Patricia DeMarco Ph.D.

"Live in harmony with nature."

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Comments on the Shell Falcon Ethane Pipeline

 

April 5, 2018

Allegheny County Public Hearing

Pennsylvania Department of Environmental Protection
Southwest Regional Office
Waterways & Wetlands Program
400 Waterfront Drive
Pittsburgh, PA 15222
RA-EPWW-SWRO@pa.gov 

 

In the Matter of: Shell Pipeline Company, Falcon Ethane Pipeline

JOINT PERMIT APPLICATION FOR PENNSYLVANIA CHAPTER 105 WATER OBSTRUCTION AND ENCROACHMENT PERMIT AND U.S. ARMY CORPS OF ENGINEERS SECTION 404 PERMIT (JANUARY 20, 2018)

My name is Patricia M. DeMarco, I reside at 616 Woodside Road, Pittsburgh, PA 15221.  I am an elected Member of the Borough Council in the Borough of Forest Hills, representing 5,600 citizens.[1] Our community lies in the area affected by air emissions and watershed contamination potential impacts from the Falcon Ethane Pipeline. I speak on behalf of the citizens I am sworn to represent and for the unborn children of the 21st century who will bear the consequences of the decisions made today.

 

I oppose the construction of this pipeline and the entire industrial complex of which it is a critical component. The Falcon Ethane Pipeline system is a 97-mile pipeline network intended to feed the SHELL Appalachia Petrochemical facility in Beaver County, Pennsylvania. The Falcon Pipeline will carry more than 107,000 barrels of ethane per day through Pennsylvania, West Virginia, and Ohio, to Shell’s Appalachia Petrochemical facility, which would then “crack,” or break apart, ethane molecules to create ethylene and polyethylene for single-use plastic materials at the rate of 1.6 million tons per year. The SHELL Appalachia Petrochemical facility would be the first step in building a regional petrochemical hub.[2] Piecemeal permitting of the multiple components of this intended petrochemical industry hub prevents the comprehensive impact review of the consequences of converting the forested, rural landscape of western Pennsylvania to an industrial mega-complex. The petrochemical industry is migrating from the storm ravaged Gulf Coast areas of Louisiana and Texas to escape the effects of climate change that their own industrial activities are exacerbating. Western Pennsylvania communities will become part of the sacrifice zone to this endeavor, as has happened in Baton Rouge Louisiana and parts of Houston, Texas.[3][4]

 

The construction of the Falcon Ethane Pipeline should be denied for three reasons: it presents a clear danger to critical ecosystem functions in violation of the Pennsylvania Constitution; it presents a public health hazard; and it contributes to the immoral and unethical destruction of our climate and planetary health. Propagating infrastructure for fossil-derived methane to be burned as fuel, and petrochemicals to be converted into single-use plastic materials accelerates the slow suicide of our civilization.

 

Falcon Ethane Pipeline violates PA Constitutional protection for the environment.

The Pennsylvania Constitution protects the natural resources of the Commonwealth:

The people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment. Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people.[5]

This Constitutional provision argues explicitly for precaution in protecting natural resources, including their inherent ecosystem functions, for the use of current and future generations.  It is clear from the proposed route of this Falcon Ethane Pipeline that the permanent right of way will assure the clearing of forest lands, the disruption of natural habitat, the exposure of wetlands, streams and rivers to spill hazards and erosion for the imposition of roads and crossings, and the loss of aesthetic and recreational use of lands. The proposed route of the Falcon Ethane Pipeline will require 1, 273 acres of construction space and 650 acres for the permanent right of way. The Shell Pipeline Company has a poor record of spills, from breaks, leaks and operations. An examination of Shell’s operations around the world makes it clear that the company operates with a brazen disregard for the safety of its own workers, the needs of local communities both here in the United States and internationally, and the long-term impact of drilling on the environment.[6]  In the United States, Shell has one of the worst environmental violation records in the industry, illustrated by these few examples. In September 2011, Shell was fined $500,000 for failing to report five toxic releases at the Deer Park refinery in Harris County; the facility is close to two schools and multiple communities; In 2010, two Shell subsidiaries were forced to pay $3.3 million in civil penalties to the government and spend $6 million to install pollution reduction equipment at refineries in Louisiana and Alabama; In addition, four years earlier, the company was fined $6.5 million for more than 50 environmental violations in Riverside, California.[7] This pattern of corporate behavior is unlikely to change in the proposed Pennsylvania operations at Shell petrochemical facilities.

