Fracking produces more hazardous radioactive waste in a week than the entire nuclear power industry does in a year. A long horizontal taking radioactive drill cuttings from Marcellus shale is effectively a radium mine.
Since so much radioactive frack waste is being produced in Pennsylvania, the frackers want to dump it in New York – particularly in low level waste dumps – like the one in Chemung County. The fractavists think otherwise. Here’s what you can do to help:
“Please forward this message to your friends asking for their help and write a few sentences of your own to the DEC at the email address below and send them by December 8 at midnight.
Here are some suggested talking points from the Sierra Club. Please do NOT copy any point verbatim and please do not copy me in (unless BCC). Thank you. You can be original or simply take one point and write about it as a teacher, parent, engineer, nurse, asthma or cancer patient, etc. No matter how short it is, your letter will be read and counted. We need all we can get.
*Written Comments must be filed by December 4, 2015*
Send to: Kimberly Merchant, Deputy Regional Permit Administrator
NYSDEC Region 8
6274 East Avon-Lima Road
Avon, NY 14414
Or email to ChemungLFExpansion@dec.ny.gov
*Sierra Club Atlantic Chapter
Talking Points on Chemung County Landfill Expansion*
November 30, 2015
1.DEC’s proposal to issue a permit to double the size of the Chemung County landfill and allow this municipal solid waste landfill to continue to accept radioactive shale gas drilling wastes is dismaying.
2.The Chemung County landfill already accepts more solid gas drilling waste from Pennsylvania than any other landfill in New York, as Environmental Advocates reported in February of this year.[i] <#_edn1> Since 2010, it has accepted nearly three times the amount of solid gas drilling waste as the second largest recipient.
3.Allowing radioactive drilling wastes to be deposited in an MSW landfill violates the prohibitions and requirements of New York’s low-level radioactive waste laws and regulations.[ii] <#_edn2>
4.Appendix 13 of the DEC’s Revised Draft SGEIS on Hydraulic Fracturing shows that gross alpha and beta in produced brine from vertical Marcellus wells drilled in New York have been as high as 123,000-123,480 pCi/L. Such levels of radioactivity mandate proper handling and tracking of these wastes.[iii] <#_edn3>
5.Radioactive materials can cause irreversible damage to human and animal health, and can contaminate water, air, land, soil and food supplies.
6.The radioactivity risks of shale gas drilling wastes are a statewide issue.
7.At least 15 New York counties have passed bans on the improper re-use and/or disposal of fracking waste.[iv] <#_edn4> As the Onondaga County law states, “The toxins and radioactive materials found in hydraulic fracturing waste are detrimental to the public health.”[v] <#_edn5>
8.DEC’s classification of gas drilling waste as Naturally Occurring Radioactive Material (NORM), thereby exempting such wastes from the stringent requirements of New York’s low level radioactive waste disposal laws and regulations is improper.
9.Without this exemption, these wastes would be banned from municipal and C&D landfills in New York. They would have to be transported to low level radioactive waste landfills and every load would have to be monitored and tracked. The wastes could not be disposed of in New York because we have no low-level radioactive waste landfills in New York.
10.Gas drilling wastes are not naturally occurring, but are processed by hydrofracturing and drilling and are processed and concentrated as they are brought to the surface, separated into waste types and gathered into large volumes for deposit in landfills and wastewater treatment plants.
11.The Pennsylvania DEP study of radioactivity in gas drilling wastes released in January of this year concludes that “There is little potential for radiation exposure to workers and the public” from the wastes.This conclusion is not supported by the data contained in the report. The data in the report shows significant levels of radioactivity associated with gas field drilling wastes.[vi] <#_edn6>
12.The PADEP report is deficient in adequately evaluating the health risks presented by the radioactivity brought to the surface in the gas drilling wastes, giving no consideration to radioactivity from the wastes entering soils and water supplies where it can be ingested and lead to years of exposure.The PA study evaluates health exposures as if those exposures were limited to brief periods of time.
13.DEC’s treatment of radioactivity risks in its revised draft SGEIS on hydrofracking has been criticized by a radiation expert as displaying a “cavalier attitude towards human exposure to radioactive material.”The expert stated that the SGEIS’s “superficial characterization of radiation risks has prompted warnings from . . .the EPA whose public comments on the SCGEIS reflect deep concerns about the DEC’s understanding and appreciation of the actual risks posed by radiation.”[vii] <#_edn7>
14.The failure of the environmental impact analysis in this proceeding to include any meaningful analysis of radiation risks is further evidence of this disregard. The final scoping document states that radioactivity issues “are not environmentally significant based on the composition of Marcellus shale waste materials that are currently being deposited at the landfill,” without examining the radioactivity of the wastes that are being deposited.
15.The Final EIS states that, the gamma detectors at the entrance to the landfill will “mitigate any potential significant adverse environmental impacts to the maximum extent practicable.”.[viii] <#_edn8>However, the difficulties of measuring gamma radiation from radium in waste samples are well known. An Earthworks report in April of this year states, “Gamma radiation is used to measure Ra-226 and Ra-228 in waste samples, but it can take 21 days in the laboratory for [gamma] to emerge, as [the samples] emit alpha and beta radiation much more strongly [citation omitted].As a result, if waste samples used by operators and facilities to obtain permits and by regulators for monitoring purposes are not correctly analyzed, radiation concentrations in both waste and landfill leachate—and in turn the potential risks posed to health and the environment—may be underestimated.”[ix] <#_edn9>
16.Radiation testing of the leachate from the landfill shows increasing levels of radioactivity.[x] <#_edn10>Such increases for the entire volume of the landfill are highly significant, but DEC and the County have ignored its implications.
17.For all these reasons, we urge DEC to deny the request to amend the Chemung County permit.