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On November 20, 2013, the US Environmental Protection Agency's (EPA) Hydraulic Fracturing Research Advisory Panel (HFRAP) met via conference call. A public comment period was included in the agenda of the teleconference.
Donald L. Hassig, Director of Cancer Action NY gave oral comment which addressed high volume hydraulic fracturing impacts on water quality and described the failure of the EPA's Dioxin Review Panel to act so as to insure that EPA used scientific knowledge to develop dioxin policy. Mr. Hassig called for action by the HFRAP to keep EPA on science as fracking policy is being written. The oral comments are available at the download button below.
Cancer Action NY written comments are provided below.
Cancer Action NY Comments for 11/20/13 Meeting of EPA Hydraulic
Fracturing Research Advisory Panel
I am aware of many instances of damage to surface and ground water
quality attributable to high volume hydraulic fracturing (HVHF).
Numerous such instances of damage to water quality are described in
the documentary film "Gasland". Additionally, I have read newspaper
articles and encountered firsthand accounts of instances of damage.
It is not surprising that such instances of damage are being observed
and reported. HVHF is a heavily polluting activity due to the use of
vast quantities of toxic chemicals in the fracturing fluid and the
release of toxic chemicals that were once isolated in shale
formations. The toxic chemicals associated with HVHF are likely to
find their way into ground and surface waters due to the presence of
avenues whereby water can move between upper strata and lower strata.
Fracturing of shale formations that lie deep within the Earth impacts
water in upper strata and on the surface of the Earth because there
are cracks and openings that communicate between the lower fractured
strata and the upper strata and surface where water is present.
Movement of chemicals and water through these cracks and openings
allows mingling of chemicals and water. This is how water becomes
contaminated with chemicals associated with HVHF.
Scientific research follows human observation. It is good that
scientists would gather information on the damages to water that are
caused by HVHF. This information will certainly serve to support the
conclusion of many who are aware of the observed instances of water
contamination their conclusion being that HVHF is a flawed technology,
which should be banned throughout the world. It is the responsibility
of the Science Advisory Board (SAB) Hydraulic Fracturing Research
Advisory Panel (HFRAP) to take actions that will insure that the
Environmental Protection Agency (EPA) develops policies for action on
HVHF that utilize the best available science.
Based upon my past experiences with the EPA and the SAB Dioxin Review
Panel (DRP), I have concluded that it is likely that the HFRAP will
not take the actions that would insure science based action by EPA.
EPA is totally controlled by the petrochemical industry. The HFRAP
was set up for the purpose of creating the illusion that scientific
knowledge was being given a hard look by EPA. In fact, EPA answers to
the petrochemical industry and will act to minimize public concerns
about HVHF facilitating continued use of this energy extraction
technology. EPA will help the petrochemical industry continue to
utilize HVHF in the United States.
The DRP referred to above failed to take the actions necessary to
insure that EPA developed science-based policies on dioxins. During
the course of the finalization of the agency's dioxin reassessment the
DRP repeatedly failed to question EPA actions that lacked a scientific
basis. In 2006, EPA published a paper in which it set forth a much
lower estimate of dioxin exposure. The lower exposure number was
arrived at by changing the way that dioxin concentrations in foods
were calculated. It is common practice to assign the quantity of half
the limit of detection to samples in which no contamination is
detected. EPA took food contamination data that had been used to
assess dioxin exposure and assigned a value of zero to all samples
that were no detects. Exposure went from 1 picogram dioxin TEQ per
kilogram body weight per day to 0.6 picogram dioxin TEQ per kilogram
body weight per day. This drop in exposure was not real. It came
about only as a result of the change in value of the no detect
samples. EPA used the lower exposure value to argue that dioxin
exposure was continuing to decrease in the 2000s. The DRP did not
question this artificial exposure reduction. EPA began using the new
exposure number as if it were the best measure of exposure available.
In 2003, EPA published a draft of the dioxin reassessment that
described a 1 in 1000 excess cancer risk associated with dioxin
exposure at the 1 picogram dioxin TEQ per kilogram body weight per day
value. This information caused much dissatisfaction among
corporations in the chemicals and foods sectors of the economy. When
EPA published the final draft of its dioxin reassessment in February
2012, it left out all information on dioxin exposure cancer risk. EPA
has promised to publish a cancer part of the reassessment, but no
action has been taken to do so. Ten years have passed since EPA first
published information describing dioxin exposure cancer risk, which
was higher than what is acceptable. EPA has made no further effort to
warn the public of the dioxin exposure cancer hazard. The DRP has not
expressed any concern about this failure on the part of EPA.
When EPA published the final draft of the non-carcinogenic effects
part of the dioxin reassessment, it stated that the food supply was
safe. This is not a science-based position. Experts in the science
of dioxin exposure and health effects have concluded that current
levels of dioxin exposure impose more than an acceptable quantity of
cancer risk. The DRP has not questioned EPA on its statement that the
food supply is safe.
The chairperson of the DRP was Dr. Timothy Buckley. Dr. Buckley was
given a job in the EPA after the final non-carcinogenic effects part
of the dioxin reassessment was published. I requested that Dr.
Buckley answer questions about the lack of attention to science in the
dioxin reassessment. Dr. Buckley declined to answer these questions.
I have contacted all of the members of the DRP and not a single member
has been willing to answer my questions.
The DRP is a group of people who will not challenge EPA actions that
go against scientific knowledge and the best interests of the public.
EPA selected these people because they had demonstrated their
willingness to go along with actions by EPA that were counter to
science but favorable to corporations. The DRP failed in its
responsibility to insure that EPA follow science in all of its dioxin
policy development actions. I suspect that the HFRAP will also fail
in its responsibility to keep EPA on the science. This is because I
know that EPA is controlled by the petrochemical industry and the
other powerful corporate sectors. EPA is the corporations.