Air Quality in the Barnett Shale - Part 2: Exposure to a toxic chemical

Did you know that the average five year old child is exposed - on a daily basis in most cases - to over 44 times the lethal dose (LD50) that has been established for the chemical dihydrogen oxide (CAS# 7732-18-5) with the molecular Weight: of 18.02?

Sounds pretty scary doesn't it?  It's all true too.  And if you were to read this in a scientific report written by experts who tout their purpose as helping "ordinary citizens understand, cope with and combat environmental issues" you might have reason for concern, especially if your kid was, in deed, being exposed.

No one wants to have themselves or their family - especially children - forced into a situation where there is "exposure" to a chemical that has scientific data indicating that it is "lethal" or a "neorotoxin" or a "known human cancer causing agent."

So when the citizens of the Town of DISH Texas read a report located on their city's webpage titled "Evaluation of Town of DISH, Texas Ambient Air Monitoring Analysis written by someone who was "Vice-Chair of the EnvironmentalProtection Agency National Advisory Council for Environmental Policy and Technology (NACEPT)" they could not be faulted for coming to the conclusion that the development of the Barnett Shale gas industry in a residential area could lead to immediate or long-term health concerns due to the production of harmful excess air emissions.

Now it is not my intention to say the that there is, or is not, a health concern posed by this operation.  The TCEQ indicates that their monitoring "after several months of operation....reinforces [their] conclusion that there are no immediate health concerns from air quality in the area."  The sampling performed by Wolf Eagle Environmental indicates concentrations above the TCEQs established short-term and long-term ESLs

Assuming that the Wolf Eagle Environmental data used for the conclusion in the report is correct; does exposure exceeding by "2 times" the ESL for meta- or para-xylene put the citizens of the Town of DISH at risk for "neurological effects" or "kidney injury and renal carcinomas?"

In other words, if a chemical is known to cause a health effect, will exposure to it result in that negative health effect happening?  What if the exposure is twice the amount deemed to be a safe level?  This concern - valid in my opinion - becomes particularly disconcerting when you talk about exposure to a chemical that is described as a "known human carcinogen" since cancers do not show up until many years later.

It is at this point that a little bit of background information on toxicity and exposure is necessary.  For the general public at large - misinformed by those with an agenda or fed information that is misleading, incomplete, or out of context - potential exposure - not of one's own choosing - to a chemical is almost always perceived as one that will or has caused a health effect.

But it is much more complex than that, and both Ms. Subra and Dr. Rich (with an MPH no less!) should have understood this paradigm.  At SRPH, we are drilled over and over on what we were told was called the "EPA Risk Paradigm."  Unfortunately, the promoter of this paradigm - Dr. K.C. Donnelly - passed away two years ago from pancreatic cancer and was never able to tell us why he called it that.  The EPA Risk Paradigm used by the EPA has a much different format and context.  The EPA's does not have the elegance of the one Dr. Donnelly taught us.  The original author is not know, so in hopes that he/she will not mind, I will henceforth refer to this as the K.C. Donnelly Risk Paradigm:

In a nutshell, just because a chemical is there, or could be generated, does not mean it will result in an adverse health effect.  Not only does it need to be released into the environment, it has to travel to the receptor, the receptor has to be exposed to it, and the chemical then has to enter into the body.  Even then there is no automatic negative health effect guaranteed since the body does a really good job of ridding these nasty chemicals as well as fixing the problems - including damage to DNA that could result in cancer - even if uptake does occur.

For air contaminants, the first five are easily met.  So looking at toluene for example; it is present as a constituent of fuel and petroleum products, so the chemical is present.  It is released into the air through exhaust or leaks, it is transported in the air, and if a person is in that path, exposure can take place.  Once exposed, the receptor - through breathing - can uptake the chemical through the lungs and into the blood stream.  All that is left is to see if the chemical now in the system will produce a negative health effect.

So lets look at our dihydrogen oxide example discussed at the start of this blog.  It is a chemical - having a Chemical Abstract Services number (CAS) of  7732-18-5.  It is intentionally released by the parent when the faucet is turned on to fill up the bathtub.  It is transported through the water system pipes into the bath tub where the child is exposed to it when they are placed into the bathtub.  The dihydrogen oxide enters into the child through breathing of vapors - especially if the bath is hot.  It is also sometimes consumed orally by the child as well as absorbed through the skin and through cuts and abrasions on the surface of the skin.  So uptake does, in deed, take place.  So will this exposure and uptake result in an adverse health effect?

This depends on one important criteria for all chemical health effects:  the dose.

Now dihydrogen oxide has a median lethal dose (LD50) of  >90 ml per Kg of body weight.  What this means is that a five year old weighing 20 kilograms (Kg) would need to have an uptake (dose) of 20 x 90 = 1800 ml or 1.8 liters to have a 50/50 chance of the negative health effect of death.  1.8 liters is a little less than drinking a two liter bottle of coke all at one time.  Now if the child sits in a bathtub full of this chemical, the amount exposed to (80 liters) is over 44 times the amount needed to cause death!  How could you let this happen to little Billy?

Now if you have not figured it out by now, dihydrogen oxide is a fancy chemistry way of saying water.  And yes, water has a toxic effect, just like any other chemical out there.  Drinking too much water can cause death if the amount consumed is over the LD50 of 90 ml/Kg.  This toxic effect is called water intoxication.

So you can see in this example that it is possible to kill a five year old in a bath tub from something other than drowning.  In this case, like in the Town of DISH, exposure to a chemical has taken place.  But the dose needed to illicit a negative health effect - death - from the uptake of water is quite high, making death by water from other than drowning possible, but not probable.

In the case of a child exposed to water we know two things.  One, the safe amount of water that can be consumed (threshold) and two, the amount that will cause a negative health effect - death.  Water, is also one of those special chemicals that can cause a toxic effect if two little is consumed as well as too much.

In the Town of DISH, all we know - according to the findings by Wolf Eagle Environmental - is that there are chemicals present in the ambient air and that their concentrations are above TCEQs ESL which are "chemical-specific air concentrations set to protect human health and welfare."

What we need to figure out - and this is where the two reports failed (in my opinion) - is what type of health effects would be possible at the concentrations reported?

