Air & Water Quality
Questions & Answers Related to the Ambient Air Study Performed by TITAN Engineering
Since its release on July 12, 2010, several questions have been asked about the “Ambient Air Quality Study."
1) How much did the study cost? Where did the funding come from?
The study cost approximately $350,000 and it was paid for by the members of the Barnett Shale Energy Education Council, comprised of energy producers, pipeline companies and related energy vendors not only committed to promoting energy education, and also best practices as it relates to oil and gas leasing, drilling, production, transportation and marketing responsible for 90 percent of natural gas operations in the Barnett Shale.
2) Some will say that we can’t trust the results of this study since it was paid for by industry. How do you respond?
We recognize that some may suggest this study was conducted on behalf of industry and therefore is biased; however, we were vigilant in our efforts to produce a transparent test that is independent and scientifically sound. The study was conducted by a fully licensed engineering firm who certified and sealed it in accordance with state law. As such, producing invalid studies, or studies based on substandard work or invalid principles, or outright falsifying data would subject the firm and the certifying engineer to both civil penalties and forfeiture of licenses. The firm, TITAN Engineering Inc., utilized best practices, analytical methods and standards used by the U.S. Environmental Protection Agency (EPA) and the American Society for Testing. Furthermore, both theTCEQ and the City of Fort Worth had input in the design of the study. The study can be found online here in its entireity including all lab reports.
3) Why did TITAN send samples collected for the air study to be analyzed by outside labs?
The vast majority of environmental engineering/consulting firms do not have in-house analytical laboratories for any number of reasons including: (1) The capital costs are exceedingly high; (2) It is a highly specialized industry with exact expertise and certifications required (i.e., it is not something you "dabble" in); (3) Most importantly, because it can present a conflict of interest when the firm recommending the number of samples is also the firm making money on the number of samples.
In fact, TITAN's use of independent, licensed third-party laboratories lends more legitimacy to the study, not less.
4) Why were all of the operators notified of site testing in advance of samples being collected?
One of the study's intents was to establish sample locations where the maximum chemical concentrations were predicted to be found by computer modeling. Consequently, the vast majority of sample locations were inside the producer properties, which are secured for safety purposes and in at least one instance, secured in compliance with federal safety laws. TITAN had to notify the producers prior to each sampling event and had to ensure that certain site maintenance activities would be suspended during the time of testing, such as those which could compromise the study results (e.g., painting). TITAN also had to make sure that the sites would be operated "normally", i.e., no wells were being shut‑in or re‑worked during the time of testing. As noted in the report, TITAN was able to document "normal" operations, based on production record reviews and observations by TITAN field personnel.
5) Why was the City of Fort Worth involved in the study?
Public environmental officials from both Fort Worth and the TCEQ were invited to select the compressor stations they wanted tested without input from TITAN, the BSEEC, or the producers, adding more legitimacy to the study.
6) Why were only 10 sites chosen for testing?
This study was not designed to evaluate a representative amount of randomly selected natural gas sites using statistical methods. Instead, the intent of the study was to identify and test the site in each City Council District with the highest projected benzene emission rate, as benzene is the study's target compound due to its known toxicity. In scientific and/or engineering analyses, this is a common and useful approach when it is not practical to test all sites, with the idea being that the results may allow reasonable conclusions to be drawn with respect to all sites. Given more the more than 1,000 natural gas wells in the area tested, this was the most practical approach. TITAN also preferred this approach because with the representative/random approach, a higher-emitting benzene site may not be tested and would therefore allow doubt and concern to remain with the public.
7) Active drilling sites where fracturing and flaring are occurring weren’t tested. Why did the study only include completed well sites?
Active drilling sites, including fracturing and flaring activities (if applicable), are short-term in nature (weeks/months), whereas compressor stations and completed well sites are expected to have 20-50 year operating lives. Since exposure to benzene for long periods of time is the most critical consideration for health effects, this is where TITAN’s efforts were focused. Furthermore, gas is not typically produced during active drilling operations (Note: there are emissions during active drilling, but they are from diesel engine exhaust). Based on the above, TITAN, the TCEQ, and the City of Fort Worth included compressor stations and completed well sites in the study.
8) The study concluded 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 that natural gas operations are contributing to emissions such as carbonyl sulfide. Why is this?
Natural gas sites, like virtually every other industry and manufacturing process, emit chemicals into the air as a by-product of their operations. That is why the TCEQ and the EPA have air permitting programs, to ensure that industrial emissions are limited to safe levels. TITAN did find that some of the sites had emissions which produced increased ambient air concentrations in the site vicinity. However, none of the site-related concentration impacts exceeded the health-based criteria as established by the TCEQ, EPA or Agency for Toxic Substances and Disease Registry.
9) The study states that elevated formaldehyde concentrations found at some of the sites tested are not being caused by natural gas operations, but instead are being caused by both vehicular traffic and an unidentified source. However, TITAN was unable to identify any type of emission source that could have caused or contributed to the formaldehyde concentrations. How can we be sure it is not from natural gas operations?
The report contains two pages of analysis with respect to these findings, which were jointly developed by TITAN’s senior air consultant, a degreed chemical engineer with over 20 years related experience and TITAN’s senior air dispersion modeler, a degreed meteorologist with over 30 years related experience. One of the two main study purposes was to assess the natural gas site contributions to measured concentrations. Based on the analysis, TITAN did that by ruling out the site as the source of the elevated formaldehyde concentrations. Specific identification of any off-site sources was only a secondary intent of the study, to be done where possible. TITAN could not specifically identify the source to the south/southwest but the data shows it was undoubtedly there and we don't make-up sources, or assign responsibility to other known sources in the area without specific proof.
10) Does TITAN have business connections with companies drilling in the Barnett Shale?
TITAN has undertaken projects for some operators in the Barnett Shale region including Chesapeake, EnCana and XTO Energy. However, based on 2009 revenues, natural gas operators and producers do not represent a significant portion of the firm’s revenue. In fact, only 7 percent of TITAN's 2009 revenues were derived from the entire natural gas industry and most of that (5 percent) was from mid-stream companies, not producers. In just the last 2 years, TITAN has completed work for 32 of the Fortune 500 companies over a diverse set of industries including Aerospace, Financial/Insurance, Chemical/Petrochemical, Power Generation, Food and Beverage, Oil and Gas, Semiconductor, Telecommunications, and Transportation (Railroad, Airline).