FLOWBACK TX-OGAP Health Report

8/7/2019 FLOWBACK TX-OGAP Health Report

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HOW THE TEXAS NATURAL

GAS BOOM AFFECTS

HEALTH AND SAFETYAPRIL 2011

Flowback

Natural Gas

EARTHWORKSTM


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This report was prepared by Sharon Wilson, Lisa Sumi, Bill Walker and Jennifer Goldman of Earthworks Oil

& Gas Accountability Project, with technical review by Wilma Subra of Subra Company. We would like to

thank the following for their review and comments of the document: Cherelle Blazer, Kathy Chruscielski,

Gwen Lachelt, Deborah Rogers, Calvin Tilman, Tammi Vajda, and Don Young. Special acknowledgments go

to those personal and community stories told in this document including the Argyle - Bartonville Commu-

nity Alliance, the Town of Dish, The Parr Family, and Christine and Tim Ruggiero.

Texas Oil & Gas Accountability Project

P. O. Box 470567 Fort Worth, Texas 76147

940-389-1622 http://texasogap.earthworksaction.org

Texas Oil & Gas Accountability Project is a campaign

of Earthworks www.earthworksaction.org

CONTENTS

EXECUTIVE SUMMARY ................. .................... .................... ................... .................... .... PAGE 3

INTRODUCTION: An Overview of the Texas Shale Boom ................... .................... ..... 4

1. HEALTH AND ENVIRONMENTAL IMPACTS OF DRILLING AND FRACKING ............6

2. CASE STUDIESPoisoned Communities ................... .................... ................... .......... 10

3. CASE STUDIESPoisoned Families .................. .................... ................... .................... ... 15

4. CONCLUSIONS AND RECOMMENDATIONS ................. .................... ................... .......... 18

EARTHWORKSTM


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EXECUTIVE SUMMARY

In the last decade, hydraulic racturing and other new drilling

technologies have turned North Texas into the leading shale

gas-producing area in the country. But the drilling boom

has brought with it serious concerns over the health and

environmental impacts o an industry that uses large volumes

o toxic chemicals in close proximity to Texas communities.

The search or deposits o shale gas is spreading to other

regions o Texas, raising the question o whether the state isadequately protecting its citizens and its resources.

This investigation by the Earthworks Texas Oiland Gas Accountability Project concludes thatthe answer is No.

We have compiled and collected data on the serious healtheects o gas drilling, hydraulic racturing (e.g., racking) andproduction on Texans throughout the Barnett Shale; watercontamination and depletion; air pollution and other impacts.We have also documented that the states present regulations,laws and enorcement policies are ar too weak. Not only are

the resources or dealing with the health and environmentalimpacts o gas production insucient to meet the scale o theboom, but state regulators consistently downplay the risks,take sides with industry against landowners, and respond tocomplaints eebly, i at all. This report presents case studies ohow this denial, complacency and bureaucratic inaction aredisrupting the lives o amilies and communities.

Too oten citizen testimonies o health eects or evidencegathered by citizens, as in this report, are dismissed as anec-dotal evidence and as long as each case is treated as an iso-lated incident the larger pattern is ignored. But when so manycitizens across almost two dozen counties report similar com-plaints and symptoms associated with gas drilling, somethingis wrong. More thorough research is needed to determine i

drilling and racking can be done more saely and under whatconditions and locations they should or should not be permit-ted. At the same time immediate action is warranted to pro-tect public health and the environment.

We recommend:

The Texas Commission on Environmental Quality must signi-cantly step up its currently inadequate eorts to protect pub-lic health by strictly enorcing emission limits rom oil and gasexploration and production equipment.

The Texas Railroad Commission, long the oil and gas industryslapdog, must become a watchdog. The Railroad Commissionmust adopt rules that provide the public with ull public dis-closure o oil and gas drilling and racking uids. To protectsurace and groundwater resources rom oil and gas con-tamination, the Commission must implement rules requiringclosed-loop drilling systems and water-based drilling uids.

The Texas Water Development Board must exercise its author-

ity to evaluate groundwater resources and the impact thathydraulic racturing withdrawal is having on groundwaterresources. The agency must implement rules that require recy-cling o owback water.

Authority to regulate air emissions rom oil and gas explora-tion and production equipment should be overseen by theU.S. Environmental Protection Agency. The EPA should over-see permitting o existing and uture point sources through aederal advisory commission that includes citizen representa-tion. The agency must also identiy the sources o methanecontaminants in groundwater.

Is the stateadequatelyprotecting itscitizenry?

EXECUTIVE SUMMARY

Reilly Ruggiero plays while a drilling rig operates in her back yard.

Photo by Christine Ruggiero


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INTRODUCTION AN OVERVIEW OF THETEXAS SHALE BOOM

Over the last decade the rise o natural gas prices has driven an

unprecedented expansion in exploration and development o

so-called unconventional gas resources, especially gas rom

deeply buried shale rock ormations. The shale gas boom

has transormed the landscape o many parts o the United

States, but none more dramatically than the Barnett Shale

ormation in North Central Texas, which is by ar the leading

shale gas-producing region in the nation.1

According to the Texas Railroad Commission, which regulatesthe natural gas industry, the Barnett Shale ormation underlies

approximately 5,000 square miles, producing gas in 23 coun-ties spreading north, west and south rom Fort Worth and

Tarrant County.2 The Barnett Shale ormation was discoveredin 1981. Since drilling began in the 1990s, production has sky-rocketed rom 11 billion cubic eet in 1993 to 1.76 trillion cubiceet in 2009.3

But the boom did not really take o until 2001. Between2001 and 2005, approximately 1,000 to 1,500 wells werecompleted annually. In 2006, 2007 and 2008, more than2,000 wells were completed per year. As o November 2010,Railroad Commission records show 15,574 wells drilled in theregion, with drilling permits issued or another 3,000 locations.Industry analysts report that Barnett Shale production has notyet peaked,4 and that the Barnett Shale may in act prove to

be the largest onshore natural gas eld in the United States.5

In the past year, concern over the health and environmen-tal impacts o shale gas drilling have led some jurisdictions,including Dallas and Grand Prairie, to issue a temporary mora-torium on new wells allowing time to update local ordinances.It is clear, however, that despite restrictions in some locations,

Texas shale gas boom is not going away in act, it is spread-ing rom North Central Texas to other parts o the state. Thechallenge or Texas is not whether to allow shale gas and oilproduction, but how to protect the communities whose lives

and landscapes are being transormed by the boom.Extracting gas rom underground shale deposits is made pos-sible by new horizontal drilling techniques drilling diagonallyunder property rom an adjacent well and new well-stimu-lation processes, chie among them hydraulic racturing, alsoknown as racking. Drillers mix hundreds o millions o gallonso water with a cocktail o chemicals and sand and inject theuid into the wellhead under high pressure. The pressure cre-ates ractures in the shale, allowing gas to be released to thesurace. Unortunately the chemical-laced racking uids canalso escape rom the shale deposit, owing back to the sur-ace or migrating to groundwater bearing zones. According toCongressional testimony in 2005 by then-Railroad CommissionChairman Vincent Carrillo, 90 percent o all oil and gas wells inthe United States are subjected to racking.6

The exact ormulas or racking uids are closely guarded com-pany secrets, but can include cancer-causing chemicals suchas benzene and chromium, heavy metals and dozens o petro-leum-derived compounds.7 An analysis o racking chemicalsknown to be used in Colorado ound no ewer than 65 sub-stances that are listed as hazardous under ederal law.8 Becausethe oil and gas industry in 2005 got Congress to exemptracking uids rom the Sae Drinking Water Act a loopholeopened ater lobbying by Houston-based Halliburton oil andgas is the nations only industry allowed to inject hazardoussubstances unchecked directly into, or directly adjacent to,underground drinking water sources.9

The Texasshale boomINTRODUCTION

Let: Barnett Shale counties. Right: Producing wells as o December 15, 2010. Oil wells green; gas wells red; and drilling permits blue.

http://www.rrc.state.tx.us/barnettshale/index.php.


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LIVING WITH THE BOOM

This large-scale industrial activity deploying vast amounts ohazardous substances is happening not at hard-hat reneriesor isolated oil elds, but in Texans back yards sometimes lit-erally, as horizontal drilling and split-estate laws make it pos-sible to locate a drill rig a ew eet rom a residence without thehomeowners consent. It is occurring in cities, suburbs, smalltowns and rural communities, within just hundreds o eet ohomes, churches, schools, parks, armland, lakes and rivers.

Texans living in the Barnett Shale have experienced rapid andin some cases extreme changes in their daily lives.

Fracking and other gas development brings massive drillrigs, high-pressured drilling and stimulation operations, highvolumes o toxic uids, contaminated wastewater, industrialcompressor stations, condensate tanks, noisy and pollutingdiesel engines, networks o pipelines, increased truck tracand noise, and concerns about drilling waste disposal andsaety. Throughout the Barnett Shale, residents are concernedabout air pollution rom oil and gas operations and the riskso groundwater and surace water contamination by rack-ing chemicals. Health problems have become central issues,with many residents complaining o odors, dizzi-

ness, nosebleeds, headaches, agitation, and in somecases, more severe symptoms.10 Livestock havedied. Homes have been abandoned on advice ophysicians.

The industry denies the risks and state regulatorsdownplay them, saying there are no denitive linksbetween drilling, racking and production opera-tions and residents complaints and symptoms. Aswe will see, thats not true: doctors and investiga-tors have documented contamination o people andproperty with chemicals used by the industry thatcould not have come rom anywhere else. One thingis clear: Where drilling goes, contamination andhealth problems ollow.