 

Clean fresh water is essential for life- single use plastic from natural gas liquids like ethane is not. Critical environmental and ecosystem functions will be at risk of damage and degradation from the effects of this pipeline and the extensive infrastructure required for the extraction of fossil methane and natural gas liquids such as ethane from the Marcellus and Utica shale fields. Fully implementing this strategy to locate a petrochemical hub in western Pennsylvania will assure the destruction of the natural landscape, watersheds, and fresh water rivers and streams for decades into the future. Protecting fresh water resources is a critical need to support the habitability and resilience of the Western Pennsylvania region.  The Falcon Ethane Pipeline compromises watersheds, wetlands, streams and rivers that provide the water supply directly for at least 8,500 people, and the 30,000 people who rely on the Ambrige Reservoir, not counting people served by private wells within the affected area.[8]

The Falcon Pipeline will directly intersect 319 streams with 361 additional streams located only 500 ft from construction areas and 174 wetlands with 470 additional wetlands located only 500 ft from construction areas. For the most part, these intersections will use open cuts and dry ditch trenching for the construction process, offering minimum protection from sediment, erosion and the introduction of contaminants.  Horizontal Directional Drilling to give greater protection to sensitive areas was indicated in some planned crossings, including highway crossings, but was not included in the plans for crossing areas that directly affect water reservoirs in the Ambridge and Tappen Reservoirs. No plans for DEP or other regulatory oversight of operations in these sensitive watershed, wetland and stream crossings are included in the Application.

 

The Montour Trail will be crossed by the Falcon Pipeline in nine locations: five by the pipeline itself, three by temporary access roads, and one by a permanent access road.[9] Construction of the pipeline and ongoing right of way maintenance will entail clearing of woods and disruption of scenery and a recreational bike way used by an average of 400,000 people annually. This constitutes a permanent and irreparable harm to a scenic and recreational asset of Pennsylvania.

 

The Falcon Ethane Pipeline will deliver ethane extracted from Marcellus and Utica shale deposits to the Shell Appalachia Petrochemical Plant in Monaca, PA. The anticipated output of this facility is polyethylene plastic, a precursor for single-use plastic packaging, among other plastic products. It is anticipated to use low-cost ethane supplied by shale gas producers in the Marcellus and Utica basins to produce 1.6 million tons (Mt) of polyethylene a year.[10] Global pollution from plastic waste has reached crisis levels. In 2010, eight million tons of plastic waste ended up in the ocean from coastal cities and river discharges.[11] With no restrictions for recycling, reclaiming single-use plastic waste, or designing for repurposing and recapturing this material, the net effect of the Shell Appalachian Petrochemical facility, and the ethane pipeline that feeds it, will be to convert fossil raw materials to trash as rapidly as possible to generate profits for the industry.  The costs to the environment in the form of permanent non-biodegradable plastic pollution will endure for generations.

 

Falcon Pipeline contributes to health effects for workers and communities.

The slick water hydraulic fracturing method for extracting fossil natural gas and associated liquids from deep shale deposits was enabled by the National Energy Act of 2005, which gave an exemption for this process from seven federal environmental and public health laws.[12]  Due to such exemptions, the Falcon Ethane Pipeline is not technically required to file for air quality permits under the Clean Air Act. The rapid expansion of the industry has been accompanied by an increasing documentation of public health and worker exposure data. As a result of the rapid growth of this industry, 9.4 million Americans in 39 states live within one mile of fracking facilities. The Fifth Compendium of peer reviewed documentation of health effects from the fracking industry has been compiled by the Concerned Health Professionals of New York and the Physicians for Social responsibility. The major findings of this study based on peer-reviewed health studies are as follows:

