Seven Deadly Sins: I'm not seeing it.

It starts like this...

Source

Which leads to this...

Source

Which leads folks to conclude that there must be something wrong since a warning has been issued.

"How in god’s name can the oil industry dump sh*t in our drinking water and not tell us what it is?" shouted Alan Hofer, who lives near the center of the sites being investigated by the EPA. (1)

Which causes this to happen...

Source

1000 cases of contamination have been documented in Colorado alone?  In the week that I started writing on this topic, I have found two cases, one in the Barnett Shale (see post) and one in Pavillion, Wyoming, for which sampling data is available, and that was with a bit of effort to locate.

So it starts with a complaint, an investigation, and then a recommendation.  In the process it leads to this:

"It starts to finger-point stronger and stronger to the source being somehow related to the gas development, including, but not necessarily conclusively, hydraulic fracturing itself," said Nathan Wiser, an EPA scientist and hydraulic fracturing expert who oversees enforcement for the underground injection control program under the Safe Drinking Water Act in the Rocky Mountain region. The investigation "could certainly have a focusing effect on a lot of folks in the Pavillion area as a nexus between hydraulic fracturing and water contamination." (2)

On the surface, it would appear that contamination found in the well water used for drinking by the good folks in Pavillion, Wyoming, is proof that the oil and gas drilling and fracturing has caused harm.  But I have been in this business for a long time to know that contaminated groundwater comes from a number of sources, all of which are present in the town of Pavillion.

• Underground fuel tanks
• Septic tanks
• Spills
• Open pits
• Natural

When investigating contamination a "Conceptual Site Model" is produced to look at all the possible sources.

Source

"Pointing fingers" is what we try to avoid.  It is easy to blame oil & gas wells since there are so many of them in the area (211 active gas wells, 30 plugged and abandoned wells, and 20 wells identified as “shut-in.” [2])

Again, though, on the surface it looks pretty evident as to who the culprit is, which is why anti-gas drilling folks like to use reports such as this and this, as evidence to prove how bad hydraulic fracturing is to public health and the environment.

I have read all of the reports issued by the EPA on their findings regarding groundwater contamination in Pavillion, Wyoming. I've tried to be as objective as I could in all of this but I am just not seeing the problem with hydraulic fracturing that is being put forward by groups like Earthworks and ProPublica.

Here is why.

First:  Without knowing the condition of the water before fracing has occurred it is impossible to say what contaminants were introduced by the procedure.

Second: With over 211 active wells in the Pavillion area, if hydraulic fracturing was introducing chemicals into the groundwater you would see a whole bunch of chemicals in the groundwater.  Look at this map of the wells in Pavillion.

Those blue dots are oil and gas wells.  The yellow/orange dots are where the wells where samples were collected.  If hydraulic fracturing was by its nature dangerous to groundwater you would see contamination of fracturing fluids in the groundwater.

This is not to say that drilling could - or does not - contribute to contamination.  Any activity involving chemicals has that potential.  Just like any airplane has the potential to crash, airplanes by their nature fly and continue to fly day in and day out.  Would we condemn all air travel as unsafe because a plane crashes?  Same can be said with hydraulic fracturing.  The hydraulic fracturing procedure, when performed correctly ("best practices"), does not pose a threat to public health through contamination of groundwater.

That's kind of a bold statement to make.  But like the title of this post says, I'm not seeing it.

But what about the contamination found in the wells of Pavillion?  There are a number of reasons possible, with the most likely being oil and gas operations in the area.  Huh?  Let me be clear on this.  Hydraulic fracturing by itself does not appear to cause or contribute to groundwater contamination.  Drilling operations using industry best practices appear to be keeping contaminants out of ground and surface water.  Operators who use industry best practices are not the concern.  It's the companies who left the "37 pits (which formerly held drilling fluids) [that] have been identified in the area" who are most likely responsible for contaminating the shallow surface water that mixes with the drinking water source.  Those, along with septic tanks and storm water runoff, have contaminated the drinking water aquifer - not hydraulic fracturing fluids.

The current operator, Encana, is now responsible for these pits.  Older properties, especially those with environmental concerns are referred to as "legacy properties" and are cleaned up and closed to meet state, federal, and industry standards.

