ERG air testors did a breakdown of the one million dollar Ft Worth air quality study. These are my notes….
1).They were not tasked to report on the topic of the huge methane losses while my handwritten notes show that Ft Worth has 5-10 ppm methane when the world wide background average is 2 ppm). Royalty owners should be upset about that as should the Railroad Commission because it is their duty to preserve our state’s natural resources.
2).They also were not asked to make any health recommendations about drilling trucks and onsite engines creating NOX which fuels our ozone noncompliance air quality problems.
3). A question was raised if they had data regarding emissions during a drilling fire or mishap, but they did not have any information on that.
After the meeting, I wanted clarification on the preproduction testing methods. I was told two sites were tested, one during drilling and another during fracking/flowback.
I asked point blank if at the time they tested the two preproduction sites, if there was any visible plumes of smoke and was told “no”. It turns out that the only site they monitored during drilling (pre production) had an electric rig. One of them commented that the operator can abuse his gas pedal and “make” those plumes happen. While I didn’t fully grasp how an operator has a way to possibly “control” those emissions, I am disappointed that ERG never captured data during huge, black plume, emission events of diesel rigs (which is what we have endured). This puts a serious question on how much more than 57 tpd would be reported if they had point source tested during preproduction phases. They stated their reason for not preproduction point source testing was that it was too hazardous for the tester. There was mention several times about how downwind, fenceline testing had generally lower emissions than point source testing. Unfortunately the fenceline area is the only location of ERG’s suma testing during preproduction activities. (A master in public health environmental testing expert said that fenceline testing is too close and needed to be in the neighborhoods. Wilma Subra once said in her experience that Benzene fallout is about 2,000 feet.) The rest of the offsite air testing consisted of 6 sites (in other phases of gas production) where the suma canisters were positioned in the same spot for two months (in Sept and Oct) and took a sample every three days for a total of 169 ambient (suma) air samples of which 9 were taken during fracking and flowback.
They performed 388 point source tests, which consists of going right up to the equipment (except compressors-they used info from the mfg.equipment emission info), they used InfraRed (FLIR) camera’s to find the leaks (but that data is limited to just that). They used a Toxic Vapor Analyzer (TVA) and Hi Flow Sampler for smaller leaks to quantify the hydrocarbons.They screen 10% of minor source leaks like valves etc (but only the suma canisters tell you “what” is in the hydrocarbons). The results were quantified which they called the “direct data approach” and then took an average, “indirect data approach” and that was how they modeled for the rest of the FT Worth sites.
Their presentation was to have us see how we are not in an immediate health threat situation. We have no choice but to trust the ESLs (Effect Screening Levels) for individual pollutants and trust that even if they go above those thresholds that we still have some extra cushion before we reach the federal levels (which are a starting point for the states to be more protective). I just read a report where the lowest risk dose of bisphenol A (BPA) “was” a health detriment to those rats who grew up to be obese, sickly, & feminine. Drilling effluents are known endocrine disruptors and new science says that endocrine disruptors can occur in parts per trillion.
I was also told by one of the ERG guys (after the meeting) that the science is not advanced on multiple pollutants. We still are in the dark on the unregulated multiple, cumulative emissions and their long-term effects of living in the gas patch. He reminded me that there is the ATSDR synergistic mixture effect like 1 + 1 = 5. He said that BTEX ESL combinations have multiple possibilities.
2012 and 2013 is predicted to be the peak production that could bring Ft Worth up to 100 tons per day of VOC’s.
ERG said the Barnett Shale has a 2% average HAP’s (Hazardous Air Pollutants).
Since ERG used TVA’s probably for all 388 sites (they also used Hi Flo meters-but I haven’t researched those machines shortcomings); any of these sites could have been exceeding the long term Benzene ESL when using TVA’s (keep walking nothing to see here) they needed to use suma canisters which can detect Benzene in parts per billion.
The spec sheet on a manufactures TVA 1000B model (which is what ERG used and is probably what the TCEQ uses too) showed the machine’s minimal dectection limit for Benzene starts at 100 ppb – the TCEQ short term ESL (Effect Screening Level) threshold for Benzene is 54 ppb! (update TCEQ has doubled this short term ESL) TVA’s R NOT SENSITIVE ENOUGH!
The parts per million equipment that firemen use is also not sensitive enough (it should be in parts per billion)…sure they’ll know if the scene they are at has “explosive” high methane levels…but they may be sending their first responders in an area and not know how much Benzene they are breathing…they need to know to evacuate the people living so close to these drill sites!! Remember Wilma Subra said the fallout for Benzene in her experience is like 2,000 feet!!!
On page 3-7 of the ERG study, the Infrared camera only sees when emissions are >10,000,000 (ten million) ppb. ERG said that the IR (infrared) camera did not detect ANY emissions at 96 sites! So how many “other” sites did the IR cameras detect at least 10,000,000 ppb? ….at the other (292 ?) sites !!! HOLY COW CANCER! Take ten million times less than 1/2 of a percent (<.004 that TCEQ said is typically in the dry Barnett Shale gas…. to be fair unknown is the concentration of BTEX emissions) to estimate the Benzene…..that would be…drum roll please— at least 40,000 ppb Benzene detected at the sites that “registered” on the IR camera!
Per Attorney Bradbury on an Aug. 8 Star Telegram editorial called “Ft Worth Air Study Has Gaps”, said the IR camera registered on one production site (the only one studied), and yet no further testing was done…so can we say that all production sites have at least an average of 40,000 ppb Benzene? The EPA claims the production phase to be the most methane losses phase…wow that really warms up the climate doesn’t it? The EPA also claims that methane losses are under reported by the industry by 9,000 times!!
ERG Ft Worth air study drilling and fracking tests were fenceline tests and NOT point source tests. I was told my an expert (Dr Rich) in the air testing field that the fenceline is NOT the correct location for testing, that is the perfect location for NOT capturing emissions due to updrafting of the plume. The plume rises (at point source) and comes down quite a ways away depending on many factors.