Marcellus Shale

Fear is Toxic: EWG and PSE Anthology of SGEIS Claims Debunked Part II

The Environmental Working Group (EWG) and Physicians, Scientists and Engineers for Healthy Energy (PSE) released a ten point document criticizing the SGEIS.  This is the second part in a two part series examining that document which serves as an example of why environmental activists are having difficulty maintaining support in New York.

They say that necessity is the mother of all invention, watching the debate over natural gas development in New York it becomes apparent anti-natural gas ideologues are at the end of the road.  Unable to gain traction on their claims, they are now recycling debunked talking points and bringing in clean-up hitters like Josh Fox in an attempt to scare Governor Cuomo like they have tried with everyone else.  Luckily, the truth always prevails and the Governor is too smart to be bullied, especially by the likes of Fox and friends.

EWG/PSE Myth #4: Underestimate of radioactive pollution; lack of a disposal plan

The Simpsons radioactive man

When all else fails, and normal scare tactics fail to gain traction, use the word radioactive, over and over again to scare the hell out of anyone listening.  In this document EWG and PSE reference a New York Times investigation (by known shale critic Ian Urbina) which declared radioactive waste was fouling Pennsylvania’s waters. EWG and PSE even use this example to paint a picture of thousands of unsuspecting Manhattan residents drinking radioactive water turning New York City into the next Chernobyl.

Reality:  In assessing the radioactivity inherent in the Marcellus Shale underlying the Empire State, the Department of Conservation found:

  • “[B]ased on the analytical results from field-screening and gamma ray spectroscopy performed on samples of Marcellus Shale NORM [naturally occurring radioactive material] levels in cuttings are not significant because the levels are similar to those naturally encountered in the surrounding environment.” (Executive Summary, p. 13)
  • “[T]he results [of gamma ray spectroscopy tests], which indicate levels of radioactivity that are essentially equal to background values, do not indicate an exposure concern for workers or the general public associated with Marcellus cuttings.” (Chapter 5, p. 5-34)

This wasn’t a guess based on reviews of previous study, it was an assertion based on the analysis of Marcellus Shale core samples using gamma ray spectroscopy.  But what of the horrible situation in Pennsylvania where all the rivers were clearly glowing green from radioactivity?  Again, the facts tell a far different story.  Continued comprehensive water monitoring by PA DEP, the state’s largest private water utility and 14 water supply agencies all showed the state’s waters continue to meet levels prescribed by the Safe Drinking Water Act.  Further, they have never exceeded background levels of radiation naturally present in Pennsylvania’s rivers and streams.

 EWG/ PSE Myth #5: Use of Outdated Studies to Assess Greenhouse Gas Impacts

The paper criticizes DEC by claiming they understate greenhouse gas emissions that are released from hydraulic fracturing operations citing an EPA study based on estimates from 9,000 natural gas wells.

Reality:  In preparation for compliance with EPA’s first federal air standards for natural gas wells that are hydraulically fractured, additional studies were released.  The most comprehensive study conducted on the issue found methane emissions in the EPA’s 2010 emission inventory were inaccurate by an order of magnitude of two to one.  The study, sanctioned by the American Petroleum Institute and America’s Natural Gas Alliance, was conducted independently by the URS Corporation utilizing a data set of nearly 91,000 wells. EPA’s study relied on data from 9,000 wells. Of course, this isn’t the first study to question EPA’s findings.  Earlier, the respected firm IHS-CERA took a hard look at the EPA study referenced by EWG and PSE.  They were very critical of the agencies findings based on erroneous assumptions made on the management of natural gas during well development and stimulation. From the report:

  • EPA’s current methodology for estimating gas field methane emissions is not based on methane emitted during well completions, but paradoxically is based on a data sample of methane captured during well completions.
  • The assumptions underlying EPA’s methodology do not reflect current industry practices. As a result, its estimates of methane emissions are dramatically overstated and it would be unwise to use them as a basis for policymaking. The recent Howarth study on methane emissions makes similar errors.
  • If methane emissions were as high as EPA and Howarth assume, extremely hazardous conditions would be created at the well site. Such conditions would not be permitted by industry or regulators. For this reason, if no other, the estimates are not credible.

What is most interesting about this “criticism” however is what it leaves out.  It seems the authors either missed, or chose to ignore, the fact that increased natural gas use in U.S. power generation, facilitated by shale development, has enabled the U.S. to significantly reduce its carbon footprint.  In fact, since 2006 the U.S. had led the world in carbon reduction and is meeting goals that were sought under failed cap and trade legislation.  This is an environmental success story, an inconvenient one at that for our anti-development friends.

EWG/PSE Myth # 6: Lack of a health assessment

This one has had anti-natural gas activists in a firestorm and has served as one of their most effective rallying points.  Of course, like so many other claims nothing could be further from the truth.

Reality: A cursory review of the SGEIS and historical experience show this claim as bunk.  In reviewing the DEC website a reader finds that on December 13, 2010 then Governor Paterson “ordered DEC to conduct further environmental review to ensure that all environmental and public health impacts are mitigated or avoided and to present this information to the public for further review.”  Clearly examining environmental and public health impacts, and determining strategies to mitigate those impacts, was a topic under no less than two Democratic governors.

In addition, a recent University of Buffalo study found the SGEIS would put into place a regulatory system that would avoid incidents experienced in other states that could impact health and the environment.

But what about these unavoidable public health impacts?

