Air Toxics One Year Report (Final) Copy

8/12/2019 Air Toxics One Year Report (Final) Copy

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Air Toxics One-Year Report: Oil Companies Used Millions of Pounds ofAir-Polluting Chemicals in Los Angeles Basin NeighborhoodsAn Analysis from the Center for Biological Diversity, Physicians for Social

Responsibility Los Angeles, Communities for a Better Environment, and theCenter on Race, Poverty and the Environment

June 2014

One year after the South Coast Air Quality Management District (SCAQMD) beganrequiring the oil and gas industry to report the use of chemicals in certain well

operations in the South Coast Air Basin, records show that oil companies have used44 different air toxic chemicals more than 5,000 times in Los Angeles and Orangecounties in the past 12 months.

The known air toxics most frequently used by oil companies in the Los Angeles air basininclude crystalline silica, hydrofluoric acid, and formaldehyde. Air toxics are thosechemicals considered to be among the most dangerous air pollutants because theyhave been proven to cause significant health harms, illness, and death. Formaldehyde,for example, harms the eyes and respiratory system and is classified as a cancer-causing substance by the International Agency for Research on Cancer and theCalifornia Air Resources Board.

The oil industry has reported the use of more than 45 million pounds or 22,500 tons of air toxics in 477 hydraulic fracturing (fracking), acidizing and gravel packingoperations in Los Angeles and Orange counties since mandatory reporting began inJune of 2013. Oil companies have also claimed trade secret protection 5,050 times toconceal information on air toxics and other chemicals used. The data also shows thatmore than half of the fracking, acidizing, and gravel packing events reported by the oilindustry have occurred within 1,500 feet of a home, school, or medical facility.

While the data collections scope is limited, the information does provide insight into theoil and gas industrys previously hidden reliance on the use of air toxics in Los Angelesand Orange counties. Further, the data highlights the danger to which communities areexposed as these chemicals are transported and used and focuses attention on thecritical need for policies that address the substantial harm that can be caused by theroutine and accidental releases of these toxic air pollutants.

Finally, the data shows the oil industrys common use of trade secret claims to concealthe true scope and nature of the dangers to which their operations expose the people ofLos Angeles and Orange counties.


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BACKGROUNDIn April of 2013, the South Coast Air Quality Management District (SCAQMD) adoptedRule 1148.2, establishing the states first notification and reporting requirements forselected enhanced oil and gas recovery activities.1

Starting June 4, 2013, SCAQMD required oil and gas well operators to submit reports(Event Reports) that disclose where and when they plan to use the oil and gasrecovery techniques of acidization, gravel packing, and fracking.

The rule also requires operators to disclose the chemicals used in these operations in apublicly available chemical report within 60 days of completing the activity (ChemicalReports). In July 2013, operators started disclosing some, but not all, of the chemicalsbeing used. As required by the rule, SCAQMD has made this data available online.

FINDINGS

Based on a review of one years worth of reports, SCAQMD data shows that oil and gasproduction employs an alarming amount of chemicals in communities in the SouthCoast Air Basin.

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Many of these chemicals are known air toxics chemicals that cancause serious health effects in people exposed to them.

Since reporting began, there have been 477 instances of fracking, acidizing, and gravelpacking in the region. In total, at least 44 different air toxics have been used 5,068times. The most commonly used air toxic, crystalline silica, was used more than 1,500times.

Hundreds of Well Stimulation EventsWell stimulation is any type of activity used to enhance the flow of hydrocarbons. Theparticular well stimulation techniques that are the focus of this reporting requirementhave been used hundreds of times in Los Angeles and Orange counties over the pastyear. The data shows that more than once per day, on average, chemicals are beinginjected into an oil well in Los Angeles or Orange County.

Well Stimulation Reported Occurrences

Acidizing 314

Gravel Packing 149

Fracking 14

Total 477

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Acidizing:Acidizing is a process in which a combination of hydrochloric acid and otheracids are mixed with brine and other chemicals and injected underground to either cleanout a well or to dissolve oil bearing rock to enhance production of oil and gas. Once theacid, chemical, and water mixture has been pumped into the well or formation, oil flows

to the well more freely. Since event reporting began in early June 2013, there havebeen approximately 314 acidizing events reported in Los Angeles and Orangecounties.

