A response to the BSEEC’s recent air quality study.
Dear Mr. Mayor and Members of Council,
After careful reading of the Barnett Shale Energy Education Council’s Air Quality report, I write with a few comments.
Firstly, TITAN Engineering is a firm with no in-house testing capabilities. Such a study is not typical of the work in which TITAN is usually engaged. They do, however, have close economic ties to Chesapeake Energy.
Secondly, the times, dates and duration of the tests were known beforehand by each operator. Nothing was random. Nothing was done without the full knowledge of those being tested. In addition, the City of Ft. Worth was involved in the site selection process.
Thirdly, ten sites were chosen as representative of over 2,000 total sites within the city. This is not a large enough comparison sampling and yet the information contained is most enlightening.
TITAN begins their report with “while previous air monitoring studies in Fort Worth have evaluated natural gas sites at random…TITAN considered compressor stations, completed well sites, and active drilling sites as candidate sites and determined that compressor stations and completed well sites would represent the worst-case with respect to benzene emissions”.
This is interesting to note. No analysis of drilling, fracking or flaring were included by TITAN. It is curious that the industry and the City of Ft. Worth would omit such obvious candidates for testing given that flaring in particular is known to be one of the most egregious polluters and contributors of benzene emissions in the entire drilling process. Strosher, whose work has been cited by governments throughout the world, found that most flares in the field burn at 65% efficiency at best and that benzene can be detected in measurable quantities up to 5 km (3.5 miles) downwind of a natural gas flare. Strosher’s study done for the Canandian government is well known by industry and yet, TITAN’s study, done for industry, states that completed well sites were projected to have the highest benzene emissions.
Doug Canter, Principal of TITAN Engineering and lead of the study stated, “because we tested sites projected to have the highest benzene emission rates and found no site-related concentrations in excess of the study’s health-based criteria, TITAN concludes that harmful levels of benzene and other compounds are not being emitted from natural gas sites in the study area.”
But the report goes on to state “TITAN determined that the NG (natural gas) Site operation contributed to the ambient air concentrations of benzene, isopentane, xylene, pentane, toluene, heptane, and hexane, as the downwind concentrations for these compounds exceed those at the upwind location…TITAN determined that the NG Site operation is contributing to the ambient air concentration of carbonyl sulfide”.
After reading this I was reminded of an email sent to me by Julie Wilson, VP of Urban Drilling for Chesapeake Energy, dated 14 August, 2009, after Chesapeake had seen the test results obtained at my home during the flaring of their gas well at Shady Oaks. Ms. Wilson stated:
“our EHS (Environmental Health and Safety) experts also note the following, based on your test results:
• The presence of chloroform, dichlorodifluoromethane (Refrigerant 12), styrene, and other solvents, all indicate air emissions from industrial sources – not from Barnett Shale natural gas operations.
• The presence of disulfides would indicate some sort of waste water treatment or biomass combustion source; even large scale composting, local biomass decay, or a lagoon could be a possible source, but certainly not Barnett shale natural gas operations.
Some of the air toxics in the sampling are compounds associated with natural gas operations. Most notably, benzene, ethylbenzene, toluene, and xylene (BTEX) can be emitted from gas facilities that treat a heavier “wet” gas containing those compounds, but not from treatment of the “dry” Barnett Shale gas”.
And yet, TITAN Engineering’s test results detected the above mentioned compounds such as dichlorodifluoromethane, styrene and other solvents, sulfides and BTEX constituents in spite of the fact that Chesapeake’s Environmental Health and Safety experts definitively and repeatedly stated that these “certainly” could not have come from Barnett Shale natural gas operations.
Further, TITAN continues by stating “five of the nine formaldehyde concentrations (over half) were higher than the 41 ppbv health- based AMCV”. Formaldehyde is considered a probable human carcinogen.
TITAN literally dances round this with the incredible statement “it is TITAN’s opinion that the elevated formaldehyde concentrations are not being caused by NG Site operations, but instead are being caused by both vehicular traffic and an unidentified source located to the near south/southwest of the NG Site. During the sampling event, TITAN field personnel did not [however] identify any type of emission source that could have caused or contributed to the formaldehyde concentrations”.
In addition, the one site chosen with condensate quite oddly had no condensate production on the day of testing. But condensate had been produced at this site for the prior thirty days. It is interesting to note, since this site showed the highest level of benzene, that the condensate levels at this site are naturally very low and are not indicative in the least of typical condensate levels in Barnett Shale as a whole. Further, the samples were not taken directly downwind from the source. With regard to condensate, “TITAN concludes that the completed well site in wet gas service makes contributions to ambient air compound concentrations”. And this when condensate production had apparently been shut down for testing. What might it have registered if the samples had been taken directly downwind while the condensate was being produced?
There are other anomalies in this study. When the first air data was collected at my home, both Chesapeake and the City of Ft. Worth in their analysis remarked on the importance of wind speed and direction in determining the level and source of emissions. And yet, the meteorological data contained in this report shows testing being conducted when half the sites had wind speeds of 10-15 MPH with gusts reaching as much as 37.5 MPH. Wind speeds greater than 10 MPH are known to disperse plumes of emissions. Much of the wind speeds throughout the testing were gusting above 20 MPH and yet still TITAN continued testing. Further, many of the samples collected by TITAN were short term (1 hour or less) and could easily have been skewed by gusts of wind so as to have compounds appear nonexistent or at the least much diluted.
For the past year we have been told repeatedly by industry that these compounds may have come from other sources “but certainly not Barnett Shale natural gas operations”. We now have a report commissioned by industry, conducted by industry and interpreted by industry which states “TITAN determined that the NG (natural gas) Site operation contributed to the ambient air concentrations of benzene, isopentane, xylene, pentane, toluene, heptane, and hexane, as the downwind concentrations for these compounds exceed those at the upwind location”. And yet, even though industry now admits that these compounds do indeed exist around these facilities, they claim that they are not in quantities that are harmful to our health.
This is beginning to have a familiar ring to it, an all too familiar pattern; outright denial moving on to admission with caveats that our health is perfectly safe.
Further, TITAN is basing such health conclusions on information from air tests which were conducted with wind speeds gusting up to 37.5 MPH, an exceedingly small sample size (10 sites) in comparison to the 2,000 wells in Ft. Worth and 15,000 wells in Barnett Shale and no testing done during drilling, fracking or flaring.
The remedies for these emissions are known, readily available and cost effective. They must be used as we now have industry’s confirmation that these compounds “certainly” were coming from these facilities all along.