The Barnett Shale region is the rst area o Texasto experience on a large scale the problems thatcome with unconventional gas drilling, but it willnot be the last. A boom is already well under wayin the Eagle Ford Shale ormation, which lies undertwo dozen counties mostly south and west oSan Antonio and Bexar County. From just 33 drill-ing permits in the Eagle Ford in 2008, the numberswelled to more than 1,000 by the end o 2010.11

The Haynesville Shale, the ourth-largest natural gas eld inthe U.S., is centered in northwest Louisiana, but extends intoadjacent counties in East Texas. And according to recent newsreports, gas companies are making big oers to landowners

in several counties west o Lubbock, with drilling in an as-yetunnamed shale gas ormation expected to begin this summer. 12

CURRENT REGULATIONS ARE INADEQUATE TOMEET THE PROBLEM

The spread o shale gas drilling to other parts o the statemakes it particularly worrisome that Texas current regulatoryand enorcement system is woeully inadequate or protectingcitizens rom the risks associated with hosting such hazard-ous activity in their communities. This report by the Texas Oil& Gas Accountability Project (Texas OGAP) tells the stories oentire communities and o amilies whose concerns have been

met with ocial denial, complacency or bureaucratic inac-tion. Regulations are weak, outdated or simply dont cover theunique conditions o drilling in the Barnett Shale.

In 2007, a state auditors investigation o the RailroadCommissions enorcement capability ound that almosthal o Texas oil and gas wells hadnt been inspected in thelast ve years.13 In October 2010, a scathing report by thestate Sunset Commission recommended restructuring theagency because o conicts o interest with the oil and gas

industry, which makes hety campaign contributions to theelected commissioners. The Sunset Commission also noted:The (Railroad) Commission pursues enorcement action ina very small percentage o the thousands o violations itsinspectors identiy each year.14

In December 2009, the nonprot investigative news organi-zation ProPublica surveyed the regulatory systems in 32 oiland gas producing states. The survey ound that Texas hadby ar the most wells almost 275,000 but the ewest regu-lators to oversee them. O 106 Railroad Commission sta atthe time, 83 were inspectors, meaning each was responsibleor almost 3,300 wells.15

Through the Texas Public Inormation Act, Texas OGAPobtained and analyzed records o citizen complaints to the

Texas Commission on Environmental Quality (TCEQ) aboutdrilling and racking operations in Barnett Shale counties.We ound that 256 complaints more than one a day wereled in the rst seven months o 2010, yet only three noticeso violations were issued, all or the same site in Wise County. 16

In Fort Worth, the biggest city hosting the Barnett Shaleboom, the Fort Worth League o Neighborhoods investi-gated the system o drilling regulation and enorcement andreported in February 2011 that both the city and the stateare allowing gas companies to police themselves throughthe honor system:

Regulation consists o nothing more than a permit filed [by adrilling company] with the TCEQ stating that [air] emissions willnot go above a certain threshold. But no independent routine

11 14 20 26 28 3441

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1,104

1,612

1,7761,828

0

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2,000

2,500

BCF

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

Newark, East Barnett Shale gas well production 1993 - 2010.


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physical verification o these permit claims is currently beingdone by the State or the City. This is problematic or a varietyo reasons, not least o which is that the operators have a clearconflict o interest inherent in their need to maximize profits.17

In the most notorious case o the states ailure to protectcitizens, in the summer o 2010 methane and other chemicalswere ound in the water wells o two Parker County home-owners ater two gas wells were drilled nearby. Tests by theU.S. Environmental Protection Agency strongly suggested the

methane came rom the gas wells, but or months the RailroadCommission took no action. Ater EPA determined that stateand local ocials did not plan to do anything, in February2011 the agency issued an emergency order against the drill-ing company.

But in March 2011 the Railroad Commission cleared the com-pany o liability because ederal ocials couldnt point to thespecic path the chemicals took rom the gas wells to thewater wells. As clear evidence o its bias toward industry, theRailroad Commission put the burden o proo on the EPA and by extension, landowners rather than holding drillersresponsible or making sure their wells are sae.

Texas can and must do a better job o protecting Texans

rom the undeniable hazards posed by the proximity to homes,schools, hospitals and churches o large-scale industry thatuses heavy equipment and tons o toxic and volatile chemicalson a daily basis. For public health and the environment, thestakes are too high to ignore.

HEALTH AND ENVIRONMENTAL IMPACTS OFDRILLING AND FRACKING

Airborne Chemicals

Some o the airborne emissions and odors experienced bycitizens in oil and gas communities come rom chemicals usedwhen oil and gas wells are drilled or racked. Other emissions

and odors come rom chemicals that naturally occur in oil andgas and chemicals that are created when gas is ared or whenuel is burned in engines or compressors, trucks and drillingrigs. Chemicals that have a tendency to become airborne areknown as volatile organic compounds or VOCs.

In April 2009, The Endocrine Disruption Exchange (TDEX), anindependent research organization based in Paonia, Colorado,analyzed health eects data or 61 chemicals ound in prod-ucts known to be used during oil and gas drilling or hydraulicracturing in Texas. When drilling wastes or used racking uidsreturn to the surace, they oten end up in open tanks or pits.VOCs in the uids may then be emitted to air. Approximatelyone-ourth o the chemicals examined were volatile, andaccording to TEDX can readily become airborne and can be

inhaled as well as swallowed, and can reach the skin. 18 Morethan 90 percent o the chemicals are harmul to the brain,nerves, lungs, and digestive system; 80 or more percent canaect the heart, blood and kidneys; and 67 percent can aectthe immune system.

Health andenvironmentalimpacts

1

In the most notorious case of thestates failure to protect citizens,in the summer of 2010 methane and

other chemicals were found in thewater wells of two Parker Countyhomeowners after two gas wells weredrilled nearby.

Health eects related to chemicals used to drill and racture wells

in Texas.Photo by Sharon Wilson


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Air Emissions in Fort Worth

In the past three years, numerous air sampling studies by pub-lic agencies, private citizens and even the natural gas industryitsel have conrmed that shale gas acilities in Fort Worth where more than 1,000 gas wells are located inside the limitso a city o more than hal a millionresidents are emitting concentra-tions o air pollutants that exceedhealthy levels.

Early concerns about air emis-sions rom gas drilling activi-ties in North Texas were raised in200819 by Dr. Alredo Armendarizo Southern Methodist University,later appointed as the EPA Region6 administrator. He conducted astudy o air pollutants that con-tribute to the ormation o ground-level ozone, commonly known assmog. The study concluded thatdrilling activities were contribut-ing more to smog than all the cars,

trucks and airplanes in the Dallas-Fort Worth region.

In May and June 2009, privateair tests were conducted whichraised additional questions aboutemissions coming rom gas wellswithin the city limits o Fort Worth.

Tests were conducted on the armo Deborah Rogers (whose storyis told in Part 3) by Wol EagleEnvironmental, an environmen-tal assessment rm rom FlowerMound in Tarrant County. Thesebrought to light other toxic com-pounds apart rom the ozone con-tributors analyzed by Almendariz.

The new compounds included ben-zene, a known carcinogen, togetherwith toluene, ethylbenzene andm&p xylenes.20 In addition, various sulur compounds, particu-larly carbon disulfide, a potent neurotoxin, were detected atextremely high levels. Armendariz reviewed the ndings andadvised the landowner that carbon disulfide was ound at lev-els 300 times the norm or ambient urban air. 21

Following these alarming ndings, the Texas Commission orEnvironmental Quality ordered its own tests to determinethe extent o exposure to these newly detected compounds.

These tests conrmed that benzene, tolulene and carbondisulde, among other chemicals, were indeed being emittedby gas acilities in the Barnett Shale region. In its nal report onthe tests, issued in January 2010, TCEQ stated that gas produc-tion acilities can, and some cases do, emit contaminants inamounts that could be deemed unsae.22TCEQ ound that 21acilities in 12 locations registered benzene above long-termhealthly levels. Carbon disulde, ethane, 1,2 dibromethaneand isopentane were ound in concentrations above short-term healthy levels. In all, 35 chemicals were detected at aboveappropriate short term levels.23

In August 2010 the City o Fort Worth hired Eastern Research

Group, an air monitoring consultant in Austin, to conduct itsown air quality study. Preliminary results, released in February2011, identied benzene and carbon tetrachloride emissionsrom seven sites. Emissions at two sites exceeded TCEQs limito 25 tons o volatile organic compounds a year. Neither theCity nor the State had previously been aware o a problem at

these sites. 24

Most recently, the Fort WorthLeague o Neighborhoods com-

missioned a study that used emis-sions data rom a June 2011 studycommissioned by the BarnettShale Shale Energy EducationCouncil, a public relations eortunded by gas companies operat-ing in the region.25 The data, romsamples taken at two sites nearLake Arlington, showed elevatedlevels o carbon disulde, in onecase just below the TCEQs healthylevel and in the other almost 2.5times higher than the healthy level.

Scientists hired by the League oNeighborhoods then used com-puter modeling and more than ayears worth o meterological datato determine how ar those levelso the chemical would dispersein relation to nearby schools. Theresults, released in February 2011,ound that levels o carbon disul-de could reach the schools thatare several times higher than thesae workplace level or adults setby the U.S. Occupational Saetyand Health Administration. The

Leagues study concluded thatto protect the health o students,drilling sites should be prohibitedwithin one mile o schools.26

Water Depletion

Amid increasing scarcity o water supplies, the immense quan-tities o water required or hydraulic racturing are not sustain-able. Huge volumes o water are needed to extract shale gas.Estimates range rom 1.5 million to ve million gallons o waterper well, and wells may be reracked several times over the lieo each well.27 Recently, the oil and gas industry announced anew 12-stage completion method that uses over 9 million gal-lons o water per well.28

O the metered sources in the our-county Upper TrinityGroundwater Conservation District only a part o theBarnett Shale ormation drillers used more than 1 billion(1,146,598,272) gallons o water in 2009.29 Water was alsotaken rom unmetered sources. Some areas o the TrinityAquier have already dropped hundreds o eet.30

The Texas Water Development Board predicts massiveincreases in water used to rack shale gas, with particularlysevere impacts on rural counties. By 2020 rom 14% to 76%more water will be needed or gas drilling and production inBosque, Erath, Hamilton, Hill, Jack, Montague and Palo Pinto

Top: Aruba Petroleum emissions in Wise County.

