
minimizing all exposures to harmful chemical substances released into
the environment by shale gas exploitation.  I argued that considering
the history of shale gas exploitation throughout the United States and
the limited ability of the DEC to enforce laws and regulations already
in existence it would not be possible for DEC to act in a sufficiently
substantial manner upon any commitment to minimization of exposures.
There are many pollutant carcinogen exposures associated with shale
gas exploitation that have not been addressed in those areas where
this activity exists, including:  (1) benzene, formaldehyde,
polycyclic aromatic hydrocarbons (PAHs) and soot particulates
emissions of diesel trucks and compressors; (2) chemical carcinogens
present in fracturing fluid and disposed of so as to contaminate
surface and ground waters; (3) chemical carcinogens evaporating into
the outdoor atmosphere from holding tanks utilized at gas well sites;
(4) chemical carcinogens evaporating from HVHF waste water and
entering the outdoor atmosphere; and (5) radioactive nuclides brought
to the surface of the Earth in HVHF waste water.

Shale gas exploitation is not currently possible without imposing a
relatively large quantity of exposure to pollutant carcinogens upon
New York State residents.  At a time when cancer incidence is already
far above an acceptable level as a result of exposures to pollutant
carcinogens released into the environment by past and current
polluting activities, shale gas exploitation is not acceptable.  Our
organization advocates for a ban on shale gas exploitation throughout
the United States.

Cancer Action NY is a member organization of the New York State Cancer
Consortium (CC).  The CC is currently producing an environmental
exposure section for the 2011-2016 New York State Comprehensive Cancer
Control Plan (CCCP).  Cancer Action NY advocates for the inclusion of a
prohibition against HVHF in the CCCP.  Organizations with an interest in
expressing support for the inclusion of such a prohibition in the CCCP can
contact the CC via email at:  <nycccp@cancer.org>.