So yes, there is contamination in the drinking water wells, but not to any significant health concern other than taste and odor.  And no, in spite of what ProPublica contends, will not "have a focusing effect on a lot of folks in the Pavillion area as a nexus between hydraulic fracturing and water contamination (3)."  Go up and read the ATSDR recommendations.

In spite of the anecdotal evidence presented by Earthworks and ProPublica, I'm not seeing it.  I'm being as objective here as I can.  Here, in a nutshell, is why:

If hydraulic fracturing was causing contamination to drinking water at any significant frequency, then the more wells drilled would mean the more drinking water wells contaminated and/or the higher the concentration of chemicals.  The fact that:

TIC analyses indicate two compound types that occur in several wells and might not be attributable to well components: adamantanes and 2-butoxyethanol phosphate. Adamantanes are hydrocarbons that occur naturally in crude and gas condensate; they could be used in hydrocarbon fingerprinting analyses to determine if oil and gas production is impacting wells.  2-butoxyethanol is found on the EPA Study List of Drilling Fluid Compounds (EPA 2008) and could react with naturally occurring phosphates to create 2-butoxyethanol phosphate.  (4)  

Would also mean that it, and other fracturing fluids would show up in water wells where drilling takes place. In simple terms, the level of contaminants and/or number of contaminated drinking water wells would be proportional to the number of hydraulic fracturing that has taken place in an area if drilling was inherently harmful to underground sources of drinking water.

I'm not seeing it.

Here is what ProPublica states: (5)

Thanks in large part to hydraulic fracturing, natural gas drilling has vastly expanded across the United States. In 2007, there were 449,000 gas wells in 32 states, thirty percent more than in 2000.

Almost half a million gas wells and yet ProPublica reports:

The [Pavillion] study, which is being conducted under the Environmental Protection Agency’s Superfund program, is the first time the EPA has undertaken its own water analysis in response to complaints of contamination in drilling areas, and it could be pivotal in the national debate over the role of natural gas in America’s energy policy.

Almost half a million gas wells and only one study. Now go back up to the top of this post and read the ATSDR recommendations.  Now go read the ATSDR report.  Why are they recommending not drinking the water?  Because of the contaminants of concern found in the 41 Pavillion drinking water wells sampled.  And what were those CoCs?

Source

 
That's right, the COCs are sodium, fluoride, sulfate, magnesium, selenium, nitrate, and one well with TPH.

I'm not seeing it because there is nothing to see.

But ProPublica says:

Of particular concern were compounds called adamantanes, a natural hydrocarbon found in gas that can be used to fingerprint its origin, and 2-BE, listed as a common fracturing fluid in the EPA’s 2004 research report on hydraulic fracturing. (6)

I'll cover that in a future post, right now I'm going to switch gears and talk about a recent paper that was presented at the 2011 AHMP Conference in Austin.



Next post: Laundered Shop Towels: Making a mountain out of a pile of clean rags.




http://www.epa.gov/region8/superfund/wy/pavillion/

http://www.epa.gov/region8/superfund/wy/pavillion/PavillionAllTables.pdf


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Dogs and Phosphoric Acid...one more time.

In the words of Peter Griffin "You know what really grinds my gears?"  How we describe the hazards of a chemical when it is found to be present in the environment.

All chemicals pose a hazard at a particular dose.  If it is under that dose, then the hazard seen at a higher dose does not apply.

Yes, it is that simple.

In two previous posts I tried to explain this concept using dogs and phosphoric acid found in a can of Coke.  To summarize:

If you are describing a dog that you will come in contact with that looks like this:




Don't make it sound like it looks like this:

Which brings me to the EPA's "Imminent and Substantial Endangerment Order to Protect Drinking Water in Southern Parker County." (1)  In the Order, the EPA states:

The EPA says that contaminants are present in the aquifer.  The term "contaminant" means:

[A]ny physical, chemical, biological, or radiological substance or matter in water. (2)

What the EPA is claiming is that they found "substances" in the water.  That definition does not require that the concentration - dose - be at any particular level, only that "any" amount was found to be present. "Any" means any.

The EPA goes on to say in the order:

These substances, according to the EPA, are in an "any" amount that may present an "imminent and substantial endangerment to the health of persons."