Photo by Tim Ruggiero

Bottom: Red Oak Gas Operating Co. emissions in Denton

County. Photo by Robert Massagli


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Counties.31 The Upper Trinity conservation district is eldingcomplaints rom landowners whose wells are drying up.Theirwells might go rom seven to eight gallons a minute to halthat, said Executive Director Bob Patterson. He thinks rackingcould be a actor.32

Water consumption has quickly emerged as a concern in theEagle Ford region, too. Veteran Karnes County oilman JohnBraudaway says: They already know theyre gonna run thisarea out o water; theres no is, ands, or buts about it. Said Larry

Akers, assistant manager o the Evergreen Water ConservationDistrict, the water planningagency or Atascosa, Frio, Karnes,and Wilson counties: We reallyhave no idea how much waterthey are pulling rom our area,and its really rustrating.33

When the water used or hydrau-lic racturing returns to thesurace as owback it is contam-inated with racking chemicalsand impurities rom the orma-tion. This toxic soup requires per-

manent disposal by injecting itinto deep disposal wells sealedabove and below by unbroken,impermeable strata.34 Dr. Paul F.Hudak o the geography depart-ment at the University o North

Texas says:

Disposing o used water through properly operated andmaintained injection well systems, into deep rock ormations,essentially removes that water rom the active hydrologiccycle. Conceivably, this water could return to the active hydro-logic cycle at some very distant point in the uture (speaking ingeologic terms, well beyond human time rames).35

As technological advances increase the ability to extract moreshale gas, treating water used or hydraulic racture will be crit-ical to its continued use. The technology exists to recycle ow-back allowing the water to remain in the hydrologic cycle butcurrently this technology is used on a very limited basis.36

Water Contamination

There are many pathways or water contamination rom natu-ral gas drilling, but it is dicult to determine precisely whethera given case o contamination is rom spills, leaks, illegaldumping, waste pits or racking. This is not only because oinadequate or inecient regulation, but because the industryholds its chemical ormulas and processes as closely guardedtrade secrets. The Energy Policy Act o 2005 eliminated the U.S.

Environmental Protection Agencys ability to monitor or regu-late hydraulic racturing and allows industry to claim chemicalsused as trade secrets.37 When private water wells are contami-nated during or ater hydraulic racturing, the burden o proois placed on individuals who cannot even know exactly whatchemicals to test or to prove contamination.

Water contamination was a consequence o Barnett Shaledrilling rom the beginning. The potential or the Barnett Shalewas rst realized in the 1980s when Mitchell Energy was exper-imenting in Wise County with ways to extract gas by usinghydraulic racturing. A landowner named Jim Bartlett suedMitchell Energy in 1987 because his newly drilled water well

was contaminated with natural gas and hydrogen sulde. Asa result o the lawsuit, which did not go to trial until 1996, theRailroad Commission investigated and ound that more than100 wells in the county didnt have enough surace casing toprotect groundwater and that records about the surace cas-ing had been alsied.38

But the problem has not gone away. Larry Bisidas has 40 yearso water well drilling experience in Wise County. In the pastew years, he has witnessed dramatic declines in water qual-

ity and an increase in contaminated water wells. He told theWise County Messenger that hebelieves contamination occursbecause operators are not runningthe casing pipe (the pipe, securedwith cement, that holds the drill-head in place) deep enough: [It]has to be deep enough or else itsgonna leak up through the strata.I dont know why people cant seethat. His 30-year-old water wellsnow produce water that is too saltyto drink. He buys bottled water.39

In Grandview, Johnson County,three amilies lost their drinkingwater when their private waterwells were contaminated soonater Williams Production-GulCoast Co. racked the second otwo gas wells a ew hundred yards

rom their homes. The water wells were contaminated with tol-uene, a solvent that is harmul to etal and child developmentand that does not occur naturally. Shortly ater Christmas in2007, several animals died rom drinking the water, one land-owner asked a worker at the drill site what happened. Theworker said a drilling pipe had ruptured 700 eet below thesurace. The company claimed they were not responsible.40

Range Resources in Parker County

The most controversial case o water contamination in theBarnett Shale comes rom southern Parker County. In 2009,Range Resources o Fort Worth drilled two gas wells, about 120eet rom one private water well and 470 eet rom another.In December 2009, our months ater gas production started,one water well owner noticed that his water was eervesc-ing, or zzing. He began raising concerns with the RailroadCommission, in July 2010 discovered he could set the waterrom his garden hose on re a phenomenon that has beenound at other racking sites where methane has contami-nated water supplies.41

In August 2010, the owners o both water wells commissionedtesting which ound benzene, tolulene, methane and ethane.Soon aterward, both the Railroad Commission and the EPAconducted their own tests. The Railroad Commission oundbenzene and tolulene; the EPA ound the same chemicalsas in the water well owners tests, plus propane and hexane.Isotopic testing by the EPA indicated that the methane in thewater was likely rom the same source as methane ound in thenatural gas produced by Ranges wells.

In November 2010, the EPA concluded that the danger oexplosion was so great that it advised the owners o bothwater wells to stop using the water. EPA later reported:

Braden Exploration waste pit just eet rom a creek that ows

into Denton Creek, Wise County. Photograph by Sharon Wilson.


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EPA has consulted with the appropriate State o Texas and localauthorities, including the Railroad Commission o Texas, theTexas Commission on Environmental Quality, and the ParkerCounty re marshal, regarding the presence o contaminantsin the source o drinking water . . . and disclosed the potentialendangerment to the health o persons. . . . EPA has determinedthat the appropriate State and local authorities have not taken

sucient action to address the endangerment described hereinand do not intend to take such action at this time.42

On Dec. 6, 2010, EPA issued an emergency order direct-ing Range Resources to provide the water well owners withreplacement water supplies, to sample all water wells within3,000 eet o the two gas wells, to test or gas in the soil andindoor air o the homes o the owners, and to identiy andremediate gas leaks into the Trinity Aquier.

The emergency order set o a bitter public dispute betweenthe Railroad Commission and the EPA over ederal author-ity vs. state authority in regulating racking and emissions.Range Resources challenged the order, saying that the chemi-cals more likely came rom a much more shallow deposit o

gas that had long been identied as a source o methane inwell water, not the Barnett Shale ormation the companyswells tapped. Ranges lawyers made much o the act thatEPA could not identiy the exact route the methane took romthe gas wells several thousand eet deep to the water wells aew hundred eet deep. The companys hired expert said: Weknow that the ractures (caused by process) dont grow morethan a ew hundred eet.43 This, however, contradicts industryexperts testimony in a landmark Texas Supreme Court case,Garza v. Coastal, that a racture planned or 1,000 eet mightreach 2,000 eet or just 400 eet.44 The EPAs position is that ithas the legal authority to ask a company who we believe mayhave caused or contributed [to water contamination] . . . to col-lect the data.45

On March 7, 2011, Railroad Commission hearing examin-ers announced a nding that Range was not responsibleor methane contamination o the water wells in otherwords, the Railroad Commission issued a ruling that sup-ports its own position and its inaction. Two weeks later, theull Railroad Commission armed the examiners initial rul-ing. Range said it expected the EPA to withdraw the orderor lack o evidence, but the Agency said it remains con-dent that the natural gas that is now in the drinking wateror these two homes is the natural gas that [Range] are pro-ducing rom a production well nearby which [Range] hydro-racked during the summer o [2009].46 The U.S. Department

o Justice has led a case in ederal court to enorce EPAsemergency order under the Sae Drinking Water Act.

More Water Contamination

Additional cases o water well contamination believed to havebeen caused by drilling or racking operations in the BarnettShale include:

Doug and Diana Harris, Denton County. Water contami-nated with aluminum, arsenic, barium, beryllium, calcium,chromium, cobalt, copper, iron, lead, lithium, magnesium,manganese, nickel, potassium, sodium, strontium, titanium,vanadium, and zinc shortly ater Devon Energy racked a gaswell near their home.47

Grace Mitchell, Johnson County. Water contaminated withhydrocarbons shortly ater racking by Chesapeake Energyand Encana. 48

Jim and Linda Scoma, Johnson County. Water contaminatedwith benzene and hydrocarbon by products ater racking o

Chesapeake Energy gas well.49

J.D. Johnson, Tarrant County. Water turned gold and sandyimmediately ollowing hydraulic racturing.50

Carol Grosser, Edwards County. Water contaminated andwater pressure issues ater hydraulic racturing o well nearproperty. Goats gave birth to deormed kids.51

Amber and Damon Smith, Denton County. Testing oundarsenic, chromium, butanone, acetone, carbon disulde,and strontium in well water ater Devon Energy racked gaswell.52

Catherine and Brett Bledsoe, Wise County. Shortly aterAruba Petroleum racked wells near their property, waterstung their eyes and had odor. Animals reused to drink.

