GASP is encouraged to hear the Allegheny County Health Department is considering tougher air regulations on Marcellus Shale activity. In addition to the well-publicized danger that shale drilling operations pose to our water, there is an equally troubling risk to our air. Compressor engine exhaust, off gassing from storage tanks, and raw natural gas emissions during well completions are just a few of the many sources of air pollution associated with natural gas production. Such emissions are now causing unhealthy ozone levels in Wyoming. Given the fact that much of southwestern Pennsylvania fails to meet ozone or particulate matter standards, we can’t afford to increase the pollution burden in the air we all must breathe. That’s why GASP has been pursuing efforts at both the state and county level to adopt tough standards to limit air pollution from this industry. For this industry a number of effective air pollution control technologies exist. What’s more, because many of these technologies reduce pollution by increasing capture of hydrocarbons during the gas production process, these controls are not only cost effective, they often pay for themselves. This demonstrates once again that a healthy environment is good for the economy. We hope ACHD follows up on this talk with effective regulation and that DEP takes notice as well.

On Feb. 8, State Rep. Greg Vitali and supportive lawmakers proposed legislation that would enact a severance tax on natural gas drilling.  They pointed to The Pennsylvania Budget and Policy Center’s “Severance Tax Ticker” which today shows that the delay in enacting a severance tax has cost Pennsylvania over $149,000. GASP supports the enactment of a severance tax on natural gas in Pennsylvania, and hopes we can soon drop the stigma of being the only state not to levy a severance or extraction tax on this industry. So, what is a severance tax, anyway? The Pennsylvania Budget and Policy Center’s recent report, “Responsible Growth: Protecting the Public Interest with a Natural Severance Tax,” is an in-depth look at the issue.  The report explains that a severance tax is a method for internalizing the external costs of natural gas drilling not currently paid by the natural gas producers. Without this tax, the burden of covering these external costs is given to state and local taxpayers. For example, Pennsylvania has no severance tax on coal extraction and as a result has suffered from many negative environmental impacts from the coal industry, such as acid mine drainage. Taxpayers now have to pay to try to fix these problems, not the industry that produced them. A recent grist.org article points out that highly polluting industries are so successful because the cost of these externalities are not reflected in prices.  If we continue to make the prices of these externalities hidden, consumers will not know the full costs of the natural gas industry, and thus cannot make informed decisions. Currently, we are the only state that has high production of fossil fuels that has not enacted a severance tax on natural gas extraction. Of the 35 states that do collect a severance tax, they received a total of $16.7 billion in severance tax revenue in 2007-2008. Much of this money goes to educational systems and environmental clean-up programs. Pennsylvania’s gas industry is growing very rapidly.  While an expanding industry is great for those being employed by it, most of Pennsylvania’s natural gas industry does not pay corporate net income taxes or property taxes, let alone a severance tax. It’s a serious problem, and we desperately need a severance tax to protect Pennsylvania citizens from the burden of this industry’s externalities. What are some of these externalities? Surface erosion, contamination of water, soil compaction, and abandoned wells are among some of the main concerns. Erosion and subsequent silting is caused by construction processes before, during, and after the wells have been drilled. Water supplies can be contaminated through failures of cement well casings, surface spills, or improper wastewater disposal. The water that returns to the surface after drilling contains radioactive isotopes, such as radium-226. There is also a lack of decontamination sites to handle this water.  Finally, the wells that are abandoned must be capped, and the state is often held responsible for this burden. As of 2009, the Growing Greener fund has used up $9.3 million to cap abandoned wells. Through this summary, one can see that lacking a severance tax will put a heavy burden on Pennsylvanians, especially future generations who more than likely will have nothing to do with hydraulic fracturing. How do we ensure this severance tax will be fair to Pennsylvanians? The Pennsylvania Budget and Policy Center produced an article that explains how to make a severance tax fair to Pennsylvanians and to the gas industry. Their recommendations include: Set a reasonable tax rate, one that is fair but still competitive.  Our rate should account for factors such as our proximity to gas markets. Do not allow loopholes in the tax, such as deducting costs for transportation and production, or tax breaks during the early, very productive years of production. Do not exempt low-producing wells from a severance tax, which could make only one third of natural gas produced by wells subject to the severance tax. Further recommendations include allowing local governments to collect property taxes on oil and gas, developing a specific plan for where tax revenues will be allocated, and requiring the gas industry to keep their production open to the public. Our citizens should not be held responsible for externalities associated with natural gas drilling. It is unjust to put such an immense burden on so many that have nothing to do with the natural gas industry. GASP supports a severance tax that takes these recommendations into account, and is working with partners to make this a reality. Guest written by Claire Thomas, Chatham University student and GASP Intern