By several measures, evidence for fracking-related health problems is emerging across the United States and Canada. Studies of birth outcomes in regions of intensive unconventional oil and gas extraction continue to point to reproductive risks, including low birth weight and preterm births. In Pennsylvania, as the number of gas wells increase in a community, so do rates of hospitalization, and community members experience sleep disturbance, headache, throat irritation, stress/anxiety, cough, shortness of breath, sinus, fatigue, wheezing, and nausea. Drilling and fracking operations are also correlated with increased rates of asthma, elevated motor vehicle fatalities, ambulance runs and emergency room visits, and gonorrhea incidence. Benzene levels in ambient air surrounding drilling and fracking operations are sufficient to elevate risks for future cancers in both workers and nearby residents, according to studies. Animal studies show numerous threats to fertility and reproductive success from exposure to various concentrations of oil and gas chemicals, including at levels representative of those found in drinking water. Two dozen chemicals commonly used in fracking operations are endocrine disruptors that can variously disrupt organ systems, lower sperm counts, and cause reproductive harm at levels to which people can be realistically exposed.[13]

Given that significant public health impact is already evident from the build out of the petrochemical industry based on hydraulic fracturing, the continued expansion of this industry, including the pipelines that connect the fracking sites with petrochemical production, processing and export facilities, is not in the public interest. This industry may be technically operating legally due to a special interest exemption from environmental and health protections, but its continued development will come at a tremendous price in avoidable human suffering.

 

Ethical Arguments against expanding fossil-based petrochemical industry.

Climate change and global pollution from synthetic non-biodegradable materials are the existential crises of our time. In addition to carbon dioxide produced from the direct combustion of fossil methane from Marcellus and Utica shales, the proposed power plant to drive the Shell Appalachia Petrochemical facility and the millions of diesel-fueled trucks that connect all the parts of this industry contribute to accelerating global warming. Methane leaks from U.S. oil and gas operations were significantly higher than previously estimated, as were U.S. methane emissions overall, which increased by more than 30 percent over a twelve -year period. Most of this excess methane, which is responsible for 30-60 percent of the recent upsurge of global atmospheric methane, represents leaks from U.S. gas and oil operations.[14]

 

There is a three-layered ethical conundrum surrounding fracking.

  1. The hydraulic fracturing industry only exists because the Halliburton Loophole in the National Energy Act of 2005 gave exemptions from seven federal environmental protection and worker safety standards. It may be legal, but it is wrong to suspend environmental and worker protections to promote the profitable extraction of a fossil resource for the economic benefit of corporations. Using petrochemical liquids from fracking to add to the single-use plastic burden of the Earth is another highly unethical consequence of this industry.

 

  1. Environmental justice issues arise from exposures to people who live in proximity to pollution sources such as fracking operations, coal fired power plants and petrochemical facilities. The areas around such sources are considered “sacrifice zones” where people cannot afford to leave and are subject to pollution for generations. (See the lengthy literature on Baton Rouge cancer alley, for example) There is also the issue of the supremacy of mineral rights over surface rights. This is an ethical issue especially when the surface  rights include essential ecosystem functions such as watersheds, wetlands, forest, prairie grasslands and rivers. In Pennsylvania, where the mineral rights owners are given access to fossil resources even over the objections of surface property owners, the Constitutional protection for natural resources for future generations is ripe for testing in court.

 

  1. Inter -generational justice issues arise as the fracking process extends the use of fossil fuels and infrastructure for its extraction, processing and use for another thirty years. Global warming from increasing greenhouse gas emissions is an existential threat to all life on Earth as we know it. This is a step in the wrong direction.

 

Finally, policies for a just transition for heavy industry need to be developed. As the whole industrial supply chain moves to a more circular system based on sustainable practices for resource management, the fate of existing workers and the human and social needs in the transition must receive focused attention. Economics alone in a market heavily skewed by embedded fossil industry subsidies will not drive a just and equitable transition to a sustainable future. Policies that suspend the environmental and health protections to the advantage of the petrochemical, oil and gas industries at the expense of public health and worker well-being impede progress to a more sustainable future.