If you read the conclusion in both reports, emphasis on the fact that "high concentrations of carcinogenic and neurotoxin compounds in ambient air near and/or on residential property" was found, and "many of the compounds in the air exceeded the Short-term and Long-term Effects Screening Levels (ESLs) according to [TCEQ] regulations." is stressed over and over again  This appears to imply that the health effects possible (cancer, neurological) are plausible because of the concentrations exceeding the safe level (threshold) established by the TCEQ in the form of an ESL.

What's in play here is really no different than that of water.  the effects may be different as well as the threshold  needed to be exceeded, but the basics of exposure - dose - is exactly the same.

Next post: Air Quality in the Barnett Shale - Part 3:  TCEQs Effects Screening Levels.

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Air Quality in the Barnett Shale - Part 12: Oil & Gas, it's better if you go green!

Took some time off for the holiday which is why Part 12 has been late in coming.

OK, so in my last 11 posts I have concentrated on two main issues revolving exposure to chemicals:

1. It's all about the dose
2. It's all about the K.C. Donnelly Risk Paradigm

Yeah, I have also spent a good deal of Currier font lambasting the work of Alisa Rich, a fellow MPH who - through her company Wolf Eagle Environmental - produced data and reports for the Town of DISH, Texas that are misleading and flawed.

It would be easy to discount my analysis and explanation as being oil & gas friendly, but as I pointed out in my first post, i have no dog in this hunt other than to make sure the truth, the whole truth, and nothing but the truth is presented.  I'll cover this in my next post to hopefully shed more light on where I am coming from and what my bias is - or may be. 

The point here is that my last 11 posts should not be seen as "look!  There is no issue.  You people who are complaining should just shut the heck up and let the O&G industry do what ever they please." 

There are two things in play here that cannot be swept under the rug or discounted.

1. Oil and Gas production contributes to air pollution - they are a point source.
2. Those that live near Oil & Gas production wells are impacted.

The degree of that air pollution and the type of impact (health, odor, view, noise, dust) is what needs to be addressed in a thoughtful and reasonable manner.  This is where the battle lines are drawn.  Somewhere between a business' "Zero Cost" mentality and a "Zero Risk" desire of the public there can be found some middle ground - what I refer to as "Harmony".

Because there are emissions from Oil & Gas production - and - because these operations have impacted the surrounding community - primarily through noise and odor - the O&G Industry must be cognizant about their past mistakes and how their current operations and intentions are perceived.  It can no longer be business as usual.  A new model for drilling, operating, storing, and transporting must be adopted, and, in my opinion, they must change how they currently operate or the tide will continue to turn against them regardless of actual risk posed.

Dr. Al Armendariz with the Department of Environmental and Civil Engineering at Southern Methodist University in his report for the Environmental Defense Fund, titled "Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost-Effective Improvements" has calculated the following emissions from the various source categories related to O&G in the Barnett Shale area:

So what does this table show?  Well for one thing, the "Total Daily Emissions" is in "tons per day" or tpd.  It is really hard to imagine 174 tons of VOC being spewed into the air.  That's 348,000 pounds of Volatile Organic Constituents being released into the air per day.  That's a lot.

So the question becomes this:  If the O&G industry in the Barnett Shale will put into the air 12,702,000 pounds of VOC in a year - and - this amount of VOC, according to the TCEQ, "will [pose] no immediate health concerns from air quality in the area, and that when they are properly managed and maintained, oil and gas operations do not cause harmful excess air emissions," should the O&G industry continue to operate with no additional changes to its current methods?

Or....can they make reasonable changes to their standard operating methods to reduce the amount of pollutants they currently are putting into the air?

You can see the dilemma here can't you?  From a business point of view, why should I reduce something that is not causing any harm?  My answer to that is because you can and should - simply for the fact that every reduction in the amount of pollutants you put into the air improves air quality over all.  Plus, going "green" improves the bottom line in ways that are unrelated to the actual cost of the operation.  O&G needs to look at the big picture here, not just the monthly bottom line.

So what "reasonable" changes should be adopted - or - imposed?  Dr. Armendariz proposes the following which I think should be considered by the O&G industry:

1. The use of "green completions" to capture methane and VOC compounds during well completions
2. Phasing in of electric motors as an alternative to internal-combustion engines to drive gas compressors
3. The control of VOC emissions from condensate tanks with vapor recovery units
4. Replacement of high-bleed pneumatic valves and fittings on the pipeline networks with no-bleed alternatives

Texas A&M is also actively involved in a joint industry partnership with a number of public and private entities working on a program called "Environmentally Friendly Drilling (EFD) Systems" as a means of "integrating advanced technologies into systems that significantly reduce the impact of petroleum drilling and production in environmentally sensitive areas."  All of this is designed to make a positive change that is both cost effective and beneficial to the community and environment.

So what we need here is a new paradigm shift.  We can drill and produce oil & gas in an environmentally friendly manner.  As the folks at EFD concluded:

It 's not so hard to be green!

Next Post: Air Quality in the Barnett Shale - Part 13: Why bother writing about this?


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Air Quality in the Barnett Shale - Part 11: Is there a real concern for DISH, Texas?

So what do we know so far regarding the real health concerns for the citizens of the Town of DISH, Texas?:

• Benzene and other chemicals were found in the seven samples collected during one 24 hour sampling event conducted by Wolf Eagle Environmental.
• The TCEQ has sampled the air in the Town of DISH, Texas and reports hourly values below the short-termAir Monitoring Comparison Values (AMCV)  
• The TCEQ has sampled the air in the Town of DISH, Texas and reports hourly values below the short-termAir Monitoring Comparison Values (AMCV)  

Here is what I gathered from the TCEQ website for air monitoring at DISH, Texas:

Note: Report generated on Dec 16, 2010.  Monthly and Yearly data reported for BTEX.

As you can see, the amount of BTEX (Benzene, Toluene, Ethylbenzene, and Xylene) is under the AMCV for each chemical.  That's a good sign.  But lets make the assumption that the 24 hour results reported by Wolf Eagle Environmental are what the citizens of DISH, Texas are being exposed to on a regular basis.  Would there be a health concern?