Notice what it says about the ingestion of benzene - one of the contaminants found:

[B]enzene if ingested or inhaled could cause cancer, anemia, neurological impairment and other adverse health impacts."

In other words, the EPA is telling us is that if you walk into this kennel (drink water from this aquifer) you will run into this dog:

What type of dog did the EPA actually find:

And:

Benzene - a "contaminant" - was found to be present in the water at the following concentrations:

3.1 ppb or 0.0031 ppm
6.12 ppb or 0.00612 ppm
4.55 ppb or 0.00455 ppm

The average benzene concentration is:

4.59 ppb or 0.00459 ppm

I wonder if the EPA has anything to say about how much of a "contaminant" can be found in drinking water before it is considered unsafe?  You know, like is there a maximum amount of certain chemicals that determine if the water is safe to drink?  Like maybe something called a "maximum contaminant level" or "MCL?"

Well by golly, there is!  Here is what the EPA has established under the SDWA:

Maximum Contaminant Level (MCL) - The highest level of a contaminant that is allowed in drinking water. MCLs are set as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration. MCLs are enforceable standards.

Maximum Contaminant Level Goal (MCLG) - The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals. (3)

So an MCL is the "highest level" of a contaminant allowed in drinking water below which "there is no known or expected risk to health."

In other words, if the concentration of the contaminant found in the drinking water is below the MCL or MCLG, there would be "no known or expected risk to health" according to the EPA.

I wonder if the EPA has established an MCL for benzene?  By golly, they have!

http://water.epa.gov/drink/contaminants/index.cfm

The MCL for benzene is 0.005 ppm.  What was the benzene concentration in the three samples:

3.1 ppb or 0.0031 ppm
6.12 ppb or 0.00612 ppm
4.55 ppb or 0.00455 ppm

The average benzene concentration is:

4.59 ppb or 0.00459 ppm

Only one of the three samples had a concentration above the MCL of 0.005 ppm with the average benzene concentration below it.  Based on this, the EPA should have said that there is no known or expected risk to health associated with the benzene.  Instead the EPA states:

There is no MCL for hexane, propane, or ethane.  The MCL for toluene is 1 ppm.  All three samples were well below this.

This is the same thing as telling a Coke drinker about the phosphoric acid in their drink:

Phosphoric acid is corrosive.  Ingestion may produce burns to the lips, oral cavity, upper airway, esophagus and  possibly the digestive tract. Circulatory collapse. Unconsciousness, possibly death. (post)

Did the water pose an "Imminent and Substantial Endangerment" to public health?  Possibly.  Maybe because of the flammability of the methane, propane, and ethane found.  Flammability - based on flash point, flammable range, or percent LEL - was not determined by the EPA.

Is it possible that enough gas could form in the well?  I'm not sure about that.  The flammable range of methane is 5-15% in the air. (3).  Sampling of the air for LEL within the well would be required to make a flammability determination at the concentrations found.  The fact that the pumps locked up and effervescence was noticed makes further review necessary.

Flammability is the only potential "Imminent and Substantial Endangerment" situation that may be present.  The presence of "any" contaminants found fall below EPA's MCLs and should not have been mentioned as their level in the water presents "no known or expected risk to health."

Rule number 1:  If the contaminants fall below the MCL do not identify them as a possible health concern, or as a health concern greater than what the dose would manifest. (Dogs)

Rule number 2: Do not describe health hazards associated with a chemical at a dose that is higher than what is actually found. (phosphoric acid)


Now, where was I?  Oh yeah, the Seven Deadly Sins...

Next Post: Seven Deadly Sins: I'm not seeing it.


..

Seven Deadly Sins: 22 years ago there was a problem.

Under the seven deadly sin of "The Safe Drinking Water Act" Earthwork's Renee Lewis Kosnik writes:

Unfortunately, the EPA’s findings are not consistent with the numerous personal accounts of those living in oil and gas patches around the country.  Peggy Hocutt and her husband retired to their house on the river in Jefferson County, Alabama. After years of mysterious ailments affecting everyone in the area and tap water that smelled of petroleum, Mrs. Hocutt had black, jellied grease coming out of her faucets. She and many of her neighbors also had cancer. The energy company hydraulically fracturing in that area and the state of Alabama refused to admit that their aquifer had been contaminated by fracking activities. Instead, the company refused to renew their land lease and evicted them from the property. They lost their physical and mental well being, as well as a forty-year investment in their retirement home.

