On April 27, Victoria Powell told me that the EPA will conduct a site visit on Witt Farm. Unfortunately, I did not hear anything else about it and there was no report about this in the local news. I therefore decided to write an email to the EPA on 5/12/2014:
"To whom it may concern,
It came to my knowledge that the EPA was called upon and visited what
the Michigan DEQ calls Adrian 25, a central oil processing facility
within city limits that flared off the natural gas of up to 7 oil wells
for more than a year, mostly burning unclean. I reported about this on
my blog, e.g. http://adrianoil.blogspot.com/2014/03/will-city-county-or-deq-do-something.html.
I did not see any official confirmation of this site visit that
supposable happened on 4/29/2014 and nobody contacted me about any
details that could be added to a ongoing investigation.
My questions are now: was there a site visit and what if anything will
happen? If you need a chronology of the violation, please consult with
my blog or respond to this email.
Thanks in advance, Tom"
About two weeks later I received a voice mail from one of the EPA officers that were on site. I returned the call a few days later and was told that the EPA found violations of the Clean Air Act on site and that it was caused by leaks in the system - not as I expected from the flare. The officer did not want to provide me with more details but suggested that I file a Freedom of Information Act
(FOIA) request around June 15, when the final report should have been filed. This sounded reasonable and on June 24th I filed my request EPA-R5-2014-007747 asking for expedited processing due to potential health risks and my plans to inform the public. I was shocked that my request for expedited handling was refused 6/27. I was hoping that the report would still come in reasonable time but I am getting tired of waiting and therefore wrote the below email to the EPA today:
Subject: FOIA Request: EPA-R5-2014-007747 / RE: Fee Waiver and Expedited Processing Determination
"To whom it may concern,
I am very disappointed with the decision of the case officer. I clearly
stated in my application that I intend to disseminate the information to
the general public via my local blog adrianoil.blogspot.com that is
subscribed by many Adrian citizens and any other
channel that I have - including my media contacts. I also clearly
stated that the report should be made available IMMEDIATELY (that means
expedited!) as the EPA investigation found serious violations of the
clear air act on the site and it is my understanding
of democracy and environmental justice that people living close to the
facility should know about existing health threats NOW and not half a
year later!
As this is not the first and only clear misjudgement by environmental
authorities that should safeguard our citizens and the environment I am
slowly seeing how people can think that the Michigan DEQ and the EPA are
biased or severely undermined by polluting
industries.
I EXPECT to receive the report without further delay and without fees
the latest by this Monday! I will disseminate this letter on my blog -
and I will as well cite the officer from the EPA, who gave me the
information on the findings of violations
on site. I promised the officer to hold back until I receive the final
report but due to your agency's policy of delaying information that the
public has a right to know - I will now post what I was told more than a
month ago!"
I am seriously hoping to get this report soon and I will disseminate it here and send copies to the media.
Iceland Glacier Gone
Saturday, July 5, 2014
Friday, June 13, 2014
A tribute to a great man, Terry Greenwood - Reblogged from the Gasland II Newslist
Terry Greenwood was one of the most compelling people you could ever
listen to. There was just something about the way he spoke, there was a
decency and a positivity that shone through every word no matter how
distressing or disturbing the subject matter was. It was as if when he
spoke about the things that troubled him, he was still conferring a
lightness to you, a gratitude to the person listening.
Some people just manage to bestow a great humanity and great respect onto you while they are talking. Terry was one of those people. When you listened to Terry you felt like a more generous person somehow, he just made you want to listen, and made you want to help.
Honesty, decency, generosity, care, love. These are the words that spring to mind when you listen to Terry. And his wife Kathy, will crack you up and then will feed you and feed you until you can barely get up off the chair. And those damn amazing red white and blue suspenders! You know you are the genuine article if you can get away with those.
I've never released this interview I did with Terry Greenwood in 2009 or 2010 but I am sure you will hear the tone that I am talking about in his voice. And i hope, it gives you a sense of the man and how much he loved his farm and his life.