A closer look at available data and health statistics in areas where natural gas development has taken (or is taking) place suggest the assertions put forth by those who oppose energy exploration on the basis of health concerns are largely without merit.

In the Dallas-Fort Worth area, the 4th largest Metropolitan Statistical Area (MSA) in the United States and home of the prolific Barnett Shale, more than 16,000 natural gas wells have been developed over the past decade.  Quoting a pair of public health researchers, “If health impacts would be found anywhere on a longitudinal basis, it would be here.”

To determine potential impacts the researchers closely examined Community Health Status Indicators (CHSI) data for this MSA from 2000 to 2008 in areas of high productivity, specifically Denton County. What they found was as natural gas development expanded significantly in the area over the past several years, key indicators of health improved across every major category. As natural gas production expanded and developed, the health of the populations in counties experiencing development simultaneously increased.

Further data from the Texas Commission on Environmental Quality (TCEQ) on Dish and Dallas-Fort Worth showed that after two years of extensive monitoring there have been no chemicals measured above levels of concern for public health.  TCEQ also reported that “There are no immediate health concerns from air quality in the area, and when they are properly managed and maintained, oil and gas operations do not cause harmful excess air emissions.”  In addition, while total gas production increased by 94 percent from 2000 to 2009, the levels of ground level ozone fell by nearly 15 percent.

The entire premise of the SGEIS document is “to ensure that all environmental and public health impacts are mitigated or avoided.” The idea that public health was not taken into account, and public health professionals were not consulted is false. According to the SGEIS, NYSDEC consulted at length with the New York State Department of Health (NYSDOH) to determine potential exposure pathways and the toxicity of all constituents of concern.  This is noticeable in correspondence between the then NYSDOH’s Director of the Division of Health, Dr. Edward G. Horn, and Bradley Field, the Director of the Division of Mineral Resources of the NYSDEC.

Indeed, many agencies solely focusing on the protection of public health participated in the effort, including offices in the NYSDOH Center of Environmental Health, the Bureau of Toxic Substances Assessment, the Bureau of Water Supply Protection and the Bureau of Environmental Radiation Protection.  All of these agencies reviewed information that included “confidential business information identifying the chemical composition of products used or proposed for hydraulic fracturing of gas wells in New York.”   They also reviewed flowback and production fluid data from West Virginia and Pennsylvania, specifically as related to toxicological data from the human health perspective.

EWG and PSE Myth# 7. Lack of basic data on underground water supplies, faults and floodplains

Here again history is ignored and the authors point to their interpretation of a USGS report that was in effect hijacked to suit the purpose of their cause.  In this myth, EWG and PSE also reference recent historical flooding, and the state’s lack of knowledge on flood plains as reasons to delay development.

Fault Line

Reality: First of all let’s address the flooding supposition. It’s an interesting assertion  that natural gas wells in floodplains will cause environmental challenges.  After all, during the historic flooding that befell upstate New York and central and northeast Pennsylvania last year activists drove across Pennsylvania looking for pictures of flooded natural gas rigs. Fortunately for us, and unfortunately for them, not a single natural gas well was compromised.  When faced with this reality, activists groups posted pictures online claiming a flooded natural gas rig in Pakistan was actually in Pennsylvania.  The picture even came complete with a caption that read, “Here’s more evidence Marcellus Shale drilling pads should NOT be allowed in floodplains.”

But on to the science surrounding fault mechanics and fluid transfers. According to USGS data, most aquifers in New York like this one, and this one as just a few examples, are less than a few hundred feet below the earth’s surface making it highly unlikely that an induced fracture, at even the shallowest point in the Marcellus, has the potential to reach groundwater aquifers.  This point is proven by the development of the nearly 5,000 Marcellus wells in Pennsylvania in recent years.

Fictional images of pressurized fracturing fluids that could somehow migrate through underground faults or fractures to groundwater are neither scientifically supportable nor ever documented despite drilling and fracture stimulating over a million wells. Hydraulic fracturing is simply the very short lived, few-hour application of localized hydraulic pressure on the target reservoir creating fractures of limited vertical height at depths thousands of feet below the earth’s surface. After the short lived stimulation, the localized induced pressure is then quickly released and the gas and un-trapped fluid is flowed back through the wellbore. The wellbore thus becomes a pressure sink with any available gas and fluids moving to that pressure sink and up to the surface through the wellbore that has triple or often quadruple redundant layers of steel casing and cement plus tubing that protect the shallow groundwater sources. Any fractures that have not been propped open with sand rapidly close under the tremendous pressures of the overburden and lateral tectonic stress. The only gradient and permeability path to move the un-trapped fluid is toward the wellbore as demonstrated from field experience, reservoir simulation and fracture architecture modeling.

Fluid flow dynamics, as exhibited in Darcy’s Law, require permeability and sustained pressure gradients to move whatever remaining water is left otherwise it will stay in place due to natural forces.   First the permeability and pressure gradient is to the wellbore and not vertically through the impermeable overburden. However in reality most of the fluid is also trapped for geologic time within the Marcellus Shale.


This latest salvo is predictable from our friends on the other side. The irony in their actions runs deep.  Merely a week after the release of this report Josh Fox takes to the New York airwaves to release the “Sky is Pink,” a short film parrots their some of these concerns. In it Fox argues the natural gas industry is out to deceive the world by instilling doubt in science.  All the while EWG, PSE and Fox develop nuanced arguments that explicitly avoid known science, twist its facts, and in some cases ignore its findings all together.

Isn’t it ironic? Don’t you think?



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