Testing ound benzene and very high levels o MTBE (a die-sel uel additive). 53

Steven Brock, Montague County. Flammable water. Testsrevealed high chloride levels, arsenic, chromium, barium,mercury and methane.54

Chemical Private testing, 8/8/10 (ppb) Railroad Comm., 8/17/10 (ppb) EPA 10/26/10 (ppb)

Benzene 3.1 6.84 4.55

Ethane No Test NT 5.27

Dissolved ethane 1,580 NT NT

Hexane NT NT 31.7

Dissolved methane 7,810 NT 20,100

Propane NT NT 2,280Tolulene 2.0 6.12 3.47

Results o testing rom a water well near Range Resources gas wells in Parker County, 2010. http://www.epa.gov/region6/6xa/pd/range_order.pd


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CASE STUDIES: POISONED COMMUNITIES

Dish, Texas

Dish is a town o about 200 in southern Denton County. Thetown is the site o a sprawling complex o oil and gas acili-ties, pipelines and gas wells. Almost a dozen large natural gascompressor stations are located next to each other, severalgas metering stations are just west o the compressor stationsand a large battery o condensate tanks is located less than amile away.55 These acilities are very close (100 eet or less insome cases) to residences.56 For years, Dish residents who livenear the compressors have experienced headaches, dizziness,and many other health symptoms. A number o surveys andinvestigations have tried to determine the potential healtheects that could be linked to the industrial oil and gas acili-ties located in Dish.

Subra Company

In October and November o 2009 environmental chemistWilma Subra recipient o a MacArthur genius award orher work with communities threatened by toxics conducteda health survey o the residents o Dish on behal o TexasOGAP.57

In addition to dozens o odor complaints, a total o 165 medi-cal symptoms and diseases were reported by the 31 individu-als who responded to the survey. There were 23 conditionsrequently reported by the 31 individuals. The most prevalenthealth conditions included: sinus problems, throat irritation,allergies, weakness and atigue, eye irritation, nasal irrita-tion, joint pain, muscle aches and pains, breathing diculties,vision impairment, severe headaches, sleep disturbances,

Case studies:poisonedcommunities

2


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swollen and painul joints, requent irritation, skin irritation,wheezing, requent nausea, ringing in ears, decreased motorskills, loss o sexual drive, bronchitis, easy bruising and di-culty in concentrating.

Wolf Eagle Environmental

On August 17 and 18, 2009, Wol Eagle Environmental, anenvironmental services and consulting company rom nearbyFlower Mound, sampled the ambient air rom seven locations

in Dish.58 The air samples were analyzed or substances clas-sied as volatile organic compounds (VOC), hazardous airpollutants (HAP), tentatively identied compounds (TIC) andnitrogen oxides (NOX). The sampling conrmed the presenceo high concentrations o some cancer-causing chemicals (car-cinogens) and neurotoxin compounds in air near or on resi-dential properties in Dish. 59

A number o these compoundsexceeded both short and long-termeects screening levels (ESL) estab-lished by the TCEQ.60 For example,benzene, a known human carcino-gen, exceeded the short-term at one

site and the long-term level at threesites. Fourteen other chemicals thatexceeded short- or long-term ESLsincluded: m,p-xylene, dimethyl disul-de, methyl ethyl disulde, ethyl-methylethyl disulde, trimethylbenzene, diethyle benzene, methyl-methylethyl benzene, tetramethylbenzene, naphthalene, 1,2,4-tri-methyl benzene, carbonyl sulde,carbon disulde, methyl pyridine anddimethyl pyridine.61 Sixty-one percento the health eects experienced byDish residents who responded to the

Subra Companys health survey matchthe known health eects o the chemical Wol Eagle detectedin Dishs air excess o above state ESL levels.

These air pollutants almost certainly came rom natural gasinrastructure located in and around Dish. Hazardous air pol-lutants can be released rom oil and gas well sites, compres-sor stations, gas dehydrators, oil/condensate tanks, pressurerelie values, well drilling, hydraulic racturing, gas processingplants, pipelines, and vehicle and engine exhaust.62 According

to the Wol Eagle Environmental report, Dish has virtually noheavy industry other than oil-and-gas related acilities. Thereare no other industrial activities with the capability to producethe volume o air toxins present within miles o the town.63

In October 2009, TCEQ reviewed the Wol Eagle report andexpressed concern that the monitored concentrations obenzene at several o the sampling locations could pose along-term health risk to residents i representative o normaland prolonged ambient conditions.64 TCEQ has since been

conducting its own sampling, but has not measured ben-zene concentrations as high as those ound by Wol EagleEnvironmental.

Texas Department of Health Services

In October 2009, the Texas Department o State Health Services(DHS) was asked by the mayor o Dish to test people in the

community or contaminantsthat had been identied in thecommunitys air.65 In January2010, DHS sta collectedblood and urine samples rom28 adults, as well as tap water

samples rom 27 o the resi-dents homes.66 To provide acontrol population, blood andurine samples were also takenrom ve DHS sta memberswho collected the samples.

I a volatile organic com-pound (VOC) is detected inblood or urine, it indicatesthe person is currently beingor has recently been exposedto the chemical. According toDHS, VOCs only stay in thebody or a short time (several

hours); thereore these measurements only reect ongoing orrecent exposures, and not historical exposures.67 A high leveldoes not necessarily mean that a person will experience healtheects, nor does a lower concentration indicate that there willbe no health eects. Individuals are not equally susceptible toa particular chemical68 some are more sensitive, some may beexposed to many chemicals at the same time, and these chem-icals may interact or the eects add up to cause an impact toa persons health. DHS compared concentrations o VOCs in

61%Health eects reportedby the DISH community

were associated with

toxics measured in excessof TCEQ screening levels

16Chemicalsmeasured in

DISH ambient air

above TCEQscreening levels

Abnormal EEG

Brain disorders

Bronchis

Chronic Eye Irritaon

Decreased Motor Skills

DepressionDizziness

Eyes Burning

Falling, Staggering

Frequent Irritaon

Frequent Nausea

Increased Fague

Irregular/Rapid Heart Beat

Muscle Aches & Pains

Nasal Irritaon

Pre-Cancerous Lesions

Severe Anxiety

Severe Headaches

Sinus Problems

Throat Irritaon

Tired

Weakness

Allergies

Difficulty in Concentrang

Easy Bruising

Nervous System Impacts

Benzene

Carbon Disulfide1,2,4-Trimethylbenzene

Xylene

Naphthalene

Carbonyl Sulfide

Trimethyl Benzene

Methyl-Methylethyl

Benzene

Tetramethyl Benzene

Methyl Pyridine

Dimethyl Disulfide

Methyl Ethyl Disulphide

Ethyl-Methylethyl

Disulfide

Diemethyl Pyridin

Diethyl Benzene

Over 60 percent o healtheects o Dish residentsmatch eects associated withchemicals detected in air.

Glass o water rom the Smiths tap in Dish, Texas ater

Devon Energy completed nearby racturing operation.

Photo by Sharon Wilson


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DISH residents blood to what is known as a 95% reerencevalue or each chemical 95% o the U.S. population has con-centrations below that level.69 I a chemical is ound at a higherconcentration than the reerence level, it means the personhas recently been exposed to an unusually large amount othe chemical compared to the rest o the population.

Blood rom the Dish residents was tested or 33 dierent VOCs.Some o the chemicals are known to be present in cigarettesmoke (2,5-dimethyluran, styrene and BTEX chemicals ben-zene, toluene, ethylbenzene, xylenes), so results were talliedseparately or smokers and non-smokers. Major ndings:

A total o 15 VOCs were detected in the residents blood. Mostrequently ound were toluene (detected in 18 residents),m-/p-xylene (15 detections) and styrene (13 detections). Atotal o 14 VOCs were detected in non-smoking residents.

The only chemical not ound in the blood o at least onenon-smoking resident was 2,5-dimethyluran. This chemicalis a biomarker known to be present in cigarette smoke and isgenerally undetectable in nonsmoking adults.70 Three VOCsknown to be present in cigarette smoke were also ound innon-smokers: toluene was ound in 13 non-smokers, ethyl-benzene in our, o-xylene in three and m-/p-xylenes in 10

non-smokers. I these residents were not exposed to thesechemicals rom smoking cigarettes, what are other sourceso these chemicals? Natural gas, especially gas that has con-densate associated with it, 71 contains the BTEX chemicals,and these can be released to the air when gas is ventedrom compressor stations, pipelines, condensate tanks, wellsites or gas processing plants. By comparison, only six VOCswere ound in the blood o the DHS staers who were non-smokers.72 In other words, approximately twice as manychemicals were detected in non-smokers rom Dish thannon-smokers rom DHS sta.

Some Dish residents have been exposed to VOCs at higherlevels than 95% o the U.S. population. O the chemicalsdetected in residents blood, 15 VOCs were ound in at leastone resident at a level that is higher than 95% o the U.S.general population. Three o the chemicals ound in Dishnon-smokers (bromoorm, chloroorm and dibromochlo-romethane) might be coming rom the towns water sup-ply they are known to be ormed when chlorine is addedto public water systems as a disinectant.73 But nine other

VOCs ound at extremely high levels in the blood o non-smoking residents o Dish cannot be linked to chlorinatedtap water. Again, DHS sta did not have VOCs in their bloodin concentrations as high as residents. Only one chemical dibromochloromethane, likely rom drinking chlorinatedwater was ound in DHS sta at a level higher than 95% othe general population.

