Tag Archives: hazard mitigation questionnaire

Gas Drilling : Sullivan County’s Hazards Mitigation Plan


In early January 1987,  emergency sirens in Cochecton, Lake Huntington  and Callicoon shattered  the cold  afternoon.*    The children and I stared fearfully at the Plektron© where it sat on its living room shelf  crackling with meager details.  Like any good fire chief’s wife, I didn’t  pick up the phone to call him.  He’d ring us  the minute he had a chance.

Slowly, painfully,  news reached us.  A train had derailed just behind the Callicoon hospital on route 97.  A chemical had spilled and was filling the air with  caustic vapor.

Snow and mud were making access difficult.  All we knew for certain was that several train  cars had jumped the track and were lying on their sides.

For hours,  the nature and toxicity of the chemical remained unknown but  our husbands, brothers and  sons  were having trouble seeing and  breathing.  The Ladies Auxiliaries prepared coffee and sandwiches that remained undelivered.  We were banned from the site.  Our unanswered questions floated in the air around us,  “Where’s Conrail?  What kind of  poison is it?  What’s happening to our men?”

Barely two miles south of the spill,  as our eyes and throats began to tingle,  we learned that young Doc Salzberg had rolled up his sleeves and was helping to evacuate the hospital.  There were too few ambulances for speed or efficiency.

The baby in my belly kicked as my own fear rose.  At some point,  I remembered to feed his brother and sisters and thanked the fates we weren’t amongst the families being forced from their homes.

That was the night  we learned there were serious holes in our  county-wide disaster response.

Within weeks of the incident, local leaders, representatives of ConRail and our Congressional representatives gathered at the Cochecton Firehouse and began to rectify the situation.  It was an admirable and worthy effort on the part of a small county with minimal resources and to this day,  I couldn’t be more grateful for the care our leaders showed.

Fast forward to 2010 and Sullivan County is asking  residents to help update its All-Hazard Mitigation Plan by completing and returning its Hazard Mitigation Questionnaire by March 31, 2010.  According to Sullivan County’s Division of Planning and Environmental Management,  “[The questionnaire] can be mailed, faxed or emailed to Michael Brother at Barton and Loguidice, the consulting firm that is conducting the plan update.  His contact information is listed on the first page of the questionnaire.”

Although the questionnaire does not address  gas drilling or hydraulic fracturing specifically,  comments concerning  the gas extraction industry and its potential for disastrous accidents can be appended at the last page of the questionnaire.

In December 2009,  the Cornell Law School Water Law Clinic submitted its comments on the Draft Supplemental Generic Impact Statement (dSGEIS) issued by New York State’s Department of Environmental Conservation (DEC).  The report stated, “...[DEC’s] current staffing incapacties must be remedied….To demonstrate the critical need for additional field staff, principal tasks specifically identified in the Chapter 7 of the dSGEIS are summarized in the 15-page Memorandum…”

In turn,  the Memorandum states unequivocally,   “…. The scope and extent of these tasks are clearly beyond the capacity of the DEC.” (Cornell comments dsgeis)  (Cornell Law School WLC Memo)

During Mayor Calvin Tillman’s  recent tour of upstate New York and Pennsylvania,   the DISH, Texas official  was asked,  “If a well catches fire in Texas, do local firefighters get called in?”

“No,”  he answered.   “We go to the scene  but  even emergency responders aren’t allowed on a site.  Even if they were,  most  don’t have special training.  If  a relief valve goes off,  our emergency responders  show  up  and  just wait for the guy to turn it off.  We can’t  get access.”

According to  the Environmental Protection Agency’s  (EPA) 2000  report on compliance in the Oil and Gas Extraction Industries, “Oil and gas extraction facilities are inspected much less frequently (46 months between inspections on average) than facilities in most other industries… and the enforcement to inspection ratio (0.05) is among the lowest of the included industries.” (Page 121: Environmental Protection Agency’s  Compliance Assistance Notebooks:  Oil and Gas Extraction Industry)  In a chart on page  120 of the report,  the “enforcement to Inspection Rate” in Region 2  (including New York State)  was  0.17%  while  Region 3’s rate  (including Pennsylvania)  was  .04%.   (More recent data was unavailable at the site.)

So, if  oversight and enforcement of  the gas drilling industry “is beyond  the capacity of the DEC,”  and  the enforcement ratio was already abysmal during Clinton’s “boom times”  in the 1990s,  what disaster mitigation can we expect now in cash-strapped Sullivan County relative to gas drilling and hydraulic fracturing?

Here are a few  clues:

  • if residents see  a possible gas drilling spill or other emergency,  we’re encouraged to call the EPA’s  newly-established TIPLINE  (877-919-4EPA)  or  email the Agency at  eyesondrilling@epa.gov
  • of the 30-plus gas extraction States in  the US,   only  Pennslvania and New York have no severance tax on the industry.  States that have the tax use its revenue for, among other things, community services and infrastructure;
  • under emergency conditions, the FRAC Act (S1215 – 5 sponsors,   HR2766 – 51 sponsors)   would require gas extractors to reveal the  fracturing toxins used at a  particular site.  Unfortunately, it’s nowhere near passage and  consequently,  there is no reason to believe emergency personnel would know the nature of the chemical soup confronting them.