 

From the beginning, the industry has been touting the production of jobs and a resurgence of manufacturing in the area. As Shell states in its promotion for the Shell Falcon Ethane Pipeline, “The project will bring new jobs to the area, with up to 1,000 workers at peak of construction and four to six permanent employees when completed.”  [15] The Shell Appalachia Petrochemical project is slated to create approximately 6,000 jobs during the construction phase and a further 600 permanent positions upon completion. However, an investment of the equivalent of the $1.34 trillion anticipated to build out the petrochemical hub in western Pennsylvania may preclude more sustainable and long-term opportunities.  Imagine what the re-investment of this amount of capital in long-neglected communities in Pennsylvania could accomplish with investments in renewable energy systems, regenerative agriculture, and a circular supply chain for products produced by green chemistry processes.  While Pennsylvanians still support natural gas, the level of understanding for the environmental risks of fracking is eroding that support to the extent that 55% of people polled in March of 2018 say the environmental risks of fracking are greater than its economic benefits.[16]

 

It is time to put a stop to this destructive and dangerous build-out of a petrochemical hub in western Pennsylvania.  It is an investment in a backward-looking industry that forecloses better options for the future.

 

Citations and References:

[1]  This statement represents the views of the author alone and does not necessarily represent the opinion of the Mayor of the Borough of Forest Hills or any other Member of the Borough Council.

[2] Ref https://www.fractracker.org/projects/falcon-public-eia/ Accessed April 3, 2018.

[3] Ted Genoways. “Port Arthur Texas: An American Sacrifice Zone.” On Earth. August 26, 2013.    http://archive.onearth.org/articles/2013/08/if-built-the-keystone-xl-pipeline-will-end-in-one-toxic-town Accessed April 3, 2018.

[4] Pollution A to Z. Cancer Alley, Louisiana. Louisiana Forum. http://www.pollutionissues.com/Br-Co/Cancer-Alley-Louisiana.html  Aslo see:  Centers for Disease Control. (2002). Cancer Prevention and Control “Cancer Burden Data Fact Sheets, Louisiana.” Atlanta, GA.  Accessed April 3, 2018.

[5] Constitution of the Commonwealth of Pennsylvania, Article I. Declaration of Rights § 27. Natural resources and the public estate. http://www.legis.state.pa.us/WU01/LI/LI/CT/HTM/00/00.HTM Accessed April 2, 2018.

[6]  Alaska Wilderness League. “SHELL Oil- A Record of Environmental and Corporate Malfeasance.”  June 2012. Page 3. http://www.shellnews.net/wikipedia/documents/CompressedShellReport.pdf Accessed April 2, 2018.

[7] Alaska Wilderness League. “SHELL Oil- A Record of Environmental and Corporate Malfeasance.”  June 2012. Page 5. http://www.shellnews.net/wikipedia/documents/CompressedShellReport.pdf Accessed April 2, 2018.

[8]  https://www.fractracker.org/2018/01/falcon-hca/ Accessed April 3, 2018.

[9] Frack Tracker Alliance. “The Falcon: Routes, Facilities and Easements.” January 27, 2018.  https://www.fractracker.org/2018/01/falcon-routes/ Accessed April 2, 2018.

[10]  Hydrocarbons technology. “Shell Pennsylvania Petrochemicals Complex.”     https://www.hydrocarbons-technology.com/projects/shell-pennsylvania-petrochemicals-complex/ Accessed April 2, 2018.

[11]  J.R. Jambeck, R. Geyer, C. Wilcox, T.R. Siegler, M. Perryman, A. Andrady, R. Narayan, K. L. Law. “Plastic waste inputs from land into the ocean.” Science  13 Feb 2015:Vol. 347, Issue 6223, pp. 768-771 http://science.sciencemag.org/content/347/6223/768 Accessed April 3, 2018.

[12] National Energy Act of 2005 gave exemptins for hydraulic fracturing from provisions of seven federal environmental laws and their associated implementing regulations: National Environmental Policy Act (1969, 2005); Clean Water Act (1972, 1987, 2005); Safe Drinking Water Act (1974); Clean Air Act (1970, 1977, 1990); Resource Conservation and Recovery Act (1976); Emergency Planning and Community Right to Know Act (1986); Comprehensive Environmental Response, Compensation and Liability Act (Superfund)(1980) For further analysis see: Renee Lewis Kosnik. “The Oil and Gas Industry’s Exclusions and Exemptions from Major Environmental Statutes.” Earthworks. 2007.