VIDEO IS HERE:
https://vimeo.com/98104966
He had been speaking openly and publicly about how 10 of the 18 calves that his cows gave birth to died just after birth or were stillborn and how he was very worried that it had something to do with the fact that fracking fluids and other substances had leaked into the pond where his cattle drank. I had head his story in the press and heard him speak about it in person, and I had heard of many stories of animals in heavily drilled areas from Arkansas to Colorado- of cows and goats who were failing to breed or who were having stillborn calves and kids. Terry was deeply troubled at the loss of so many of his calves, but more than that he was troubled by the fact that he felt his well water and springs had been contaminated by drilling, spills, leaks and fracking.
The interview speaks for itself. I am uploading it as a tribute to Terry and as a testament to everything he stood for. One of my favorite moments in any interview I've ever conducted is when Terry says "Money, money money! Our lifestyle wasn't about that. We worked hard for what we got, we didn't need it handed to us." It's a declaration of values that we can all only aspire to. Terry was saying what so many of us know and what we wish was more prevalent, that there are some things worth more than money, and one of them is decency.
When I heard, a few months ago that Terry had been diagnosed with brain cancer, I went to see him. In late March, he was having some trouble speaking, he was a bit weak, but his eyes were still telling you everything. He was still fighting, he was still positive, he was still going to find a way to make you smile. And as usual Kathy fed us amazing food until we could barely get up and packed the car with Western PA special buffalo chicken and pretzels n that n that n that.
In the last days, recently, when Terry was in the hospital, we were all asking what we could do to help. Terry simply said, "Tell my story."
So what does that mean? Does it mean tell the story of how gas companies barged onto his land? Does it mean speak about the water contamination they suffered, the insult added to injury when PA DEP ignored his complaints, the death of the cattle, his own death to cancer? Of course, that is part of the story.
But the bigger part of the story, it seems to me is of the man himself and of his family. To refuse greed. To speak truth. To act with such impassioned kindness, to try somehow to have some of that generous twinkle in the eye, to try to smile when you are talking and to make sure that you are appealing to that inside of us that is most sincere and honest. That's telling Terry's story.
This was a man who was truly brave, truly courageous in walking out into the public eye to tell his own story. And this was a man who did it without anger, although his anger would have been justified, who did it without self pity or depression, although no one would have blamed him for either. This was a man who could never prove all of what was done to him, but could only prove himself to be a good man, and he proved it with each sentence and in every gesture and smile. For us to tell it now is to try to be as brave, kind, straightforward and loving.
So when we tell Terry's story, try to find some of that mysterious positive charge, that brightness, that giving spirit that we will all miss so much.
We owe you Terry. We'll miss you brother.
Thank you.
God Speed and I damn sure hope there's Harleys out there where you are.
Some people just manage to bestow a great humanity and great respect onto you while they are talking. Terry was one of those people. When you listened to Terry you felt like a more generous person somehow, he just made you want to listen, and made you want to help.
Honesty, decency, generosity, care, love. These are the words that spring to mind when you listen to Terry. And his wife Kathy, will crack you up and then will feed you and feed you until you can barely get up off the chair. And those damn amazing red white and blue suspenders! You know you are the genuine article if you can get away with those.
I've never released this interview I did with Terry Greenwood in 2009 or 2010 but I am sure you will hear the tone that I am talking about in his voice. And i hope, it gives you a sense of the man and how much he loved his farm and his life.
https://vimeo.com/98104966
He had been speaking openly and publicly about how 10 of the 18 calves that his cows gave birth to died just after birth or were stillborn and how he was very worried that it had something to do with the fact that fracking fluids and other substances had leaked into the pond where his cattle drank. I had head his story in the press and heard him speak about it in person, and I had heard of many stories of animals in heavily drilled areas from Arkansas to Colorado- of cows and goats who were failing to breed or who were having stillborn calves and kids. Terry was deeply troubled at the loss of so many of his calves, but more than that he was troubled by the fact that he felt his well water and springs had been contaminated by drilling, spills, leaks and fracking.