GASP Educates Families About Air Pollution at the Children’s Museum of Pittsburgh “WHOOSH! It’s All About Air” exhibit Children’s Museum of Pittsburgh March 19th, April 2nd, and May 28th (Saturdays) Noon-3 PM WHOOSH! It’s all about air! That’s what we’ve been saying at GASP for years. The Children’s Museum of Pittsburgh agrees, and is hosting a traveling exhibit exploring the qualities of air and air-related themes. Kids can test their own parachute designs, enter the Whirlwind Room for twisty blasts, or play with and learn from many other activities. GASP sends a giant THANK YOU to the Children’s Museum for allowing us to collaborate with them on this wonderful exhibit. GASP will explain the relationship between air and pollution as part of this exhibit through a variety of engaging activities, including a visit to the “LabAIRatory,” where kids can learn about pollution sources and how pollution moves through the air via hands on experimentation. Other fun stuff: play a mix-and-match game identifying friends and foes of pollution; create a Clean Air message for local leaders; read about how the Magic School Bus crew retrofits its trusty yellow friend, or how Coco the Chameleon changes color in response to air advisory alerts. One lucky winner will receive a family 4-pack of tickets to the Children’s Museum of Pittsburgh. The raffle for the tickets will occur at the March 30th event: Stories, Science, and Solutions, to be held at Chatham College from 5:30-9:00 PM (see our Calendar for more details). Lara Nagle, GASP Intern

At today’s Allegheny County Board of Health meeting, GASP urged the board to allow the Air Quality Program to develop their own outdoor wood fired boiler regulation as opposed to adopting the state’s inadequate regulation. While wood smoke may seem harmless compared to air pollution created by vehicles and large stationary sources of pollution, it is actually quite toxic. Wood smoke is made up of a complex mixture of gases and fine particles produced when wood and other organic matter burn. Carbon monoxide, nitrogen oxides, sulfur oxides, and hazardous air pollutants (HAPs) such as benzene and dioxin are released when wood is burned. Fine particle exposure is associated with asthma, respiratory infections, reduced lung function, cancer, heart attack, stroke, and premature death. Children, the elderly, and those with cardiovascular or respiratory disease are especially at risk. Ninety percent of wood smoke is in the most harmful particle size range, averaging less than 1 micron – so small that closed doors and windows cannot stop it from entering, even in newer, energy-efficient, weather-tight homes. These toxic, ultra-fine particles can penetrate more deeply into the lungs, enter the bloodstream, and even pass through cell membranes. The EPA estimates that the lifetime cancer risk from wood stove smoke is twelve times greater than that from an equal volume of second hand tobacco smoke. You might be asking, why do these devices create so much pollution? The basic design of OWBs creates significant stack emissions.  When an operator dampers down the unit, the lack of oxygen to support combustion creates a buildup of materials such as creosote. When opening the damper, these materials burn and release immediately to the air. Excessive loading or low demand for heat further aggravates this problem. In addition, OWBs emit more pronounced smoke than woodstoves due to the short stack height, which does not disperse smoke above living spaces in neighboring homes. Unfortunately not all OWB owners are responsible users.  State agencies have documented the burning of wet, large, unsplit wood; wood waste; yard waste; refuse; tires; and railroad ties.  Burning prohibited fuels results in greater PM emissions, and even more troubling, it also results in the production of significant quantities of dioxins. Outdoor wood fired boilers simply have no place in an urban area like Pittsburgh, and even in suburban areas can be very problematic.  You can find much more stringent OWB regulations in other cities and states.  The State of Connecticut; State of New York; Suffolk County; NY, City of Binghamton, NY; Village of Owego, NY; Town of Warwick, NY, and the State of Vermont all have regulations that require much larger setbacks than what is required in PA. The state of Washington and 15 towns in Connecticut have banned the use of OWBs all together. There is no good reason for Allegheny County to adopt PA’s regulation when we can and should develop better regulations that are more protective of residents’ health.  It should also be noted that even the most carefully crafted regulations will remain insufficient to prevent all OWB-related nuisance violations, and as the use of OWBs and other wood-burning appliances increases, additional measures may be necessary to address the regional impact of PM and HAPs resulting from wood combustion. Because OWB-related nuisance violations are inevitable, the ACHD must be vigilant in enforcing opacity and odor regulations. Following GASP and others’ comments, as well as a presentation by the Air Quality Program, the Board of Health agreed to let the Air Quality Program look at developing their own regulation. Check out the PG article covering the board of health meeting.

