Air Quality in the Barnett Shale - Part 30: The End... finally!

It all started...so long ago...29 posts ago to be exact, not including this one.

There I was trying to get a bit of information on the air requirements for oil & gas fracing operations in Texas, when I stumbled across the final report Alisa Rich of Wolf Eagle Environmental prepared for the Town of Dish, Texas.  That started Post 1.

Now I promised myself I was not going to write a rant or indignation type of blog; that this blog was going to be nothing more than trying to explain complex environmental laws and regulations and how they impact day-to-day operations. I also wanted to talk about public health issues involving chemical exposure - a new-found interest for me after obtaining my MSPH last May.  Basically though, this blog is nothing more than my attempt to consolidate the information out there so that I understand the topic better.  If it helps someone else understand it better too, well than win-win!

Now what I found interesting in all this research (and after 29 posts I have looked at a lot of stuff on this topic) was this graph from the TCEQ:

As a scientist and as a guy who has spent his career looking at numbers to decide what is "dirty" and what is "clean," any time I see a downward trend (my paycheck excluded) I think "good!"  So "bad" ozone levels - which is basically VOCs - is on the downward slide.  And benzene, the most problematic of the VOCs in terms of health issues, is also on the decrease as well.  And at the same time, oil & gas production is on the rise.  Go figure.

Now you can explain this away anyway you want, economic downturn, manufacturing going to China, pollution control, increase enforcement, but the fact is, with an increase in oil & gas production in the Barnett Shale area, the air has not become more contaminated with these two dominant pollutants of concern.  Which means that the foot print of a well maintained oil & gas production site poses a minimal impact on air quality in this area based on the data we have....and we have a lot of data to bolster this.

I have read all of the reports referenced by all the parties involved.  I have looked up the procedures and read them.  I have looked up the citations and the references.  I have checked and double checked the calculations.  All of this has been done in an effort to either support or dismiss the scientific work presented.

I know - because I have been there and I work with hundreds of different people from different disciplines and organizations - that we humans make mistakes.  Sometimes through sheer incompetence (example), others because the issue was illusive, subtle, or extremely nuanced (i.e. Tedlar bag artifacts).

The whole point of this blog is to look at complex topics, tear them apart, and try to understand all the different things that impact it and give it substance and weight.  What you read here is not my expertise but my journey towards an understanding while I try to comprehend it better.  Because it interests me, it may be of interest to someone else as well, or, it may be helpful to someone trying to better understand an issue.

It may seem after 29 posts that I am being hypercritical of the work performed by Alisa Rich and Dr. Sattler.  I am not.  My critique is about the method and data they used, the assumptions they made, and the inferences drawn by these two professionals for their clients including the town of Dish, Texas and the FWLN.

Alisa Rich holds a Master in Public Health (MPH) and is working on a Ph.D.  For me to consider the possibility that she is not aware of the fundamental difference between an ESL and an AMCV is to say UNT's MPH program is derelict in it's course work.  And if that's not the case then what is it?  The reports she wrote for her clients ignore the basic principle of assigning and describing risk - something she should have learned while obtaining her MPH as well as during her time perusing her Ph.D.

And what about Dr. Sattler?  She is an engineer.  But not just an engineer, but a PE!  That's the top of the heap in terms of the ability to show competence and good engineering principles.  And to top it off she is a professor at a major Texas university.  To build a model around one single sample, to estimate an exposure concentration two miles away that is three times higher than the PEL, to ignore non-Gaussian dispersion in the other samples collected at the same time, and to continue using an ESL - derived for odor no less - for ambient air samples because you don't know if  "the technically competent people [at TCEQ] were involved in this [AMCV] decision."  How can a person with this standing and education and credential allow such questionable work to pass as valid?

And because of the work of these two environmental professionals, the FWLN presented their report to the FWISD recommending set-backs of one mile based on the potential for receptors - children - in this area to be exposed to carbon disulfide and carbonyl sulfide at levels way above those deemed harmful for an adult worker.