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This number is likely less than the actual number of acidizing events that haveoccurred.5

Several reports disclose that the operator used acid for an acid wash oracid perforation, but failed to check Y under the acidizing query on the reporting form.Thus, even though large amounts of acid, chemicals, and water have been pumped intothe ground, it is not counted on aggregate data searches because the operator did notcheck the acidizing box on the form. This analysis did not attempt to correct for thisdiscrepancy and, therefore, may underreport the actual number of acidizing events.

Gravel Packing:In gravel packing, gravel is injected with a chemical mixture andplaced near the wellbore to form filters that help prevent the buildup of sand inside thewell. Minimizing sand buildup increases the flow of oil to the surface. Since June 2013,there have been approximately 149 gravel packing events reported in Los Angeles andOrange counties. Again, some reports indicate that gravel packing has occurred, but theoperator did not categorize it as gravel packing on the report. For example, an operatorreported Not Stim[ulation] Gravel Pack, but left the gravel packing box unchecked.Thus, like acidizing, even though gravel packing has occurred, it is not always includedin aggregate data searches because the operator did not check the gravel packing boxon the form. Consequently, the actual number of gravel packing incidents may behigher.

Hydraulic Fracturing:Also known as fracking, hydraulic fracturing is a recoverymethod in which large amounts of water, sand (typically), and chemicals are injectedunder extremely high pressures into a rock formation to create fractures in the oil-bearing rock to enhance oil flow from the well. Since June 2013, there have beenapproximately 14 fracking events reported in Los Angeles and Orange counties.

Most Common Air ToxicsA review of the data from June 4, 2013, through June 3, 2014, shows that at least 44different chemicals reported as being air toxics were used by operators. Thesechemicals were used in at least 5,068 instances. More than 45 million pounds or22,500 tons of these air toxics were used.

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The 12 most commonly used air toxics are shown in the chart below:

The 12 Most Commonly UsedAir Toxins in Unconventional OilProduction in the L.A. Basin6

Rank Chemical Number

ofInstancesUsed7

Totalamount bymass (lbs.)

Known Health Effects

1 CrystallineSilica

91590 25,497,493 Harmful to skin, eyes, and sensory

organs, respiratory system, immunesystem and kidneys; mutagen.

2 Methanol 810 166,751 Harmful to skin, eyes, and sensoryorgans, respiratory system,gastrointestinal system and liver,

brain and nervous system, immunesystem, kidneys, reproductive andcardiovascular system; mutagen,developmental inhibitor andendocrine disruptor.

3 HydrochloricAcid

498 10,897,302 Harmful to skin, eyes, and sensoryorgans, respiratory system,gastrointestinal system and liver,immune system, cardiovascularsystem and blood.

4 Formaldehyde 232 32,519 Harmful to skin, eyes, and sensory

organs, respiratory system,gastrointestinal system and liver,brain and nervous system, immunesystem, kidneys, reproductivesystem and cardiovascular system;mutagen, developmental inhibitor.

5 AmorphousSilica

10215 750,300 Harmful to skin, eyes and other

sensory organs, respiratory system,

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gastrointestinal system and liver;linked to lung cancer.

6 HydrofluoricAcid

204 5,454,496 Harmful to skin, eyes, and sensoryorgans, respiratory system,gastrointestinal system and liver,

brain and nervous system, immunesystem, kidneys, reproductivesystem and cardiovascular system;mutagen, developmental inhibitor.

7 Naphthalene 185 25,014 Harmful to skin, eyes, and sensoryorgans, respiratory system,gastrointestinal system and liver,brain and nervous system, immunesystem, kidneys, cardiovascularsystem; mutagen, endocrinedisruptor, developmental inhibitor.

8 2-ButoxyEthanol11 177 69,988 Harmful to skin, eyes and othersensory organs, respiratory system,

gastrointestinal system and liver,brain and nervous system, immunesystem, kidneys, reproductivesystem and cardiovascular system;mutagen, developmental inhibitorand endocrine disruptor; linked toliver cancer. Also linked to adrenaltumors.