Shorts and T-shirt weather is (almost) here! And Athletes United is kicking off the warm weather with the first of three hikes in our Side Street Strolls series, a partnership with Venture Outdoors. The first hike will explore the South Side Flats from 1 p.m. to 5 p.m. April 9th. This will be a leisurely hike, with plenty of stops at hidden gems tucked in the back alleys of this historic neighborhood. The itinerary includes stops at the CCI Center, Green Building Alliance, Oliver Bathhouse, and much more. We’ll stop for free snacks halfway through. Please call Jamin at 412-325-7382 for more information, or go straight to Venture Outdoors to register.

Jonathan Nadle has been GASP’s president for two years now, having joined GASP as a member a decade ago. A Penn State grad with a political science degree, Jonathan believes in “staying involved” and has worked on various political campaigns, community cleanups, and environmental causes. An active board member, Jonathan sits on GASP’s Communications Committee and helps proofread and edit the Hotline, in addition to coordinating GASP events and meetings. Previously he served for several years as vice president and prior to that as board secretary. Jonathan’s interest in environmental issues extends to his job, where he works as an energy auditor and program manager for Conservation Consultants, Inc., a local nonprofit that works to increase the efficient use of energy and resources in the built environment. He also makes time to contact decision-makers about topics he cares about. As he points out, “unfortunately there’s no shortage of environmental issues courtesy of the Bush administration.” In his spare time, Jonathan “enjoys hiking the many trails our region is blessed with, road biking, camping, and canoeing.” He has played competitive volleyball since high school. He can often be seen in Frick Park with his dog, Sapphire, an unusual mix of Husky, Shepherd, and Beagle. He can’t help but admit that “She’s very cute and knows it.” When not working or spending time outdoors, he enjoys exploring the city’s extensive variety of interesting restaurants. When asked if he has any interesting stories to tell, Jonathan shares this one: “Two summers ago, I was helping a friend caulk around her windows. A thunderstorm was brewing outside, but I didn’t pay much attention as I was focusing on the task at hand. The window frames were metal, by the way. About the third window, I heard a buzz and felt tingling, and then an arc of electricity leapt from the frame to my hand. For a second, I thought I had somehow contacted the electric outlet below the window, but when I heard an enormous boom, I realized a close lightning strike had electrified the window! I learned the hard way to heed the advice not to be near metal windows or doors during an electrical storm. After recovering from the surprise shock, I looked out the window and saw flames shooting from the roof of a nearby house — a direct strike to the metal roof vent. I ran to the house and pounded on all the doors. No one was home. Neighbors started to come out, saying they couldn’t call the fire department because their phones were dead. Lesson two: Cordless phones may not work when the power is out. Fortunately, I had my cell phone and was able to reach the fire department. They were able to save the house, but it suffered extensive damage. I have a deeper respect for the power and potential danger of lightning.”

