Air Quality in the Barnett Shale - Part 19: Dr. Sattler's Deposition - Down with bad science!

Here is why I am critical of the work performed by Alisa Rich of Wolf Eagle Environmental and Dr. Sattler, of UTA.

From Fort Worth's NBC station:

"When you start actually looking at the levels of carbon disulfide, it's shocking," said Deborah Rogers, who has been involved in the league and monitoring natural gas drilling for the last several years. "People are going to be concerned."

Please read my post on TICs.  It is doubtful that carbon disulfide is present in the air.  Carbon disulfide is a TIC and is not positively identified nor is it quantified in the GC/MS test method used for the other contaminates.

The study makes the following recommendations for all Fort Worth ISD leases going forward:

1.Setbacks of approximately one mile from the school boundaries are needed to ensure that emissions of carbon disulfide (neurotoxin), benzene (carcinogen) and other drilling toxics do not exceed 8 hour limits for short term health benchmarks (See Dispersion Modeling Results).

Now whether setbacks are appropriate is not being questioned by me.  However, basing the one-mile setback on work performed by Rich and Sattler is.  Carbon disulfide is a TIC and its identity and quantification unverifiable.  Benzene concentrations from ambient air samples were backed in to the air dispersion model - generating an emission rate for that source.  Background benzene - that which is not from the source being modeled - was also included in this calculation generating a potential emission rate that would be higher than if the actual emission rate was known.  See my post on backed in data

Furthermore, Rich and Sattler compared these model contaminant levels to ESLs -which are for permitting and 70% lower than they need to be - and not to AMCVs - which are for ambient air.  See my post on ESLs & AMCVs.

Now I am in favor of a lot of the proposed requirements, such as green completions and substitution for toxic chemicals (depending on cost/benefit).  I think they are within reason, and if everyone is required to do them, that cost can be factored in as the cost of doing business.

So here is what really bothers me about bad science and those that should know better willingly feeding it as fact to the masses.

From the Star-Telegram Barnett Shale Blog

DISH Mayor Calvin Tillman, an outspoken critic of current drilling practices in the Barnett Shale, was the subject of a story in the Philadelphia Inquirer last week.  The story ends with a peek into Tillman's latest worry: 

Though Tillman's blood and urine came in below levels expected for the general population, he is still worried. "I'm not sure I'm going to be able to live here," he said earlier this week.

Tillman's water tested positive for traces of three contaminants, all below federal legal limits for public water: styrene was 3,700 times below the limit; ethylbenzene was 28,000 times below the limit, and xylenes were 47,393 times below the legal limit.

"The most disturbing is the toxins found in our water," Tillman said in an e-mail. "They should not be there at all. Not sure what to do about that."

Well I can tell you what you should not do about that.  Don't contact Alisa Rich, Wilma Subra, Dr. Sattler, or Wolf Eagle Environmental for advice.

You see, even when there is nothing there some people still worry.  So giving others this worry by telling them something is there does nothing more than bring in consulting dollars while causing more worry.

And from a public health point of view, worry causes stress, stress causes disease.  The worry over nothing is more likely to harm you than the air or water you are exposed to at your home.

Here's to good science in the future.


Next Post: Air Quality in the Barnett Shale - Part 20: Dr. Sattler's Deposition - The Gaussian Model

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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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