That's a difficult one to make a call on.  In fact it is so uncertain that even Wolf Eagle Environmental and Wilma Subra in any of their reports do not make any claim what-so-ever as to these levels creating a undo health risk.  All that is said is that they exceed the ESL for some of the chemicals found.

The TCEQ, on the other hand, does state:

"24-hour air monitors in the Barnett Shale area are showing no levels of concern for any chemicals." and "there are no immediate health concerns from air quality in the area" and "that when they are properly managed and maintained, oil and gas operations do not cause harmful excess air emissions.”

Now I know better than to rest my case on one set of data.  However, I have at my disposal - and anyone clicking the links I cite does as well - a whole bunch of data or 'n'.  This gives me more confidence to agree with the statement TCEQ has issued above.

There is one more issue in play that leads me to conclude that the air is safe and that the folks in the Town of DISH, Texas are not going to experience " health concerns from air quality in the area."

Exposure is but one step of the K.C.Donnelly Risk Paradigm I discussed in Part 2.

What needs to happen after exposure to a chemical takes place is uptake.  That is, the chemical has to enter into the body where the dose, time, and pharmacokinetics now come into play.

The question becomes, OK, if they are exposed, how much are they actually getting into their system?  In order for a health effect to manifest, uptake must take place.  And if uptake has taken place, we can measure the actual concentration of the chemical in the blood stream or tissue.

And wouldn't you know it, that has been done.

Much of the concern about natural gas operations has been centered in DISH, so in early 2009, the Texas Department of State Health Services performed blood tests on 28 DISH residents (representing about 13 percent of the town’s population).

Test results showed that the exposure of DISH residents to VOCs was similar to that of the general U.S. population, and that exposure to certain contaminants was no higher than that of the general U.S. population.

The study further found that the only residents who had higher levels of benzene in their blood were smokers. Cigarette smoke contains benzene, so finding this in smokers’ blood is not unusual, the department noted. (1)

So now what do we know?

• We know that we have detected chemicals contaminants in the 24 hour samples collected by Wolf Eagle Environmental
• We can assume exposure has taken place.
• We can show - through blood tests - that exposed citizens have levels of contaminants no higher than those of the general US population.

So what can we conclude from all this?  That excluding odor, noise, and catastrophic events, the TCEQ is correct in asserting "that when they are properly managed and maintained, oil and gas operations do not cause harmful excess air emissions.”


Next Post: Air Quality in the Barnett Shale - Part 12: Oil & Gas, it's better if you go green!

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Breast Milk and PFASs - Part 1

This caught me a bit off guard on my Google News Feed:

Huh? soon gave way to no, no, no...please don't go there.  And that was without looking at the data to support that headline.

Having gone through a public health masters' program, you get indoctrinated into the concept of the of "the greater good."  You learn that there is a risk of a negative health outcome with almost everything you do, drink, eat, breath, or come in contact with.  You decide based on what gives you the best outcome overall.  And you decide based on compelling evidence to do, or to do not.

I am a chemical hazard guy.  A hazardous waste guy to be specific.  I like looking at chemicals and their risk.  I buy into the notion that there are positive health outcomes when you decrease the amount (dose) of the chemical.  I also accept that there is a dose you - including a baby - can be exposed to where there is minimal risk of a negative outcome.

I also accept, advocate, and believe to be true the "Donnelly Risk Paradigm" which you can read about here.  Basically, if there is exposure, there needs to be uptake and there needs to be a negative health impact.  Without exposure there is no uptake, without uptake there is no negative health impact.  The problem here is, that even if there is exposure and uptake there does not necessarily manifest a negative health outcome since the body is pretty good at detoxifying stuff that gets into it.

Limiting exposure is a good thing but exposure and uptake does not mean a bad thing will happen (see the liver).

With this in mind, let's look at the paper that got Google to tell the world about breast feeding giving your baby toxic chemicals.

Philippe Grandjean, the study author and environmental health expert at Harvard T.H. Chan School of Public Health stated that it was indeed an absurd situation breastfeeding women need to think of the kind of chemical exposures they could contribute to the child although breast milk is heralded as the best possible source of nutrition for the baby.

Wait...Harvard...no, no, no...Will this journal paper discourage a new mom from breastfeeding her baby?  Was that considered before they published it?  One news article goes on to quote one of the authors on this:

Grandjean and the other experts continue to emphasize that breast milk still is the best food for babies. But, it is just that it is less healthy and pure than was intended by nature and previously believed.

That's real helpful there professor.  What the public now sees is "Breastfeeding can expose babies to toxic chemicals."

Arggg.

Remember, the greater good!  Breastfeeding is for the greater good of the baby.  If you are going to tell new mothers that their breast milk is "less healthy and pure" then you should have anticipated it going full speed ahead to "breast milk may be tainted with toxic chemicals" once the press got a hold of it.  You and your cohorts on this paper should have understood this, so your research better show that breast milk is contaminated high enough so that continued feeding is more harmful to the baby then the benefits.

Before I go on, please note that I am all for this type of research.  It is important to understand exposure pathways.  If PFASs are causing harm, then this type of research is important.  But you need to chose your words carefully and keep this research on the down-low, because all the public sees is "Breastfeeding can expose babies to toxic chemicals."

And armed with that Google news feed title, can you blame a new mother for choosing not to breastfeed?

Next post: Part 2

The Village of DePue: Batter up! - Part 3

At some point a decision must be made.  When it involves a determination of risk, that line we draw in the sand, that line that says "safe," is not always easy to see and even less easy to understand.

I wasn't always this way in my thinking.  In fact, up until about 2008, I would have sided with the folks in DePue.  I would have sided with them because I had not made the jump from making a decision based on the perception of risk to one based on the understanding of risk.

It was not until I entered into the Master's program at Texas A&M's School of Rural Public Health's Environmental and Occupational Health program that the light bulb clicked on.  I have been dealing with hazardous waste and remediation of contaminated sites since 1984 and I did not understand the basic concept of risk for adverse health effects - which is the driver for cleanup levels and remediation plans.