And to bolster this report as valid, two additional Ph.Ds signed on as part of the "team of scientists and experts – Dr. Ramon Alvarez, Dr. Melanie Sattler, Dr. David Sterling, and Carl Weimer – who donated their expertise and time to the League to produce this report."  These two Ph.Ds aren't slacks either.  Dr. Sterling is the "Chair of Environmental and Occupational Health, University of North Texas Health Science Center, Fort Worth."

So why should Deborah Rogers - the FWLN "liaison between the League and the team" - question what this team produced?  Why should anyone who reads the FWLN report question its validity with these experts on board?

And therein lies the problem.

If I have not made my case after 29 posts, well I don't know what more I can offer.  I can defend my critique of their work, its all there in cyber black and white.  If I am wrong, then show me so that I may correct it.  That's the intellectuality honest thing to do.  Right now the ball is in Dr. Sattler's court for her to defend her work as valid.

Which is why I took her up on that challenge she made in the Deposition:

I think my work stands up to anybody that has expertise in dispersion modeling.  If anybody was criticizing it, they probably didn't have --well, it wouldn't surprise me to see somebody without a scientific background criticize it, because they probably wouldn't understand it.

Well I don't have expertise in air dispersion modeling, but my white lab coat has allowed me to look at it objectively and question the premise of backing in an ambient air concentration to derive an emission rate.  Oh, and I do have the scientific background to criticize it because after 29 posts, you should see that I do understand it.

So here it is, once more:

In the Town of Dish, Texas report prepared for by Alisa Rich, the six samples collected and used to calculate the emission rate which was then used to develop the plumes, do not show Gaussian dispersion in the ratio of contaminates analyzed.  Explain?

In the FWLN you produced a model - Plot 1 - for carbon disulfide that is based on one sample collected on one day.  Please explain how Plot 1 can be determined to be representative of all the oil & gas production sites in the Barnett Shale area?

In the Town of Dish, Texas report, the model you produced is based on identification and quantification of carbon disulfide identified by the lab as a TIC.  In the FWLN report, Plot 1 utilizes a carbon disulfide identification and quantification that is identified by the lab as a TIC.  In the FWLN report, Plot 2 is based on a carbonyl sulfide identification and quantification from a sample collected in a Tedlar bag which is known to produce artifacts of carbonyl sulfide.  How confident are you in these concentrations you used to "back in" to your model to determine the emission rate?  What is the basis you use to support their validity?

In order for the Gaussian dispersion model to work for a year's worth of plumes, the emission rate must stay constant.  Please explain how in Plot 1 of the FWLN report, at two miles from the source the air concentration for carbon disulfide could be at three times the OSHA PEL without causing illness, death, or a significant odor problem in and around the source if that is, indeed, the correct emission rate?

You assume in all your models, including FWLN, that all of the contaminant found in the ambient air is coming from the O&G source.  When looking at other scientific papers where an ambient air sample is "backed in" there is an upwind sample collected so that background contamination - not from the source - is not included (subtracted out).  On what scientific basis does including background levels of contaminants in your emission rate calculation fall under?

That's all Dr. Sattler needs to respond to.  Five appropriate and scientifically-based questions dealing with her work.

If these are non-issues, well you got me on that.  But I think they are real issues that need to be addressed in order to conclude that the need for a one-mile set-back is valid.  Even Dr. Sattler acknowledged this in her Deposition:

I just think with this [FWLN] study imminently going to provide results of lots of data, that it's prudent to -- to get the results of that study, so that if it recommends a setback distance of 400 feet, say, from a well, we could try to locate the well 400 feet from wherever it is.

"Prudent" to base the recommendation on the results, which I assume means results that can be held up to scrutiny and critique.

And in case you have no idea why this matters to me, read my post on "why bother writing about this."

And to bolster what I wrote back then, read this story on chronic fatigue syndrome that appeared in the Chicago Tribune (I read it today in Sunday's local paper The Eagle.)

And to further support the reason: (4/3/11) "Health officials struggling to contain a measles outbreak that's hit hard in Minneapolis' large Somali community are running into resistance from parents who fear the vaccine could give their children autism." (1)

So lets put an end to bad science, dubious science, misleading science, incompetent science, and just plain ol' science to bolster an agenda.

Regarding the impact of oil & gas on the air in Barnett Shale....me thinks this dead horse done been whipped enough!


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