[13] Concerned Health Professionals of New York & Physicians for Social Responsibility. (2018, March). Compendium of scientific, medical, and media findings demonstrating risks and harms of fracking (unconventional gas and oil extraction) (5th ed.) Pages 114-126. http://concernedhealthny.org/compendium/ Accessed April 3, 2018.

[14] Concerned Health Professionals of New York & Physicians for Social Responsibility. (2018, March). Compendium of scientific, medical, and media findings demonstrating risks and harms of fracking (unconventional gas and oil extraction) (5th ed.) (See footnotes 714-716, 724, 733, 734.)

[15] https://www.shell.us/business-customers/shell-pipeline/falcon/about-the-falcon-pipeline.html Accessed April 3, 2018.

[16] Center for Opinion Research, Franklin & Marshall College.  /StateImpact Pennsylvania Poll. March 29, 2018.  https://www.fandm.edu/uploads/files/708725106986767486-f-m-poll-release-march-2018.pdf  Accessed April 4, 2018.


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Fracking: Health Effects and Worker Safety

Fracking: Health Effects and Worker Safety

By Patricia M. DeMarco

{Summary of remarks at The Battle of Homestead Foundation screening of “Gaswork” by Josh Fox on August 25, 2016}

Hydraulic fracturing (Fracking) for natural gas is touted as the centerpiece of American energy leadership for climate change and economic security. Sadly, this entire industry rests on “The Haliburton Loophole” in the Energy Policy Act of 2005, which grants exemptions from seven major federal statutes intended to protect public health and the environment, including the Safe Drinking Water Act, Clean Air Act, and Toxic Release Inventory provisions. The Fracking Responsibility and Awareness of Chemicals Act to close the Haliburton Loophole has been introduced by Senator Casey (D) PA, every year since 2011 with bipartisan support, but has been kept in committee without a hearing.

Fracking Pollution Sources:

Fracking pollution occurs at all stages of the process: site access and preparation, material transportation, drilling operations, production and processing, gas compression, pipelines, and combustion at the final point of use. Between 2005 and 2016, 137,000 wells have been drilled in 20 states. The industry operates in rural areas of the country, separating the various components of the industrial process to avoid consolidated review of environmental impacts. In many jurisdictions, as is true in Pennsylvania, local government entities are limited in what restrictions they can place on fracking activities. Unfettered by normal environmental and health protections, the industry has expanded rapidly.

In spite of industry assertions of safe practices, evidence of widespread environmental and health harm is accumulating.

  1. Climate Effects. Approximately 4% of the gas produced by fracking is lost through leaks and flaring at the well site, equivalent to 100 million tons of carbon dioxide. Fossil methane is a potent contributor to the greenhouse gases that cause climate change with a 105 times greater impact than carbon dioxide over 20 years.
  1. Surface water and groundwater pollution. Groundwater pollution occurs from well casing leaks, estimated to have a 5% per year failure rate, and leaks through the fractured rock.(Ref) Water contaminants can be mobilized from older pollution sources such as mine drainage from the hydraulic fracturing shocks. Surface water pollution can occur from several paths including discharges and spills at the well site, wastewater disposal, and transportation spills.

Water pollutants associated with fracking disharges include carcinogens such as benzene, toluene, butoxyethanol, and zylene; toxic chemicals including boric acid, methanol, dissolved methane; and 120 endocrine disrupting chemicals such as naphthalene. (Ref)

  1. Air pollution. Drilling gas wells, producing the gas, and completing the wells releases fine particulates, and volatile organic compounds. These also come from spills on site, produced water evaporation pits, flaring gas at the well site, surface transfers, compression stations and processing facilities. In addition, thousands of diesel truck trips for hauling sand, chemicals and materials contribute to local air pollution.
  1. Ground pollution. Produced water from the fracking wells, labeled “Dirty water” legally can be discharged onto the roads for dust control or ice control. Sludge from evaporation pits goes into landfills and some produced water can be added to municipal waste in landfills. The process of developing access roads and pipelines has fragmented habitat in forests and parks, degraded farmland, and contributed to land erosion. Common contaminants include heavy metals such as arsenic and lead, bromides, radioactive isotopes of radon, boron, uranium and chromium, and chlorides from heavy brine.