Perhaps it was because in 1984 we were just learning about how chemical contamination effects a population and without a lot of data we assumed that the presence of chemical A equaled the health concern seen when exposure to chemical A took place.  For the bulk of my career, if chemical A was present the assumption was that there was risk.  So for the longest time the remediation method was to remove it.

No chemical A, no risk from chemical A.

But that ignores the basic concept of toxicology, the dose.  In other words, just because chemical A is present, if the dose is not high enough there will not be any adverse health effects.

For years my understanding was this: If chemical A can cause health effect B, then chemical A presents a health risk. In other words, my thinking had been skewed to automatically think that the mere presence of the chemical in the area automatically implies risk.

Enter the Donnelly Risk Paradigm (see this post):

    

I had been automatically programmed to think chemical = health effect, completely ignoring all the steps necessary to bring about that health effect.  Once I understood this, my focus shifted from perception of harm to trying to actually quantify harm.

So when I say" It does not matter if it is there, what matters is the dose (uptake)" hopefully you will see where I am coming from.  This is the same concept the EPA uses with the toxicity characteristics for hazardous waste.  We do not care how much of the toxic chemical is in the waste.  What we care about is what will come out (release).

That's what the RCRA TCLP is all about.  We assume a material is a hazardous waste if it will release a chemical above a threshold.  We assume that the mere ability to release the chemical presents a risk.  However, in reality, there are three more steps necessary to associate that release with a health effect; transport, exposure, and uptake.  And even if there is uptake, that uptake must be at a high enough dose (unit of chemical to unit of body weight) to manifest the health effect.

Same concept is in play in DePue.  We have a bunch of contaminated sites where a bunch of chemicals know to cause various health effects are present.  Here is the thinking of those behind the "Clean Up DePue" web page:

The slag and waste left behind continue to leach heavy metals and carcinogens into ground water that runs off into Lake DePue, which flows directly into the Illinois River. Contaminated debris blows onto public and private property throughout the village and surrounding natural areas, exposing residents -- more than a quarter of whom are children under the age of 16 -- and local wildlife to arsenic and heavy metals such as lead, mercury and cadmium.

The reason this has become a news story is that a plan has been adopted that these folks at "Clean Up DePue" find unacceptable:

“The companies spent millions of dollars on consultants in an attempt to show that this SuperFund site poses no significant risks, and they delivered a superficial plan that barely touches many of the contaminated areas, leaves the slag pile and other waste in place, does nothing to stop contamination from seeping into the groundwater, and leaves backyards, playgrounds and Lake DePue without real remediation.” 

All of this boils down to this:

“The consent order required the responsible parties to come up with the plan, supervised by the Illinois EPA. I don’t know how to respond to that plan. It’s not even close to what’s needed.” 

So I will ask:  What is needed?

Well according to Mr. Garcia, the science teacher at DePue High School, ExxonMobil and CBS is:

"jeopardizing the health and well-being of the children, families and wildlife in DePue,”

Okay, so now we have a baseline to start with.  At this present time, folks like Mr. Garcia, believe that the current conditions are "jeopardizing" public health.  Therefore, a remediation plan that does not remove the contaminant will continue to jeopardize the health and well-being of the children, families and wildlife in DePue.

So my question is, are the children, families and wildlife in DePue coming in contact with contaminants from the contaminated site that will jeopardize their health?

Enter the data...

In my last post I randomly chose one of the 1,976 samples that were taken that just so happen to also be at the baseball field where Mr. Garcia's science class took a soil sample.  With that data I can make a general statement about the risk for that particular area.

First, we must agree on a few things:

1. We are going to accept the samples as representative of the area as a whole.
2. We are going to accept that there is a level of contaminant - a threshold - that "can be tolerated by the organism with essentially no chance of expression of the toxic effect.” (EPA)

We are going to draw a line in the sand...

You must agree to those two concepts before we move on.  If you have a different concept, then let me know.

I am doing this in real time, so I do not know what the data is going to lead me to conclude.  What I do know is that what works for the baseball field is what will apply to all areas where the children, families and wildlife in DePue live, work, and play.

So lets look at the data we have...

Mr. Garcia's science class found:

Source

The "Contamination Map" on the "Clean Up DePue" web page shows two samples that were collected:

"The map shows the location for 1,976 samples taken by the companies over the past several years, exactly which contaminants were found in each sample, and the health risks of residents’ prolonged exposure to these contaminants."

Here is what is shown for location "6" on that map:

Expanding Sample GYP-MW-15LS we see:

Source

Wow...that's a lot of numbers.  Numbers = data.  Data = good.

Okay, that's what we have.  This makes sense to me, but is there anywhere on the "Clean Up DePue" website or the Chicago Tribune article where these numbers are explained?  Oh sure, it states "Contaminants above MCL for drinking water." but it does not explain how that concentration is  "jeopardizing the health and well-being of the children, families and wildlife in DePue,”

If you have read any of my previous posts you should know by now that I hate, HATE, hate it when a threshold is used without explanation or relevance to the situation in play.  I can make sense out of this data and relate it to risk.  But look at it from the standpoint of a non-scientist.  How would a normal person interpret "Contaminants above MCL for drinking water?"  What's that mean to them?  What's their thinking when they click on that little red question mark and read:

MCL: MCL stands for Maximum Contaminant Level and is the US Environmental Protection Agency's "level of a contaminant in drinking water below which there is no known or expected risk to health." EPA standards for human health risk in soil are relatively close to those set for drinking water.  On this website, secondary MCLs (those related to aesthetics such as water taste or smell) which are exceeded are marked in yellow, whereas primary MCLs (those related to health) which are exceeded are marked in red. 

As my wife would say "too many words" or as they say on the website Reddit "Too long, Didn't Read - TL;DR."  What they see, if they look at this data is "Contaminants above MCL for drinking water."  What do you think enters into their thinking when a value exceeds something called a "Maximum Contaminant Level?"

Are the folks who put this web page together being purposely disingenuous or are they just plain ignorant to what those values mean?  I am not using ignorant in a derogatory way here.  I just get a bit annoyed when statements such as  "Contaminants above MCL for drinking water" are used without context or proper explanation.  I do not expect the townsfolk of DePue to understand this, so when I read that they have assistance from Northwestern University's Environmental Advocacy Center, I expect someone at the University level to understand the context and present the information correctly.