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9 Alumina /

AluminumOxide

145 761,889 Harmful to skin, eyes and other

sensory organs, respiratory system,and brain and nervous systems.

10 Xylene 116 97,178 Harmful to skin, eyes and othersensory organs, respiratory system,gastrointestinal system and liver,brain and nervous system, immunesystem, kidneys, reproductive andcardiovascular system;developmental inhibitor andendocrine disruptor.

11 Glutaral/

Pentanedial

116 67,298 Harmful to skin, eyes, and sensory

organs, respiratory system,gastrointestinal system and liver,

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brain and nervous system, immunesystem, kidneys, reproductive andcardiovascular system; mutagen,developmental inhibitor andendocrine disruptor.

12 Ethylbenzene 111 81,934 Harmful to skin, eyes, and sensoryorgans, respiratory system,gastrointestinal system and liver,brain and nervous system, kidneys,reproductive system andcardiovascular system; suspectedcarcinogen, mutagen, endocrinedisruptor, developmental inhibitor.

Chemicals Used Close to Schools, Hospitals and Homes

SCAQMD data shows that roughly 265 reported well stimulation events occurred atsites within 1,500 feet of at least one hospital, preschool, or residence and somewere as close as 12 feet. Many wells are close to several facilities housing peopleespecially vulnerable to toxic chemicals. For example, Freeport-McMoRan Oil and GasCompany conducted three acidizing events at its Jefferson production site, a cluster ofwells located in a densely populated part of Los Angeles. Those chemical-intensiveactivities took place just 85 feet from homes, 145 feet from a church, and 770 feet froman elementary school. Use of industrial chemicals near children and the elderly isespecially concerning because chemicals may have relatively severe health effects inthese vulnerable populations compared to the general adult population. Medical andhealth professionals warn of substantial and detrimental health risks for surrounding

communities.

Voices from the Medical Community

James Dahlgren, M.D.

Children, the elderly, and people who are already sick are especially at risk from

exposures to air toxics. Data collected over the years strongly supports the need for

special attention to be paid to these populations because they tend to have reactions to

chemicals at lower levels than the general adult population.


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Fig. 1: The Jefferson wells in Los Angeles and their proximity to surrounding receptors.

In another example, Brea Canon Oil Company acidized its Joughlin 3-D well located inthe middle of a residential neighborhood in Harbor City. The nearest home was only 50feet from the well where dozens of toxic chemicals were used to acidize the well.

Figure 2: Joughlin 3-D well and its proximity to residences in Harbor City, California

Jefferson Wells

770 ft. from

elementary school

85 ft. fromresidences

145 ft from

Church

Joughlin well

50 ft. from nearest

residences


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Trade Secret Claims Conceal Key InformationOil industry reporting may significantly understate the frequency and volume of chemicaluse because operators have withheld chemical information from their reports in 5,050instances.

The full extent of the risks of oil recovery techniques is still unknown, in part because oilcompanies have kept the identity of certain chemicals hidden from the public based onclaims that the list of chemicals used incertain products is a trade secret. Instead ofdisclosing the chemicals used, the companymerely submits a vague description, whichSCAQMD substitutes for the real chemicalinformation when the reports are postedonline. These descriptions are often so vaguethat they do not provide the public with useful

information about what chemicals were used.For example, some trade secret chemicalsare described as a lubricant, surfactant, orsimply, mixture.

Trade secret claims can be used bycompanies to hide their proprietaryinformation, but such protections do not applyto chemical identities and concentrations related to well stimulation. California state lawclearly states:

Notwithstanding any other law or regulation, none of the following shall beprotected as a trade secret: [t]he identities of the chemical constituents ofadditives, including [chemical abstract service] identification numbers.13

Thus, none of the 5,050 claims for a trade secret is valid under state law. Despite theclear and explicit statute, operators continue to withhold chemical information bysubmitting claims of trade secrecy for a large number of chemicals, leaving the publicwith no knowledge of what chemicals are being used or in what quantities. Despitemultiple requests14

to SCAQMD asking for public disclosure of all chemical identities,SCAQMD has so far offered no information or explanation as to why the informationremains withheld from the public.

