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Comments to Fort Worth Independent School District Board of Trustees Ed Ireland, Ph.D. Executive Director Barnett Shale Energy Education Council March 8, 2011
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Topics Addressed Carbon Disulfide: Not a problem Setbacks: One mile not necessary Minerals leases: Once a drilling unit is finalized, the opportunity to participate has passed
Carbon Disulfide is NOT associated with natural gas produced in the Barnett Shale in Fort Worth
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Analyses show minute to no amount of hydrogen sulfide in the Barnett Shale
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Without hydrogen sulfide, carbon disulfide cannot be formed
Carbon Disulfide: Not a problem
Natural gas wells cannot emit compounds into the air if they are not present in the composition of natural gas
EPA says that the primary sources are biogenic sources such as decomposing organic matter Industrial sources; used in the production of rayon, cellulose, rubber and in metal plating
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Setbacks: One mile NOT necessary BSEEC/TITAN Engineering study City of Fort Worth/ERG study Flower Mound/Kleinfelder air testing Mickey Leland National Urban Air Toxics Research Center/Desert Research Institute
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Setbacks: One mile NOT necessary BSEEC/TITAN Engineering Study “Based on the results of this study and the health effects criteria employed, TITAN concludes that harmful levels of benzene and other pollutants are not being emitted from natural gas sites in the study area.” – Doug Canter, P.E, Principal, TITAN Engineering
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Setbacks: One mile NOT necessary Mickey Leland/DRI Study Findings Initial hypothesis was that a problem existed; conclusions showed no problem found “Carbon disulfide was present in very low concentrations in 1-hour canister samples, below 0.05 ppb.” “The average concentrations of species …were low, generally below 1 ppb.”
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Setbacks: One mile NOT necessary Mickey Leland/DRI Study Findings “There was a steep, exponential decrease in emission concentrations from the site closest to an emission source.” “The concentrations of emissions from the tank decreases to near background levels at the distance of approximately 100 meters.”
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Setbacks: One mile NOT necessary Mickey Leland/DRI Study Findings “This steep decrease in concentration is very similar to that observed in other studies (for example, in the 2009 API exposure Classification Project) , where measured downwind pollutant concentrations decrease to upwind background levels within about 100 m of a roadway.”
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Setbacks: One mile NOT necessary 1.0 is the maximum relative value for each compound. None of the averages exceeded the ESL. Source: Mickey Leland National Urban Air Toxics Research Center Air Quality Study, July 2010
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Setbacks: One mile NOT necessary Mickey Leland/DRI Study Findings “Monitoring of Emissions from Barnett Shale Natural Gas Production Facilities for Population Exposure Assessment,” Final Report, November 11, 2010 Prepared by Division of Atmospheric Sciences, Desert Research Institute for Mickey Leland National Urban Air Toxics Research Center Conducted near Rhome, Texas, last summer Objective was to provide a “better understanding of the potential contributions of emissions from gas production to population exposure”
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Setbacks: One mile NOT necessary Flower Mound/Kleinfelder Study “…concentrations appear to be consistent with published background ambient air concentrations…” “No VOC noted exceeded the AMCV or ESL criteria”
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Setbacks: One mile NOT necessary Flower Mound/Kleinfelder Study “Based on the above considerations, the identified RSCs (reduced sulfur compounds) are not considered a health concern and may be present only as an artifact of sampling and analyses with low detection limits. Additionally, based on previous sampling by Kleinfelder for baseline efforts in other undeveloped areas of the DFW Metroplex, similar and even higher elevated concentrations of carbon disulfide and carbonyl sulfide have been noted.”
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Setbacks: One mile NOT necessary Flower Mound/Kleinfelder Study "According to the TCEQ, “recent significant health concerns expressed outside of the agency regarding these reported carbon disulfide levels appear unwarranted and may distract focus and resources from other chemicals which likely represent more of a potential health concern based on reported data and available scientific literature (e.g., benzene).” (TCEQ Memo, February 8, 2010)"
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Setbacks: One mile NOT necessary Fort Worth Qir Quality Study by Eastern Research Group “No pollutant concentrations were observed that exceeded any published short-term (or acute) health benchmark published by the Texas commission on Environmental Quality (TCEQ), EPA, or the Agency for Toxic Substances and Disease Registry (ATSDR).”
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Should FWISD wait to lease because the price is too low? No, because once a unit is finalized, the opportunity to participate has passed The only way to get into a unit once it is formed is to file a “forced pooling action”withthe Railroad Commission and being successful is low probability
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The Science is Clear and Definitive Natural gas sites are not the source of air emission problems Carbon disulfide is not associated with natural gas in the Fort Worth area Setbacks of 600 feet as specified by the City of Fort Worth ordinance is protective
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