Microsoft Word Marcellus Radon doc

Mitigation of Impacts

Because radon is an inert gas radon cannot be chemically removed from the natural gas stream. But since radon has a 3.8 day half-life, the radioactive gas potentially could be stored for a sufficient period of time to allow the radon to decay to safe levels. In order to adequately protect residents of New York State, the material could be stored at wellhead locations for several months. If the gas was stored for two months, there would be a significant diminution of the hazard. Over this time period, the hazardous radioactive gas, radon, will decay by a factor 100,000.

From Gogolak, the estimated cost is on the order of $10 billion to develop sufficient pressurized storage in tanks. Some lag storage will be required in any case, since use of natural gas will not be uniform. The estimated costs for mitigating the environmental impact of radon is beyond the scope of this report.

Conclusion

The potential environmental and public health impact of radon in natural gas from the Marcellus Shale formation is enormous. This paper has calculated the number of lung cancers in New York State as ranging between 1,182 and 30,448. This calculation is based on reasonable assumptions for a gas well in the Marcellus Shale, including the concentration of radon at the wellheads, the transit time between wellheads and homes, the dilution expected in a typical household, and reasonable risk factors drawn from studies by the US Environmental Protection Agency.

In its 1400-page Draft Supplemental Environmental Impact Statement, the New York Department of Environmental Conservation has devoted one sentence to the issue of radon.. The sentence states “Radon gas, which under most circumstances is the main health concern from NORM [Normally Occurring Radioactive Materials], is produced by the decay of radium-226, which occurs in the uranium-238 decay chain.”

Clearly, this one sentence does not constitute an adequate or thorough analysis of the potentially serious risks associated with the impacts of transporting radon-contaminated natural gas into the apartments and homes of New York State residents. The Draft Supplemental Environmental Impact Statement is obviously insufficient as written. It has completely ignored the problems associated with radon and the Marcellus Shale formation.

The Draft Supplemental Environmental Impact Statement must be withdrawn and it must be substantially revised so as to discuss the important environmental impacts and public health concerns of the radon problem. Until the radon risk has been appropriately studied and assessed, the Department of Environmental Conservation should not award any drilling permits in the Marcellus Shale formation in New York State. As a first and crucial step the DEC must make certain that radon at the wellheads from the Marcellus Shale formation in presently operating wells is measured. Tests must be conducted by independent experts and agencies. Such tests also must be scientifically rigorous in their design and be conducted with full transparency to assure public confidence in the validity of the testing.

There are strong economic interests supporting the development of Marcellus Shale gas. The potential for significant generation of jobs through the development of this resource is a real and important factor. Doubtless these economic factors will weigh on policy makers in Albany and potentially influence decisions regarding whether the Department of Environmental Conservation will move forward to adequately address the concerns raised in this paper.

The long-term environmental risks and public health concerns of radon in Marcellus Shale natural gas formations are far too serious to be ignored. The potential impacts of radon must not be swept under the rug. Nor should these impacts be sacrificed to shortterm, economic policies or to unrealistic and/or inaccurate assessments of the benefits of natural gas development in New York State.