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Letter to DRBC Regarding Gibbstown, NJ Export Facility

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September 3, 2020

Delaware River Basin Commission
25 Cosey Road
West Trenton NJ 08628

Governor Andrew M. Cuomo
Member of the Delaware River Basin Commission
NYS State Capitol Building
Albany NY 12224

The Honorable Tom Wolf
Office of the Governor of Pennsylvania
508 Main Capitol Building
Harrisburg PA 17120

Governor Phillip D. Murphy
Member of the Delaware River Basin Commission
PO Box 001
Trenton NJ 08625

Office of the Governor
c/o John Carney, Chair – Delaware River Basin Commission
Tatnall Building
150 Martin Luther King Jr Blvd South
Dover DE  19901

Dear Governors,

As health experts, scientists, and first responders, we write to urge that you deny the proposed liquefied natural gas (LNG) and natural gas liquids (NGL) export facility in Gibbstown, New Jersey, part of the Delaware River Basin. The facility is proposed as a hub for storage and transport of natural gas liquids, brought by freight rail cars and trucks, to then be transported down the Delaware River by large shipping vessels. We ask that you deny the project given that the transport and storage of LNG is extremely hazardous and the activities associated with the extraction of so-called “natural gas” are highly dangerous, posing significant threats to the people, communities, and environment in the Delaware River Basin. 

Extracting, transporting, and storing LNG is inherently dirty and dangerous. The LNG that would be transported is fracked natural gas that has been super-cooled to a bubbling, cold liquid (-259°F). Prior to super-cooling, the gas must be stripped of volatile impurities like benzene, making the liquefying process a potent source of toxic air pollutants (Fracking Science Compendium footnotes 1226-1242). 

LNG is explosive. It explodes when spilled into water. If it spills on the ground, LNG can turn into rapidly expanding clouds of vapor that can flash-freeze human flesh and asphyxiate by displacing oxygen. If LNG vapors are ignited at their source, they can become flaming pool fires that burn hotter than other fuels and cannot be extinguished. Such fires can reach temperatures hot enough to cause second-degree burns on people and animals up to a mile away. For these reasons, LNG facilities have been identified as potential terrorist targets.

These risks were made acutely and tragically clear in an incident in China this June when a truck carrying LNG exploded on a highway. Nineteen people died and more than 170 more were injured. Various other LNG facilities, including facilities in the United States, have experienced major explosions and other safety problems. 

A 2008 Congressional Research Service report concluded that LNG infrastructure is “inherently dangerous” with serious risks including pool fires with intense heat, which can occur when LNG spills near an ignition source; flammable vapor clouds that can drift until reaching an ignition source; and a rapid phase transition that can generate a flameless explosion. More recent studies confirm these inherent dangers and risk to public safety, which are particularly problematic on inland waterways.

We are deeply concerned that no full quantitative risk assessment has been conducted to identify the likelihood and frequency of transportation-related accidents and consequences. The number and scale of freight rail and truck trips make the risks to communities throughout the region significant. A single incident like the LNG truck explosion in China could spell disaster for people and the environment. Many local first responders do not have the training or equipment to deal with LNG accidents, and work-related training opportunities are infrequent or unavailable.

If built and operated as proposed, the Gibbstown facility would be the first LNG facility to rely extensively on rail and trucks for transportation. Never before has LNG been transported overland in such volumes and for such distances.

Any incident either on land or with shipping vessels in the Delaware River could be catastrophic, affecting the environment and the quality of water on which more than 15 million people rely. Introducing an intensive industrial process, based on largely untested and unstudied systems, poses a significant risk. These risks are on top of the known impacts that would come from building the LNG export terminal, which would entail significant dredging of the river, thousands of truck trips, and significant rail and shipping activity.

Additionally, we believe the climate change implications of the proposed LNG facility are contradictory to the mission of the Delaware River Basin Commission (DRBC) and the climate commitments of Delaware, New Jersey, Pennsylvania, and New York. LNG derives from fracked gas, which is already very damaging to the climate given significant methane leaks, and makes it even worse for the climate. The super-cooling process and transportation requires a substantial amount of energy and leads to even greater emissions during the required boiling off, evaporative cooling process. Overall, the export of LNG is an extremely high Green House Gas (GHG) emitting process.

The DRBC Adjudicatory Hearing on the project, completed May 20, 2020, did not address the issues we have raised in this letter. Most importantly, it did not address the public health and safety issues or broader concerns about accidents and explosions. While the Adjudicatory Hearing reviewed implications for critical species, the review suffers from not considering impacts related to these and other cumulative impacts and risks.

Please address the significant risks and known impacts of the proposed LNG/NGL export facility in Gibbstown, New Jersey. To protect public health, community safety, the environment, and the Delaware River, deny this dangerous and unnecessary project. 

