We have decided that the benefits of industrialization are worth some risks of harm. You want that nicely starched shirt? Well, it will cost you up to ten tons per year of emissions of perchloroethylene from your drycleaners down the street. Another way to put this is that we have decided it is acceptable for some people to get sick and die as an unintended (but foreseen) consequence of, let’s call it, development.
Given that we can’t lead risk-free lives, what shall we count as acceptably safe? The EPA has their answer: “In developing risk-based standards to reduce health risks from air toxics, EPA strives to ensure that those standards provide the maximum feasible amount of protection by: Limiting an individual’s cancer risk to approximately 100 in 1 million. This means that a person living near a facility and exposed to maximum concentrations of a pollutant for a 70-year-lifetime would have no more than a 100 in 1 million chance of getting cancer as a result.”
There are 17,000 gas wells on the Barnett Shale. Each gas pad site (which may contain more than one well) is allowed to emit a certain amount of pollution into the air. Indeed, under the Texas Administrative Code’s Permit by Rule, here is what an oil and gas site (OGS) can legally emit (based on something similar to EPA’s logic about acceptable risk):
Do we know how much of these toxins natural gas pad sites are actually emitting? The short answer is NO. The Texas Commission on Environmental Quality (TCEQ) has very few monitors in this region and only a couple that are near pad sites. They base their emissions inventories largely off of estimates derived at the time of permitting the site and self-reporting by operators. These estimates are based on well-validated scientific models about what a typical pad site emits. But they are not actual counts of actual emissions.
In short: there is an extreme lack of monitoring of natural gas pad sites. This is problematic for a couple of reasons. First, pad sites don’t always behave as models expect them to. Valves can get stuck, pipes can leak, and other accidents can happen that lead to periodic and potentially massive emission events (I have this first hand from someone in the industry). This is particularly true of older pad sites, which are typically run by operators with smaller budgets. We all have seen these kinds of images of unidentified plumes from pad sites....makes you wonder: was that planned...is that in the model...or is something going wrong? It would be nice to know.
But most importantly, this is problematic, because monitoring is how we identify and learn about potential problems. Without it, we are just sticking our heads in the sand and assuming that everything is performing according to the model. We cannot eliminate risk – that is true. But we can learn about and take actions to reduce risks. I call this renovation. We have an innovation system that enrolls technologies into society without a full understanding of their actual risks. To renovate means to learn along the way and upgrade the technologies on the basis of that information.
Indeed, I put the lack of monitoring of shale gas development in the same bucket with secret fracking chemicals, frackademic misinformation campaigns, and non-disclosure agreements. In all these cases, we are prevented from learning about the true risks created by the oil and gas industry. In all these cases, we are told to just trust that everything is alright…but what we don’t know can hurt us. We need to shed more light on the true impacts that drilling and fracking have on our air quality.
That’s why you should come out to City Council on Tuesday April 16 for their work session (see item 4) where they will discuss an air and water quality monitoring program. You also should come see Dr. Jay Olaguar’s talk on Monday April 22:
Thanks Adam for remaining involved. I will attend both of these events. I am glad to see the city taking forward steps on monitoring.
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