Today, we want to take you back to 2008, when the U.S. Environmental Protection Agency (EPA) revised the National Ambient Air Quality Standards (NAAQS) for ozone. The revision to that standard triggered an obligation for all major sources of nitrogen oxides (NOx) and volatile organic compounds (VOCs) in ozone nonattainment areas to submit determinations that they have Reasonably Available Control Technology (RACT) in place to limit their emissions, which cause ozone pollution. Because the 2008 revision to the ozone NAAQS was the second such revision to trigger an obligation to perform RACT determinations, the determinations that it triggered are referred to as RACT II. They are submitted to state air pollution regulators like the Pennsylvania Department of Environmental Protection (DEP) and Allegheny County Health Department (ACHD), and if approved by them, are further submitted to EPA for final approval and inclusion in the applicable State Implementation Plan (or SIP for short). EPA’s Final Rule implementing the 2008 NAAQS for ozone required states with designated nonattainment areas to submit revisions to their SIPs to include RACT II determinations within 24 months of a nonattainment designation, and to require sources subject to the RACT II requirement to implement RACT II within five years of a nonattainment designation. All areas of Pennsylvania were designated as non-attainment for the 2008 ozone standard on July 20, 2012. “That means that DEP should have made RACT II determinations for all major sources in Pennsylvania by July 20, 2014, and those sources should have implemented RACT II by July 20, 2017,” GASP senior attorney John Baillie explained. If you are looking at those 2008 and 2012 dates and asking yourself, “But what do deadlines matter?” we hear ya. Because just last week, EPA published a proposed rule that would disapprove RACT II determinations made by one now-shuttered coal-burning power plant in our region (the Homer City Generating Station) and two still-active coal burning power plants in our region (the Conemaugh and Keystone Generating Stations) - all three of which are major sources of NOx emissions. Yes, we also blogged about the harm resulting from these power plants’ sulfur dioxide emissions last week. “EPA’s proposed disapproval means that the three power plants still have not implemented the RACT II requirement that was triggered by the 2008 ozone NAAQS revision,” Baillie said. In a nutshell, in its disapproval EPA found that DEP (and the power plants) failed to justify why the plants’ NOx emission rates were the lowest reasonably achievable, given that emissions data for the plants showed they could (and often did) achieve lower rates of NOx emissions. “The apparent problem here is that for cost reasons, the plant operators do not want to control NOx emissions at all times using what’s known as selective catalytic reducers that are already installed at the plants,” Baillie explained. “DEP was poised to let them, however, EPA would not allow it.” If finalized, EPA’s proposed disapproval will require that either: DEP explain and justify why lower NOx emission rates are not feasible despite the three power plants’ having achieved them when they operated their selective catalytic reducers; or revise the RACT II determinations for the power plants to lower their emission limits for NOx to meet the lower rates that they achieved when operating their selective catalytic reducers. “Remember, all of this was supposed to have been over and done with by July 2017 at the latest; the regulators’ failure to get their acts together resulted in six-and-a-half years’ of ozone pollution that should have been prevented,” GASP Executive Director Patrick Campbell said. Editor’s Note: You can send a message to the regulators that it is well past time to make these power plants use their emission controls at all times to reduce ozone pollution. Members of the public are invited to comment on EPA’s proposed rule by March 22, 2024. You can submit comments to EPA, identified by Docket ID No. EPA-R03-OAR-2024-0047 at https://www.regulations.gov or via email to gordon.mike@epa.gov. GASP continues to follow this issue closely. Stay tuned, we’ll keep you posted as the process proceeds.