Nonetheless,  as Sullivan County’s Manager, David Fanslau says, “Federal law requires that the municipalities of Sullivan County develop and implement local hazard mitigation plans in order to obtain future FEMA grant monies for hazard mitigation.  These plans must be updated every five years.  Upon final approval from FEMA, Sullivan County and each participating municipality must formally adopt and approve the plan.”

In light of FEMA’s requirements and the potential harm from  drilling activities,  Breathing suggests the following:

  • Encourage  the Sullivan County Legislature  to hold  public meetings where residents can hear  from, and ask questions of, our Commissioners of  Public Health, Public Works, Planning and the County’s emergency responders;
  • Ask your  Town, Village and County representatives if they were present in Narrowsburg on February 19, 2010 when  Mayor Tillman met with local officials to discuss his  and his residents’ experiences with the gas industry in DISH, Texas;
  • Ask your  County Legislator to propose and/or support a Resolution demanding  that New York State maintain a moratorium on gas drilling until  cumulative impact studies have been conducted on the industry and drilling; until Congress completes its investigation of  the industry’s practices;  until residents can be assured of adequate oversight and enforcement of the industry; until  New York State has a severance tax which can be used to train emergency personnel and maintain our infrastructure; and until the FRAC Act has been passed and communities have full-knowledge of the  toxins we’ll confront in an emergency.

Some County Legislators can be be contacted  here and if you’re not sure which District is yours, look on this Legislative District map.

Individual Town websites will have contact information for your Supervisor and Town Board.

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**Sullivan County’s Gas Drilling Task Force Report.   Its  Emergency Mitigation portion is excerpted here:

“Along with impacts to local road infrastructure, emergency management  issues are another concern at the local level. Interviews with Emergency
Management counterparts in other parts of New York State indicate that gas  drilling companies have been very good to allow the emergency services (police,
fire and EMS) to attend training sessions which explain how and where a drilling  operation will be set up to include a site visit and hands on question sessions. In
summary, our investigation has shown that most natural gas production wells are located in the Western part of the state and the Emergency Service agencies in
those counties have reported no fire or health hazardous to be associated in there areas for the past twenty plus years.  A few safeguard measures and protocols must be instituted:

  • We must be provided with a list of operational telephone numbers and  email addresses of management contacts and especially emergency contacts that can be called in the event  of an incident near or at a drill  site.
  • Each well site will need a 911 address and access information (gate and lock locations plus access) to ensure that emergency response units can access the site. As will be discussed in the section to follow, the driveway permit process at the town level can be integrated with 911 addressing provided by the Sullivan County Division of Planning. As will be discussed in the next section, the driveway permit forms will need to be revised to require a site plan showing the drilling site and driveway access, as well as photos of the site before construction, after a well is installed and after any subsequent change (e.g., when a well is capped or abandoned) requiring a change in or addition to the NYS DEC permit).
  • Interface with NY Alert to inform Sullivan County residents of a chemical spill or gas fire.
  • Communicate with the public about the importance of registering on-line with NY-Alert to secure receipt of notifications of emergencies.
  • Transportation of waste water/or fracing fluid should be reviewed with emergency response agencies by each operator of a drill site.
  • Emergency management personnel should have access to, or know, the contents of the fracing fluids, to know how to treat injuries and protect the health of emergency personnel and medical staff.
  • For the purposes of health treatment by EMS units and hospital ER’s, the exact contents of the fluid should be on record so that proper treatment is made available.
  • Municipal emergency management staffs need to interact with DEC Region 3 Office and the Mineral Division of the DEC to understand the use of blow out preventers during drilling operations to understand how to control unexpected flows of gas which could result in fires. Along with the DEC, municipal emergency management staff should witness a blow out preventer test prior to drilling.
  • Local emergency management personnel should understand the gas flaring procedure and the layout of flow lines. As for pipeline transport of product through the existing natural gas line or new lines as built, we already have emergency reporting information and training as to how to response to a natural gas line break. This information is updated yearly by the Columbia Gas Transmission Company with their contractor for safety:Paradigm Liaison Services, Wichita, KS.

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*Here’s a  NY Times reference to  what we subsequently learned was  an acetaldehyde spill behind the Callicoon Hospital  in 1987:

DERAILMENT IN UPSTATE NEW YORK CALLICOON, N.Y., Jan. 4 (AP) -Twenty-seven cars of a Conrail freight train derailed in a wooded area near the Delaware River this evening, discharging a hazardous chemical from one car and forcing the evacuation of several homes and a small hospital, state police officials said.

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Resources you might find helpful as you fill out the County’s  Hazard Mitigation Questionnaire:

Environmental  Protection Agency’s Emergency Planning and  Community-Right-To-Know Act

Environmental Protection Agency’s  Compliance Assistance Notebooks:  Oil and Gas Extraction Industry