What is interesting to me is that the paragraph before this states:

The EPA released its final version of the Phase I study in 2004 entitled, Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs. The main finding of this study stated, “the injection of hydraulic fracturing into CBM wells poses little or no threat to Underground Sources of Drinking Water.

In other words, we hear what you are saying EPA, but we don't believe you.  I mean look what happened to Mrs. Hocutt!  Explain that EPA!

You can read about Mrs. Hocutt's situation here.  Excluding a direct link to her cancer, assuming that everything she reports is true, lets look at why this is a poor example to justify why:

Hydraulic fracturing must be regulated by the Environmental Protection Agency under the Safe Drinking Water Act in order to adequately protect the United State’s drinking water supply from the harmful chemicals used during this process.

Twenty-three years ago  The Alabama State Oil & Gas Board, Tuscaloosa, Alabama, issued Permit #5946-C., to USX-Amoco Oil Production, in September, 1988.  According to Mrs. Hocutt:

When the gas well was operable, the run-off was piped directly from the site to a point and then left to run uncontrolled down a hillside gully, through a culvert, and down a ravine where it then emptied into the slough behind our boathouse.  The run-off was the color of Coca Cola, foamy, with oily streaks in it, and smelled like oil and rotten eggs.  It killed all plant life and water creatures in its path.  I never again saw another salamander, bull frog, or lily pad around our boathouse. I didn't know anything about methane gas wells at that time, but I realized if the run-off killed plant life and water creatures, it certainly posed a potential danger to the health of humans.

OK, stop right there.  Again, assuming this is true, this is a violation of the Clean Water Act.  Period.  No industry, including Oil & Gas, may discharge into waters of the United States without a permit:

As authorized by the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Point sources are discrete conveyances such as pipes or man-made ditches. [I]ndustrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. Since its introduction in 1972, the NPDES permit program is responsible for significant improvements to our Nation's water quality. (1)

[A]n NPDES permit issued for the drilling activity would need to be consistent with 40 CFR Part 435, Subpart C, which states that ‘there shall be no discharge of wastewater pollutants into navigable waters from any source associated with production, field exploration, drilling, well completion, or well treatment (i.e., produced water, drilling muds, drill cuttings, and produced sand). (2)

That requirement has been on the books since 1972.  No additional regulation under the SDWA would have changed the situation for Mrs. Hocutt.

Assuming that what Mrs. Hocutt said is true, the issue was in violation of the CWA and is not a SDWA issue.  The situation described is alleged contamination of surface water that led to the alleged contamination of drinking water from her well.

The SDWA does not regulate private groundwater wells.  It regulates public water systems as well as underground injection wells.  This is where the issue with oil & gas comes to a head with folks like Earthworks:

‘Underground injection’ is defined as the “subsurface emplacement of fluids by well injection.” In 2005, legislative amendments made clear that the SDWA does not regulate hydraulic fracturing operations. The Energy Policy Act of 2005 amended the SDWA to exclude from the definition of underground injection “the underground injection of fluids or propping agents (other than diesel fuels) pursuant to hydraulic fracturing operations relating to oil, gas, or geothermal activities.” Many sources critical of the exception refer to it as the “Halliburton Loophole.” Thus, with the exception of fracing using diesel fluids, the SDWA does not impose direct regulation. (3)

The situation that happened to Mrs. Halcutt 22 years ago is not an appropriate example to use for explaining why hydraulic fracturing should fall under the Underground Injection Control (UIC) program.  Surface water discharge contamination of underground drinking water supplies are covered under the Clean Water Act.

A more appropriate example would be this:

EPA Letter

In this case, the EPA contends that the extraction process has released methane into the drinking water wells:

As a result of investgatory work performed, the [EPA] has determined that an imminent and substantial endangerment to a public drinking wateraquifer has occured (or may occur) through methane contamination which is directly related to oil and gas production facilities under your operation.

This is a proper example to use when making a claim that compliance under the SDWA's UIC program may be necessary.  Not a surface water release that happened 22 years ago.

