Chris Salmon Technologies

Here is part of a discussion, where I am trying to teach my friend Audrey, an anti-fracker activist, how hard knowing the truth really is:

Audrey Said:

"The gas industry is anything but "innocent". For 2 years now I have followed what is going on, traveled around to see things firsthand, talked and written to many people. It is horrible what suffering is going on. The chemicals they use are now in our food chain, from so many spills, blowouts, and migrations underground. You can't be that naive to think that they really "care" what happens to people."

My Reply: 

@Audrey Simpson - Audrey .. the more I interact with you, the more I think you are probably a really good person. I think Gilbert Davis is probably a really good person too. Regarding your thought that people in the gas industry don't care what happens to people, I can't speak for everyone, and I'm a small timer in the oil business, not gas - but I care.  And everyone I know cares.  I think you are just wrong and maybe you don't even know any oil or gas industry people, or have friends or family in the business like I do.  I personally, NEVER think of lying or scamming people myself, so I tend to see the best in others. That has burned me many times before. When I first came off the ranch, I was a naive country boy - a hick from the sticks, believe me, it was pathetic. "Done went off to the city!" Hell I believed anything anyone told me and trusted everyone when I was that 17 year old ranch kid. Ok ... well look... meaning well and being sincere doesn't mean your conclusions are correct, OK? In fact, some of that goodness and well-intentioned attitude can lead you to the WRONG conclusions. I personally think that is what is happening to you and a lot of other anti-frackers.

Looking at your sentence I pasted above, what I see is someone who - don't get angry, just listen - has subjected herself to a number of statistical biases such that her observations are unintentionally skewed and leading to a wrong conclusion.

- number one, and I have seen this a LOT in stuff coming from BOTH sides of this debate ... SELF-SELECTION BIAS.You are talking to people who have selected themselves to talk to you. You are not talking to people who do not want to talk to you. Thus, you have a viewpoint based on what people who feel motivated to talk to you say. It can get even worse than that - and probably is! Let's say you attend public meetings designed to drum up anti-fracking support, or to present anti-fracking "education" (read: indoctrination) materals. There, you, in all sincerity, get involved in discussions with people who are active and gregarious in their willingness to talk to you. NOW you have a DOUBLE SELF-SELECTION BIAS - you have isolated only those people willing to come to such meetings. Then from that sub-population, you are listening to only those people there who want to talk to and influence others to their point of view!! People who selected themselves as MOTIVATED to influence you, out of a group that selected themselves to be part of an anti-fracking group meeting! 

Someone recently accused me, with some justification, of hiding inconvenient facts from readers here. Ok, let me not do that and tell you... self selection and other statistical bias is not limited to one side.The Duke University study from earlier this year suffered from a severe self-selection bias. This is because their sampling of the population of water wells in PA was so incredibly small as to be worthless. Seriously - 68 wells? Susquehanna County alone has over 20,000!! I know because I downloaded the PA-GWIS database and mapped it. AND because they could not sample anyone's well, unless they volunteered to be part of the study. People who wanted Duke to come in and show something, volunteered. People who didn't .. didn't.

Now, here comes Penn State, via the Center for Rural Pennsylvania, with a competing study that shows the opposite thing! Now, the Penn State study is better, because they did before-and-after sampling. But they STILL HAD THE SAME SELF-SELECTION BIAS because they can only ask for people to volunteer to be part of the study. People who like and trust Penn State volunteered. People who apparently were about to allow drilling on their land may have preferentially volunteered. People who didn't... didn't. 

So, depending on how they identified and approached water well owners, and how they worded their request to sample their water well, they could basically make the study come out almost any way they wanted. Let me give you an example:I want to study water wells in an area, say 5 counties. I download a database and obtain owner information. I write a request for volunteers to have their well sampled as follows:

"Hello, I am Chris Salmon, a geologist and charter member of the Division of Environmental Geosciences. We are conducting a study on the effects of fracking on the chemistry of residential water wells. I am kindly asking for your help - we need residents to allow our associates to come on their property and take water samples. Your samples will be preserved using EPA methods and analyzed by a professional laboratory legally certified by the state. Would you help us?"

OK - all of that is totally true. I *am* a geologist and charter member of the DEG. I *would* like to send out a crew to get water samples. I *would* send it to a certified lab using the right procedures. Fine.

Or I could write THIS request:

"Hello, I am Chris Salmon, geologist with Salmon Oil Company. We are doing an exploratory survey for oil & gas deposits in your area. I am the scientist-in-charge of determining what properties are best for us to focus our leasing and drilling efforts. As part of our study, we would like to sample your water well and do a chemical analysis on it. This will help us determine if there is reason to further explore drilling on your property. For your inconvenience, we are willing to pay $500 just for you to allow a geologic technician to enter your property and take samples of your water well. You will receive a copy of our analysis for your own use. If you are interested, please sign the enclosed allowance and non-disclosure agreement."

OK.. now that is ALSO totally true! And I would STILL send it to a certified lab, and do EPA recommended handling of the sample. But I wouldn't mention that to them, if I wanted to eliminate people who didn't want the EPA or the state involved.

So... can you see the self-selection bias I have induced into my study merely by how I worded the request to take samples from water well owners? In the first, people with a bone to pick, people who already think their water is suspect and want a free test for "proof", people who only own surface rights, people who are anti-drilling and pro-environment, are going to select themselves to respond. People who want to see if they have legally valid information for a suit will respond. People who are pro-EPA and anti-industry will respond! 