Kate St. John joined GASP as a dues-paying member in early 1998 during the final days of LTV’s Hazelwood Coke Works and became a board member in 1999. She currently helps keep GASP’s financial I’s dotted and T’s crossed as chair of the Finance Committee. When LTV wanted to close the plant, Kate remembers, “Even where I live, one mile downwind from the LTV site, the air pollution was horrible.” While this was going on, Kate read in the newspaper that GASP was taking LTV to court. “I was so thankful that someone was addressing the problem that I sent in my membership right away.” The plant finally closed in February 1998. When the news reported that Sun Coke Company might locate a new coke plant on the former LTV site, Kate became very active in GASP. By then, the air in nearby neighborhoods was noticeably cleaner, and Kate was appalled at the idea of living with another coke plant: “I attended GASP’s public forum about the Sun Coke plan in mid-August [1998] and got involved in CHOC (a community spin-off of GASP) to fight the new plant.” Due in part to the efforts of GASP, CHOC, and other concerned local groups, Sun Coke decided to locate elsewhere. Kate says, “My involvement in GASP has taught me it never hurts to write letters and attend public hearings. It can make a difference.” In her personal life, Kate’s an avid bird watcher and hiker, and feels it’s important that we protect birds and save their natural habitats. During the past year, her main project has been volunteering with the Western Pennsylvania Conservancy (WPC) to provide a nest box for a pair of Peregrine Falcons at Pitt’s Cathedral of Learning tower. The peregrines have been matriculating at Pitt for at least two years, but without a good place to nest they had never raised any young. Kate is happy to report that, this spring, she was able to watch the peregrine family successfully raise four chicks and see the chicks learn to fly. “It was gratifying to know that my effort has helped increase the population of peregrines, which are still endangered in Pennsylvania.” Regular Sunday hikes deepened Kate’s commitment to saving land, so in 1999 she became a volunteer land steward for WPC. Land stewards help monitor land and conservation easements in western Pennsylvania by visiting and reporting on their assigned sites at least four times per year. Kate’s site is on the Clarion River in Elk County, just across from the Allegheny National Forest. In addition to birding and hiking, Kate occasionally writes articles on birds and nature for The Nature Observer News and the GASP Hotline and discusses hiking once a month with Paul Wiegman on WYEP’s Allegheny Front radio show. Kate has a Bachelor of Science degree in computer science from Penn State, and in her work-a-day life is WQED’s Director of Information Technology. Or as she modestly puts it, “I am in charge of computers.” Kate lives happily with her husband and two cats in Greenfield.

IMMEDIATE RELEASE – Nov. 16, 2009 Contact: Rachel Filippini or Joseph Osborne 412-325-7382 AIR QUALITY FORECASTS DON’T ALWAYS WARN OF HIGH AIR POLLUTION DAYS Recently southwestern Pennsylvania has enjoyed a bout of unseasonably warm weather giving residents an excellent final opportunity to enjoy the outdoors before winter cold sets in. Unfortunately, this warm weather has been accompanied by unhealthy levels of air pollution that were not predicted by air quality forecasts and thus went largely unnoticed and unreported in local media. On Sunday, Nov. 15, air pollution in the Liberty-Clairton area was higher than anywhere else in the country. For most of the day the U.S. Environmental Protection Agency’s (EPA) Air Quality Index (available at airnow.gov) categorized Liberty-Clairton’s air as orange or unhealthy for sensitive groups. Under these conditions EPA discourages sensitive populations (i.e. children, the elderly, and individuals with cardiovascular or respiratory conditions) from engaging in prolonged or strenuous outdoor activities. From approximately 4 a.m. – 10 a.m. Sunday the air quality worsened to red or the “unhealthy” category. When air conditions are in the red category all individuals are discouraged from engaging in prolonged or strenuous outdoor activities. The Air Quality Index is intended to protect individuals from short-term health effects of exposure to significantly elevated pollution levels such as asthma attacks, heart attacks, and stroke. Unlike chronic health effects that may result from long-term exposure to even modestly elevated pollution levels, it is crucial that the public receive notification when pollution conditions are severe enough to cause immediate health problems. This weekend, although air pollution levels were dangerously elevated, few were aware of the poor air quality. Forecasts often fail to alert people to the potential high hourly readings. Recent forecasts did not warn residents in Liberty-Clairton of these air action levels. This was not an isolated event, on Monday, Nov. 9, Liberty-Clairton air was in the red category for much of the day, but local media outlets failed to report this. “It is imperative that people have access to the most current and accurate air quality information possible, especially when there is an action alert that puts sensitive populations at risk for adverse health effects,” GASP Executive Director Rachel Filippini said. “Local news outlets