A super opinion piece in the Star-Telegram by Jim Bradbury. I’m posting it here in it’s entirety because it won’t be available on the S-T long term.
Fort Worth air quality study has gaps
Posted Monday, Aug. 08, 2011
By Jim Bradbury
The length and complexity of Fort Worth’s recent air quality study make it difficult to decipher and its information thus virtually unavailable to most residents. While we now have information that we did not have before, we do not have the clear-eyed answers that we need.
We must do far more. I encourage the mayor and City Council to not place this report on a shelf as a question answered but instead use it as a foundation to address emission controls for natural gas production activities over the long term.
The value of royalty income will prove fleeting if we discover all too late that the health of our young and old was diminished because we were unwilling to press this issue.
The $1 million cost of the air quality study was enormous for the results that were provided. The city staff failed to take a sufficiently aggressive approach in managing the work and the contractor and allowed the final cost to run significantly over budget.
Credibility was key for this work. After the protocol was developed and Eastern Research Group selected to do the work, the city staff folded back into a behind-the-scenes process of developing the contract. The process was not open to the Air Quality Study Committee or the public.
Eastern Research was asked to conduct air quality sampling to determine the existence and prevalence of harmful emissions from natural gas operations citywide. The ambient air monitoring report revealed relatively consistent signs of important air quality issues.
Benzene, the contaminant that has drawn much of the current attention on air quality, was detected 94 percent of the time. It is the best marker of an emission problem.
Seven other volatile organic compounds were detected at rates higher than 90 percent. That these values were collected citywide underscores the gravity of the situation.
The report identified seven key pollutants for Fort Worth. Eastern Research’s analysis appears to judge the presence of the pollutants only by whether they produce an “urgent health hazard.” That leaves open a very important question about Fort Worth’s overall near- and short-term air quality.
This may be too simplistic for air scientists, but if we find benzene 94 percent of the time, we have a problem.
The most important part of the study was to be point-source testing at every natural gas site in the city. The air quality committee was surprised but also impressed that Eastern Research assured us that so many sites would be closely evaluated.
The committee discussed at length the use of testing and detected rates of emission instead of oil and gas “book estimates.” Unfortunately, as the details of the report make clear, the consultant utilized “surrogate emission profiles” and industry-estimated values in its analysis.
Stunningly, the report reflects raw averaging and even wholesale assumptions that nontested equipment was not leaking. That is not what the city asked or paid for.
Notwithstanding the consultant’s assurances, the report acknowledges that not all of the sites’ emissions were even tested.
For example, certain parts of storage tanks, wastewater and condensate loading equipment and flaring were not tested.
The report highlights compressors as well as gas treatment plants as the greatest sources of obvious emissions. The reported values for the one gas treatment plant examined are significant. The city should inventory all gas treatment plants that are just outside city boundaries and produce emissions that can or do drift into the city.
Certain emissions were detected by infrared camera at a well completion site but were not measured otherwise. The evaporative units at the city’s waste disposal pilot project were not tested for emissions.
Despite requests, testing in heavy condensate production areas outside of Fort Worth was not done.
We have no sense of the volume of emissions that drift into our city from production areas that are known to emit volatile organic compounds.
The real question facing the city and its residents concerns Barnett Shale natural gas development’s cumulative effect on air quality and good health. The answer still eludes us.
Jim Bradbury is a Fort Worth attorney practicing environmental law and a member of the city’s Air Quality Study Committee.
Thank you, Jim Bradbury, for wading through all the mess.