 

Hydraulic Fracturing Health Concerns

Fracking environment and health effects come from the environmental disruptions of the process, the chemicals used in the slick water hydraulic fracturing process, and the contaminants that are extracted from the shale and brought to the surface with the gas. The most pervasive health effect comes from degradation of the environment and the systems that generate fresh water, fertile ground and the biodiversity of species that support life on Earth. Fracking uses about 500,000 gallons of fresh water per well, causing stress on watersheds, domestic and agricultural water needs, especially in drought stricken areas.

About 649 chemicals are associated with the fracking process. Of these, 75% cause acute skin, eye and respiratory irritation; 40-50% affect the brain, nervous, immune and cardiovascular systems and kidney functions; and 37% are known endocrine disruptors. 25% of the most common fracking chemicals cause cancers and mutations that may take years to emerge. Those most clearly associated with fracking include silicosis, lung cancer, liver cancer, leukemia, Hodgkins lymphoma and reproductive disorders. These are especially of concern because they increase the incidence of birth defects, low birth weight, miscarriages and stillbirths. These kinds of health effects are reported at statistically significant elevated levels among populations within a mile of fracking operations, potentially affecting about 9.4 million Americans.

About 170 thousand workers in the oil and gas industry are exposed to harmful chemicals as part of their regular work experience. Fatal injuries occur at a rate seven times higher than the rate for general industrial workers. Trucking accidents happen when the driver is overcome by exposure to volatile organic compounds during transport of wastes with no cautionary hazard placards. Workers suffer from strange painful rashes and neurological disorders without any idea of what caused them. NIOSH reports that 47% of workers at 111 sites they examined were exposed to levels of fine silicone dust at ten times the allowable level. Many suffered from silicosis and lung cancers from inhaling the fine sand used for propant in fracking. Workers exposure to benzene levels far in excess of the 0.1parts per million standard for occupational exposure was found at 88% of work sites. Most of the workers in the fracking industry are not represented by a union, have no advocate for their health and safety, and often are facing few alternatives to working in dangerous and unhealthy conditions.

Because of the Haliburton Loophole, the fracking health exposures to both the public and the workers are legal, but it is not ethical or morally right to allow such a broad segment of the population to be affected so harshly.

(See https://patriciademarco.files.wordpress.com/2014/10/8-25-2016-fracking-health.pdf for the slides of this presentation.)

 

Data Sources:

OSHA Info Sheet “HAZARD ALERT: Silica Exposure during Hydraulic fracturing” March 25, 2016.   https://www.osha.gov/dts/infosheets/


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The Limits to Methane Regulations- Comment to the EPA

Environmental Protection Agency

EPA-HQ-OAR-2010-0505-4776

Oil and Natural Gas Sector: Emission Standards for New and Modified Sources

My name is Patricia DeMarco. I am a biologist by training with a thirty-year career in energy and environmental policy.[1] I speak on behalf of my grandchildren and the unborn children of the 21st century whose fate we determine by our actions today. I support the EPA’s efforts to regulate the oil and gas development industry as part of the 2009 Endangerment Finding, where the EPA Administrator found that the current, elevated concentrations of greenhouse gases in the atmosphere—already at levels unprecedented in human history—may reasonably be anticipated to endanger public health and welfare of current and future generations in the United States. In your background of the regulation you state:

“As Earth continues to warm, it may be approaching a critical climate threshold beyond which rapid and potentially permanent—at least on a human timescale—changes not anticipated by climate models tuned to modern conditions may occur.” http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2010-0505-4776

 

In the face of such dramatic findings, the regulations proposed here have the effect of putting a Band-Aid on a hemorrhage. The regulations you are considering come late in the process for an industry shamefully protected by Section 322 of the National Energy Act of 2005 with exemptions from the Clean Air Act, the Safe Drinking Water Act and the Resource Conservation and Recovery Act. These exemptions for high volume hydraulic fracturing and other deep drilling operations assure weak regulatory provisions. Nevertheless, as citizens we must reiterate the plea for regulations that take consideration of the public health and safety for those affected by fugitive methane and volatile organic compounds produced at all stages of the gas and oil production process.