The interview speaks for itself. I am uploading it as a tribute to Terry and as a testament to everything he stood for. One of my favorite moments in any interview I've ever conducted is when Terry says "Money, money money! Our lifestyle wasn't about that. We worked hard for what we got, we didn't need it handed to us." It's a declaration of values that we can all only aspire to. Terry was saying what so many of us know and what we wish was more prevalent, that there are some things worth more than money, and one of them is decency.
When I heard, a few months ago that Terry had been diagnosed with brain cancer, I went to see him. In late March, he was having some trouble speaking, he was a bit weak, but his eyes were still telling you everything. He was still fighting, he was still positive, he was still going to find a way to make you smile. And as usual Kathy fed us amazing food until we could barely get up and packed the car with Western PA special buffalo chicken and pretzels n that n that n that.
In the last days, recently, when Terry was in the hospital, we were all asking what we could do to help. Terry simply said, "Tell my story."
So what does that mean? Does it mean tell the story of how gas companies barged onto his land? Does it mean speak about the water contamination they suffered, the insult added to injury when PA DEP ignored his complaints, the death of the cattle, his own death to cancer? Of course, that is part of the story.
But the bigger part of the story, it seems to me is of the man himself and of his family. To refuse greed. To speak truth. To act with such impassioned kindness, to try somehow to have some of that generous twinkle in the eye, to try to smile when you are talking and to make sure that you are appealing to that inside of us that is most sincere and honest. That's telling Terry's story.
This was a man who was truly brave, truly courageous in walking out into the public eye to tell his own story. And this was a man who did it without anger, although his anger would have been justified, who did it without self pity or depression, although no one would have blamed him for either. This was a man who could never prove all of what was done to him, but could only prove himself to be a good man, and he proved it with each sentence and in every gesture and smile. For us to tell it now is to try to be as brave, kind, straightforward and loving.
So when we tell Terry's story, try to find some of that mysterious positive charge, that brightness, that giving spirit that we will all miss so much.
We owe you Terry. We'll miss you brother.
Thank you.
God Speed and I damn sure hope there's Harleys out there where you are.
Saturday, April 19, 2014
Air Pollution and Odor Nuisance Continues
How could I believe that Savoy would be done polluting our air when they finally started marketing natural gas from the 7 wells attached to Witt Farm? I received notice of one massive incidence of gas odor and personally reported two other incidents yesterday (April 18) and the day before yesterday (April 17). Kristie Shimko (DEQ) looked into the causes for the April 17 complaint and reported that Savoy is redrilling the Witt Farm well and diverted the natural gas to the flare. Yesterday (April 18) Savoy reported to have problems with their equipment. The flare did not seem to burn but the odor on Howell Hwy was horrible. Seems that lots of gas escaped their permitted dehydrator and compressor - and I guess that is OK...
Not really - but I wonder how much negligence has to be proven to an almighty energy company for the state to be able to fine them for their wrong-doing. My gut feeling is that the DEQ cannot do anything about it - Savoy could report to have problems forever and get away with it. This is absurd and unknown in most parts of the civilized world but not here in the State of Michigan, and The Land of the Free that should rather be called The Land of the free Corporations.
Not really - but I wonder how much negligence has to be proven to an almighty energy company for the state to be able to fine them for their wrong-doing. My gut feeling is that the DEQ cannot do anything about it - Savoy could report to have problems forever and get away with it. This is absurd and unknown in most parts of the civilized world but not here in the State of Michigan, and The Land of the Free that should rather be called The Land of the free Corporations.
