Professor Proposes Monitoring Equipment for Gas Well Sites

Morgantown Dominion Post
22 October 2013
By David Beard

CHARLESTON — The WVU professor who studied health and pollution hazards at gas well sites told legislators that rethinking well setbacks may not be the best way to handle those hazards.

He has what he thinks is a better idea.

The Department of Environmental Protection recommended rethinking setbacks in a May letter to legislative leaders based on his study. Law sets a 625-foot setback from the center of a well pad.

But WVU School of Public Health professor Michael McCawley told members of the joint Judiciary Committee on Monday, “The problem with the setback is it assumes everything happens at and is emitted from the center of the pad.” In fact, much action happens elsewhere.

He wasn’t suggesting any operator would do that — simply that it’s legal.

“The answer to all of this, I think is simple and straightforward,” he said. His idea: Fence-line monitoring.

It means the operator would place four or five pieces of equipment — totaling a bit more than $100,000 — in a U-Haul sized trailer stationed at the nearest point of potential impact, whether that be a home, school, hospital or something else.

The trailer would send constant live data to a company monitoring station and allow the company to adjust its operations if any pollutants — the study addressed noise, dust, light and volatile organic compounds (VOCs) — if levels rose too high.

“That’s just good quality control,” McCawley said. “This is a different way of approaching this than the DEP does now.”

McCawley reviewed three problems that his study identified. One, while VOCs were consistently within National Ambient Air Quality Standards, toxic benzene at several sites exceeded Centers for Disease Control safe levels.

Two, the U.S. Environmental Protection Agency sets noise levels but doesn’t enforce them. Noise levels at the pads studied were below the EPA’s guideline of 70 decibels (dB) — the level where hearing loss may occur during extended exposure, the OOG said in its study synopsis. But they did periodically exceed other EPA levels: 55 dB for outdoor activity and 45 dB for indoor activity — the thresholds for annoyance and interference with the ability to hear.

And, moment by moment, they often topped 100 dB, enough to disrupt sleep and lead to cardiovascular problems. “It doesn’t take 100 decibels for very long to wake you up,” he said.

Three, atmospheric inversions trap air in West Virginia’s valleys, concentrating pollutants in one area for potentially long periods. Setbacks don’t address that. “So 625 feet is almost meaningless at that point.”
    While $100,000 may seem like a high figure for a unit, he observed, the trailer is mobile and can be moved from site to site. And the equipment would have a five- to 10-year lifespan, so the cost is spread out.

McCawley agreed with Delegate Woody Ireland, R-Ritchie, that weather and topography won’t always mean that the closest occupied building would be the one most affected. McCawley said the equipment should be placed in the same airshed.

The DEP and operator should discuss placement as part of the permitting process, he said.

In addition, he said, as a good-neighbor gesture, the operator should make the live data available online for public viewing.

McCawley said fence-line monitoring wouldn’t require new legislation. The DEP would just have to tweak its existing power to require “best available control technology.”

McCawley didn’t criticize the DEP for not posing his idea to the Legislature. It’s buried in his report, he said, and really wasn’t part of the question he was asked to answer. “That’s why I’m here.” He’s been preaching this idea for five years and developed some of the equipment the U.S. Department of Energy uses to study pollutants.

Like West Virginia, he said, other states are using some sort of setback law for gas well operations, although Texas requires noise monitors. But varying conditions make some kind of universal setback almost impossible to work with. “We ’re ahead of the curve if we proceed down this path.”

Ireland wondered if fence-line monitoring would allow a shorter setback than 625 feet in some cases. McCawley said yes.

Ireland also asked if Mc-Cawley recommends any further study on pollutants. McCawley said the EPA doesn’t regulate ultrafine particulates, which come from diesel emissions. “They seem to have the ability to do a lot of biological damage,” and can be connected to cardiovascular problems and asthma. Some sites in West Virginia have the same levels as downtowns in some European cities. That needs more research.

Sen. Herb Snyder, D-Jefferson, was a member of the Select Committee on Marcellus shale that developed the original version of the Natural Gas Horizontal Well Control Act, and played a key role in the negotiations that led to the 625-foot compromise. He told McCawley, “This monitoring equipment does sound like a happy medium,” and said legislators will look closely at the idea.

After the meeting, David McMahon, co-founder of the West Virginia Surface Owners Rights Organization, said, “When the bill passed, we supported delegate Ireland, who said it shouldn’t be distance but in fact the pollution levels of noise, etc., that reach people’s houses.” So they also support and appreciate Mc-C aw l e y ’s proposal.

Given the DEP’s stated reluctance to suggest any action other than rethinking setbacks, following three legislative studies, some questioned whether the DEP would take up McC aw l e y ’s idea. Julie Archer, with the West Virginia Citizens Action Group, said, “We agree with him that we don’t necessarily need more legislation. The DEP has the authority to do these things, but I don’t know if they will if the Legislature doesn’t put pressure on them.”

DEP spokesman Tom Aluise said in an email exchange, “Simply placing a monitor with no clear criteria against which results would be assessed would not be a good use of resources in DEP’s opinion. Minimizing emissions does not need to be based on monitoring, but rather practical and technical feasibility.”

Don Garvin, with the West Virginia Environmental Council, said the state needs to rethink setbacks and work with McCawley’s suggestions on monitoring. He was disappointed the meeting didn’t touch on McCalwey’s suggestion for long- and short-term public health studies.

Delegate Mike Manypenny, D-Taylor, played a key role in amending the legislation that became the Horizontal Well Act, and regularly proposes new bills on gas well environmental and surface owner issues.
    “Any monitoring, more monitoring, is always good,” he said. He’d like to see more research on eliminating VOCs at the site by incinerating them at the flowback tanks. But on the topic of setbacks and monitoring, it’s not an either-or, he said.
    “It’s a complex issue. I don’t think there’s any easy answer. … I think it’s a marriage of all of them together.”