Comment on Air Quality – Propose Exploratory Drilling at Ballinlea
(E/2013/0093/F Rathlin Energy Ltd.)
Background Information and longer-term Considerations
• No long-term study has been done anywhere in the world on the health effects of
chronic exposure of human populations to the emissions from gas/oil extraction.
Hence, the long-term risk is not known. However, it is known that extended exposure
to the radioactive and chemical emissions typically associated with gas/oil operations
poses a serious mortality and morbidity risk.
• The risk to residents living within a few hundred meters of a well pad may be very
significant due to exposure to products of flaring and radon, compressors and pipe
networks, when these are transported by the prevailing wind. The long-term risk to
such residents, particularly the ill and elderly, the young and the not-yet-born, is likely
to be serious.
• The atmospheric concentration of highly carcinogenic polycyclic aromatic
hydrocarbons (PAHs) measured across a natural gas patch in Colorado (taken to
represent a typical gas field) was 15.5 ng/m3, 60 times that allowed in UK. This is
likely to be the level of PAHs over onshore oil/gas field anywhere and can be
expected to have clinical significance. A number of investigations reviewed by
Colborn et al (Human and Ecological Risk 2011 vol.17 (5) p 1039-1056) highlight the
health risk particularly cancers for those exposed to polycyclic aromatic
hydrocarbons. Babies prenatally exposed to polycyclic aromatic hydrocarbons with a
total concentration at much less than 15.5 ng/m3 suffered developmentally.
(Vandenberg L, Colborn T, Hayes T, et al. 2012. Endocrine Rev 33(3):378-455). The
proposed regulatory regime at Ballinlea would not detect such emissions or control
them.
• The cumulative effects or synergy of components in emissions needs to be taken
into account. Laboratory investigations to determine safety limits typically measure
exposure to one chemical at a time, while real-life conditions entail simultaneous
exposure to a number of volatile chemicals, with interactions that cannot be predicted.
Government standards are typically based on the exposure of a grown man
encountering relatively high concentrations of a chemical over a brief time period, for
example, during occupational exposure. They do not address the issue of exposure to
many chemicals simultaneously which is precisely what a flare emits.
• Extended low-level pollution from a wide range of chemicals is known to cause a
variety of chronic illnesses – skin irritation, severe headache, eye irritation, sinus
problems etc (Steinzor et al. New Solutions 2011 Vol 23(1) p55-88). Common
illnesses induced by emissions,with likely prevalence in the neighbourhood of well
pads have been documents. McKenzie, Witter, Newman, & Adgate (2012, Science of
the Total Environment DOI: 10.1016/j/sciotenv.2012.02.018) examined neurological,
respiratory, hematologic and developmental effects in relation to proximity to a gas
well and their findings are not consistent with an evaluation of 'low risk'.
• Endocrine disruption through chronic exposure to airborne emissions is being
urgently discussed worldwide. National emissions standards do not apply to exposure
faced by individuals (including pregnant women, children, and the elderly)
experiencing chronic, low-level exposure, 24 hours a day 7 days a week in natural
gas/oil neighbourhoods. Emission limits do not take account of an atmospheric
cocktail of endocrine-disrupting chemicals, which can be particularly harmful during
prenatal development and childhood (Colborn et al (Human and Ecological Risk 2011
vol.17 (5) p 1039-1056), Dejmek J, Solansky´ I, Benes I, et al.2000. Environ Health
Perspect 108:1159-64).
• Emissions and associated smog induced by ozone formed in the hydrocarbon/Noxrich atmosphere over an oil/gas field may critically affect those already ill with a
chronic condition such as respiratory or cardiovascular disease.
• The risk of persistent organic chemicals/heavy metals entering the food chain is not
discussed. Ballinlea is rural. Soil particularly will be contaminated with PAHs for
long periods. Bamberger and Oswald (2012 New Solutions 22 (1) 51-77) pointed out
the accessibility of toxins from oil/gas fields to the human food chain, via meat and
dairy produce, with implications for human health and agriculture.
Summary of Objection
The applicant has presented an air dispersion study of carbon monoxide (CO) and oxides
of nitrogen (NOx) emissions from flaring affecting properties in the prevailing wind from
the flare. Use of the wind records data from Belfast airport to undertake air dispersion
modelling for houses which are approximately 100 m from the flare is not justified. The
applicant states that in the vicinity of the residences located within about 100 metres from
the flare, the CO and NOx and VOC levels are likely to be at levels which comply with
Air Quality Objectives. In such a critical instance site specific data must be used.
There is an imperative particularly here to consider the cumulative effect of all emissions
and impacts on residents- chemical, noise, traffic and lighting disturbances.
Also, there are at least three other toxic emissions scenarios described below which were
not considered by the applicant which may breach Air Quality Objectives.
New Air Dispersion Studies on Sulphur Dioxide (SO2), Polyaromatic Hydrocarbons and
Particulate Matter (PM) are needed.
An appropriate plan for Monitoring and Mitigation of Emissions is needed
Air Dispersion Studies Needed
i)
Sulphur Dioxide (SO2)
The applicant states that:
“Sulphur dioxide (SO2) has not been examined within this assessment due to the understanding
that there is negligible sulphur content in the natural gas.”