Saturday, April 12, 2014
Saturday, April 5, 2014
Flare Seems to be Mostly Down
According to the Daily Telegram (March 25, 2014), Savoy began piping the previously flared gas to an oil-processing facility in Adrian Township from March 14 on. This is good news and long time passed due. Slowly becoming cynical, my explanation is that this winter brought up gas prices and now it is finally "financially doable" for Savoy to do the long-time over-due right thing. However, I always find a "hair in the soup" of a seeingly just good thing. Savoy is presently using a compressor and dehydrator that does not require a DEQ Air Unit permit despite the fact that it constantly emits benzene and other VOCs - this time unburned and thus in full potency - but admittedly, in much less concentration than from the flare under bad conditions. The DEQ Air Quality Division, Jackson District is currently working on a permit that will allow Savoy to use a more powerful dehydrator that will require a permit currently under consideration. Scott Miller from the DEQ told me that Savoy also plans to install a condenser, which would reduce (hopefully) emissions. I attach a image of the PDF I received from Scott below.
Friday, March 7, 2014
Will the City, the County or the DEQ Do Something About the Flare?
Below are questions and comments that arose from the meeting at the County Health Department. Questions were answered by Kristie Shimko and Sersena White from the DEQ or followed from documents provided by Kristie Shimko. Some answers are edited or extended by me.
- Q: Are flares permitted to burn 100,000 cft per well and per day?
A: According to CAUSE 18-2007, a order of the DEQ Supervisor of Wells, the allowable amounts and duration of flaring within the Trenton and Black River formations are specified. These procedures were agreed upon in a discussion between the DEQ and the following oil and gas companies: Continental Resources, Inc.; West Bay Group; Savoy Energy LP; Trendwell Energy Corp.; Matrix Exploration & Development, LLC and Titan Energy, LLC.
“Gas that is not reasonably marketable may be flared. The volume of gas flared is restricted to 100 MCFGPD (100,000 cft gas per day) for a 40-acre drilling unit or 50 MCFGPD for a 20-acre drilling unit, which shall be the net volume of gas flared not including gas used for reasonable and necessary lease fuel purposes. The permittee of a well that is flaring gas shall, within 30 days of a letter of request from the Supervisor, submit to the Supervisor data necessary to determine whether the well can economically market gas. If data is not timely submitted to the Supervisor, the Supervisor may require the permittee to cease the flaring of gas. Based upon the data supplied by the permittee and other information available to the Supervisor, and after meeting with the permittee as necessary, the Supervisor or his authorized representative shall determine whether gas from the well can be economically marketed and shall inform the permittee in writing of that determination. Within 90 days of a determination in the affirmative, or at such later date as the Supervisor may specify, the permittee shall cease the flaring of gas from the well. If the permittee disputes the Supervisor's determination, the permittee may file a petition and request a hearing; but the filing of such petition shall not stay the effectiveness of the determination. If the Supervisor determines that gas from the well cannot be economically marketed*, the permittee shall be allowed to continue flaring gas at the rate specified above. Permission to flare does not grant an exception to any other required permits or approvals.
*Marketing of gas be deemed not economic when an operator provides reasonable evidence to the Supervisor that the cost to connect a well to a pipeline or facility for the transportation and processing of gas will take in excess of two years to pay out based upon the average monthly natural gas production sales.
Get the full PDF-document here. - Q: There is no permit needed to flare off natural gas for as long as it takes, even if the flare gas contains benzene and other toxic and cancerous compounds.
A: No answer by DEQ – I guess this answers that there is no additional permit needed as follows from 1.) above. My search for the name the industry uses for flares enclosed in open oil tanks, I found several commercial combustion tools that ensure better and cleaner burns (e.g. mrw-tech.com, abutec.com). It seems that the Michigan DEQ does not require such cleaner technologies. - Q: There should not be any odors (and no elevated levels of volatile/gaseous pollutants) from any well-burning flare, oil well, or oil pump. A well-burning flare should also produce no soot. Flares should be maintained so the burn at least 96% of the combustible compounds.