should be reporting actual air quality index levels as opposed to simply relying on forecasts which may be prepared days in advance and may not be accurate.” What are the potential health effects of these unhealthy air levels? The pollutant of greatest concern in the Liberty-Clairton area is PM2.5 or fine particulate matter. Fine particulates include both solid particles and liquid droplets that commonly result from fossil fuel combustion. Fine particulates are linked to such health problems as asthma attacks and possible asthma onset, coughing and difficulty breathing, chronic bronchitis, decreased lung function, heart attacks, stroke, cancer, and premature death. Children, the elderly and people with existing respiratory or cardiovascular ailments are especially sensitive to particulate matter. What caused the elevated air pollution concentrations over the weekend? In addition to fossil fuel combustion, particulate matter levels are influenced by weather and topography. In the river valleys of southwestern Pennsylvania, the levels of fine particulates often increase dramatically at night due to a meteorological phenomenon known as an air inversion. During an inversion, the normal vertical temperature gradient is reversed such that the air is colder near the surface of the Earth. This can occur when, for example, a warmer, less dense air mass moves over a cooler, denser air mass. During an inversion instead of rising high in the air pollutants become trapped close to the ground, increasing ground-level exposures. The Group Against Smog and Pollution, Inc. (GASP) is a non-profit citizens’ group working for a healthy, sustainable environment. Founded in 1969, GASP has served as a watchdog, educator, litigator, and policymaker on many environmental issues, with a focus on air quality in southwestern Pennsylvania. ###

Key Points: DEP’s Marcellus air studies monitored for 44 pollutants at 8 Marcellus Sites The study focused solely on concentrations sufficiently elevated that short-term exposure would pose a health risk. For several of the pollutants we would most expect to see near natural gas sites, DEP’s monitoring equipment was not sufficiently sensitive to detect these pollutants unless air concentrations were well above levels where short-term exposure is dangerous. No consideration of long-term exposure risk. No consideration of cumulative impact on regional ozone or particulate matter levels. Measured pollutant concentrations are only reliable to the extent the 8 natural gas sites are representative of routine operation at all PA natural gas sites. A PDF version of this article containing additional references is available here. ---------- Last week the Pennsylvania Department of Environmental Protection (DEP) released a study of air quality around Marcellus Shale operations in northeastern Pennsylvania. Here are some typical headlines from articles on the study: “Pa. DEP study finds Marcellus air emissions OK,” “DEP Says Air Near Marcellus Drilling Sites Is Safe,” or even “DEP finds no health threat from Marcellus air emissions.” If those headlines are accurate, why do GASP and other environmental organizations keep going on and on and on and on about the massive quantities of air pollution that result from natural gas production? Both can’t be true, right?  So what explains the discrepancy? Limitations of the DEP Studies First, as DEP acknowledges, the data collected during this study simply is not sufficient to support the bold, sweeping claims found in headlines like those I listed above. This study, as well as a similar study from southwestern Pennsylvania DEP released last fall, selected a few sites where natural gas activity was occurring and conducted air monitoring at each of these sites for no more than four days. The goal was to determine if any of 44 specific pollutants DEP selected were present in the atmosphere in sufficient concentrations that breathing that air for a short period (generally somewhere between one hour and 24 hours) would pose a threat to human health. So already some of the studies’ limitations are clear: Between these two studies DEP has conducted monitoring at only 8 natural gas sites, never monitored at any one site for more than 4 days, and ignored the risks of long-term exposure to these pollutants.  Are these studies useful? Absolutely, but they don’t justify a sweeping conclusion that natural gas operations pose no risk to our air. In fairness to the journalists who reported on the DEP’s study, I should also note that the majority of news stories on the DEP’s studies also mention these limitations, but you have to make it most of the way through the typical article before they’re mentioned. And while I’m being fair, I should also mention that DEP acknowledges these limitations in the executive summaries to both of these studies (though press releases and public statements are another matter, which I’ll get to in a moment): “Due to the limited scope and duration of the sampling and the limited number of sources and facilities sampled, the findings only represent conditions at the time of the sampling and do not represent a comprehensive study of emissions.  