Dish residents also provided urine samples to DHS sta. Thesesamples were analyzed or breakdown products (known asmetabolites) o our VOCs: PMA, a metabolite o benzene;DHBM, a metabolite o 1,3-butadiene; BMA, a metabolite otoluene; and AMCA, a metabolite o N,N-dimethylormamide,also known as DMF. All residents and DHS sta had urinarymetabolites o 1,3-butadiene, toluene, and DMF. Three resi-dents also had metabolites o benzene (two smokers, one non-smoker). None o the urine samples rom DHS sta containedmetabolites o benzene. Residents also had higher levels othe metabolite o N,N-dimethylormamide than DHS sta andlevels ound in published research, but DHS sta could oer noreason or the high levels ound in residents.74 Although thereare no recognized standards to determine sae levels in urine,the tests conrmed that residents o Dish are being exposed tobenzene, toluene, 1,3-butadiene and N,N-dimethylormamideor other VOC chemicals.75

VOCS FOUND IN AIR, WATER AND RESIDENTS (BLOOD SAMPLES) IN DISH, TX

Range o levels ound

in DISH air (ug/m3)

Detected

in air (# o

sites)

Found in DISH

tap water (# o

sites)

Range o levels (ug/m3)

detected in blood o non-

smokers (# o non-smokers)

Range o levels (ug/m3)

detected in blood o

smokers (# o smokers)

benzene 1.91 247.88 7 No (0) ND* 0.027 (1) 0.045 1.45 (5)

ethylbenzene ND 93.21 6 o 7 Yes (14) ND 0.124 (4) ND 1.437 (4)

toluene 2.76 -523.03 7 o 7 Yes (1) ND 0.839 (13) 0.174 3.25 (5)

M/p-xylene 3.56 366.3 7 o 7 Yes (15) ND 0.389 (10) 0.084 1.32 (5)

o-xylene ND 170.8 5 o 7 Yes (17) ND 0.118 (3) ND 0.186 (4)

styrene 1.64 5.44 3 o 7 Yes (16) ND 0.068 ( 8) 0.045 0.525 (5)

trichloroethene ND - 2.16 1 o 7 ND 0.013 (1) ND (S: 0)

* ND: not detected

Air data rom Wol Eagle Environmental. Sept. 15, 2009. Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report. http://www.bseec.org/

sites/all/pd/airquality/13.pd. Blood and water data rom TxDSHS Exposure Investigation. Tables 1 b. and 4. 76


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Source of the Chemicals

Many o the chemicals ound at high concentrations in theblood o Dish residents have previously been ound in air sam-ples in and around Dish. Some o these chemicals were also

detected at low levels in tap water samples rom the homes othe residents involved in the DHS biomonitoring study.

Since many o the chemicals ound in residents blood werealso ound in air samples, it seems a reasonable assumptionthat natural gas drilling and acilities are the source o at leastsome percentage o the chemicals in blood especially sinceDish has no heavy industry other than oil-and-gas related acil-ities that could produce the high volumes o air toxins ound.77But the DHS report concluded that because not all residentshad high concentrations o the same VOCs in their blood, theinvestigation did not indicate that community-wide expo-sures rom gas wells or compressor stations were occurringin the same population.78 Instead, the report suggested that

other possible sources o high concentrations in residentsblood such as cigarette smoking, the presence o disinectantby-products in drinking water, and consumer or occupational/hobby related products could explain many o the ndings.79Perhaps the highest levels o benzenes, ethylbenzene, tolu-ene and xylene ound in residents blood can be attributed tosmoking, but there were cases where non-smokers had higherconcentrations than smokers. And there were cases wherenon-smokers had higher concentrations in their blood than95% o the general population.80

There are other possible reasons why not all 28 residents hadthe same VOCs known to be associated with gas wells and

compressors in their blood. First, the blood collected romthe residents represented a snapshot in time. Depending onthe wind and atmospheric conditions it is possible that notall residents were being exposed to chemicals rom oil and

gas acilities on the day when their blood was sampled. Also,some residents may have had higher exposures i they spentmore time outside or had windows open when the chemicalswere in the air. And i people were being exposed to chemicalsthrough water as well as air, concentrations in blood wouldvary depending on how much contact they had with thesechemicals through inhalation, ingestion or contact with skin.

DHS admitted that its study was a one-time sample event;thus it could not consider external actors that could haveaected results such as season, temperature, wind conditions,and variations in the natural gas operations.81 DHS sta alsoacknowledged the presence o odors in the community, andrecommended that i sampling rom the TCEQ indicated pos-sible environmental exposures, additional sampling should

take place in the summer, when temperatures are higher andwhen people indicate that odors are the greatest.82


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Argyle and Bartonville, Texas

Until 2010, the afuent Denton County communities o Argyle(pop. 3,600) and nearby Bartonville (pop. 1,600) had only a ewgas wells. Today, the communities have a major gas process-ing acility, tank arms, pipelines and multiple wells withinone square mile o the homes o approximately 2,000 people.Residents are especially concerned about the approval o twowell pads, gathering lines and pipelines under developmenton either side o the Argyle Intermediate School.83 The area

has had poor air quality or some time, but that only showshow strong the impact o drill-ing has been: Beore the boom,complaints to TCEQ werealmost non-existent; morethan 100 complaints wereissued in 2010.

But prior to the boom, citizensalso organized to conductbaseline testing to measurethe quality o their air beorelarge-scale development tookhold. In baseline testing, only

seven o the 84 air contami-nants typically tested or by

TCEQ showed up in Argyle-Bartonville air samples.84 Astank arms, compressor sta-tions, pipeline and additionaloil and gas acilities havemoved into the area the Argyle-Bartonville Communities (ABC)Alliance began documentingindividual health eects. 85 And

TCEQs most recent testing on the high school band prac-tice lot detected up to 65 o

the 84 air contaminants usuallytested or by the agency.86

In October 2010, parents spokeat an Argyle school boardmeeting voicing their con-cerns about their childrenshealth. The day o the meet-ing, the ABC Alliance releaseda detailed account o studentsrecent health problems, suchas one who complained ounusual chest pains ater run-ning around the high schooltrack.87

Its ruining us, Bartonvilleresident Kelly Gant told TheNew York Times in February2011. She said her 14-year-old daughter and 11-year-oldson have had severe asthmaattacks, dizzy spells and head-aches since a compressor sta-tion and a gas well were setup near her house about twoyears ago. Im not an activist,

an alarmist, a Democrat, environmentalist or anything likethat, Ms. Gant said. Im just a person who isnt able to managethe health o my amily because o all this drilling. 88

Members o the ABC Alliance began to keep track o theunusual health complaints they were experiencing since theincrease in drilling activity. They noticed the timing o healthcomplaints coincided with environmental events at the nat-ural gas acilities in the area. They combined the health loginormation into a detailed list o incidents and the combined

health eects were prepared, which in late 2010 Texas OGAPpresented to the U.S. EnvironmentalProtection Agency.89

Residents reported a wide range ohealth eects, including abnormalmenstrual bleeding and nosebleeds,rashes, chest pains and dicultybreathing, asthma attacks and anadult onset asthma diagnosis in a40-year-old non-smoker, dicultyconcentrating and overwhelmingatigue. In just one eight-day period Nov. 13-21, 2010 ten people in the

neighborhood reported symptomsincluding coughing, sore throat,headache, nosebleed, burning orwatering eyes, vomiting and jointpain.

Besides the health impacts, prop-erty values in Argyle and Bartonvilleare plummeting. One residence thatwas valued at $361,000 on the 2009tax rolls was valued at $95,000 onthe 2010 tax rolls.90

The Argyle school district signedleases to allow gas drilling on

its property and according tothe Denton Record Chronicle, hasreceived more than $680,000rom the leases. But Susan Knoll, aBartonville parent, pointed out thatthe royalties received would noteven cover the cost o treating onechild with a case o leukemia.

You cant put a price on keepingour kids healthy, Knoll said.91

Top: Williams Energy Gul Coast LPs Argyle Central Facility

100 eet rom residence. Photo by Susan Knoll

Bottom: Argyle and Bartonville residents protest as Argyle

Central Facility is installed.


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Case studies:poisonedfamilies

3

CASE STUDIES: POISONED FAMILIES

Bob and Lisa Parr, Wise County

Bob and Lisa Parr and their 7-year-old daughter, Emma, live inthe Allison community o eastern Wise County. Their 40 acresare graced with immense pecan trees, green pasture, a creek and are surrounded by 21 gas wells.

Shortly ater moving to the area in August 2007, Lisa Parrspreviously excellent health began todeteriorate. She began having breath-ing diculties, nausea and headaches.She had angry red rashes rom the top oher head to the bottoms o her eet thathave let her body scarred with pock-marks. She had oozing welts on her scalpand our ping-pong-ball-sized lumps onher neck. Eight doctors treated her overthe course o a year. None could nd anillness to blame her symptoms on, untila specialist suggested she might be su-

ering rom environmental exposures.92

She visited her neighbor, Christine Ruggiero (whose story ol-lows), and compared her medical records with Ruggieros logo spills, releases and air testing rom the gas wells on theirproperty. Her medical episodes coincided with the gas wellactivity.

On July 25, 2010, she called TCEQ complaining o strongodors o natural gas chemicals around her home causing diz-ziness and burning nasal passages. TCEQ investigator DamonArmstrong noted in his report that the operator, ArubaPetroleum, was in the process o using nitrogen to clear drill-ing uids rom the wellhead o a nearby rig. The emissionscoming rom the rack tank were visible to the naked eye and

were o such concentration and duration to aect the healtho the investigator.

