The Pennsylvania Land Trust Association, a coalition of conservation organizations, wanted to conduct a report on the number of violations which have occurred in the course of Marcellus Shale drilling operations. In order to obtain the necessary information they made a Right To Know Request to the Department of Environmental Protections which is responsible for policing environmental requirements and keeps records of all violations.
The association had only a small staff to devote to the project, so when the DEP offered to send a spread-sheet with a list of all the violations, the association accepted it. The report compiled by the association from this information throws much light on the reality of drilling operations.
However, because it came in spread-sheet form, there was information missing which keeps the report from being comprehensive. Elana Richman, projects coordinator for the association and co-author of the report, said the report does not give a portrait of the size of the spills. "We don't know their severity," she said.
"To figure out the severity of the spills requires cross-referencing the date and type of a violation to an area newspaper which reported on it," she said, "this is hard though because originally a lot of this material wasn't covered in newspapers."
The report also does not say what types of penalties were levied against the offending companies. "Again, we're not sure," said Richman, "there have been some orders to temporarily stop drilling and some operators have voluntarily suspended their operations but we haven't heard of any sites being permanently shut down."
The value of the report lies in the sense of scope it gives to the practice as well as creating categorizations of the different types of violations that have occurred. "Even though we don't know the exact size of some of these spills, we can see that different types of violations, such as Discharge of Industrial Waste, are obviously going to have a detrimental impact," said Richman.
There were 154 violations in the Discharge of Industrial Waste category. A violation falls into this category if involves improperly releasing industrial waste onto the ground; polluting waters of the commonwealt; and drill cuttings, brine and oil discharged into streams.
This is an especially important category because of the toxicity of the chemicals. Of the hydraulic fracturing chemicals analyzed, over 94% can cause skin, eye and respiratory harm, 93% can harm the gastrointestinal system and 83% have brain and nervous system effects. Over 40% can affect the kidneys, over 40% can affect the immune system and over 20% are endocrine disruptors. (The Endocrine Disruption Exchange: "Products and Chemicals Used in Fracturing" February 2009).
The Pennsylvania Land Trust Association is comprised of eighty of Pennsylvania's most active conservation organizations. These organizations elect the board and set PALTA's purposes. The organizations in turn count more than 100,000 Pennsylvanians as members and contributors.
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In the wake of the BP disaster, there is tremendous public distrust of the oil & natural gas industry. Transparency is the key to alleviating this problem. Locally, this distrust has been focused on a process used in oil & natural gas exploration – hydraulic fracturing. Used on over a million wells since the technology was discovered 1949, it remains mysterious and even frightening to the public.
The industry has maintained that the process is safe, and is even beneficial for the environment – by substantially enhancing the production of wells, we can reduce the total number of wellbores drilled.
However – the public remains skeptical. Perhaps the biggest reason is the unwillingness of oil & natural gas companies to disclose the chemical additives (that account for less than 0.5% of total fluids) used in the process. The reason for this was (legitimately) to protect the engineering work invested in developing stimulation chemistries. The leading service companies in this line of work have highly paid chemical engineering staff that work to optimize well treatment programs. If disclosure is required, companies that invest in chemical engineering would be at a competitive disadvantage to those companies that just pirate their competitors’ recipes.
This week, Range Resources announced its voluntary disclosure policy. Service companies working for Range will have to disclose the exact makeup of their stimulation program. Here is a link to a sample of Range’s disclosure form:
http://www.rangeresources.com/Disc2/RRC%20sample%20marcellus%20disclosur...
This is a great first step in developing public trust.
The article references 154 violations that constitute discharge of industrial waste. Without further detail, the public will likely assume that most of these are very serious. Some may be. But consider a chemical used in almost every hydraulic stimulation job: Chlorine. According to Wikipedia:
“Chlorine is a toxic gas that irritates the respiratory system...Coughing and vomiting may occur at 30 ppm and lung damage at 60 ppm. About 1000 ppm can be fatal after a few deep breaths of the gas.[4] Breathing lower concentrations can aggravate the respiratory system, and exposure to the gas can irritate the eyes…When used at specified levels for water disinfection, the reaction of chlorine with water is not a major concern for human health”
The article cites the statistics relating to skin, eye, respiratory, etc. Chlorine (in a highly concentrated form) has the potential to destroy any and all kinds of flesh. But we use it in our drinking water, and we use it in our pools and spas.
If a natural gas company spills a barrel of dilute water/chlorine solution, it constitutes a “discharge of industrial waste”. If I dump my hot tub in the back yard, nobody seems to notice. I state this not to dismiss concerns, but to provide some context to the discussion.
Regarding the “The Endocrine Disruption Exchange” – this radical organization produces non-peer-reviewed allegations - including the notion that hydraulic fracturing is causing widespread impotence across America.
Again – my point is not to dismiss legitimate concerns. But, with more than a million wells that have undergone hydraulic fracturing – spanning over 60 years, it would seem that we would have a mountain of documented cases.
Hopefully, industry will continue its slow march into the sunshine – everyone will be more comfortable in under the light of disclosure.