With this example, the question now can be posed as such:

Would the UIC program have required anything more substantive in terms of drilling, cementing, and casing than is already required of oil & gas by the Texas RRC? (see post).  Secondly, does this one case of methane entering into the drinking water indicate a problem inherent in all hydraulic fracturing wells?

But first, I need to get something off my chest...

Next Post: Dogs and Phosphoric Acid...one more time.

Seven Deadly Sins: Oil & Gas gets away with nothing.

Out of town...again.  Starbucks and the local newspaper...

A spokeswoman for the Environmental Working Group, a coalition of community and environmental organizations, said the panel’s draft recommendations were “disappointing.”

“They do state some obvious grievances with fracking — such as the general need for more regulation, air pollution controls and more disclosure from companies,” said Leeann Brown in an e-mail. “However, they refuse to reference the seven deadly sins of the fracking industry — the exemptions from seven major environmental and health protection laws.” (Can't find the link, but this was basically what was printed)

Seven deadly sins of the fracing industry?  Well that got my curiosity up, so with a little bit of research I found them, here.  The basic contention is that the Oil & Gas industry "enjoys sweeping exemptions from provisions in the major federal environmental statutes intended to protect human health and the environment.

1. Comprehensive Environmental Response, Compensation, and Liability Act
2. Resource Conservation and Recovery Act
3. Safe Drinking Water Act
4. Clean Water Act
5. Clean Air Act
6. National Environmental Policy Act
7. Toxic Release Inventory under the Emergency Planning and Community Right-to-Know Act

There they are, the seven deadly sins.  You can read the paper to find out why the author,  Renee Lewis Kosnik, MSEL, JD, Research Director, Oil and Gas Accountability Project (a project of Earthworks, 2007), believes these exemptions are should be done away with.  

What I want to do is to try and show how an exemption or exclusion does not mean the varmint is gettin' away with somthin'.  I call this blog the "Wacky World of Waste" for a reason, and that reason is because of how absurd regulations can be, especially how the Resource Conservation and Recovery Act (RCRA) identifies what is a hazardous waste.  If you ever attend my Hazardous Waste Management course, you will hear me say two things (spoiler alert!)

1. Check you logic at the door.
2. It's about the definition, not the hazard.

The reason I am writing about these "seven deadly sins" is because I was made aware of them on August 11, 2010 just like many other folks who read the same syndicated article that appeared in many other newspapers.  Quoting Earthworks' Leeann Brown's contention that the oil and gas industry "refuses to reference" these exemptions implies that there is something sinister going on.

If you take Earthworks word for it, there is.  But is there?

First of all, lets get one thing straight.  There are a lot of reasons for providing an industry or activity an exemption.  Sometimes they are purely political, but most of the time there are sound reasons for doing so. The bottom line question that must always be asked is does the exemption contribute to the problem or is it benign?

In the case of Oil & Gas, Earthworks contention is that these seven exemptions are allowing this industry "to streamline their piracy and contamination of the American public."  In other words, if we were to do away with these exemptions and exclusions, oil and gas would no longer be legally allowed to "contaminate" our land, air, and water.  This statement by Earthworks implies that the Oil & Gas industry is at this very moment unfettered by any laws and regulations regarding environmental contamination and pollution.

That is untrue.

Let's look at Texas.  Texas, as you might expect is very - and I mean VERY - Oil & Gas Friendly.  So Friendly in fact that they allow Oil & Gas to be regulated not by the State's EPA, the TCEQ, but by an industry loving Rail Road Commission (RRC). Surely under this cozy relationship Oil & Gas would be allowed to do what ever it pleases in pursuit of good ol' Texas T.

So let's look at how Texas Regulates Oil & Gas under the RRC: (Source)

In Texas, fracing is not formally regulated. The only regulations that apply to fracing operations also apply to all other oil and gas operations. The RRC promulgates and enforces regulations related to oil and gas matters and has jurisdiction over all “oil and gas wells in Texas; persons owning or operating pipelines in Texas; and persons owning or engaging in drilling or operating oil or gas wells in Texas.

Like all oil and gas development in Texas, fracing operations require the RRC to issue a permit authorizing drilling and/or deepening of a well.

Besides the standard permitting, two key areas where the RRC’s regulations have an impact on fracing operations (other than standard permitting):

• 16 TAC § 3.8 “Water Protection”

• 16 TAC §3.13 “Casing, Cementing, Drilling, and Completion Requirements.” 