And if no one at Northwestern University's Environmental Advocacy Center understands the difference between a health based MCL (Primary) and and Ascetic level (Secondary) then they need to quit advocating for the environment because they are misleading people in believing there is a problem when there most likely is none.

First, it is putting stress into the lives of the people who live in DePue.  Stress is a public health concern.  Second, it is taking money that could be spent actually helping the citizens of DePue and spending it on things that do not and will not benefit the the health and well-being of the children, families and wildlife in DePue,”

But I digress...

Back to the question of risk at the baseball field.  Do those mg/kg and mg/L numbers for all those chemicals mean that the health and well-being of the children, families and wildlife in DePue are being jeopardized?


Next post: The Village of DePue: I'll take information for $200, Alex - Part 4

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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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The Village of DePue: Wants and Needs - Part 16

I suspected all along that the main issue with the folks in DePue was based solely on one issue; nothing short of complete removal of the contamination will meet with their acceptance.

• What DePue wants is removal.

• What they need is exposure to these contaminants lowered to a level that we understand to be safe.

• What DePue wants is the pile gone.

• What DePue needs is future exposure to these contaminants at or below the concentrations we understand to be protective of their health.

• What DePue wants is to wake up in the morning with the knowledge that the pile is no longer there.

• What DePue needs is day-to-day existence without coming in contact with contaminants from that operation in concentrations that can cause harm.

Wants and needs.  Which should prevail?

Just so y'all know, I come from the industry of dig it up and remove it.  That's how I made my money.  I made piles like the one in DePue go away.  I spent a lot of other peoples money doing that and in the end, produced more risk to human health and the environment than had we left it in place.

Let's make sure we are clear on this.  There are many situations that warrant the removal of a material and placing it someone else's backyard.  It is a balance of risk that must - MUST - motivate that decision.  Not cost, not perception, not fear, not market, not nothing but looking at the risk.

I did not come to this leave-it-in-place acceptance easily.  It was not until I went back for my Master's that I was able to understand this.  It is all about risk.

As I have many times before, they drilled into our heads in the Environmental and Occupational Health program for the Masters in Public Health at Texas A&M's Health Science Center's School of Rural Public Health this thing I now call the K.C. Donnelly Risk Paradigm:

In one of my past posts I wrote (corrected a bit):

In a nutshell, just because a chemical is there, or could be generated, does not mean it will result in an adverse health effect.  Not only does it need to be released into the environment, it has to travel to the receptor, the receptor has to be exposed to it, and the chemical then has to enter into the body.  Even then there is no automatic negative health effect guaranteed since the body does a really good job of ridding these nasty chemicals as well as fixing the problems - including damage to DNA that could result in cancer - even if uptake does occur.

What I am advocating for is moving away from focusing on the chemical and instead looking at the uptake - or dose - that the receptor could reasonably be anticipated to get into their system.

When Gabby Garcia - the young lady in the picture...:



...hears her fellow townsfolk call the mound behind her a "pile of black death” and is told that the soil in White City Park contain heavy metals that Northwestern University says "in general leads to increased incidence of neurological issues and cancer" she becomes concerned and I get agitated.

My agitation is the result of a perception of risk based on the mere presence in the area of a chemical.

In my first post on DePue I ended with a few questions:

So what necessitated an article in the Chicago Tribune about the pace of hazardous waste cleanup?  Why does the paper claim that this pace "frustrates DePue residents?"  Why does Northwestern University's Environmental Advocacy Center think they can "help the town finally realize its goal of eliminating or containing the contamination."  And, for me, why is there "good reason for [DePue] to be worried about the type of cleanup [they are getting]?"

I'm a skeptical type by nature, so I don't believe what I read and hear until I look into it a bit more.  It was the press release that really got me looking, this one statement in particular:

Visit www.CleanUpDePue.org to see an interactive map that details the way-above-normal concentrations of pollutants at hundreds of contaminated sites.

That statement just did not ring true.  If you read any of my previous posts you'll see that I am critical of how agencies look at risk.  If anything they are too conservative.  The folks who make decisions for the public on the health and safety involving a contaminated property do so in a way that is preventative.  There was no way, as I saw it when I read that statement, that Illinois EPA would allow this to happen:

The slag and waste left behind continue to leach heavy metals and carcinogens into ground water that runs off into Lake DePue, which flows directly into the Illinois River. Contaminated debris blows onto public and private property throughout the village and surrounding natural areas, exposing residents -- more than a quarter of whom are children under the age of 16 -- and local wildlife to arsenic and heavy metals such as lead, mercury and cadmium.

I'm skeptical...so I looked.

After 15 posts on this topic and after looking at the data presented in the the CleanUpDePue.org web page, I have found a reasonable answer to my questions.

First. The folks in DePue are frustrated because the plan does not include removal of the slag pile.

Second: The slow pace is because the relationship between the three parties, Illinois EPA, PRPs, and DePue, has expanded to include elected officials and lawyers.  These two additions are even less likely to not understand what the exposure risk is in DePue necessitating more "studies" by the Illinois EPA to show the original plan they concur with is safe.

Third: Contaminated debris does not appear to blow onto public and private property - or if it does - the contaminants it carries are below health-based thresholds.  I base this on in part the samples Mr. Garcia collected and had analyzed.  These concentrations are not "disturbing" or" elevated."  They are below soil screening levels and Illinois EPA cleanup objectives (see Post 4). And the leaching?  According to the Illinois EPA:

The DePue Group constructed and began operation of the Interim Water Treatment Plant (IWTP). The IWTP can treat up to 100 gallons per minute of contaminated surface water and groundwater intercepted from the North Ditch, slag pile drains, and shallow interceptor trenches associated with the IRM walls. Treated effluent had been discharged to the South Ditch until June 1, 2000, when the treated effluent was rerouted to the Illinois River via the River Water Line.

Forth: The type of cleanup proposed for DePue, as detailed in the letter to the Illinois House and Senate, appears to be sound based on the level of contamination where the folks in DePue live, work, and play - OU-4.  The final plan for the other OUs, including the slag pile, appears to be protective of public health.

