Saturday, October 19, 2013

WVU Professor Addresses 625 Foot Set-Back Rule for Marcellus Wells

Commentary by S. Tom Bond
Retired Chemistry Professor & Resident Farmer, Lewis County, WV

Usually when you write about a meeting, the procedure is to focus on what was said.  In this case the emphasis must be on interpretation of what was said, because the background formed what was said, not the research.

The meeting was titled “Monitoring of Marcellus Drilling Operations.”  The speaker was Dr. MIchael McCawley of the WVU Department of Occupational and Environmental Health Scienc. These lectures were held at Philip Barbour High School auditorium, Philippi, WV on October 15 and again the 16th at Erickson Alumni Center at WVU.

Dr. McCawley was handed a really raw deal with this research assignment.  The Marcellus industry is having to fight a vast number of complaints of health effects, from people who live in the vicinity of drilling operations, compressors, NG liquids separation plants, and pipelines. And,  similarly down stream from the places they take their flowback.  Apparently the geologists and petroleum engineers did not anticipate the effects of use of “slick water fracturing,” which has proved a couple magnitudes of order worse than the fracturing done before the year 2000.  Partly this is a matter of new chemicals used, and partly a matter of the scale of the effort.

The industry is in trouble.  It barely makes any money for those at the top, except the bankers who loan the money and get their share “up front.”  One internet site in Pennsylvania has a “List of the Harmed” which now runs over 1200.  The Sierra Club is putting together a similar portfolio, documented cases where people have complaints subsequent to drilling in their neighborhood.  Physicians, untrained in the hazard, who once would not listen to some of the complaints, are beginning to see a pattern.  Worst of all, lawyers have perked up their ears and many court battles are on the way.

What the Marcellus industry needs is ammunition to use in court.  Unfortunately, both the business men and the legislators who wish to accommodate them don’t have a background in science and aren’t particularly motivated to listen to those who do.  Failing scientific evidence already in existence, they want a law to take the place of it, since law is cheaper to come by.  Hence, the idea that a legislated distance between the drilling pad and the home (or large livestock building) will provide safety for the rural residents.

This is where the 625 foot “set-back” comes from.  The exact figure is a guess, a fervent hope.  Will everyone be safe if they live in a residence 625 feet or more from the well being drilled?  That is the question the legislature and the industry have put, and Dr. McCawley was expected to answer.

So how was Dr, McCawley funded?  Minimally, of course.  He and his students had funds from DEP to make short term measurements at only seven sites.  This was to detect any and all chemicals in the air, noise, light and radiation.

It reminded me of something that happened during the 19 years I taught Sophomore Analytical Chemistry.  A Member of the College Board of Directors brought me a lump of rock from a gold mine he had bought out West.  Would I assay it for him, please?  Fortunately, I was able to convince him I didn’t have the resources, connections and experience to provide these particular answers.   Dr. McCawley wasn’t so fortunate at convincing state government they had asked a bad question.

The effect of chemicals and noise depends on the direction the wind is blowing (toward or away from the sampling site or some oblique), how fast it is blowing and factors which affect turbulence (mixing the chemical in the air), such as hills and valleys, trees, buildings, and inversions.

Dr. McCawley discussed inversions extensively in his talk.  This is a common occurrence in Appalachia when the wind is quiet.  Temperature normally decreases as you go up in the atmosphere from ground to space.  An inversion is when temperature goes down as you go up, then there is a layer where it gets warmer, then goes down again above that.  The effect is to capture gases and particulates being emitted in the ground hugging layer and accumulate them for some time, frequently up to dangerous levels.  A famous inversion disaster occurred at Donora, Pennsylvania in 1948.

So what could Dr.McCawley come up with from the seven sites where the companies knew where he was sampling and why?  The chemical tests were for dust, a variety of hydrocarbons, ozone, sulfur dioxide, nitrogen oxides, and diesel emissions . (Incidentally Dr.  McCawley was instrumental in discovery that diesel particulate emissions are carcinogenic, cancer forming, earlier in his career.)  This is the carefully worded abstract for the meeting:

The West Virginia Natural Gas Horizontal Well Control Act of 2011 required determination of effectiveness of a 625 foot set-back from the center of the pad of a horizontal well drilling site.  An investigation was conducted at seven drilling sites to collect data on dust, hydrocarbon compounds and on noise, light and radiation levels.  Measurements of air contaminants were taken at these sites to characterize  levels that might be found at 625 feet from the well pad center at unconventional gas drilling sites during activities at those sites.  While there were detectable levels of dust and volatile organic compounds found to be present at the set-back distance, the duration of the specific activity of interest at each of the sites did not allow comparison of collected data to limits of the National Ambient Air Quality Standards (NAAQS) and therefore  did not allow recommendations to be made for a setback distance based on the NAAQS values.  Some benzene concentrations were, however, found to be above what the CDC calls “the minimum risk level for no health effects.”  This is a concern for potential health effects that might arise due to these exposures over a long time.  Also, not all of the studied contaminates emanate from the center of the pad, so any new regulations might consider a different reference point or points (such as roadways) from which to measure the setback distance.  There does not seem to be a simple solution to specifying a single point from which to specify the set-back distance to assure exposure control.  There is no single geometry to which all drill site activities conform.  The activities follow the terrain of the site  and the needs of the process.  There is no reason to believe using the center of the pad as the reference point from which the setback is taken will assure that activity associated with  some possible sources of the studied contaminants will not occur closer than 625 feet from the actual source.  Studies have shown that meteorology (and topography) may be a more important  factor than a distance measured on a map for determining air contaminant concentration.  The levels of contaminant that were seen were not unexpected based on previous studies.  However, they were seen to fluctuate over a wide range (i. e. have a high standard deviation) so that consideration needs to be given to increased control monitoring of the process such as directed reading monitors  at sensitive locations near the well pad connected wirelessly to the operations center at the pad.

Read that last sentence again carefully.  Dr. McCawley is suggesting the only rational way to protect people – put monitors on the homes and barns, and shut down or modify operations when the danger level is reached.  My prediction: It will never happen in this world.  It wouldn’t happen if they were getting ten dollars a thousand cubic feet of gas at the wellhead.  It involves expense, a new set of specialists, and slowing the “hell-for-leather” pace down.  Never happen.