A: No odors should occur and should be reported. If odors occur it indicates a less than proper burning rate of at least 96% and thus more unburned pollutants that might not have an odor at toxic levels (such as benzene). The Witt Farm flare smells almost every day and is thus most of the time burning way below 96% efficiency. - Q: The current air quality application is only concerned with Savoy's plans to send off the currently flared gases to the tank farm on Tipton for commercial use?
A: Savoy applied for a permit to finally capture and market the gases coming in to the Witt Farm (Adrian 1-25) from currently 7 wells. The current air quality application is concerned with the proposed installation of any piece of equipment that will emit an air contaminant. And those pieces of equipment are a glycol dehydration unit and an internal combustion engine. The company is also proposing a refrigeration unit but it is totally enclosed and thus has no emissions to the ambient air. - Q: The current application might be held back because the presence of benzene, too much water and to high BTU. The levels of toxins that I received from you in a table are levels that only matter for the permit process of marketing gas - not for flaring?
A: The current application will be evaluated with respect to the presence of benzene in the gas intended to be marketed, its relative high water content and a higher than permissible BTU to determine if their proposal will comply with applicable rules. This might delay the marketing of the gas and keep the flare going. - Q: Flaring will still go on even after marketing the gas if there is more gas then can be send to commercial use or if there is a technical problem preventing to send off the gas?
A: The flare will remain at the site for any of the following reasons:
* flaring off gas in the event of an emergency
* flaring off gas for equipment maintenance
* it may possibility be needed as a control device to ensure compliance with a rule (this will be determined in the upcoming technical review). - Q: The DEQ does not and will not monitor the Adrian 1-25 (Witt Farm) flare and discouraged the county, city or an independent monitoring due to the difficulty to relate potentially high levels of benzene 500 meters away from the flare to actual health issues.
A: DEQ-AQD did not intend to discourage the county, city or any independent monitoring entity from pursuing air emission risk assessment monitoring. AQD only intended to inform those present of the types of details and the length of the project for conducting a risk assessment monitoring project. The allowed air emissions of benzene as identified in the air toxics attachment is 0.1 µg (micro grams = 1 millionth of a gram) per cubic meter of air at or beyond the property boundary on annual averaging time. An approved permit to install for regulated emission units at this site would require this limit is met.
Reference: Michigan Department Environmental Quality - Air Quality Division List of Screening Levels (ITSL, IRSL and SRSL) in Alphabetical Order. - Q: What are the costs for a well permit, a tank farm permit, a brine disposal permit? Are there any independent and unannounced water and air monitoring procedures done or initiated by the DEQ that Savoy has to pay for? If yes when? Baseline, every month???
A: The cost for an oil well/brine disposal well permit is $300. There is no cost for a tank battery [like Witt Farm or Adrian 1-25]. A permittee of a well shall submit secondary containment plans, for approval before construction of a facility. After construction completion and before the facility can be put in operation, the permittee must submit: a statement certifying that the facility was constructed in accordance with the approved plan; the results of initial pressure testing of the piping; approved spill or loss response and remedial action plan; a water sample to establish ground water quality. Testing of the flow lines and underground piping is required annually. Secondary containment (ground water) monitoring is required every six months. Savoy contracts the flow line pressure testing and ground water sampling to qualified, independent third parties. DEQ can and will collect soil, groundwater and/or gas samples if deemed necessary. - Q: How much money does Savoy have to put into an emergency escrow account to pay for the cleanup and containment of well, pipeline, or trucking spills?
A: Savoy has a $250,000 bond on file with the Office of Oil, Gas and Minerals. [This money will not reach very far in case of a major spill – and who will pay for the rest? I am sure that will be the tax payer…Another example of corporate irresponsibility and the principle of externalization that takes advantage of everything true and trustworthy and undermines what we all learned as kids: if you make a mess you clean it up!] - Q: Are there any drills and exercises between all involved agencies and departments to make sure that the emergency responders are well prepared to contain and cleanup spills and other accidents?