 

As you consider the reams of technical comments received in this docket, I ask that you recognize that the hydraulic fracturing process for developing natural gas from deep shale formations happens in neighborhoods, next to schools, in and under parks and on farms where our food is grown. The industry has intruded with impunity into the most intimate parts of communities and sets up industrial operations adjacent to sensitive areas and in watersheds. Fugitive emissions from such operations affect people where we live, work and play. The EPA’s mission is to protect human health and the environment, but has lost the confidence of the people because the industry has eviscerated its capacity to act strongly in the public interest. The EPA’s purpose is to ensure that all Americans are protected from significant risks to human health and the environment where they live, learn and work. These regulations restricting the emission of methane and volatile organic compounds from oil and gas industrial operations must draw a clear line of safety for the public.

 

Hydraulic fracturing now takes place in 39 states, with millions of people living within five miles of a fracking facility. For people in the zone of impact, the national average data used for assessing “significant risk” are not relevant. If your house is within 100 feet of a well, or your school is 200 feet from a compression station, or your business is 300 feet from a processing facility, you are exposed to numerous volatile organic compounds. Theo Colborn and colleagues compiled a list of 632 chemicals (an incomplete list due to trade secrecy exemptions) identified from drilling operations throughout the U.S. Their research found that 75% of the chemicals could affect the skin, eyes, and other sensory organs, and the respiratory and gastrointestinal systems. Approximately 40–50% could affect the brain/nervous system, immune and cardiovascular systems, and the kidneys; 37% could affect the endocrine system; and 25% could cause cancer and mutations.[2]

 

Fugitive methane mobilized by the fracking process has migrated into water supplies, even wells posing significant health and safety hazards to the persons affected. Inquiries for documentation about the number of people for whom the gas companies are providing trucked drinking water were not obtainable, as proprietary information. Requests for documentation of the composition of emissions were not obtainable because the industry has no requirement to disclose, or even measure what they are. This arrogant attitude of disregard for the concerns of people about their health and safety cannot stand.

 

These regulations on methane and VOC emissions should apply to existing oil and gas facilities as well as new and major modifications. Strengthen the requirements for documentation and reporting of leaks at all stages of the operations: Pre-production, Production, Processing and Transmission.[3] Establishing required protocols for monitoring and reporting leakages of methane and volatile organic compounds will contribute to the understanding of this entire system.[4] Annual or semi-annual data collection is insufficient to protect the public health.[5] Continuous monitoring stations should be required for every unconventional oil and gas facility that is within five miles of residences, businesses, schools, parks or populated areas. The data from such monitoring stations should be publicly available, and local authorities should be notified when levels exceed established limits of safety. Corporate voluntary compliance protocols are inadequate to protect the public health and safety.

 

Uncertainty remains over a potential environmental benefit of High Volume Hydraulic Fracturing that has public health implications. Natural gas is more efficient and cleaner burning than coal. When burned, natural gas releases 58% less CO2 than coal and 33% less CO2 than oil. Because of that, it has been promoted as a transitional fuel to begin conversion to greener energy such as wind and solar. Although natural gas burns more cleanly than coal, a recent study argues that replacing all of the world’s coal power plants with natural gas would do little to slow global warming this century. Switching from coal to natural gas would cut the warming effect in 100 years’ time by only about 20%. [6]Although a 20% decrease in warming over 100 years is significant, the consequences of the warming not prevented will have grave implications for public health.[7]

 

If the objective of this regulation is to reduce the emission of methane and other VOC’s as greenhouse gases affecting climate change, I question the effectiveness of the investment contemplated in this regulation as the best way to do so. As stated in the background of this proposed regulation, the EPA estimates the total capital cost alone of the proposed regulation will be $170 to $180 million in 2020 and $280 to $330 million in 2025. This amount of investment in solar and renewable technology implementation would have a far greater positive effect on greenhouse gas reductions with virtually no public health effects. We require a comprehensive energy policy that moves forward to an economy that is not based on fossil fuels. Continuing to build out the infrastructure, fine-tuning the way we extract oil and gas, is not solving the underlying problem.

