Monday, August 5, 2013

PA DEP: The more toxins there are, the more we allow!

PA DEP: The more toxins there are, the more we allow!

What concerns me about PA DEP's analysis is that
"as long as it is below ambient, it's OK".

My question is, how is the "ambient levels" of these toxins established?
What is the graph of how this level changes over time?

This is absurd!

By this rationale, the more pollution has happened
in the past (establishing the ambient or background state),
the the more future pollution will be allowed!!!
It is absolutely inexcusable for a state regulator to be using
"background rates" to establish regulations for public safety.

To me, this is similar to establishing a "background rate of murder",
or "ambient levels of rape". As long as the number of violent crimes
stays below the ambient levels, it's not cause for concern.

Sorry, that's Bullshit.

Of course NE-PA will have high ambient levels!

Susquehanna County PA now has something like 25 compressor stations
in operation, and at least another 5 permitted.

How many well pads? How many miles of gathering lines?

How many facilities which do gas refining? (Dehydration? NGL sep., Sour Gas scrub, etc)?

Here is a fact: SOURCES OF AIR POLLUTION
  • All well pads are emitters of GHGs, VOCs, CO2, CH4, NOx, SO2, etc. etc.
  • All gas processing facilities are emitters of GHGs, VOCs, CO2, CH4, NOx, SO2, etc. etc.
  • All compressor stations are emitters of GHGs, VOCs, CO2, CH4, NOx, SO2, etc. etc.
Of course NE-PA will have high ambient levels!
So even more is OK?

NO!


Baseline reference should be established as to SAFE levels, NOT ambient
Instead, it seems to me that the baseline reference should be established
as to what SAFE levels are.
Air quality testing should be tested AT THE POINT OF EMISSION

The other problem, which PA DEP is well aware, is HOW these air quality testing is done.

Air pollutants disperse quickly in turbulent air. Up, down, every which way.

Ground-based summa canisters which are placed
at some radius R away from the point source of emissions
will AT BEST be able to detect in the range of 1/(R^2)
or perhaps 1/(R^3) -- since we are talking about 3D space.

And due to how air currents move and change, there is a an intrinsic
VERY LOW PROBABILITY that detectable levels of pollutants will be detected
as R is increased.

Only taking R to ZERO (i.e., taking the measurement AT THE
POINT OF THE EMISSIONS) will the PA DEP be able to get an idea about
the emission from that source, and ONLY THEN by aggregating ALL of these
various sources from all over the Gaslands, will PA DEP be able to get a sense
of the cumulative impacts of gas drilling.

PS: New York State, were I live, is both DOWNWIND and DOWNSTREAM
from fracking operations in PA. So I am VERY CONCERNED and disturbed
by what is going on there.

Thanks for your attention to this matter,
William Huston,
Binghamton NY




On Mon, Aug 5, 2013 at 10:27 AM, Vera Scroggins   wrote:


From: aludra
Sent: Monday, August 5, 2013 10:16 AM
Subject:  Fwd: PA DEP "Odor" complaint during frac job, summa cannister results, 4 organics detected in elevated concentrations


-----Original Message-----
From: Wejkszner, Mark <mwejkszner@pa.gov>
To: aludra, finan.frank  mwalker
Cc: Bellas, Roger <rbellas@pa.gov>; Connolly, Colleen <coconnolly@pa.gov>
Sent: Tue, Jul 2, 2013 9:09 am
Subject: RE: PA DEP "Odor" complaint during frac job, summa cannister results, 4 organics detected in elevated concentrations