A: OOGM encourages the oil company to equip/relay knowledge of the wells and facilities with the local fire department/responders. [I guess this is a good thing but it does not seem to be reinforced and might not happen in most cases making emergency situation even more dangerous…] - Q: What are the rules about drilling wells close to rivers and lakes? I already know that pipelines up to 5 inches diameter do not need a permit to go under a river or through wetlands.
A: As long as the well pad does not encroach upon a river/lake, it can be constructed. As long as sediment does not enter the water/stream/lake, they can construct the drill pad. [This seems to also just waiting for an accident to happen that will leave many people without potable water – actually something we saw happening in West Virginia this year, and something that happens for many people in Texas, Colorado, Wyoming and other states where hydraulic fracturing (fracking) adds to the problems we are facing here in Adrian and SE Michigan.
Meeting at the Lenawee County Health Department
As previously reported, the Lenawee Health Department hosted an informal meeting on my request to discuss the health risks for citizens of Adrian and Adrian and Raisin Township imposed by the large flare (see below) on Witt Farm (Adrian-25). The meeting took place on Friday, February, the 21st.
The following people attended this meeting:
Patsy Bourgeois (Health Officer, Lenawee County Health Department), Martha Hall (Environmental Health Director, Lenawee County Health Department), Elise Garcia (Adrian Dominican Sisters), John Kuschell (Adrian resident, recycling activist), Jim Berryman (Mayor of the City of Adrian), Shane Horn (Interim Administrator of the City of Adrian), Sersena White (Senior Environmental Engineer, Michigan DEQ Air Quality Division), Terry Wright (Permit specialist, DEQ Air Quality Division), Kristie Shimko (Geologist, DEQ, Office of Oil, Gas, and Minerals, Lansing District Office, covering Jackson, Hillsdale and Lenawee Counties), Terry Collins (Lenawee County Commissioner for District 6: Westside of the City of Adrian and retired police chief of the City of Adrian), Amy Wassmer (Adrian resident and environmentalist), and Tom Wassmer (Assistant Professor of Biology at Siena Heights University and Environmentalist).
Q: What was the meeting about?
A: Health Risks of the Massive Flare Within City Limits
Q: What is a flare?
A: A flare is a way to get rid of “waste” gas in oil and gas operations. Instead of using perfectly useful and energy-rich natural gas, many oil and gas companies do not want to invest in the technology needed to capture and market the gas and rather burn it off. This is not only a waste but produces greenhouse gases warming up our planet unnecessarily, and also set free poisonous and cancerous by-products such as benzene (more below)
Q: Where is there a flare on Witt Farm ? – I do not see a flame!
A: The flare is enclosed (hidden) from the view in a empty oil container with the top removed. This is supposable done to avoid that people are reporting a fire, and to allow for a better burning rate (see below). However, I am not sure that it is (also) a psychological trick to avoid that people are realizing what happens and become aware what is done here to our health and the environment.
Location of the flare (pink rectangle)
But what is inside of the empty tank barrel is this: A massive flame that burns up to 770,000 cft of gas per day combining the maximum permitted amount of flare gases of currently 7 wells, which Savoy can further increase to a maximum of 10 wells - and then 1,100,000 cft of gas burned per day. In size and dimensions something like the open flare shown below:
Picture credit: alleghenysc.org
If this flame burns at an efficiency of 96-100% then all is good. A minimal amount of methane, which is 100x as bad as a greenhouse gas as carbon dioxide and also minimal poisonous and cancerous hydrocarbons such as benzene are emitted. BUT, flares rarely burn at this efficiency due to winds and inconsistent flow rates of the "waste" gas itself. The consequence is a more orange flame with more soot (which you cannot see or cannot see very well in a enclosed flare) but also bad odor. If a flare smells then it is NOT burning at high efficiency. Some of this smells indicate that more methane escapes uncombusted, which makes the impact of a flare on global climate change worse. Much more concerning than bad odor are the higher concentrations of poisonous and cancerous hydrocarbons such as benzene that most people cannot smell at these concentrations but they can still cause short-term and long term health problems (see below).