 

Specific Recommendations:[8]

Recognizing that the process is in motion, the following specific recommendations may help to make these regulations more effective.

 

  1. Require Reduced Emission Completions (REC), also known as “green completion,” to reduce methane and other VOC leaks for all wells, not only gas wells. RECs and green completions refer to technologies that capture methane and other gases at the well head during and after well completion and avoid their release into the atmosphere.
  2. Require Leak detection and repair (LDAR) programs for all stages of oil and gas development.
  3. Require advanced technologies to control fugitive emissions.
  4. Require reduction of diesel particulate matter through the use of cleaner combustion engines and alternative fuel types at oil and gas development operations, especially in the transport of water, wastes and chemicals from High Volume Hydraulic Fracturing operations.
  5. Limit venting and flaring gas associated with oil production and ensure that all gas is captured or used on-site.
  6. Require comprehensive characterization of all pollution sources in unconventional oil and gas development and quantitative assessment of pollutants and emission rates through research and updated federal and state inventories.
  7. Improve air quality monitoring before, during, and after well development and around all sources.
  8. Expand the federal and state ozone monitoring network to better characterize air quality in rural areas highly impacted by pollution from oil and gas development.
  9. Require identification and implementation of adequate and protective setback requirements to reduce the exposure of residents to intermittent and chronic levels of air pollutants and toxins. Such research could draw on findings from analyzing the dispersion of air pollution as a function of the distance from road traffic and consider data from the effects of new or existing setback rules in states with unconventional oil and gas development. See, for example, the study being conducted by the Geisinger Health System in Pennsylvania.[9]

 

In closing, I call for the closure of regulatory loopholes in federal environmental programs to fill data gaps, increase transparency and oversight of the oil and gas industry and ensure public health protections. As the evidence of significant and ongoing public health effects from unconventional oil and gas drilling accumulate, it is unconscionable to continue expanding and protecting this industry. In the interest of protecting the health of our planet and the health of our people, we must cease developing fossil deposits that are destroying our life support system.

 

Thank you.

 

[1] See full Curriculum Vitae at https://patriciademarco.files.wordpress.com/2014/09/patricia-m-demarco-2013-cv.pdf

 

[2] Colborn T, Kwiatkowski C, Schultz K, Bachran M. 2012. Natural Gas Operations from a Public Health Perspective, Human and Ecological Risk Assessment: an International Journal 17(5):1039-1056.

[3] J. Bradbury, M. Obeiter, L. Drucker, A. Stevens, W. Wang. “Clearing the Air – Reducing Upstream Greenhouse Gas Emissions from the U.S. Natural Gas System.” World Resources Institute. April 2013. www.wri.org/publication/clearing-air Accessed September 25, 2015.

[4] Ramon Alvarez, Steven Pacala, James Winebrake, William A. Chaneides and Steven P. Hamburg. “Greater Focus Needed on Methane Leakage from Natural Gas Infrastructure.” PNAS. Vol. 109 no. 17. Pp. 6435-6440. www.pnas.org/109/17/6435 Accessed September 25, 2015.

[5] Bamberger, M., Oswald, R. (2012).Impacts of Gas Drilling on Animal and Human Health. New Solutions: A Journal of Environmental and Occupational Health, 22(1): 51-77.

[6] Finkel ML, Law A. The rush to drill for natural gas: a public health cautionary tale. Am J Public Health. 2011;101(5):784–785.

[7] Howarth R, Santoro R, Ingraffea A. Methane and the greenhouse-gas footprint of natural gas from shale formations. Clim Change. 2011;106(4):679–690.

[8] Tanja Srebotnjak Miriam Rotkin-Ellman. “Fracking Fumes – Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities.” Natural Resources Defense Council. Issue Paper ip:14-10-a. December 2014. http://www.nrdc.org/health/files/fracking-air-pollution-IB.pdf Accessed September 24, 2015.

[9] Geisinger Research, “Geisinger Leads Marcellus Shale Initiative Coalition Explores the Potential Health Effects of Natural Gas Mining in the Region,” Geisinger Research Connections Winter: 1–3, 2013.