According to his report, while on the property Armstrong su-ered rom dizziness and a sore throat. A toxic vapor analyzerregistered an average reading o over 2,500 parts per million.Armstrong collected air samples and detected concentrationso 20 chemicals, including benzene, at concentrations exceed-ing TCEQs sae level or long-term health eects. Five wereat concentrations exceeding sae levels or short-term healtheects. 93

Four days later, Dr. William Rae o the Environmental HealthCenter in Dallas tested Lisa Parrs blood and lungs. In her bloodand lungs he ound more than 20 chemicals, including six thatmatched the VOCs detected by TCEQs air sampling o the wellsite.94

Lisas husband and daughter are also having symptoms thatmay be related to gas drilling activity. Bob Parr has experi-

enced loss o balance and neurological symptoms. He said hedrarely had a nosebleed in his lie, but in thelast year had about three a week. Emma,too, had rashes and requent nosebleeds:Shed wake me up at 6 a.m., crying, cov-ered in blood, said her mother.95 Emmawas recently diagnosed with asthma.

The Parrs contracted or private testingo their home and again ound numer-ous chemicals matching the prole o thenearby well. The concentration o meth-ane in her daughters room, Lisa said, wasat asphyxiation levels. She later told the

Wise County Messenger what happenednext:

She showed the results to her doctor, who told her to leave herhome within 48 hours.

The doctor told me right then . . . I had to move immediately.

Bob, Lisa, and Emma Parr at their home in Wise County.

Used with permission by Lisa Parr.


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Because i I did not, we would have to spend more time andmoney on hospitalization, on chemotherapy and morticians ormy whole amily.96

The Parrs are now living at Bobs oce in Denton, where there isno drilling nearby. Their health is greatly improved.

Tim and Christine Ruggiero, Wise County

On September 16, 2009, with no prior notice, Aruba Petroleumcut the ence around Tim and Christine Ruggieros horse pas-ture, drove bulldozers onto their property and began buildinga pad site to drill two wells on their 10 acres in Allison, WiseCounty.

Six weeks later, Christine Ruggiero saw black, smoky liquid

shooting out rom the drilling rig, across the waste pit andinto the neighbors trees. A week later, Christine and her10-year-old daughter Reilly walked out o the house and ounda heavy cloud o diesel exhaust coming rom the drilling rig,surrounding their home and stretching out along the horizonor miles. Christine made a complaint to the TCEQ and escapedwith her daughter to stay at a hotel that night. The TCEQinspection report stated: Continuous operations o three die-sel engines greater than 400 horsepower at this site resultedin signicant emissions o nitrogen oxides. An estimate omaximum nitrogen oxide concentration over one hour on thecomplaintants property was predicted to be 380 parts per bil-lion.97 No enorcement action was taken.

On January 10, 2010, as the Ruggiero amily let or church,they saw men shoveling sand onto the drill site rom a truck.Later that day, an anonymous caller inormed them thatGilbow Oileld Services had spilled approximately 9,000 gal-lons o wastewater the day beore. Christine reported the spillto the Railroad Commission. The inspection report said thespill covered an area 30 by 60 eet, and orderd Aruba to imme-diately remove any uids, excavate the area and initiate andcomplete remedial clean-up operations. The Ruggieros never

observed that the ordered remediation took place and theregulators did not ollow up to enorce it.

Ater the second spill, the Ruggieros contracted with WolEagle Environmental to test the spilled wastewater, the spilleddrilling mud and the air around their property. Fiteen chemi-cals were ound in the wastewater and mud, including ben-zene and tolulene, in concentrations ranging rom a trace to1,500 parts per billion. O the air samples, Wol Eagle reported:

...numerous hydrocarbons indentied as Recognized andSuspected human carcinogens and neurotoxins. ...The com-

pounds identied are known to emanate rom processes relatedto the natural gas industry. The laboratory results conrmed ugi-tive air emissions exceeding TCEQ Eects-Screening Levels (ESLs)

or Benzene (Long-Term), and Propane (Short-Term and Long-Term). In addition, concentrations o Methane were identied inlevels that exceed ambient air background concentrations.98

A week ater the second spill, Christine Ruggiero noticed aheavy chemical odor similar to propane and complained to

TCEQ. Two weeks ater that, they led a similar complaint. Onboth occasions, TCEQ sta took air samples with summa can-isters and a GasFindIR inrared camera. They detected morethan two dozen VOCs, including benzene, tolulene and vinylchloride. All but one o the compounds were in concentrationsexceeding TCEQs 1-hour saety limit or short-term healtheects.99

Aruba has vented natural gas at the wells and brought inworkover rigs numerous times.

There have been at least two more wastewater spills. In thespring o 2010, the Ruggieros observed bubbles rising rom awastewater pit or rom puddles in their pasture, and discov-ered they could set the bubles aame with a lighter. In March2010, the Railroad Commission inspected, and in April told theRuggieros The bubbles are believed to be a natural occur-rence caused by a settling and compaction o the soil due towater saturation. 100

Christine Ruggiero and her thoroughbred mare, Sweetheart.

Photograph by Tim Ruggiero

Compound

Concentraon

(parts per

billion)

Over short-

term health

AMCV

Over

long-term

health

AMCV

1,2,4-trimethylbenzene 54 No Yes

2,3-dimethylbutane 100 No Yes

2-methylpentane 1100 Yes Yes

2-methylheptane 260 No Yes

2-methylhexane 500 No Yes

3-methylheptane 230 No Yes

3-methylhexane 420 No Yes

3-methylpentane 730 No Yes

Benzene 120 No Yes

n-butane 13000 Yes Yes

cyclohexane 460 No Yes

n-heptane 900 Yes Yes

n-hexane 1700 No Yes

Isobutene 6800 No Yes

Isopentane 3700 Yes Yes

methylcyclohexane 720 No Yes

methylcyclopentane 410 No Yes

n-octane 520 No Yes

n-pentane 3600 Yes Yes

m & p-xylene 200 No Yes

Chemicals found in the air near Aruba Petroleum well near Parr residence, July 25,

2010.


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In September 2010, the Wise County Appraisal Board deval-ued their property by 75 percent. Originally on the 2010 taxrolls or $257,330, their home and 10-acre horse property arenow worth $75,240.101 I wouldnt sell it or $78,000, said Patsy

Slimp, a board member and ormer real estate agent. I couldnot sell this house in a clear conscience.102 The Denton RecordChronicle reported:

Ater the meeting, Tim and Christine Ruggiero had tears in theireyes.

Christine Ruggiero said she knew the day the drilling rig arrivedthat their property was lost, so the acknowledgement by theappraisal review board was not happy news.

They know they need to move in order to protect their daughtershealth, Tim Ruggiero said, and that its possible their credit couldbe ruined.

The bank could call the note on our home tomorrow, he said, in

which case hed probably hand them the keys to the house.

Deborah Rogers, Fort Worth

Deborah Rogers lives in Westworth Village, a tiny municipalityinside Fort Worth city limits, where more than 15 gas wells arelocated in one square mile. When Chesapeake Energy Corp.began drilling near her home, she reported bothersome odorsto the TCEQ hotline but the response time was unsatisactorybecause the emissions usually subsided by the time an inspec-tor arrived hours later. She ound it curious that just as TCEQcalled to say they were on their way, the odors disappeared, sothe inspector ound nothing: It was as though someone hadshut o a valve, simple as that. Thats when I knew these odorscan be contained at will.103

Rogers a dairy owner, ormer nancial analyst and membero the advisory board or the Federal Reserve Bank o Dallas was likely the rst person to ever conduct air testing aroundgas wells in North Texas. In May and June 2009, private envi-ronmental consultants and labs detected the ollowing toxicair contaminants on her property: benzene, dichlorodiuoro-methane, chloroorm, m&p xylene, 0 xylene, 1,2,4 tricholor-benzene, toluene, carbon disulde, dimethyldisulde, methylyethyl disulde, methyl propyl disulde, diethyl disulde, ethyly,methylethyl disulde, dimethyl trisulde and ethyl n-propyldisulde.104 All o the sulur-based compounds were ound atlevels above short-term and long-term TCEQ Eects Screening

Levels. The level o carbon disulde was 300 times higher thanU.S. EPAs normal limit or ambient urban air. Further testingconrmed the results, at slightly lower levels.105

Rogers has experienced nausea rom the strong odors and twomassive nose bleeds that began with severe headaches. Thenosebleeds, she said, are spontaneous and very righteningbecause the blood ows copiously and within seconds youare covered in blood. I have never had nose bleeds in my lieeither.

The same evening the rst air sampling was conducted on herproperty, several o Deborahs perectly healthy baby animals two baby goats and six baby chicks died o asphyxiation.Ater looking at the test results, Dr. E. Murl Baily, Jr., seniorveterinary toxicologist at Texas A&M University, wrote a let-ter o concern to the mayor o Westworth Village concludingthat the compounds were problematic to animals and humanhealth as they move up the ood chain in milk and meat. 106

In June 2009,Dr. David Sterling, Chair o Environmental andOccupational Health at UNT Health Science Center reviewedair testing results taken during aring o a well near Deborahsarm. He wrote:

The compounds ound range rom those with acute primar-ily irritation issues, to oxygen deciency potential (i.e. heavierthan air and may accumulate low to the ground and in gul-leys, displace oxygen, with potential asphyxiation), to chronicorgan toxicity and known or suspect carcinogens. The levelsduring aring exceeded in most cases the Texas Commissionon Environmental Quality (TCEQ) eects screening levels, bothlong and short term, which are State levels o exposure to airtoxins which can trigger adverse health eects.

Deborah Rogers,

owner o Deborahs

Farmstead.

Photo by Lee Chastain

Ruggieros home and property. Photo by Tim Ruggiero


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Conclusion andRECOMMENDATIONS

The fndings o the Texas Oil and Gas AccountabilityProjects investigation have implications or both stateand national oil and gas policies and regulations. Toooten citizen testimonies o health eects or evidencegathered by citizens are dismissed as anecdotal evi-dence; and as long as each case is treated as an iso-lated incident the larger pattern is ignored. But whenso many citizens across almost two dozen countiesreport similar complaints and symptomsassociated with gas drilling, something iswrong. More thorough research is need-ed i drilling and racking can be donemore saely and under what conditions

and locations they should or should notbe permitted. At the same time, immedi-ate action is warranted to protect publichealth and the environment. Texas can,and must, do better.