There was one more question I asked that I felt was relevant.  The press release states that the residents "more than a quarter of whom are children under the age of 16" are being exposed to "way-above-normal concentrations of pollutants at hundreds of contaminated sites."

I said "show me the data!" and the CleanUpDePue.org web page delivered.  You can read about what I found in OU-4, the area where people live, work, and play, starting with this Post.

Here is what I concluded about those "way-above-normal concentrations":

Because I know that the cleanup objectives and screening levels are very health protective, these average exceedances are nothing that would cause me a concern.  That's not to say I would recommend nothing being done about them.  I did go to the website.  I did look at the interactive map.  I did crunch the numbers from the Excel sheets they provided.  What I found does not come close to how I view "way-above-normal."

I also asked the question; what does "real remediation" mean?  According to their petition it means:

...full restoration of Lake DePue, removal of the slag pile and other hazardous substances from the plant operation’s site and the entire DePue community.

Removal of the waste presents an ethical problem of sorts since it takes it from one backyard and places it in someone else's.  I wrote about that in this Post.

The bottom line for me and for the Illinois EPA is finding an answer to this question; would the folks in DePue be exposed to less contamination if the pile were removed?  Based on what I have read about the site and contamination areas, removing the slag pile would provide no decrease in exposure.  Additionally, the measures in place and the proposed remedy make the risk of leaving the waste in place an acceptable and sound plan for protecting public health now and in the future.

I want to protect Gabby from actual exposure, not protect her from a pile behind a fence.  This is why you have heard me say "I don't care about what is in the pile, I only care about what comes out."

Because of all the things that Illinois EPA and the PRPs have done to date, that pile of black death is no more dangerous than a lion in the zoo.  If it does not come out of the cage it cannot hurt you.

The power to get some wants is in the hands of DePue.  All the PRPs have to do is meet the law and requirements set forth by Illinois EPA.  Right now they know they can wait this out while the politico's and agency come to a decision, and those guys won't move without more "studies" which become necessary because DePue finds the proposed plan unacceptable, which delays the cleanup of OU-4.

It sucks that a big pile of contamination will be left there.  Time to move on and makes sure Gabby is safe and protected from that pile now and many years into the future.  Get OU-4 cleaned up to soil screening or Illinois EPA cleanup objective levels.

Oh, and a new state-of-the art community center would make that bitter pill a little easier to swallow PRPs.  Throw in some exercise equipment and maybe fund a music and PE program for Gabby and her fellow students and public health just got better too.

Wants and needs...


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Dear Sierra Club, Please Stop. Comparable Fuels Rule Part 10

Golly jeepers!  This is my tenth post on this topic.  I swear I only though it would take me three.  Seems that to support my claim that the Sierra Club and friends are wrong in thinking that the Court's vacating of the Comparable Fuels Exclusion is not going to bring about any of the changes they claim:

The burden is on me to support why they are wrong, and, well its taken me this many posts to get there.  Unfortunately, this is not going to be the last one.  I have no idea where these blog posts will take me once I start.  As I write them, something always comes to the surface that requires research, and that endeavor brings about a new rabbit hole to chase down.

Bear with me, this may seem like an aside, but it plays into the determination of risk.  That determination was made by the EPA but not accepted by the Court.  Nor did the Court address risk.  The Court decided this case on a procedure but if you read between the lines, they, like the Sierra Club and friends, doubt that safety of public health and the environment was adequately addressed when 40 CFR 261.32 was finalized.

The Court eludes to the issue of risk not being addressed (though that is not why they used it) by citing a comment to the proposed 261,38 regulation by Molten Metal Technology Inc. who asserted:

Therefore, the Agency’s comparable fuels proposal will likely result in higher exemption concentrations than levels that would normally be derived using a risk-based approach. Such an approach would violate the clear Congressional mandate in Section 3004(q) of RCRA to regulate the burning of hazardous waste for energy recovery “as may be necessary to protect human health and the environment.” 

Ignoring the Court and what they were thinking, I want to address to Molten Metal Technology they think 261.38 will result in a higher concentration of hazardous constituents?  I want to also ask, if it does, is the public impacted at a greater risk then burning fossil fuels because of that?

I went looking for this question posed by Molten Metals and was lucky enough to find it on the EPA's website. It's in a document called "Response to Comments Document Hazardous Waste Combustors Revised Standards Final Rule Part I."  This quote is attributed to "CFAP.07.c(commenter 136)" which I am going to assume (as I cannot find a key to the numbers) is molten Metals.

Now I am a little embarrassed by not knowing who Micro Metals was.  You see, with a Google search I was able to find a Boston University School of Management Case Study on the company:

Just six years since its founding in 1989, Molten Metal Technology Inc. (MMT) was on the verge of huge successes. The company had successfully developed an exciting new technology called Catalytic Extraction Processing (CEP) which would not only break down hazardous and radioactive wastes into benign form but also recycle them back into marketable products. 

Now you might be thinking, so what?  But that's really kind of relevant here.  The Court, out of all the comments, chose the one stating that there will "likely result in higher exemption concentrations than levels that would normally be derived using a risk-based approach" generated by Micro Metals.  The Court then uses that question referencing the EPA's decision to use a "benchmark approach" while "rejecting a 'risk' approach."

The Court writes:

Nonetheless, EPA’s response to Molten Metal’s comment suggests that EPA understood Molten Metal to challenge EPA’s statutory authority to exclude comparable fuels in the first place and affirms its authority to do so.

As EPA’s response to Molten Metal’s comment demonstrates, that EPA had statutory authority under section 6924(q) to exempt some hazardous-waste-derived fuels from regulation was a “key assumption” underlying EPA’s exercise of its “discretion to classify such material as a fuel product, not as a waste,” and thereby “exclude” it from section 6924(q)’s ambit. 

Here is the question from Molten Metals in full:

Here is how the EPA responded:

Section 3004(q) applies to hazardous wastes which are burned for energy recovery. The provision does not speak to EPA’s authority to determine whether particular fuels produced from secondary materials are, or are not, products rather than wastes. It is rational for the Agency to determine, after rigorous examination, that secondary materials which have the same heating values and composition as normal commercial fuels, and the same types and levels of hazardous constituents, are no longer solid wastes.