Rebecca, thank you for providing us the results of your summa canister.  We reviewed the concentrations and found that the levels detected on your property are consistent with ambient levels throughout the state.  We also had our Harrisburg staff review the results and compare them to what has been analyzed throughout the state and they confirmed that these levels are what one would expect everywhere at generally the same concentrations.  The results are as follows:
Compound                                         Rebecca's Result converted to ppb         PA ambient levels ppb
Chloromethane                                              0.5314                                                        0.569
Trichloroflouromethane                                0.2669                                                        0.264
1,1,2-trichloro-1,2,2-trifloroethane              0.0821                                                        0.089
Carbon Tetrachloride                                    0.0986                                                        0.092
If you have any questions please feel free to contact our office.
Sincerely,
Mark J Wejkszner, P.E. | Program Manager
Department of Environmental Protection | Air Quality
Northeast Regional Office
2 Public Square | Wilkes-Barre PA 18701
Phone: 570.826.2528 | Fax: 570.826.2357
From: aludra
Sent: Friday, May 31, 2013 1:43 PM
To: Wejkszner, Mark; finan.frank  mwalker
Subject: Re: PA DEP "Odor" complaint during frac job, summa cannister results, 4 organics detected in elevated concentrations
Dear Mark,
           I attached the report and Wilma Subra's comments. There were 4 organic compounds detected over detectable limits. Rebecca
-----Original Message-----
From: Wejkszner, Mark <mwejkszner@pa.gov>
To: aludra
Sent: Wed, May 29, 2013 12:00 pm
Subject: RE: PA DEP "Odor" complaint during frac job, summa cannister results, 4 organics detected in elevated concentrations
Rebecca, can you provide a copy of the summa canister results? 
Thanks,
Mark J Wejkszner, P.E. | Program Manager
Department of Environmental Protection | Air Quality
Northeast Regional Office
2 Public Square | Wilkes-Barre PA 18701
Phone: 570.826.2528 | Fax: 570.826.2357
From: aludra
Sent: Thursday, May 23, 2013 3:32 PM
To: Wejkszner, Mark
Subject: Fwd: PA DEP "Odor" complaint during frac job, summa cannister results, 4 organics detected in elevated concentrations
Dear Mark Wejkszner,
            I apologize for not including you in this original email. I thought it appropriate for you to be in this loop. The summa results show CHLOROMETHANE, TRICHOLOROFLOUROMETHANE, 1,1,2-TRICHLORO-1,2,2-TRIFLOUROETHANE, and CARBON TETRACHLORIDE in elevated levels exceeding the MRL.
           I had requested at the last PA DEP Public hearing for the Williams Central Compressor that PA DEP provide a running tally, simple addition, of all the major categories of air pollution  PA DEP notes in their issued" Air Quality Permits":NOX, HAPS, VOCS, SOX.  You issue the permits for natural gas compressor stations, you have the data, our tax dollars fund PA DEP. Please consider providing the public with this information.  I am looking forward to hearing PA DEP's report about the fire last week at the Williams Central Compressor, about a mile up the road from my house.
                                                           Thank You,
                                                          Rebecca Roter
                                                          Brooklyn PA Susquehanna CO
-----Original Message-----
From: aludra 
To: mcooley <mcooley@pa.gov>; coconnolly <coconnolly@pa.gov>; llegere <llegere@timesshamrock.com>
Sent: Thu, May 23, 2013 11:51 am
Subject: PA DEP "Odor" complaint during frac job, summa cannister results
Dear Mr Cooley,
               I have independent summa canister results showing 4 organic chemicals in elevated concentrations, over the "MRL" obtained from a backyard adjacent to this site, the Cabot Teddick pad on Turnpike Rd, Brooklyn PA Susquehanna CO. The summa canister was put in place during the frac job. The lab used is EPA certified. Did PA DEP use the mobile air unit to do any air testing at the Teddick pad while fracing was underway...taking wind direction into account? I see your mobile unit was in Elk Lake and nothing out of the ordinary was detected. Did you confirm the compressors were up and running and that the Lathrop station was in full operation with all dehydrators on and all the gas flowing? Did Williams provide their operators info the station was fully operational when you were "testing"?
                                                           Thank You,
                                                           Rebecca Roter 
-----Original Message-----
From: Cooley, Marc B <mcooley@pa.gov>
To:'aludra
Sent: Wed, May 1, 2013 11:41 am
Subject: RE: Odor Complaint....frack site Susquehanna CO PA
Ms. Roter,
Upon receipt by the East District Oil & Gas program of your e-mail below, the referenced Teddick well site hydro-fracking operations were inspected on Tuesday 4/30/13 and nothing out of line was documented.
No inordinate volume of dust was observed, the operation appeared to be conducted as per standard procedure.
It was reported to the Department while on-site that OSHA personnel had previously visited the site during the hydro-fracking operations finding no problems.
Marc Cooley | Environmental Group Manager
Department of Environmental Protection | North Central Regional Office
208 West Third Street Suite 101 | Williamsport PA 17701
Phone: 570.327.0553 | Fax: 570.327.3420
www.depweb.state.pa.us
From: Cooley, Marc B
Sent: Tuesday, April 30, 2013 1:35 PM
To: aludra@aol.com
Subject: FW: Odor Complaint....frack site Susquehanna CO PA
Ms. Roter,
The information in your e-mail below has been received.
Your concerns regarding the hydro-fracking operation at the referenced site will be assessed at the Department's earliest opportunity.
Regarding your noise concerns, please be advised that the PaDEP does not regulate noise.
That is a matter handled by ordinance at the local municipality level.
Marc Cooley | Environmental Group Manager
Department of Environmental Protection | North Central Regional Office
208 West Third Street Suite 101 | Williamsport PA 17701
Phone: 570.327.0553 | Fax: 570.327.3420
www.depweb.state.pa.us
From: aludra
Sent: Friday, April 26, 2013 10:13 PM
To: Aileo, Maribeth; Connolly, Colleen
Subject: Odor Complaint....frack site Susquehanna CO PA
Dear Ms Nestor,
                  I am not sure if you are the correct person to report an odor complaint to at DEP Northeast: I am ccing Colleen Connolly. I live on Turnpike Rd in Brooklyn Township, my mailing address is 575 Turnpike Rd Kingsley PA 18826. There is a Cabot well pad about 1500 feet up my road, on the Teddick property. The fracking started this past Monday, 2/22/13. Today around 4pm I think the wind shifted as all of a sudden it was REALLY LOUD. Along with the noise came a bad smell. Standing on my porch, walking to my mailbox, I smelled a chemically manurey diesel smell. It left a weird chemical taste on my tongue and lips.  I drove to the pad and saw the wind sock blowing my way.  I got a slight headache. The plumes of silica are visible. Please let me know if this is sufficient to file an odor complaint with DEP and if a field agent will call me to follow up.

                                                                      Sincerely,
                                                                    Rebecca Roter
                                                                


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