Several state legislators have oeredpolicy reorms in the 82nd Texas Legis-lature to protect citizens, the environ-ment and public health. Promising leg-

islation includes:

SB 1049, by Sen. Wendy Davis, wouldrequire disclosure o chemicals used inhydraulic racturing uids to propertyowners and water users.

SB 772, also by Davis, would requirethat racking uids contain tracer ele-ments that could be used to identiythe source o water contamination.

HB 1226, by Rep. Lon Burnham, wouldreduce toxic air emissions by requiringvapor recovery units on storage tanksin the Barnett Shale.

HB 1556, also by Burnham, wouldprohibit gas wells within 1,200 eet o

public schools.

RECOMMENDATIONS:

The Texas Commission on Environmental Qualitymust signifcantly step up its currently inadequateeorts to protect public health by strictly enorc-ing emission limits rom oil and gas explorationand production equipment. TCEQ must requiremore acilities and units to meet emission lim-its and issue meaningul penalties or violations.

We heartily endorse the Sunset Commissionsrecommendation to replace the Texas RailroadCommission with an appointed oil and gas commis-sion in light o the Railroad Commissions shame-ul record, it is hard to imagine a single change thatwould mean greater protection or Texas landown-ers. In the meantime, the Railroad Commission must

also signifcantly step up its eorts.The Railroad Commission mustadopt rules that ban the injection odiesel uel in drilling operations andprovide the public with ull public

disclosure o oil and gas drilling andstimulation uids, including chemi-cal constituencies and amounts.The Commission must implement areporting requirement or hydraulicracturing operations that documentsthe volumes o racturing uids usedand recovered, as well as criticalinormation relating to actual pres-sures used in racturing operations,and estimated racture sizes andextents.

TheRailroadCommissionmuststep

up its currently inadequate eortsto protect surace and groundwaterresources rom oil and gas contami-nates. The Commission must imple-ment rules requiring closed-loopdrilling systems and water-baseddrilling uids.

The Texas Water DevelopmentBoard must exercise its authority toevaluate groundwater resources andthe impact that hydraulic racturingwithdrawal is having on groundwa-

ter resources. The agency must implement rules thatrequire recycling o owback water.

The EPA must identiy the sources o methane contami-nants in groundwater.

Authority to regulate air emissions from oil andgas exploration and production equipment shouldbe overseen by the U.S. Environmental ProtectionAgency. The EPA should oversee permitting o existingand uture point sources through a ederal advisorycommission that includes citizen representation.

Several statelegislators have

offered policyreforms in the 82ndTexas Legislatureto protect citizens,the environment andpublic health.

Photo by Kathy Chruscielski


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19

Endnotes

1 Pickering Energy Partners, Inc. Oct. 2005. The Barnett Shale Visitors Guide to the Hottest Gas Play in the US. Appendix

B- Comparison o Organic Shales in the U.S. p. 46. http:/www.tudorpickering.com/pds/TheBarnettShaleReport.pd

2 Archer, Bosque, Clay, Cooke, Comanche, Coryell, Dallas, Denton, Eastland, Ellis, Erath, Hamilton, Hill, Hood, Jack,

Johnson, Montague, Palo Pinto, Parker, Shackleord, Somerville, Stephens, Tarrant, Wise. http://www.rrc.state.tx.us/

barnettshale/index.php

3 http://www.rrc.state.tx.us/barnettshale/index.php

4 The Perryman Group, 2009.An Enduring Resource: A perspective on the past, present and uture contribution o the

Barnett Shale to the economy o Fort Worth and surrounding areas. www.barnettshaleexpo.com/docs/2009_eco_

report.pd

5 http://www.rrc.state.tx.us/barnettshale/index.php

6 http://www.rrc.state.tx.us/commissioners/carrillo/press/energytestimony.html.

7 http://www.ewg.org/node/26651

8 http://www.ewg.org/node/26651

9 Hartman, Todd. 2007. Industry Oversight, Rocky Mountain News, December 11, 2007, p. 14.

10 Brown, L. & Tabor, B. De nton Record Chronicle, October 24, 2010. Parents voice health concerns: gas drilling near

Argyle schools making kids ill, residents tell board.

11 http://www.chron.com/disp/story.mpl/business/energy/7467068.html

12 Slother, B. KCBD-TV, Feb. 16, 2011, South Plains landowners receiving big oers rom oil companies.

13 http://s3.amazonaws.com/propublica/assets/natural_gas/texas_railroad_commission_auditor_report_aug2007.pd

14 http://www.sunset.state.tx.us/82ndreports/rct/rct_dec.pd

15 http://www.propublica.org/article/state-oil-and-gas-regulators-are-spread-too-thin-to-do-their-jobs-1230

16 http://www.dentonrc.com/sharedcontent/dws/drc/specialprojects/drilling/stories/DRC_Gas_

Health_1015.186b27b.html

17 Fort Worth League o Neighborhoods,Recommendations For Policy Changes For Gas Drilling Near Schools , February

2011.

18 The Endocrine Disruption Exchange. April 2009, unpublished.Chemicals Used in Oil and Natural Gas Operations in

Texas.

19 Armendariz, A., September 30, 2008, For Environmental Deense Fund. Emissions rom Natural Gas Production in the

Barnett Shale Area and Opportunities or Cost Eective Improvements. www.ed.org/documents/9235_Barnett_Shale_

Report.pd

20 May 25, 2009. Wole Eagle Environmental. Ambient Air Monitoring Analysis Project, Final Report. http://

earthworksaction.org/TXOGAP-CaseStudy-Rogers.cm

21 August 7, 2009. Letter to Deborah Rogers rom Dr. Al Armendariz. http://earthworksaction.org/TXOGAP-CaseStudy-

Rogers.cm

22 Fowler, T., Houston Chronicle, January 28, 2010. Air tests clear at most Barnett Shale sites. http://www.chron.com/

disp/story.mpl/business/energy/6839196.html

23 http://www.tceq.state.tx.us/assets/public/implementation/barnett_shale/2010.01.27-healthEects-BarnettShale.pd

24 http://www.star-telegram.com/2011/02/15/2852228/two-gas-well-pad-sites-in-ort.html

25 http://www.bseec.org/sites/deault/les/BSEEC_Final_Report.pd

26 Fort Worth League o Neighborhoods,Recommendations For Policy Changes For Gas Drilling Near Schools , February

2011.

27 Heinkel-Wole, P, Denton Record Chronicle, December 9, 2006,Drilling could sap water supply

28 ADVANCED RESOURCES INTERNATIONAL, INC, slide 34, Gas Shale Development Workshop, Beijing, China April 2010

29 Records obtained through Texas Public Inormation Act

30 Evans, B, Wise County Messenger, March 23, 2008,Aquier dropping and it could get worse

31 Adrian, P, FOX 4 Investiga tion, June 12, 2007, Drilling Boom Brings Water Worries

32 Smith, J, Star-Telegram, Barnett Shale search or acts on racking, September 4, 2010

33 Crowe, R. San Antonio Current, Jan. 5, 2011. Sinking eelings: Gas racking may already be lowering water tables in

South Texas

34 Railroad Commission o Texas, Saltwater Disposal Wells Frequently Asked Questions (FAQs)

35 Personal communication, Dr. Paul F. Hudak, Department o Geography, University o North Texas

36 RIGZONE, Water Treatment Key to Hydraulic Fracturings Future, http://www.rigzone.com/news/article.asp?a_

id=97222

37 Lustgarten, A, Scientic American, Drill or Natural Gas, Pollute Water, November 17, 2008

38 Lee, M, Star-Telegram, Texas Supreme Court ruling discouraged suits against gas drillers, December 28, 2009

39 Evans, B, Wise County Messenger, Unwell water: Drilling leaves a bad taste or some, October 3, 2010

40 Gorman, P, FW Weekly, Water Foul: An aquier is at risk along with property values, livestock, and dreams ater gas

wells move in, April 30, 2008

41 Douglas, J., WFAA, Texas acts on faming aucets in Montague County. October 6, 2010.

42 http://www.epa.gov/region6/6xa/pd/range_order.pd

43 Lotis, R, Dallas Morning News, January 22, 2011.

44 http://www.supreme.courts.state.tx.us/historical/2008/aug/050466cd.htm

45 http://www.star-telegram.com/2011/02/10/2840390/epa-ocial-is-grilled-in-range.html#ixzz1DcWiq81O

46 Lotis, R, Dallas Morning News, Gas in Parker County homes drinking water puts drilling, EPA in national spotlight,

January 22, 2011

47 Harris vs. Devon Lawsuit http://press.wturley.com/Harris%20v.%20Devon%20Energy.pd

48 Mitchell vs. Encana and Chesapeake Lawsuit http://press.wturley.com/Mitchell%20vs.%20Encana%20Oil%20&%20

Gas%20and%20Chesapeake.pd

49 Scoma vs Chesapeake Lawsuit http://press.wturley.com/Scoma%20lawsuit.pd

50 Smith, J, Star-Telegram, The Barnett Shale search or acts on racking, September 4, 2010

51 Hydraulic racturing ruins another water well and dream http://txsharon.blogspot.com/2010/07/hydraulic-racturing-

ruins-another.html

52 Heinkel-Wole, P, Denton Record Chronicle,Filmy water vexes amily, June 5, 2010

53 Evans, B, Wise County Messenger, Unwell water: Drilling leaves a bad taste or some, October 3, 2010

54 Douglas, J, WFAA, Texas acts on aming aucets in Montague County, October 6, 2010

55 Wol Eagle Environmental. Sept. 15, 2009. p. 2. Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report.

http://townodish.com/objects/DISH_-_nal_report_revised.pd

56 Subra, W. (Subra Company). December 2009.Results o Health Survey o Current and Former DISH/Clark, Texas

Residents. Report prepared or Earthworks. p. 10.