In addition to permitting regulation, §3.8 also regulates the storage, transfer and disposal of oil and gas wastes. Presumptively, this includes any fracing fluids that are brought back to the surface as part of oil and gas production.

Earthworks contends that the "seven deadly sins" allow Oil & Gas to "contaminate the American public" by allowing "toxic chemicals and hazardous wastes [to permeate] the soil, water sources and the air threatening human health to an alarming extent." (1)

Well here is what 16 TAC § 3.8 “Water Protection” has to say about that:

(b) No pollution. No person conducting activities subject to regulation by the commission may cause or allow pollution of surface or subsurface water in the state.

That, by the way, is the first regulation you come to after "(a) definitions."  Now let's look at how Texas defines "pollution:"

(a)(28) Pollution of surface or subsurface water--The alteration of the physical, thermal, chemical, or biological quality of, or the contamination of, any surface or subsurface water in the state that renders the water harmful, detrimental, or injurious to humans, animal life, vegetation, or property, or to public health, safety, or welfare, or impairs the usefulness or the public enjoyment of the water for any lawful or reasonable purpose.

In Texas, Oil & Gas is regulated quite significantly by the RRC (2).  If Texan's don't allow the Oil & Gas industry to pollute under their industry friendly regulations, isn't it quite possible that federal regulations prohibit the same thing?

Basically it comes down to this: If the Oil & Gas industry is prohibited from causing or allowing "pollution of surface or subsurface water in the state" would removing those seven exemptions and exclusions change anything?  

The need for additional permitting or regulation will not stop something that is not there in the first place.  If, as Earthworks contends, Oil & Gas is allowing "toxic chemicals and hazardous wastes [to permeate] the soil, water sources and the air threatening human health to an alarming extent," why is this being allowed to happen under current law?

It is not happening.

And if any company sets out to operate in a way that does threaten public health or the environment, no amount of permitting, rules, regulations, or laws will stop them.  So for these bad apples, inspection and enforcement is the only option - unless you propose throwing the baby out with the bathwater.  

In her report, Earthwork's Renee Lewis Kosnik writes: "it is time regulators focus on the adequacy of existing regulations to protect human health and the environment from the real and potential dangers of the oil and gas industry’s waste."  Well they have:

"The [RRC] commission's strict rules in effect now on how wells are constructed have protected and continue to protect groundwater.  The decades-long safety record on fracking in Texas backs this up." (3)

But what about Jefferson County, Alabama's Peg Hocutt "mysterious ailments affecting everyone in the area and tap water that smelled of petroleum?"

Yeah...about that...

Next post: Seven Deadly Sins: 22 years ago there was a problem.

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Swimming and eating stuff from the water downstream.

From "This American Life," a show I listen to and like...

The second, Conrad "Dan" Volz, at the University of Pittsburgh, estimated how much toxic crap—chemicals and pollution from gas exploration—might be getting into water supplies. (1)

In my last post, I made the comment that you can't get to the conclusion Dr. Volz presents in his report from his comparison to EPA/ATSDR limits that have been established so that “daily human exposure to a hazardous substance that is not likely to pose an appreciable risk of adverse noncancerous health effects” when the assumption of a "lifetime exposure" will not be met.  In other words, if that water is not going to be consumed at the point where sampling took place, there is also no assumption that someone at 70kg could drink it daily for a 70 year lifetime (MCL).

Comparing the barium concentration in the effluent with an MCL was wrong, and the comment "this is approximately 14 times the [MCL] of Ba in drinking water" is therefore misleading.  But what about Dr. Volz's contention that:

Recreationalists are at high risk of being exposed to outfall contaminants through ingestion, inhalation and through dermal exposure.  [C]hildren wade and swim in the creek during warmer weather... Anglers catching and eating fish from upstream or downstream of the effluent outfall are at risk for exposure to multiple contaminants that were sampled in this study.

What does the term "high risk" convey?  Is it at the level of death?  Should it illicit an OMG! if one comes in contact with the water?  "High risk" of what, exposure?  Dr. Volz reports that I will have a high risk of coming into contact with barium, bromides, strontium, benzene, TSS, and pH if I ingest, inhale or contact the Blacklick Creek Water?  Will that exposure lead to a health effect?  Are we talking about a high risk of exposure to a puppy or a Doberman? (that will make more sense if you read this post).

