Wednesday, April 20, 2011

Committee Democrats Release New Report Detailing Hydraulic Fracturing Products

Lets file this post under "Factoids that are true but nonetheless misleading because they loom larger in people’s minds and emotions than they merit." (1)

April 16: Committee Democrats Release New Report Detailing Hydraulic Fracturing Products (2)
“Hydraulic fracturing has helped to expand natural gas production in the United States, but we must ensure that these new resources don’t come at the expense of public health,” said Rep. Waxman. “This report shows that these companies are injecting millions of gallons of products that contain potentially hazardous chemicals, including known carcinogens.  I urge EPA and DOE to make certain that we have strong protections in place to prevent these chemicals from entering drinking water supplies.”
Fair enough.  We do a lot of Hydraulic Fracturing, especially in Texas, so looking at the potential for public health and environmental impacts as we increase the number of wells is prudent.  We have a lot of data, we have a lot of wells established already.  This is how we should be looking at the impact.  What do we see now?  What can we do to minimize the possibility of an impact?  Does hydraulic fracturing increase the risk of impact to an extent that warrants an increase in concern?

Bottom line: There is always a risk whenever you do anything.  Does Hydraulic Fracturing put forth risks that are unreasonable when compared to other activities we encounter and participate in?

Now if you have read any of my posts on the Barnett Shale, you will know I do not like presenting information in a way that it is truthful but not the whole truth and nothing but the truth.  So when I read Rep. DeGette's statement regarding this report:
“Of particular concern to me is that we learned that over the four-year period studied, over one and a half million gallons of carcinogens were injected into the ground in Colorado." 
My "not again" alarm started dinging, sending me to the Bat Cave...err, I mean to the Blog-o-Sphere, so that I can add a bit of clarity to these waters clouded by misinformation and a lack of how toxicity, especially carcinogens, in the environment works.

Yes...yes I know, there is no safe threshold for a carcinogen, so if benzene is present, then the whole fluid must be considered a carcinogen.  But that's not how it works.

But let's say she's right, that all the water - a half million gallons - is a carcinogen.  If that premise is true, then gasoline, which contains up to 2 percent benzene (20,000 ppm), is a carcinogen too.  Which means you would need to be equally outraged at the fact that we are burning 378 million gallons a day in the US.  In four years, that equates to 551,880,000,000 gallons!  And from an exposure point of view, inhalation exceeds ingestion considerably.

Why is the benzene in the frac water that's injected more of a concern than the benzene in the gasoline that's burned? Benzene is benzene.  Why no concern over 552 billion gallons of carcinogens being put into the air?

Why?  Because we are not putting 552 billion gallons of carcinogens in the air, just like we are not injecting 1.5 million gallons of carcinogens into the ground in Colorado.

Lets look at this a bit more objectively.  Just because a carcinogen is present in the mix does not make the mix a carcinogen.  On top of that, you need to have uptake of that carcinogen in order to even have a chance of getting cancer.

So the fact that frac'ing (no "K") uses fluids that contain constituents that are carcinogens, those carcinogens must be released into the environment at a concentration high enough so that the receptor uptake would be at a dose shown to cause an adverse health effect.

It's the Donnelly Risk Paradigm in play.
It's dose/response in play
It's Pharmacokinetics in play
It's the cancer slope factor in play

Look at  Rep. DeGette's statement one more time:
“Of particular concern to me is that we learned that over the four-year period studied, over one and a half million gallons of carcinogens were injected into the ground in Colorado." 
Now lets look at what the report says:
Overall, these companies injected 10.2 million gallons of fracturing products (Colorado = 1.5 million) containing at least one carcinogen.
Now maybe I'm slitting hairs here, but I see a big difference in 1.5 million gallons of carcinogens and 1.5 million gallons that contain a carcinogen.

The concern over what is in these fluids should be addressed.  Removal of the bad actors - carcinogens - should be addressed.  These are important issues to exam as we perform hydraulic fracturing more and more.

But in presenting these fluids used and the waste generated as containing "products contained chemicals that are known or possible human carcinogens, regulated under the Safe Drinking Water Act, or listed as hazardous air pollutants," we elevate the concern to a level that is greater than the actual harm.

It's the perception I'm concerned with being presented in this report.  Every time we scare people with a factoid that is true but nonetheless misleading because they loom larger in people’s minds and emotions than they merit, we hurt the goal of sound policy regarding protecting public health and the environment.

Presenting to the public information that is not properly explained does nothing to help us protect ourselves or make rules and regulation under which to live by.

Lets look at this statement from the Waxman report and take it to its conclusion.
The absence of a minimum national baseline for disclosure of fluids injected during the hydraulic fracturing process and the exemption of most hydraulic fracturing injections from regulation under the Safe Drinking Water Act has left an informational void concerning the contents, chemical concentrations, and volumes of fluids that go into the ground during fracturing operations and return to the surface in the form of wastewater.  As a result, regulators and the public are unable effectively to assess any impact the use of these fluids may have on the environment or public health. 
Will filling up this void with information positively impact the environment or public health?  It's looking for a boogyman when there is a real man waiting in the shadows. There are three bigger issues to focus on that would greatly reduce the potential for a negative impact to the public and the environment:
  1. Fracturing operations should follow an industry agreed upon standard, preferably green drilling
  2. Frac water should be treated to enable continuous reuse and/or discharge at drinking water levels
  3. Oil and Gas Operations should be adequately maintained for the life of the operation
Based on what I have seen and the research I have been doing, I am pretty confident that the amount of carcinogens in fracturing fluids is unlikely to present an impact on public health or the environment that is more significant than similar operations where these chemicals are used.

We can always do better by substituting a less hazardous material for more hazardous one.  We have been doing that since Pollution Prevention (P2) came into existence and it has worked.  Remember 111-trichloroethane?  Greatest degreaser ever!  Hardly used anymore. Win-win for employee and public health as well as the environment.  This is the direction to move Hydraulic Fracturing Products.

Work with industry to develop standards and level the field, support research on safer fluids and frac water treatment, and use science properly to explain risk.



The EPA also looked at the constituents of Hydraulic Fracturing Products in 2004.

For those of you who do not understand the Hydraulic Fracturing Products the following video on YouTube may help.






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