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03/02/2011

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I just don't get it. They know it's bad, but the energy is more important.

This is disgusting to me. (HOW is this nasty contaminated water coming into Maryland,anyway??!!) These large energy companies are making hay because the country is so focused on the economic crisis, and cutting funding to EPA. In a bad economy, there is a vacuum of public opinion, and a dearth of oversight because it costs money to"...do the right thing..." For the first time is DECADES, the efforts of the CBF, coupled with the muscle of the EPA, are making small, but measurable strides (Bay report card) in cleaning the bay. We are looking at a potential reversal of the huge strides in both public opinion and funding in a death from 1,000 cuts scenario, as developers and the energy companies join forces in an environmentally hostile climate to roll back landmark legislation championed by this current administration. We need vigilance and a protection plan to both publically monitor, and advocate against efforts to revoke, repeal, or water down these hard fought, and hard won legislative initiatives. We cannot rest for a moment, because big money is out there, ready to pocket our government. Stay Vigilant! - Ted Turner, Hollywood, MD

Do folks in the Chesapeake Bay region know that the biocides used in gas drilling and fracturing fluids often include dibromonitrilopropionamide (DBNPA) and dibromoacetonitrile (DBAN)? So what, you think? These compounds are lethal to Bay oysters at concentrations below their chemical detection limits! Check with the ATSDR if you don't believe me, a New York State biochemist.

It's one thing for "fracking" fluids with these biocides to be released into our Susquehanna headwaters, far from your oyster beds; it's another for you to let them be dumped right in your own Back River.

What are you all thinking?

That's an excellent question, Dr. Bishop. I know you have studied hydraulic fracturing and its potential environmental ramifications, so I appreciate your insights.

I have asked the Maryland Department of the Environment your questions about DBNPA and DBAN, and hope to get a response from them that I will share with you and the other readers.

Pursuing Dr. Bishop's question, I checked the Pennsylvania Department of Environmental Protection's official list of known chemical components of hydraulic fracturing fluids and it does list the pesticide (also called a "biocide") dibromonitrilopropionamide as an ingredient.

You can look yourself at:

http://www.dep.state.pa.us/dep/deputate/minres/oilgas/new_forms/marcellus/Reports/Frac%20list%206-30-2010.pdf

In addition, an EPA study of DBNPA concluded that it poses a "high risk to aquatic organisms."

The EPA study says: "study results suggest that DBNPA is moderately toxic to estuarine fish and shrimp, highly toxic to estuarine mysids and very highly
toxic to estuarine shellfish and larvae. Acute effects to estuarine oyster (Eastern Oyster) were seen at levels below the analytical detection limit, 0.070 mg/L."

However, the EPA study also says: "When secondary biological treatment is performed, data suggest DBNPA and its degradates would be sufficiently degraded to
adequately mitigate the risk" to aquatic organisms.

You can read this for yourself at: http://www.epa.gov/oppsrrd1/REDs/3056.pdf

Look on page 17 of the study for aquatic effects.

Music through War ! Of course we all agree that the EPA is just a political machine! Not a Scientific one :-(

Here is the response that an MDE spokesman emailed to me this morning, following up on four questions that I asked the agency last week (based on Dr. Ron Bishop's questions)

In essence, MDE said that the pesticide DBNPA in fracking wastewater is not a risk to oysters in the Back River and the Chesapeake Bay because it is removed during the sewage treatment process.

..........................

Tom, answers to your questions are provided below, but we want to make sure you understand the regulatory structure here. The State issues permits for discharges to surface water, including discharges of treated effluent from WWTPs. These WWTPs, especially in urban areas, receive wastewater from commercial and industrial facilities as well as from residences. The Pretreatment Program is the mechanism by which these non-residential discharges are managed by the WWTPs. Baltimore City regulates Clean Harbors’ discharge to its WWTP through the City’s pretreatment program. If you want specific information about how the City does this, you should ask the City. Ralph Cullison would be a good place to start.


1) Was MDE aware that hydraulic fracturing fluids often contain DBNPA and DBAN?
We are aware that the Pennsylvania Department of Environmental Protection has compiled a list of chemicals used by hydraulic fracturing companies in Pennsylvania and that the list includes DBNPA. We will be reviewing the additives that applicants for drilling and hydraulic fracturing permits in Maryland propose to use.

2) Does MDE consider this a risk to Back River or Bay oysters?
We do not think that there was any risk to Back River, the Bay, or oysters. The wastewater that Clean Harbors pretreated was sent to the Back River WWTP, where it underwent further treatment, along with all the other wastewater, before discharge. This treatment would have adequately treated any DBNPA that might have been present in the original wastewater. In addition, it would have been diluted dramatically by the sewage and further diluted when it was discharged to surface water.

The EPA study of DBNPA, Reregistration Eligibility Decision (RED) 2,2-dibromo-3- Nitrilopropionamide (DBNPA), EPA 738-R-94-026, stated on page 21 “After evaluating available data and consultations between Agency Offices (Office of Pesticide Programs, Office of Water, and the Office of Pollution Prevention and Toxics), the Agency has determined that aquatic risk concerns for all uses of DBNPA, except single flow-through cooling systems, may be adequately mitigated by secondary biological treatment of waste water.” To put this in simpler language, EPA considered all the toxicology information, including the data on oysters, and determined that if the wastewater was treated by a WWTP with secondary biological treatment, the resulting wastewater would not contain sufficient DBNPA to harm oysters or other aquatic life.

3) Did Clean Harbors test the waste water (before or after) for DBNPA or DBAN?
We do not have this information, but as noted above, the DBNPA would have been treated adequately in the Back River WWTP.

4) Did Clean Harbors or the Back River WWTP treat the waste water to remove DBNPA or DBAN?
Regardless of what treatment Clean Harbors provided, the treatment at the Back River WWTP was effective to remove DBNPA. The EPA document referenced above, at Appendix G, page 3, states that wastewater containing DBNPA can be discharged to wastewater treatment plants without pretreatment because the biological degradation readily occurs in the WWTP.

Thanks.

Jay Apperson
Deputy Director, Office of Communications
Maryland Department of the Environment
1800 Washington Boulevard
Baltimore, MD 21230

The water from the back river may not be used for drinking but the wastewater may affect the living organisms on that river which is also considered as water pollution.

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