While this short-term sampling effort does not address the cumulative impact of air emissions from natural gas operations . . . the sampling results do provide basic information on the type of pollutants emitted to the atmosphere during selected phases of gas extraction operations in the Marcellus Shale formation.” There are also problems with these studies that DEP does not acknowledge. DEP used several different types of monitoring equipment to detect these pollutants: gas chromatography/mass spectrometry, open path FTIR, infrared cameras, and canister sampling. I won’t get in to all the technical details of each of these technologies, but each has its strengths and weaknesses in terms of accuracy, sensitivity, length of sampling time, and the types of pollutants it is capable of detecting. For around a dozen of the 44 pollutants DEP looked at, pollutant concentration data was provided only by the FTIR, meaning that for those pollutants, any conclusions about their air concentrations near well sites are entirely subject to the limitations of the FTIR. The FTIR monitor detects pollutants by shooting an infrared beam through the open air at the site where monitoring is occurring. The beam bounces off a carefully placed reflector and travels back to the monitor to be analyzed. However, as the DEP studies note, a “tradeoff exists between the length of the open path and detection limits; the longer the path, the higher the detection limits.” In other words, the longer the beam, the higher the pollution levels in the air must be before the monitor can detect them. Any pollution concentrations lower than the detection limit essentially register as zero. For instance, the pollutant nitrogen dioxide (NO2) is associated with respiratory problems and can transform into dangerous ozone or particle pollution in the atmosphere. Compressor stations are by far the largest source of NO2 associated with natural gas production, but amazingly, DEP detected absolutely no NO2 near a compressor station in DEP’s northeastern PA study. How can that be?  It’s because the FTIR’s minimum detection limit was far too high to detect NO2 at concentrations ever realistically found in the atmosphere. DEP listed its FTIR detection limits in the appendices to each study.  These limits changed with each 7-hour monitoring period due to variations in equipment placement and environmental conditions. During compressor station monitoring for the northeastern PA study, during its most sensitive monitoring session, the FTIR was only capable of detecting NO2 at concentrations of 198 parts per billion (ppb) and above. To put that 198 ppb figure in perspective, consider that as I write this, the highest hourly average NO2 concentration recorded in Allegheny County in the last 48 hours was 42 ppb.  As of 2007, the annual average statewide NO2 concentration was right around 11 ppb. The federal health-based standard for one hour of exposure to NO2 is 100 ppb. So, on their best monitoring day at a northeastern Pennsylvania compressor station, DEP was incapable of detecting NO2 unless those concentrations were 18 times the typical concentrations we see statewide, nearly five times the highest hourly concentration we’ve seen in Allegheny County in the past 48 hours and double the short-term health-based standard. That means not just that NO2 may have been elevated near these compressor stations, but that it would have to be sufficiently elevated to be nearly double the short-term health standard before DEP’s monitoring would even detect it. And keep in mind, that was by far DEP’s best NO2 detection limit at a northeastern PA compressor station.  Their next lowest is 434 ppb, followed by 448 ppb, 985 ppb, 1015 ppb, and 1041 ppb. DEP’s monitoring for hydrogen sulfide (H2S) provides an even more drastic example. Hydrogen sulfide is a potent neurotoxin often associated with natural gas operations.  Like NO2, H2S is a pollutant you’d expect to see some concentration of near natural gas operations, but this is another pollutant DEP has never detected at a natural gas site. Between the southwestern and northeastern studies, the best detection limit DEP ever achieved during a monitoring session was 2528 micrograms per cubic meter (μg/m3).  The worst was 35,950 μg/m3. According to the DEP studies, the maximum safe H2S concentration for short-term exposure is 42 μg/m3.  On its best monitoring day, DEP would have been unable to detect hydrogen sulfide unless it was present in concentrations 60 times the maximum safe short-term exposure concentration DEP cites. And the problem isn’t limited to H2S and NO2 (see charts at right). In both the southwestern and northeastern air studies, formaldehyde and sulfur dioxide minimum detection limits also routinely exceeded the short-term health standard. In DEP’s press release announcing the publication of the northeastern Pennsylvania Marcellus Study, the agency states, “DEP’s air sampling did not find concentrations of any compound that would likely trigger air-related health issues associated with Marcellus Shale drilling activities.” What DEP says is technically true, but without knowing about the minimum detection limit problem, one would naturally assume DEP “did not find” unhealthy concentrations because unhealthy concentrations were not present. These studies rarely detected pollutants in concentrations approaching short-term risk levels, but given that DEP’s monitors were incapable of detecting several air pollutants commonly associated with natural gas operations unless they were present at concentrations many times greater than