Before being burned - the gas contains most probable (if Savoy is honest) the below components. In March 201, shortly after establishing the flare on Witt Farm (Adrian 1-25), Savoy Energy took a sample of the gas flared at Witt Farm (Adrian 1-25) and send it to a lab in Traverse City. I am puzzled that Savoy was not required to have the DEQ take the sample and send it to DEQ’s own environmental laboratory via a costly “Chain of Custody” to guarantee that it is the unhampered sample taken on location that arrives at the lab. This is the costly procedure every citizen has to go through to have air samples tested – why does the same rule not apply to a well-off company? However, the analysis still shows the presence of toxic and cancerous compounds such as BTEXs (benzene, toluene, ethylbenzene, and xylenes), most importantly benzene. Below are the analytical results for the sample(s) received by SPL on Thursday, March 28, 2013.
Here is a link to the original PDF
Q: The amount of benzene and other pollutants is surely too low to be concerned – otherwise the authorities would not allow flaring?
A: Unfortunately, local and regional authorities have no say in these matters and the DEQ and EPA are giving the oil and gas industry still unprecedented rights or have no legal tools to ask those industries to be more responsible. There is little information and research out there as these industries are very powerful and keep politicians, the court system, and even independent science out of their business. I already cited the exceptional study by James Argo in another blog post. Even in a well-burning flare, the following amounts of chemicals were released:
| On site characterization | Mg/m3 | Thermal Absorption > 10 mg/m3 | mg/m3 | Solvent Extraction > 10 mg/m3 | mg/m3 |
| Hydrogen | 20 | Pentane | 12.8 | Subst benzene | 9.83 |
| CO | 15.7 | 3-penten-1-yne | 19.3 | Azulene | 21.2 |
| CO2 | 4890 | Benzene | 144.5 | Subst benzene | 11.47 |
| Carbon | 54.2 | 1,5-hexadiyne | 48.2 | Naphthalene | 99.39 |
| Methane | 103.8 | Methyl benzene | 27.5 | 2-methyl naphthalene | 9.25 |
| Ethylene | 29 | Ethyl benzene | 13.7 | 1-methyl naphthalene | 6.18 |
| Acetylene | 53.7 | Ethynyl benzene | 94.8 | 1,1'-biphenyl | 58.7 |
| Ethane | 9.9 | Ethenyl benzene | 82.1 | Biphenylene | 42.81 |
| C3 HC's | 11.7 | Benzaldehyde | 18.7 | 1H phenalene | 21.01 |
| C4 HC's | 6.4 | Phenol | 26.4 | 9H fluorene | 41.09 |
| Benzene | 116.5 | Naphthalene | 88.7 | Phenanthrene | 10 |
| Toluene | 18.2 | 1,1'- biphenyl | 16.1 | Anthracene | 42.11 |
| Xylenes | 29.8 | Biphenylene | 19.1 | Fluoranthene | 51.35 |
| Styrene | 75.5 | Acenaphthalene | 23.2 | Pyrene | 32.37 |
| Ethynyl benzene | 79.6 | 4-methyl; pyrene | 9.1 | ||
| Naphthalene | 77.2 | 1 methyl pyrene | 8.4 | ||
| Other HC's | 128.5 | 38 Other HC's | 132.8 | Benzo(ghi)fluora nthene | 10.18 |
| CE | 65.0 % | Cyclopenta(cd)- pyrene | 29.77 | ||
| Benz(a)- anthracene | 17.33 | ||||
| 48 Other HC's | 94.47 |
I just want to focus on benzene (highlighted in red) as this is really bad stuff.