Sincerely,

Physicians for Social Responsibility
Concerned Health Professionals of New York   
Physicians for Social Responsibility – New York
Physicians for Social Responsibility — Pennsylvania

Individual health professionals, scientists, and first responders

Jacob Adams, MD, MPH
Rochester NY

Barbara Andrew, LCSW, LMFT, BCD
Princeton NJ

Pauline Beam, RN
Brooklyn NY

Kelly Branigan, RN
Cooperstown NY

Florence Buckley, RN
Philadelphia PA

Rosemary Caolo, PhD, LCSW           
Scranton PA

Lyn Capurro, MD      
Great Neck NY

Juliette Corazon, MPH
Ithaca NY

Silverio Caggiano, Battalion Chief, 1st Responder
Youngstown OH

Kelly Choi, MD          
Madison NJ

Kurt Crowley, MD
Berwyn PA

Stephen Dungan, MSW, LCSW
Springfield NY

Susan Deane-Miller, LCSW-R          
Poughkeepsie NY

Candice Dunn
Margaretville NY

Larysa Dyrszka, MD
White Lake NY

Joan Farber, MD
New York NY

Amy Freeth, MD
Cooperstown NY

Marta Guttenberg, MD         
Philadelphia PA

Catherine Hunt, RN  
Monroe Township NJ

Sherwood Johnson, DVM, DACVIM
Gibsonia PA

John Judson, MD       
Mechanicsburg PA

Anna Marie Kalafut, RN, MSN, CSRN
Butler PA

Ned Ketyer, MD
Venetia PA

Douglas Kinney, DMD          
Oneonta NY

Arati Kreibich, PhD 
Glen Rock NJ

Dorothea Leicher, NCPSYA  
Philadelphia PA

Robert Little, MD      
Harrisburg PA

Jack David Marcus, MPH, MSW       
New York NY

John Markowitz, MD
New York NY

John McCormick, MD
North Wildwood NJ

Jean Naples, MD-PhD
Suffern NY

Kathleen Nolan, MD, MSL, FAAP
Woodstock NY  

Carmi Orenstein, MPH
Ithaca NY

Alan Peterson, MD   
Willow Street PA

Phyllis Perna, PsyD   
Westport NY

Pouné Saberi, MD, MPH       
Philadelphia PA

Patricia Schecher, RN           
Saint James NY

Barton Schoenfeld, MD, FACC
Valatie NY

Dein Shapiro, MD     
Stockton NJ

Moon Smith, CNM
Philadelphia PA

Margaret Craven Snowden, MD      
Voorheesville NY

Sandra Steingraber, PhD
Ithaca NY

Julie Takatsch, RN    
Port Jervis NY

Debra Teplin, Physicians Assistant
New York NY

Walter Tsou, MD
Philadelphia PA

Jeanne Warmkessel, RN       
North Wales PA

Lauren Wessler, MD 
New York NY

Marilyn Williams, MD          
Lewiston NY


Planning For Fracking on the Barnett Shale: Urban Air Pollution, Improving Health Based Regulation, and the Role of Local Governments

Air Pollution, Peer Reviewed, Public Health, Uncategorized

Abstract

In the last decade hydraulic fracturing for natural gas has exploded on the Barnett Shale in Texas. The region is now home to the most intensive hydraulic fracking and gas production activities ever undertaken in densely urbanized areas. Faced with minimal state and federal regulation, Texas cities are on the front line in the effort to figure out how best to balance industry, land use, and environmental concerns. Local governments in Texas, however, do not currently have the regulatory authority, capacity, or the information required to close the regulatory gap. Using the community experience on the Barnett Shale as a case study, this article focuses on the legal and regulatory framework governing air emissions and proposes changes to the current regulatory structure. Buy premarin
Under both the state and federal programs, the regulation of hazardous air emissions from gas operations is based largely on questions of cost and available technology. There is no comprehensive cumulative risk assessment to consider the potential impact to public health in urban areas. Drilling operations are being conducted in residential areas. Residents living in close proximity to gas operations on the Barnett Shale have voiced serious concerns for their health, which have yet to be comprehensively evaluated. Given the complexity of the science, and the dearth of clear, transparent, and enforceable standards, inadequate studies and limited statistical analysis have been allowed to provide potentially false assurances. The politically expedient bottom line dominates with little attention paid to the quality of the science or the adequacy of the standards. Buy strattera
Determining and applying comprehensive health-based standards for hazardous air pollutants has been largely abandoned at the federal level given uncertainties in the science, difficulties of determining and measuring “safe” levels of toxic pollutants, and the potential for economic disruption. Neither the state nor the federal government has set enforceable ambient standards for hazardous air pollutants. Identifying cumulative air pollution problems that may occur in urban areas, the State of California has called upon local governments to identify “hot spots” and to consider air quality issues in their planning and zoning actions. In Texas, however, preemption discussions dominate the analysis. Any local government regulation that might provide protection from toxic air emissions otherwise regulated by the State must be justified by some other public purpose.
Texas should consider authorizing and encouraging local level air quality planning for industrial activities, similar to what California has done. Care should be taken to separate these facilities from sensitive receptors and “hot spots” that may already be burdened with excessive hazardous air emissions. Given the difficulty of the task, there is also an important role for the state and federal governments in working to establish ambient standards for hazardous air pollutants, as well as standards for health based assessment and public communication. The uncertainty inherent in any of these standards should be made clear and accessible to local governments so that it may be considered in making appropriate and protective land use decisions. Texas should consider allowing local governments to have the power to establish ambient air quality standards, emissions limitations, monitoring, reporting, and offsets for hazardous air pollutants, following the model applied to conventional air pollutants pursuant to the federal program.

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Charted Institute of Environmental Health Northern Ireland Hydraulic Fracturing:Impacts on the Environment and Human Health

Documentation, Public Health, Reports, Uncategorized

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