If we are not going to drink the effluent, will exposure to these chemicals at the concentration found at the point of discharge cause "an appreciable risk of adverse noncancerous health effects?”  Fair question.  What are the concentrations of these chemicals in the water where the children wade and swim?  What are the levels of these contaminants in the fish caught and consumed?  There isn't any of that data presented in Dr. Volz's report.

What the report does is imply that if a chemical - such as barium - is discharged into the creek, it will present an exposure risk to someone who comes in contact with the water downstream "of the effluent outfall ."  In other words, high risk of exposure must translate to "an appreciable risk of adverse noncancerous health effects."

That's not how environmental public health professionals look at a chemical exposure manifesting into a health risk.  You can't get there from here.  You can speculate, imply, assume, insinuate, and wish it to be true, but that's not what an environmental public heath professional is supposed to do.

So once more, with feeling...

To estimate risk we need to know the amount of chemical entering into the receptor (uptake), the length of time the exposure has taken place, the toxicokentics, and compare them to a concentration assumed to present no appreciable risk of adverse noncancerous health effects.

When we know the amount of uptake (how much of the chemical got into the system) from the exposure, we can compare it to a number, such as the MRL.  Keeping with the barium concentration in the effluent reported, Dr. Volz states:

The ATSDR minimum risk levels (MRL) for intermediate and chronic human exposure is .2 mg/L/day; the barium in PBT- Josephine effluent water is approximately 135 times the MRL’s for both intermediate and chronic human exposure.

Lets look at what ASTDR says about barium in it's ToxGuide for Barium:

Notice what Dr. Volz - a DrPH, MPH and (former) Director of the U of Pitt GSPH's Environmental Health Risk Assessment Certificate Program failed to take into account?  That MRL value of 0.2 mg is not per liter, but per kilogram body weight of the receptor.

A 30 kg child would need to consume 0.2 * 30 = 6 mg of barium for 15 - 364 days to potentially have a negative health impact.  To put this in perspective....

If the effluent (discharge end of pipe) contains a maximum of 37 ppm, little Suzy or Billy would have to stand near that pipe and consume about 250 ml of the creek water.  That's the amount of water in the container little Suzy is holding.

Oh, and she would have to do drink that amount for 15 - 364 days.  And even if she did, the ASTDR states:

Exposure to a level above the MRL does not mean that adverse health effects will occur. (2)

The effluent is not 135 times the MRL.  At the end of the pipe - where the samples were collected - it is only 7 times higher than the maximum detected level of barium.  What the barium concentration is downstream where little Suzy and Billy "wade and swim" was not sampled by Dr. Volz.  That's where the sample's should have been taken if risk "of these chemicals in the water where the children wade and swim" was to be evaluated properly.

It is quite possible - as that is the reason for the NPDES permit the treatment facility discharges under - that the water "where the children wade and swim" is below the MRL for barium and all the other chemicals reported.

But heck with the kids!  What about the guys who eat the fish swimming in the "toxic crap?"

Once again we need to know how much barium would be consumed when they eat the fish.  Believe it or not, there is a calculation for that:

http://www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/usersguide.htm

And for barium, the amount in the fish that would create concern for the EPA requiring cleanup would be 270 mg of barium per kg of fish.

http://epa-prgs.ornl.gov/cgi-bin/chemicals/csl_search

This is how we look at risk from exposure to a chemical.  The fact that a chemical is present in the environment and we come in contact with it does not mean we will be subject to an appreciable risk of adverse noncancerous health effects.  There is a proper - agreed upon - method to look at estimating elevated, or high risk, when exposed to a chemical.  Dr. Volz must understand that what he present in his report was not a valid indication of the risk to public health and the environment from the water discharged by this frac water treatment facility.

Choosing to ignore the science and objectivity is what led to Dr. Volz no longer being the director of the University of Pittsburgh's Center for Healthy Environments and Communities at Pitt's Graduate School of Public Health.

I am glad that Dr. Volz believes he has a "calling for advocating for public health."  All I ask is that he and others so inclined present and describe the risk properly and objectively.

