Gregg P. Macey

Air Concentrations of Volatile Compounds Near Oil and Gas Production: A Community-Based Exploratory Study

BackgroundHorizontal drilling, hydraulic fracturing, and other drilling and well stimulation technologies are now used widely in the United States and increasingly in other countries. They enable increases in oil and gas production, but there has been inadequate attention to human health impacts. Air quality near oil and gas operations is an underexplored human health concern for five reasons: (1) prior focus on threats to water quality; (2) an evolving understanding of contributions of certain oil and gas production processes to air quality; (3) limited state air quality monitoring networks; (4) significant variability in air emissions and concentrations; and (5) air quality research that misses impacts important to residents. Preliminary research suggests that volatile compounds, including hazardous air pollutants, are of potential concern. This study differs from prior research in its use of a community-based process to identify sampling locations. Through this approach, we determine concentrations of volatile compounds in air near operations that reflect community concerns and point to the need for more fine-grained and frequent monitoring at points along the production life cycle.MethodsGrab and passive air samples were collected by trained volunteers at locations identified through systematic observation of industrial operations and air impacts over the course of resident daily routines. A total of 75 volatile organics were measured using EPA Method TO-15 or TO-3 by gas chromatography/mass spectrometry. Formaldehyde levels were determined using UMEx 100 Passive Samplers.ResultsLevels of eight volatile chemicals exceeded federal guidelines under several operational circumstances. Benzene, formaldehyde, and hydrogen sulfide were the most common compounds to exceed acute and other health-based risk levels.ConclusionsAir concentrations of potentially dangerous compounds and chemical mixtures are frequently present near oil and gas production sites. Community-based research can provide an important supplement to state air quality monitoring programs.

The Natech: Right-to-Know as Space-Time Puzzle

Federal environmental law began with a plea: that agencies and other parties consider, and mitigate, the environmental impacts of their work. The task remains unfulfilled given the nature of those impacts: They feature system effects, nonlinear interactions, feedback loops, discontinuous and threshold dynamics, and uncertain boundaries. The administrative state has limited means to address them. It relies on artificial constructs to assess and respond to impacts, such as worst-case scenarios, reasonable foreseeability, and scales that are either inappropriately narrow (“linked” projects) or large and vague (“program-level”). Right-to-know laws share this shortcoming, a product of the disasters that led to their enactment and the laws to which they were appended. In place for a quarter century, the framework is under renewed scrutiny. Recent accidents reveal risks from new and repurposed infrastructure, and point to chemical listing, threshold, labeling, and other potential reforms. But these are incremental adjustments to a baseline approach to chemical risk that operates under longstanding temporal and spatial constraints. Right-to-know privileges annualized data and the state of knowledge shortly after a release beyond a facility boundary. These choices limit data available for emergency response, particularly when chemical processing, oil and gas production, and other infrastructure are placed under stress. To explore how right-to-know laws can better account for system effects, I focus not on the black swan events or worst-case scenarios that shape new legislation and consume an outsized portion of administrative resources, but rather on increasingly common, geographically dispersed, and temporally discontinuous infrastructure stressors known as natechs. A natech event occurs when a natural hazard such as a storm, earthquake, or flood triggers technological accidents that result in the release of chemical agents into the environment. Natechs share several traits, including simultaneous releases, cascading and domino effects, and scattered or inaccessible infrastructure. They often occur under “best case” conditions, due to the weakness of the natural hazard trigger or the readiness of infrastructure in its path. They lead to non-state responses that identify, reconstruct, and track cumulative impacts that would be lost to regularized reporting at discrete scales. These non-state responses ensure situational awareness in emergent spaces, irrespective of facility boundary. And they suggest event sequences that can be leveraged for hazard mitigation. By focusing on a growing inventory of mundane infrastructure stressors, natechs can serve as proxies for some of the cumulative, delayed, distributed, and nonlinear impacts that environmental laws find difficult to address.