Now if you think for one minute that the comments posed by Molten Metals was really over concern about the risk to public health and the environment, well you need to get yourself out of Colorado and breath some fresh air.  I can't really tell what's in the hearts of the guys who wrote the 30 different comments on every part of this rule and submitted them to the EPA.  I can point out this:

MMT was developing excitement around its experimental process for several years. While the process worked in laboratory tests, commercial implementation still lay ahead. The company had carefully orchestrated its commercial demonstration programs to learn from and share with a broad cross-section of industry and government. By the end of 1995, the groundwork was set and Molten Metal was proceeding with its plan to make the transition into full commercialization for addressing the range of issues confronting hazardous and radioactive waste cleanup efforts.

Check that date out.  When did the Comparable Fuels Exclusion, 261.38 get finalized?  1996.  Here is what else we learn:

Molten Metal entered the market during this time of increasing regulatory oversight, intense industry competition and heightened interest in environmental solutions. Armed with a technology it argued to be the most innovative of its class and able to go beyond the traditional paradigm of stabilization or simple destruction, MMT set off to capture waste management opportunities.

The company asserted that the worldwide generation of over 600 million tons of hazardous industrial waste would demand “pollution prevention and recycling solutions like CEP (Catalytic Extraction Processing).”  MMT promoted its CEP technology on its regulatory and environmental merits, claiming that it avoided the environmental pitfalls of incineration and landfilling waste, while also sheltering MMTand the end-users from regulatory oversight due to the recycling nature of the process.

You see the problem here?  MMT, which was :proceeding with its plan to make the transition into full commercialization," was about to lose a big ol' chunk of the easy pickings with this new Comparable Fuels Exclusion.  MMT was not going to burn this waste in place of fuel, it would treat the waste as a form of “pollution prevention and recycling solutions."

This created two problems for MMT.  One would be the loss of the Listed wastes streams that were going to incinerators, their "first and foremost" competitor, and the second would be their process, CEP, was not using the Listed waste as a fuel, so they could not take that waste in unless it was classified as a Listed Waste.  What generator would do that?

So what strategy works best when EPA wants to change a rule that will take away an ongoing revenue source?  Muddy the waters with concerns of woe.

Here is where it gets all soap-opera like.  Remember Syngas?

Well guess why that regulation is there?

[From EPA] It appears to the Agency, for example, that the Molten Metals operation, which planned to solicit and accept most types of identified and listed hazardous wastes, is easily cognizable as a hazardous waste treatment operation, notwithstanding the syngas generated as an output of the process.

[From CMA - a friend of MMT] In the final rule, EPA should merely clarify that uncontained syngas, or any other gas not confined to a container, is not subject to RCRA regulation. CMA supports EPA's confirming that syngas manufacturing projects are not subject to RCRA - some of CMA's members are participants in Molten Metals Technology's and other syngas projects. However, for EPA to finalize the exclusion as proposed would be to codify implicitly an unprecedented expansion of its RCRA jurisdiction. 

 [From CMA - a friend of MMT] The Agency notes that "Molten Metal Technology commented that the CEP is not in fact a combustion technology, and the Agency has attempted to reflect this in the definition" of combustion.

[R-P a competitor] R-P opposes the proposed exclusion for synthesis gas fuel (17465) which EPA has expressly included for the catalytic extraction process (CEP) unit developed by Molten Metals Technology (MMT). The CEP "thermal reaction" process proposed by MMT is essentially hazardous waste incineration in a starved air environment (i.e., a pyrolysis reaction).

ENSCO a competitor] ENSCO also opposes the proposed exclusion for synthesis gas fuel (17465). This proposal would allow any combustion unit, disguised as a "desorber" or other alternate technology label device, to partially burn hazardous waste, producing harmful off gases loaded with toxic PICS, dioxin, furan, and metals. EPA states that it is aware of one such process proposed to be operated by Molten Metals Technology (MMT). 

Judge Judy wrote her biography and titled it: Don't Pee on My Leg and Tell Me It's Raining.  If you read these comments you can see where Judge Judy is coming from after listening to all manner of reasoning and justification in her court.  Same here with the EPA:

ENSCO also applauds EPA for setting specifications for the full range of hazardous metal and organic constituents under Appendix VIII, and urges EPA to retain this in the final rule. 

Well of course you do ENSCO!

Okay, you get the picture.  What about risk?  How does the EPA address risk?  All this posturing and nonsense (noise) detracts from the real question.  Was the public protected by this regulation?

Next Post: Dear Sierra Club, Please Stop.  Comparable Fuels Rule Part 11

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Air Quality in the Barnett Shale - Part 7: Benzene Exposure and the No Significant Risk Level.

Carcinogens are a bit trickier to deal with in terms of determining a safe level.  This is because there is no concentration other than zero that one can say will present no chance of getting cancer from exposure to it.  Instead of a threshold dose, we look at a exposure level determined to present "no significant risk."

This level is defined as the level which is calculated to result in not more than one excess case of cancer in 100,000 individuals exposed over a 70-year lifetime. In other words, if you are exposed to the chemical in question at this level every day for 70 years, theoretically it will increase your chances of getting cancer by no more than 1 case in 100,000 individuals so exposed. (5)

What it does not mean is that one person per 100,000 individuals will get cancer.  This is the same concept behind rolling a six sided die.  You expect to see a "one" show up every six rolls, but you could roll it 50 times without ever rolling a one.

Basically, the ESL and AMCV are calculated the same way:

• (chronic)ESL = 0.00001 / URF
• (chronic)AMCV = 0.00001 / URF

The URF or "Unit Risk Factor" for carcinogens do not have a threshold dose at which below that concentration no cancer would take place. What this means is that any exposure has the chance to cause cancer and that the more exposures the more chances for cancer to manifest itself result.  This makes exposure to "Benzene, a know human cancer causing agent" a scary thing to read over and over again in a report (7).  This is where context and explanation are critical components to any report involving a complex formula, a number, and the words "know human cancer causing agent."  This is also where Alisa Rich, who - need I remind you again - has a Master in Public Health, failed to convey the risk properly.