116.5 mg benzene/m3 when the gas is flowing at 6 m3/min in a sweet gas flare or 699 mg benzene released per minute. The authors find that the sweet gas flare has a maximum benzene concentration of 0.06 µg/m3 at about 500 m from the flare and measurable amounts at 5 km. These values are based on much smaller flares. The one on Witt Farm is permitted to flare up to 1,100,000 cft of gas per day – this would mean about 3.6x as much as the standard flare used in Argo’s calculations resulting in a benzene concentration of 0.22 µg/m3 at about 500 m and 0.09 µg/m3 at 5000 m. This is just below a lifetime risk of 1:1,000,000 for adult leukemia corresponding to an annual average benzene concentration of 0.096 ug/m3. Again this assumes 96-100% combustion rate (Values from Argo 2001, adjusted to likely concentrations and flow rates of the Witt Farm flare).
Combustion efficiency (CE) in a flare is severely affected by wind. Flares burning waste will only operate at
95+% if winds are less than about 2 kph. Winds of 25 kph will cut the CE to below 55-65%. In Adrian it is unlikely to have winds below 2 kph for at least 90% of the year! Enclosed flares are a little better but the frequency of bad odor from the flare confirms that it is most of the time NOT burning very well. Therefore the estimated concentration of benzene in the plume (wind direction) is most likely above the acceptable maximum value of 0.096 µg/m3 over at least 5 km from the source and an estimated peak value of benzene at about 500 m of about 4.8 µg/m3 or 50 X the acceptable maximum. This means: There might be an elevated risk for cancer may be present in the first 2.5 to 5 km from the flare. Residents in this zone have the potential to be affected by benzene exposure (described below). This concentration of benzene is below the odor threshold for most people (values and text passages from Argo 2001, values are representative for the Witt Farm as well).
The flare on Witt Farm and the 5km radius around the flare in which to expect health impacts due to benzene alone. At least 15,000 people live within this circle.
Q: What are the health risks of benzene exposure?
A: Benzene is a systemic toxicant in humans at any concentration and a cause of aplastic anemia (deficient red blood cell production). The major effect of benzene in the body is depression of bone marrow leading to pancytopenia, (a general depression of erythrocytes (red blood cells), leukocytes (white blood cells) and thrombocytes (platelets)). A widespread reduction in erythrocytes in a population will lead to a general increase in morbidity (Argo 2001).
Benzene is a known human carcinogen, causing leukemia; it is non-mutagenic. An annual time weighted average concentration (TWA) for a risk of 1 in a million is an annual average concentration of 0.096 µg/m3.
The odor threshold (threshold is the concentration when an average person becomes aware of an odor) of benzene is 4.5 mg/m3 and the odor is described as sweet. An average person will become aware of the presence of benzene at a concentration 4500 / 0.096 = 46,800 x maximum acceptable value for annual exposure of a risk of 1:1,000,000. An average person can be at risk of leukemia and never be aware, take steps to protect or otherwise act in defense of their health and integrity (Argo 2001).
Increased morbidity and elevated risk of leukemia is everywhere possible for residents within 5 km under these conditions. Those most at risk of long-term health effects are persons under age 30 (Argo 2001).
Further Information can be found using the below literature:
- D'Andrea MA, Singh O, Reddy GK. 2013. Health consequences of involuntary exposure to benzene following a flaring incident at British Petroleum refinery in Texas City. American journal of disaster medicine 8(3):169-79. Abstract on PubMed
- D'Andrea MA, Reddy GK. 2014. Health Effects of Benzene Exposure among Children Following a Flaring Incident at the British Petroleum Refinery in Texas City. Pediatric hematology and oncology 31(1):1-10. Abstract on PubMed
- Argo J. 2001. Unhealthy Effects of Upstream Oil and Gas Flaring. Sydney, NS, Canada: SAVE OUR SEAS and SHORES (SOSS). Available from: http://www.sierraclub.ca/national/oil-and-gas-exploration/soss-oil-and-gas-flaring.pdf
Q: What can we do to make sure that we are not getting sick from this benzene exposure?
A: Please refer to my next post in which I will summarize the outcome of the meeting.
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