those risk levels, the studies simply don’t provide enough information to conclude the air is safe. And again, we’re only talking about short-term risk levels, not the much lower concentrations that pose a long-term exposure risk. In future studies, ideally DEP would find a means to ensure minimum detection limits for these pollutants better coincide with DEP’s short-term risk levels. Unless and until that can happen, I hope DEP will keep this study limitation in mind and adopt a more moderate tone when discussing the extent to which these studies indicate air near natural gas operations is safe. Finally, a central purpose of these studies is to extrapolate from these monitoring sessions to get an idea of what ambient air quality looks like around natural gas operations statewide. These studies have the most predictive power if the activities and equipment at the natural gas sites where sampling occurred were operating normally during the sampling period.  Is there any reason to think these sites weren’t operating as normal? DEP’s air sampling vehicles, called “mobile analytical units” or MAUs, aren’t exactly inconspicuous.  These are large, gleaming-white vehicles with DEP logos and the words “mobile analytical unit” boldly printed on their sides.  MAU-1, a heavily modified Winnebago, looks particularly billboard-like. For all I know, operations did not change at all at the natural gas sites when the MAUs were present, but these vehicles are hard to miss, and after spotting them rolling up to the site, it would only be sensible for a gas field worker to double check that all equipment is operating properly, hatches are closed on storage tanks, no unnecessary equipment is running, lower-emitting equipment is used preferentially when possible, etc. If a gas producer were particularly worried about air emissions from their operations, they might even go so far as to cut back production until the MAU leaves, taking its air monitors and infrared cameras along with it. I see two potential ways to mitigate this problem. First, make the MAUs less conspicuous. Second, after conducting monitoring, PADEP should exercise its authority under the Pennsylvania Air Pollution Control Act §§ 4(3) & (4) to obtain production and operational records from every site where sampling is performed. If DEP obtains records covering the sampling period and a reasonable period before and after sampling, the Department will be better equipped to judge whether sampling sites were operating under normal conditions while air monitoring was occurring, and the public would have more confidence the air monitoring results are accurate. Conclusion To sum up, DEP’s Marcellus air studies focus on detecting concentrations of 44 pollutants at concentrations sufficiently elevated that short-term exposure poses a health risk. As described above, for several of the pollutants we would most expect to see near natural gas sites, DEP’s monitoring equipment was not sufficiently sensitive to detect these pollutants at even the high concentrations necessary to pose a short-term exposure risk. For the remaining pollutants for which minimum detection limits were not an issue, we can take more comfort in DEP’s sampling results, but they tell us little about the risks posed by long-term, chronic exposure. Further, the measured pollutant concentrations are only reliable to the extent the eight natural gas sites are representative of routine operation at all PA natural gas sites. Given how conspicuous the DEP’s mobile analytical units are, these facilities may have operated with extra care while the MAUs were present—the air pollution equivalent of highway drivers tapping their brakes when they spot a police car on the side of the road. Finally, as DEP acknowledges, we also can’t rely on these studies to estimate the cumulative impact of emissions from natural gas operations. Large portions of Pennsylvania already fail to meet federal health-based standards for ozone and particulate matter.  If air emissions from natural gas operations in the Marcellus aren’t controlled, this industry has the potential to make our existing problems worse. Just ask Wyoming, Utah, Colorado, or Texas. While I stand by my criticism of DEP’s air sampling, I do see value in the Department’s studies—as imperfect as they may be.  It’s easy to forget that as recently as 2008, Marcellus Shale drilling barely existed in Pennsylvania.  DEP’s air sampling studies are an excellent start to a better understanding of the exact nature of the potential air pollution threat this industry poses. In the next few years I hope we see additional air monitoring performed by environmental organizations, academics, and additional studies by DEP. Future air monitoring efforts can benefit by looking at the DEP Marcellus Shale air studies performed to date, building on what worked well, and correcting what did not. In the meantime, it’s important that we critically evaluate any and all information we come across about this nascent, but fast-growing industry. The newspaper headlines characterizing DEP’s monitoring efforts as proof Marcellus-related air emissions are “OK” or “safe” or “no health threat” are reaching conclusions the DEP’s data simply doesn’t justify. These DEP studies are not the final word on air emissions from Marcellus Shale activity; they’re part of a long conversation that’s just getting started.