Why did Alisa Rich and Wilma Subra fail to put this information in context?  Maybe it's because they lack a basic understanding of how the "no significant risk" is calculated and how to compare the 24 hour values with this risk.  It is quite possible that we receive a much better education in our MPH program at Texas A&M's School of Rural Public Health than one receives at the University of  North Texas, but I know that is not the case here.  So instead I will assume that both of  these experts just don't fully understand the topic they sell themselves as knowledgeable in.

Here is how TCEQ explains it in their 2006 document called "Guidelines to Develop Effects Screening Levels, Reference Values, and Unit Risk Factors" in 1.5.2:

For adverse effects associated with a linear dose-response [such as carcinogens], it is assumed that an effects threshold does not exist. Therefore, a linear extrapolation from the POD [point of departure] to the origin of the inhalation dose-response curve is performed to estimate excess lifetime risk at lower doses. The slope of the line from this linear extrapolation is the inhalation URF, which is defined as the upper-bound excess risk estimated to result from continuous lifetime exposure to an agent at a concentration of 1 μg/m3 in air (i.e., risk estimate per μg/m3). 

Confusing?  Lets look at this in terms of Benzene: (8)

• EPA uses mathematical models, based on human and animal studies, to estimate the probability of a person developing cancer from breathing air containing a specified concentration of a chemical. EPA calculated a range of 2.2 x 10-6 to 7.8 x 10-6 as the increase in the lifetime risk of an individual who is continuously exposed to 1 µg/m3 of benzene in the air over their lifetime.  
• EPA estimates that, if an individual were to continuously breathe air containing benzene at an average of 0.13 to 0.45 µg/m3 over his or her entire lifetime, that person would theoretically have no more than a one-in-a-million increased chance of developing cancer as a direct result of continuously breathing air containing this chemical.
• Similarly, EPA estimates that continuously breathing air containing 1.3 to 4.5 µg/m3 would result in not greater than a one-in-a-hundred thousand increased chance of developing cancer, and air containing 13 to 45 µg/m3 would result in not greater than a one-in-ten thousand increased chance of developing cancer.

So the Benzene values obtained from a single 24 hour sampling event performed by Wolf Eagle Environmental were

Now on first glance, one might think "I'm going to get cancer because of Samples 2, 3,and 4."  But that is not the case.  There are two things necessary for one to develop cancer from breathing this particular air.  The first is you would need to breath that air - at the concentration - for 70 years.  Secondly, your body would have to have develop a cancer from the uptake of that particular contaminant.  

It's a lot like flipping a coin.  If you have a 50% chance of the coin landing on tails - when you flip the coin - either heads or tails can come up.  So if I told you you had a 1 in 2 increased chance in developing cancer, you might not want to be exposed.  Now lets change that coin for a single die with six sides.  If you exceed that level over a lifetime, you roll the die and if the number "one" shows up you get cancer.  That would be a one in six increased lifetime chance.  Now lets change out that 6-sided die for one of those funky die they use when playing Dungeons and  Dragons, only in this case, it will have 100,000 sides to it with the numbers 1 to 100,000.  Now if you continuously breath air containing 1.3 to 4.5 µg/m3 of Benzene for a lifetime, you would roll this 100,000 sided die and if the number "1" came up you would get cancer.

For samples 2, 3, and 4, the benzene level is higher than the amount deemed no significant risk.  In this case, the risk - if one were to be exposed at that level in sample 4 constantly over a 70 year lifetime-  would be between:

• 247.9 x  0.0000022 = 0.0005   and    247.9 x 0.0000078 =  0.002

Or an added - or excess - lifetime risk between 1 in 500 and 1 in 2000.  At these elevated levels, the cancer risk has increased, but that is only if the exposure remains at 247.9 ug/m3 and the body fails to repair itself and develops a cancer.  Obviously the levels of benzene detected are too high and additional investigation should be done to determine the cause and fix the problem.  But even at these levels, cancer from benzene is not inevitable.

So looking at this in context, exposure to benzene has the potential to cause cancer but unless the levels are high and sustained over a lifetime, the risk of cancer is not significant.  You may be the unlucky person that rolls the "1".  This is where evaluating risk comes into play and the concept of accepted risk and risk that is forced upon you.  One may reasonably conclude that any risk is a risk too many.  But is eliminating the potential for a one in 100,000 possibility at something negative happening worth the benefits obtained from having it?  I can't make this decision for someone who is potentially impacted by the risk coming from those benefits.  What I can do is try and put it in perspective.   Because even if you eliminated every gas well and drilling rig from the area, exposure to Benzene will still take place and cancer - from lots of other sources - will still manifest itself.

There are a lot of factors in place for citizens in and around gas production activities.  The fact that we find chemicals in the air on one particular day does not mean that exposure at that level will take place the other 364.  And even if there is exposure at that level, we still do not know if the second to final step in the K. C. Donnelly Risk Paradigm - uptake - takes place.  And even if uptake does happen, the body is very good at dealing with contaminants through a process called pharmacokinetics.  And even if we end up with a negative health effect we have very good medical procedures to treat this.

And even if the die rolls a one, we are still unable to pinpoint the culprit, for we have no background data on what levels of these contaminants were present before the gas operation began.  All of this must be taken into consideration befor you say "yes" or "no" to assuming the risk.

Now lest you think I am giving the oil and gas industry a free ride here, I am not.  I will deal with their issues at the conclusion.  What I am writing about in these posts is how Wolf Eagle Environmental and Wilma Subra have painted a picture that does not represent fully and accurately the reality the citizens of the Town of DISH Texas are facing.  That is unfair to them, unfair to the Oil & Gas industry, and unfair and damaging to my profession which is dedicated to protecting the environmental and public health.

Next post: Air Quality in the Barnett Shale - Part 8: Benzene is like a bull...

Note: 2/16/11 A bio found on the internet lead me to incorrectly assume that Alisa Rich received her MPH and was working on her Ph.D from UT.  An email I received from Barnett Shale News included a Deposition from her stating she got her MPH from UNT's Health Science Center and is working on her Ph.D at UT Arlington.
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