57 Subra,W. (Subra Company) December 2009.Results o Health Survey o Current and Former DISH/Clark, Texas

Residents.

58 Wol Eagle Environmental. Sept. 15, 2009.Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report. http://

townodish.com/objects/DISH_-_nal_report_revised.pd NOTE: The ull report is available at: http://www.bseec.

org/sites/all/pd/airquality/13.pd

59 Wol Eagle Environmental. Sept. 15, 2009.Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report. p. 6, and

pp. 19-30. http://www.bseec.org/sites/all/pd/airquality/13.pd

60 Wol Eagle Environmental. Sept. 15, 2009.Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report. p. 6, and


61 Wol Eagle Environmental. Sept. 15, 2009. Town o DISH,Texas Ambient Air Monitoring Analysis. Final Report. p. 6, and


62 Armendariz, A. Jan. 26, 2009. Emissions rom Natural Gas Production in the Barnett Shale Area and Opportunities

or Cost-Eective Improvements. Report prepared or Environmental Deense Fund. pp. 5-7. http://www.ed.org/

documents/9235_Barnett_Shale_Report.pd

63 Wol Eagle Environmental. Sept. 15, 2009.Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report. p. 6.


64 Shannon Ethridge, M.S. October 27, 2009. Health Eects Review o Ambient Air Monitoring Data Collected by

Wol Eagle Environmental Engineers and Consultants or DISH, TX.Texas Commission on Environmental Quality

Inter-Oce Memorandum. p. 35. http://www.tceq.state.tx.us/assets/public/implementation/barnett_shale/

healthEectsReview.pd

65 Texas Department o State Health Services. May 12, 2010.DISH, Texas Exposure Investigation - DISH, DENTON COUNTY,

TEXAS. p. 1. http://www.dshs.state.tx.us/epitox/consults/dish_ei_2010.pd



67 Texas Department o State Health Services. May 12, 2010.DISH, Texas Exposure Investigation - DISH, DENTON COUNTY,TEXAS. p. 2. http://www.dshs.state.tx.us/epitox/consults/dish_ei_2010.pd

68 Centers or Disease Control. Fourth National Report on Human Exposure to Environmental Chemicals. p. 2. http://www.

cdc.gov/exposurereport/index.html

69 Centers or Disease Control. Fourth National Report on Human Exposure to Environmental Chemicals. p. 3. http://www.

cdc.gov/exposurereport/index.html

70 Levels o 2,5-dimethyluran in blood refect recent exposure and are generally undetectable among nonsmoking adults.

(Source: Centers or Disease Control and Prevention web site: http://www.cdc.gov/exposurereport/data_tables/2,5-

Dimethyluran_ChemicalInormation.html)

71 For example, Armendariz reports that benzene, toluene, ethylbenzene and xylene, as well as trimethylpentane,

n-hexane, were identied in a 2006 study that looked at air emissions rom condensate tanks in Denton and Parker

counties in the Barnett Shale. Concentrations were higher rom Barnett Shale condensate tanks than rom oil tanks

in other parts o Texas. (Source: Armendariz, A. Jan. 26, 2009. Emissions rom Natural Gas Production in the Barnett

Shale Area and Opportunities or Cost-Eective Improvements. Report prepared or Environmental Deense Fund.

pp. 15-16. http://www.ed.org/documents/9235_Barnett_Shale_Report.pd).

72 Nine VOCs were ound in the TxDSHS sta. But the TxDSHS samples were not identied by smokers vs. non-smokers.

Looking at the date, one o the TxDSHS sta members was a smoker, because the chemical 2,5-dimethyluran (a

biomarker or smoking according to TxDSHS) was ound in that persons blood.

There were two other chemicals, benzene and ethylbenzene that were only detected in the blood o one o the

TxDSHS sta. These two chemicals are known to be present in cigarette smoke. So, out o a total o 9 ch emicals

detected in TxDSHS sta, its quite likely that only 6 were detected in non-smokers. (See Table 2, p. 28 o the TxDSHS

Investigation).

73 Texas Department o State Health Services. May 12, 2010.DISH, Texas Exposure Investigation - DISH, DENTON COUNTY,TEXAS. p. 1. http://www.dshs.state.tx.us/epitox/consults/dish_ei_2010.pd



75 According to TxDSHS, AMCA is a nonspecicmetabolite, and its presence in urine cold be caused by chemicals

other than N,N-dimethylormamide. (TxDSHS Exposure Investigation, p. 8).

76 Air data rom Wol Eagle Environmental. Sept. 15, 2009. Town o DISH, Texas Ambient Air Monitoring Analysis. Final

Report. http://www.bseec.org/sites/all/pd/airquality/13.pd

Blood and water data rom TxDSHS Exposure Investigation. Tables 1 b. and 4.

77 Wol Eagle Environmental. Sept. 15, 2009.Town o DISH, Texas Ambient Air Monitoring Analysis. Final Report. p. 6.






80 E.g., ethylbenzene (one non-smoker was above the reerence level, and also had a higher concentration than

two smokers), toluene (one non-smoker was above the reerence level, and also had a higher concentration

than one smoker), o-xylene (one non-smoker was above the reerence level and also had higher concentration

than one smoker) and m-/p-xylenes (two non-smokers had concentrations higher than the reerence level, and

concentrations higher than 3 smokers). See Table 1.b o the TxDSHS report.



82 Texas Department o State Health Services. May 12, 2010. DISH, Texas Exposure Investigation - DISH, DENTON

COUNTY, TEXAS. p. 12. http://www.dshs.state.tx.us/epitox/consults/dish_ei_2010.pd

83 ABC Alliance web site. Hillwood @ Argyle Intermediate School. http://abcalliance.org/?page_id=548

84 March 16, 2010. Personal communication with Argyle-Bartonville Communities Alliance. http://abcalliance.org/

85 Argyle-Bartonville Communities Alliance web site. http://abcalliance.org

86 October 18, 2010, Texas Commission on Environmental Quality. Laboratory Analysis Results. ACL Number: 101035.

http://www.tceq.state.tx.us/assets/public/implementation/tox/barnettshale/healtheval/acl/101035.pd

87 http://www.dentonrc.com/sharedcontent/dws/drc/localnews/stories/DRC_Argyle_Drilling_1024.1bd997c2.html

88 Urbina, I. Regulation Lax as Gas Wells Tainted Water Hits Rivers . The New York Times, February 26, 2011

89 Presentation by Sharon Wilson to the Environmental Protection Agency, Oce o Air Quality Planning and

Standards, October 4, 2010; and Presentation by Sharon Wilson to the Environmental Protection Agency, Oce o

Air and Radiation, December 10, 2010.

90 Denton Central Appraisal District. Account 65735. http://www.dentoncad.com

91 http://www.dentonrc.com/sharedcontent/dws/drc/localnews/stories/DRC_Argyle_Drilling_1024.1bd997c2.html

92 Evans, B. September 23, 2010. Flight or survival: Toxic Emissions orce amily to leave home. Wise County Messenger.

http://www.wcmessenger.com/news/content/EklVEZEyuVBmtmajzo.php

93 CEQ Investigation #849227, Texas Public Inormation Request

94 Texas Commission on Environmental Quality, July 28, 2010. Laboratory Analysis Results. ACL Number 100732.

95 Evans, B. September 23, 2010. Flight or survival: Toxic Emissions orce amily to leave home.Wise County Messenger.

http://www.wcmessenger.com/news/content/EklVEZEyuVBmtmajzo.php

96 Evans, B. September 23, 2010. Flight or survival: Toxic Emissions orce amily to leave home.Wise County Messenger.http://www.wcmessenger.com/news/content/EklVEZEyuVBmtmajzo.php

97 TCEQ complaint #131635

98 Wol Eagle Environmental. January, 2010. Ruggiero, Mr. & Mrs., Decatur, TX. https://docs.google.com/

leview?id=0Bw-wqoEQk60oMjhlZGI2M2MtOTEwZC00NDA3LTkzOWItNTFmMmJmZjg1NWJh&hl=en

99 TCEQ Complaint #134722, TCEQ Complaint #135420

100 April 1, 2010, Railroad Commission o Texas. Ruggiero (Christine) Complaint No. 09-10-9535.

101 Heinkel-Wole, P. September 18, 2010. Drilling can dig into land value. Denton Record Chronicle. http://www.

dentonrc.com/sharedcontent/dws/drc/localnews/stories/DRC_DrillValues_0918.1046e9a00.html

102 Heinkel-Wole, P. September 18, 2010. (See ootnote 103)

103 Personal communication. August 2010.

104 May 25, 2009. Wole Eagle Environmental. Ambient Air Monitoring Analysis Project, Final Report.

http://earthworksaction.org/TXOGAP-CaseStudy-Rogers.cm

105 May 25, 2009. Wole Eagle Environmental. Ambient Air Monitoring Analysis Project, Final Report.

http://earthworksaction.org/TXOGAP-CaseStudy-Rogers.cm

106 July 30, 2009. Letter to Mayor o Westworth rom E. Murl Baily, Jr. Veterinary Toxicologist at Texas A&M. http://

earthworksaction.org/TXOGAP-CaseStudy-Rogers.cm


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Documents

FLOWBACK TX-OGAP Health Report