It has been 230 days now since City Council passed our drilling ordinance. We asked them to include air and water monitoring requirements. They didn’t do that. BUT they did promise to create a monitoring program. See my last post on this.
Alas, still no action.Let me see if I can motivate the need for air and water monitoring a bit.
First, on water, there is a recent UTA study that sampled private water wells and found higher levels of toxins near fracking sites. Here’s a blurb from the write-up:“29 wells that were within the study’s active natural gas drilling area exceeded the EPA’s Maximum Contaminant Limit of 10 micrograms per liter for arsenic, a potentially dangerous situation. The areas lying outside of active drilling areas or outside the Barnett Shale did not show the same elevated levels for most of the metals.”
Second, on air, natural gas pad sites operate under the TCEQ permit by rule (PBR) status. This means they do not need to submit an emissions inventory. This, in turn, means we don’t know how much they are polluting. They are allowed to emit 25 tons of VOCs (like benzene and other toxics) per year (25 tpy).
Now, most likely, they are not emitting nearly that much. But we don’t know how much. And we don’t know that because there is almost no monitoring.
We can do some calculations, estimations, and extrapolations to make a guess. Al Armendariz did this in 2009 and concluded that when it comes to the “smog-forming compounds” of NOx and VOCs in five core DFW counties: “the oil and gas sector likely has greater emissions [165 tpd during the summer] than motor vehicles [121 tpd].”
The industry contests this study. They lean heavily on TCEQ estimates. But, again, the TCEQ does not know how much pollution is coming from gas wells. I talked to an environmental investigator there today and asked him if I can get numbers for VOCs from pad sites similar to those tracked at major point source polluters (like the Acme Brick plant or the Peterbilt plant go here then click on ‘2011 statesum.xlsx’). He said, no, because the oil and gas industry is not required to submit those numbers and the TCEQ is not required to keep track of them. He then said I can ask the industry for the numbers. When I asked how we could know industry numbers are accurate, he said there is no way to know that.
But wait, you say, what about this map from TCEQ? It shows hundreds of samples have been taken in our area. And most of them are green, meaning anything found was below health and safety thresholds. You say: “The TCEQ is monitoring gas wells and all is dandy!”
This doesn’t mean as much as it might seem, though. In fact, if you dig into the data on the individual dots it starts to look like a big green lie. I don’t mean they are fabricating data. I mean the data are not very robust – they don’t support the reassuring story one gets by looking at all those green dots. It’s a lie in this sense: a false sense of certainty about health impacts.
Let’s zoom in on one of those green dots to illustrate. Here is a case study from April 2012 of a TCEQ agent taking a 30-minute summa canister sample at the Corbin 1H well in Denton in response to a citizen complaint of an odor. The more astute readers out there might recognize the site – it is the same one where EagleRidge is fixing to put in four more wells:
The report concludes that there are no health threats – all VOC levels are below thresholds of concern. It notes that the sample was taken at 3:09 p.m. But we don’t know when the complaint was lodged, so we don’t know how much time had passed. Emissions from tanks on pad sites can be periodic and sporadic. So, weakness 1: they might have been too late. If you think this can’t happen, just recall the hours it took for them to respond to the recent geyser, er, emissions event.
They put one summa canister somewhere between 300 and 500 feet from the emissions source. This technique is the old standby but it is quickly being surpassed by a monitoring science business that can see and speciate plumes coming directly off the equipment. Summa canisters just sit there and collect whatever happens to waft their way. So, weakness 2: they might have missed the plume for reasons of inadequate sampling.
Here is the upshot – you get one quick snapshot with a passive monitoring canister placed about 500 feet away from the actual source of emissions at some unspecified time after an odor was detected – and viola: No problems! You get a green dot. Then multiply that several dozen times and you paint a nice, reassuring and false picture that all is well.
In short, no one really knows what is coming off of these pad sites. Not even TCEQ. That’s why we wanted a monitoring program. I think that’s why City Council promised us one.
I’ve heard some on the inside of this issue say that maybe Denton shouldn’t get in the air monitoring business because that might ruffle TCEQ’s feathers. “We wouldn’t want to send a message that we think they are doing a bad job.”
Actually, yes, that is precisely the message we want to send. There is better monitoring technology out there capable of giving us better answers about what kinds of health risks gas sites pose. We just need the political will to put it in place. We might find out that there really is nothing to worry about. But let’s not rest content with all we have now, which are false assurances.