The data to support this assumption should be provided. The solution gas coming out of any oil during
flow testing may be “ wet” and contain sulphur compounds such as mercaptans or thiols and H2S.
Modelling of the dispersion of Sulphur Dioxide (SO2) ( which is heavier than air) should be
requested.
(ii) Polyaromatic Hydrocarbons (PAH)
In the vicinity of the residences located within about 80 metres from the flare the
polyaromatic hydrocarbon concentration is expected to be above the National Air Quality
Objective for Polyaromatic hydrocarbons (0.25 ng/m3 ) and so air dispersion calculations of
this are necessary.
(iii) Particulate Matter (PM2.5 and PM10)
The applicant states that:
“Poor combustion and the presence of a smoky flame during the flaring process can lead to the
production of fine particulate matter. Concerning this site; its characteristics and its flaring
activities, this report is of the opinion that there will be no significant discharge of fine
particulate matter and as such has not been examined within this report.
This risk needs to be addressed properly. If the flare temperature drops particulates will be produced.
This scenario should be modelled to assess the risk of a incomplete combustion of the feed gas
entering the flare.
Monitoring and Mitigation of Emissions
The applicant states that:
“On‐site Monitoring During the operational phase of the proposed development on‐site
monitoring in the form of diffusion tubes may be conducted, if required, in order to give
confidence to Moyle District Council that atmospheric pollutants associated with the drilling
and flaring are within acceptable levels. Nitrogen dioxide and VOCs may be measured through
the use of diffusion tubes. Methane levels may also be monitored by appropriate methods (i.e.
grab samples or use of portable monitoring equipment)”
Use of diffusion tubes is likely to be much too slow to give warning of a problem in air quality. In this
instance real-time monitoring using Fourier transform infra-red spectroscopy or Flame ionisation
detection should be considered. This would be using the best available technology. With regard to
methane, this has a molecular weight of 16 and is lighter than air. Monitoring of Methane emissions
should take this into account.
Professor Lawrence Dunne BSc, MSc, ARCS, PhD
The person providing this comment has previous research expertise on modelling soot
production (particulates) in flames and polyaromatic hydrocarbons (PAHs) formed in
thermal decomposition of organic materials. This experience given below is highly
relevant to air quality from flaring.
Relevant Technical Publications
Formation of Twisted AB-Graphitic and Fullerene-Related Tubular Structures During
Soot Deposition from the Flaming Combustion of Polymers
By L.J Dunne, P.F Nolan, M Terrones, J Munn, A Jones, P Kathirgamanathan, J
Fernandez
Combustion and Flame
Volume 114, Issues 3–4, Pages Pages 591-593 (August–September 1998)
---------------------------------------------------------------------------------------------------------Experimental verification of the dominant influence of extended carbon networks on the structural,
electrical and magnetic properties of a common soot
By: Dunne, LJ; Nolan, PF; Munn, J; et al.
JOURNAL OF PHYSICS-CONDENSED MATTER Volume: 9 Issue: 48 Pages: 10661-10673
Published: DEC 1 1997
---------------------------------------------------------------------------------------------------------Electrical, magnetic and structural characterization of fullerene soots (vol 8, pg 2127, 1996)
By: Dunne, LJ; Sarkar, AK; Kroto, HW; et al.
JOURNAL OF PHYSICS-CONDENSED MATTER Volume: 8 Issue: 33 Pages: 6113-6113 Published:
AUG 12 1996
Electrical, magnetic and structural characterization of fullerene soots
By: Dunne, LJ; Sarkar, AK; Kroto, HW; et al.
JOURNAL OF PHYSICS-CONDENSED MATTER Volume: 8 Issue: 13 Pages: 2127-2141 Published:
MAR 25 1996
---------------------------------------------------------------------------------------------------------ELECTRONIC, MAGNETIC, AND STRUCTURAL-PROPERTIES OF AMORPHOUS CARBONS
AND THE DISCOVERY OF THE FULLERENES
By: DUNNE, LJ; CLARK, AD; CHAPLIN, MF; et al.
CARBON Volume: 30 Issue: 8 Pages: 1227-1233 Published: 1992
-------------------------------------------------------------------------------------------------------------------------
ELECTRONIC AND STRUCTURAL-PROPERTIES OF AMORPHOUS SEMICONDUCTING
CARBONS PREPARED BY THE THERMAL-DECOMPOSITION OF SULFANILIC ACID IN
THE SOLID-STATE
By: ROULSTON, SA; DUNNE, LJ; CLARK, AD; et al.
PHILOSOPHICAL MAGAZINE B-PHYSICS OF CONDENSED MATTER STATISTICAL MECHANICS
ELECTRONIC OPTICAL AND MAGNETIC PROPERTIES Volume: 62 Issue: 3 Pages: 243260 Published: SEP 1990
--------------------------------------------------------------------------------------------------------------------------
QUASICLASSICAL KINETICS ON THE GROUND-STATE POTENTIAL-ENERGY SURFACE
OF CH2
By: MURRELL, JN; DUNNE, LJ
CHEMICAL PHYSICS LETTERS Volume: 102 Issue: 2-3 Pages: 155-157 Published: 1983
This paper is about soot formation in flames.