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Is fracing unsafe to drinking water as it is currently being carried out?

This caught my attention.

From Discover blog, titled: EPA Study Probably Won’t Prove That Fracking is Unsafe, Though It May Be.

For me, the issue of water contamination due to the fracking process is not simply a yes or no question. It is a matter of risk. We must ask ourselves if we are willing to risk the possibility of water contamination occurring in our neighborhood. Given that few of the natural gas sites across the country have caused contamination, I think it is unlikely that the EPA study will demonstrate a direct correlation between hydraulic fracturing and water contamination. If this is the case, this study will do more harm than good by providing evidence, albeit faulty, for the gas industry to argue that fracking is safe. The real question is whether you are willing to take the risk of having undrinkable water. Are you?

Lets look at this, starting at the end....

The real question is whether you are willing to take the risk of having undrinkable water. Are you?

What is that risk?  Is it possible, probable, certain, unavoidable, catastrophic, or unnecessary?  The author does not elaborate on what risk is acceptable, so the conclusion must be that the possibility of a risk of water contamination is enough to stop or significantly change the process of fracing.

Contrary to what the author states, the fracing process really is a yes or no question.  If you say "no" then the risk of water contamination caused by fracing is eliminated.  At the same time, the benefits form this process (cleaner burning fuel, jobs, less foreign dependence, royalties, taxes) are also eliminated.  One goes with the other, so how much risk are you willing to accept for the benefit?

If you say any risk is too much, then how do you reconcile the risk from flying or driving?  We have tons of statistics showing the real negative outcomes from these two events.  We accept the risk, based on the benefit obtained.  You can choose not to fly or drive, but without banning those two processes, you will always be at risk from them.

This is the same with fracing.  There is the possibility of spills, explosions, and contamination just as there is the possibility of drunk drivers, poor maintenance, and underwear bombers.  What then is the incidence of these events?  Well outside of drunk drivers, pretty low, enough so that it does not happen enough to change our behavior.  And when we find a problem, we fix it, reducing the incidence further but never removing the risk altogether.

Does fracing, as it being performed now, present an elevate risk to drinking water such that question of allowing it to take place should be "no"?  What do we know about fracing, which are into the multi-thousands (millions?) of gas wells to date, and drinking water contamination?  Here is what the author of this blog writes:

• Given that few of the natural gas sites across the country have caused contamination
• “I’m not aware of any proven case where the fracking process itself has affected water, although there are investigations ongoing.”
• The problem with the critics’ argument is there is insufficient evidence to prove that the contaminated water is indisputably due to fracking.
• but with no analysis of the ground water prior to drilling, one cannot be sure that the contamination is directly caused by the fracking industry.
• Personally, even though the evidence is sparse and inconclusive, 
• First, there is little or no evidence that the toxic ingredients in fracking fluid have contaminated drinking water directly from the below-ground wells.
• Regardless, it seems that the fracking fluid and, in fact, the fracking process is not the problem.
• There are numerous physical arguments against the possibility that fracking fluid will find its way into drinking water during the hydraulic fracturing process. 
• Of course, there is the possibility that the cracks created by the process could connect with natural cracks in the rock formations leading to a direct connection between the well and the aquifer, but this is statistically unlikely.
• As described in the PNAS paper, the problem of contamination is most likely due to leaky gas-wells, not the hydraulic fracturing itself.
• Second, there are millions of natural gas wells across the country. Very few of them have been linked to any contamination. 

The debate needs to move away from the possibility and towards environmentally friendly drilling and production processes that can be adopted by industry, faithfully carried out, and modified when the data shows it necessary.  

The risk to contamination of drinking water does not appear to be more than any other public or industrial processes currently performed.  We can decrease the risk, we cannot eliminate it.  On the other hand, the evidence and statistics point to a process that is not producing a significant risk to drinking water that would require outright prohibition or modifications for the sake of appearance.

So my answer to his question: "The real question is whether you are willing to take the risk of having undrinkable water. Are you?" Is yes, yes I am.  Just like I am willing to fly in a plane that has a risk of falling out of the air.  I trust the engineers and the mechanics and the regulatory oversight to minimize that risk, not eliminate it altogether.  So far so good.  Same can be said about fracing.