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In addition, many of the trade-secret protectedchemicals are marked as an air toxic. Of the5,050 instances in which an operator withheldthe identity of a chemical, 1,037 are marked asbeing an air toxic. Another 663 trade secret

claims provide no indication of whether it is anair toxic or not. This means that as many asone third of that group of chemicals could beadditional, undisclosed air toxics being used incommunities.

Furthermore, the air toxic designation ofwithheld chemicals is not viewable whenindividual reports are viewed on the SCAQMDwebsite. Thus, a chemical under a trade secretclaim may show a Y, indicating an air toxic,

when downloaded from the site with other wellinformation, but when the individual report isviewed on the SCAQMD website, the boxindicating the presence of an air toxic next to

the same trade secret claim is left unchecked. This means a person looking up aparticular well stimulation report online will not know whether any of the trade secretclaims are hiding the use of an air toxic. This seems to be a limitation in SCAQMDsonline reporting interface.

Even More Chemicals Are Used In Other Stages of Oil and Gas DevelopmentIt should be noted that SCAQMDs data captures only those chemicals used during wellstimulation, not those used during other stages of development, such as siteconstruction, drilling, well completion, conventional extraction, transportation,processing and refining, and end-use combustion. While SCAQMD has not requiredreporting for these chemicals, many studies show significant public health and safetyconcerns associated with oil and gas activity as a whole.

For example, independent air quality sampling from Colorado showed that there was aspike of harmful air emissions during the initial drilling phase of a well. Mixtures knownas drilling muds, which contain a number of chemicals, are used to facilitate the drillingprocess. The emitted air toxics included volatile organic compounds and polycyclicaromatic hydrocarbons.

15The study found that harmful chemicals were emitted

throughout the process. Air sampling detected many chemicals known to have harmfulhuman health effects, including acetaldehyde, benzene, formaldehyde, isoprene,naphthalene, and many more.

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Chemical Profiles

Hydrofluoric Acid (hydrogen fluoride):Commonly used in acidizing to helpdissolve materials inside a well or the

underground shale formation,hydrofluoric acid is extremely corrosiveand can cause severe skin burns uponcontact. The chemical can cause avariety of health effects (see tableabove) and even cause death throughskin exposure or inhalation. Releases ofthis chemical causes extremelydangerous clouds to form and drift alongthe ground without dispersing. Becauseof its highly dangerous properties, the

SCAQMD adopted a rule to phase outits use in refineries.


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A separate study showed that toxic air emissions from well sites are likely to be fargreater than official estimates. The study found that well sites were emittingbenzene, aknown carcinogen, at a rate seven times higher than U.S. EPA estimates.17The studyalso found that methane, which can lead to increased levels of harmful ground-level

ozone and smog, was emitted at rates three times higher than U.S. EPA estimates.

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Another chemical common in oil and gas operations is methylene chloride. Exposure tothis highly volatile chemical can lead to damage to sensory organs, the liver, kidneys,respiratory system, immune system, cardiovascular system, brain and nervous system,gastrointestinal system, and endocrine system.19It is also considered a potentialcarcinogen.

20Methylene chloride is thought to be widely used as a cleaning agent for

equipment on oil and gas production sites. Because its use is separate from wellstimulation fluid, operators do not report its use, yet studies have shown that it isprevalent in air samples taken close to oil and gas operations.

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Nearby Communities at Risk of ExposureThese air toxics, which can be emitted before, during, and after well stimulation, areendangering the health of nearby residents. In Los Angeles, the AllenCo oil facility hasbeen cited for multiple air emission violations. The pollution has been linked tonosebleeds, headaches, breathing trouble, and nausea suffered by nearby residents,leading to hundreds of complaints to SCAQMD.

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After AllenCo was forced to haltoperations, the Los Angeles Timesrevealed that reports of illnesses had diminishedsignificantly. Whether or not well stimulation is used, oil and gas operations areresponsible for emitting air toxics throughout the process.

CONCLUSIONThe data reported to SCAQMD, while incomplete in many ways, shows extensive andwidespread use of harmful chemicals in the Los Angeles air basin. The pervasive andpersistent use of these chemicals threatens to contaminate local air quality and putcommunities health and safety at risk. The reporting requirements have proven theneed for immediate action to protect the public.

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Documents

Air Toxics One Year Report (Final) Copy