In the second, people who think they MIGHT MAKE MONEY, people who are dreaming of selling mineral rights and getting royalties, people who have a bias FOR and not AGAINST the oil & gas industry, are going to select themselves to respond!  People who hate the industry, who don't own mineral rights, who don't want drilling, who think oil company money is "dirty" and who don't trust me because I'm with an oil company will select themselves OUT of the study!

So there you have it. I hope you might see your own issues with statistical bias in my lesson here. I can be the same scientist, using the same tools, doing the same analysis, and come out with TWO DIFFERENT RESULTS - (oh... I guarantee they'll be different!) merely by inducing a bias in my samples of the overall population of water wells in an area. I personally guarantee I can make the same study of water wells near new hydraulic fracturing in PA come out two different ways by how I approach the sampling. Because PA has no way to force EVERY water well owner to give up before and after samples, that I know of. It's their private property! So I have to convince them, one way or the other, to select themselves for sampling. If I'm wrong, someone please tell me!! 

So.. do you see, Audrey? This is what is happening to YOU. YOU are selecting out a sample, a sub-population, of the total population that is skewed toward the very conclusion that you have naturally reached!! I would bet anyone a thousand bucks right now, that I could design a methodology and send YOU, the same Audrey, out on a mission to talk to people I brought into contact with you via a different selection method than you have used, and cause you to arrive at a different conclusion. And if you hadn't seen the other side before, or had previous personal biases (which you obviously have) you'd be just as convinced. I can see it now!

So you see... this stuff isn't as easy as maybe the untrained might think. It's not about "I talked to x, y, and z and they all said blah blah blah." It's not about, "I feel "spiritually" that my yoga instructor was leading me to be against fracking to save Mother Earth. I just had a feeling.. intuition I guess." It's not about, "I saw that "Gasland" movie and now I am SO PISSED OFF!!" It's also not about "ABC gas company is going to give me megabucks so I don't care if they pollute some." And it's not about, "I need a job so all the evidence of pollution must be wrong." ... OK? OK, it's not about any of that.

This stuff is HARD. It's WAY hard to figure out what the heck is going on. Most likely whatever you DO figure out, is only part of the picture and is wrong in some way that you'll find out later. And that goes for both sides in this debate. That's why people get so frustrated with us scientists saying one thing one year, then another thing the next year, and yet another thing 5 years later.

Science can't even PROVE anything, if you dig deep into the philosophy of it. It can only show that evidence collected in the past (even one second past) is consistent with a hypothesis or theory. You can collect evidence consistent with your view of something 100, 1,000, 10,000 times in the past. But since you can't see the FUTURE you haven't PROVEN a damn thing!! ONE contradictory observation undoes all previous consistent ones and *POOF* you have to admit your idea isn't the truth, isn't real, and is basically only statistically useful at best, if that.  This stuff ain't easy. You can't go 'round with a video camera and a notebook and ask for people with complaints to talk to you and come out with anything even CLOSE to real. You just can't.
 

 

Gasland director Josh Fox admits hiding facts from film audience 

In this clip from filmmaker Phelim McAleer, he captures Mr. Fox revealing that he knew of published reports of "troublesome amounts of methane" in the aquifer featured in his "flaming faucet" scene going back to 1976.  However Fox says he "doesn't care" and chose not to tell his audience this because it was "not relevant." He then compares this to reports of cars hitting pedestrians in Denver in 1987 (huh?).  He also reveals that he knew of reports of flammable tap water from New York water wells going back to 1936!  Actually reports of "flaming water" go back even further than that, as I wrote in "BEN FRANKLIN DISCOVERS "BURNING WATER" IN 1764"

 

Gasland director hides full facts from Not Evil Just Wrong on Vimeo.

In fact, Gasland was so inaccurate in reporting the facts in Colorado, that the Colorado Dept. of Natural Resources had to issue a Gasland Corrections Document which gives detail on the well dishonestly portrayed by Fox in the famous scene:

"The Markham and McClure water wells are both located in the Denver-Julesburg Basin in Weld County.  They and other water wells in this area draw water from the Laramie-Fox Hills Aquifer, which is composed of interbedded sandstones, shales, and coals.  Indeed, the water well completion report for Mr. Markham’s well shows that it penetrated at least four different coal beds.  The occurrence of methane in the coals of the Laramie Formation has been well documented in numerous publications by the Colorado Geological Survey, the United States Geological Survey, and the Rocky Mountain Association of Geologists dating back more than 30 years.  For example, a 1976 publication by the Colorado Division of Water Resources  states that the aquifer contains “troublesome amounts of . . . methane.”  A 1983 publication by the United States Geological Survey similarly states that “[m]ethane-rich gas commonly occurs in ground water in the Denver Basin, southern Weld County, Colorado.”  And a 2001 report by the Colorado Geological Survey discusses the methane potential of this formation and cites approximately 30 publications on this subject."

In the video clip posted here, Fox claims that "the citizens reported that they could not light their water on fire before the drilling, and after the drilling, they could light their water on fire."  But the COGCC Gasland Corrections Document addresses this claimed temporal relationship between drilling and flammable tapwater, something Fox also left out:

 

"The COGCC has also reviewed the records for all oil and gas wells located within one-half mile of the Markham and McClure wells, which is more than double the typical hydraulic fracture length in Colorado.  This review indicated that:  all oil and gas wells near the Markham well were drilled and hydraulically fractured in 1991, except for two wells that were fractured in 2005 and 2006, respectively; and all oil and gas wells near the McClure well were drilled and hydraulically fractured in 2002, except for one well that was hydraulically fractured in 2005.  The records do not reflect any pressure failures or other problems associated with these wells that would indicate a loss of fracture fluid or gas from the well bore into the surrounding geologic formations."

 

The COGCC investigated claims by Mr. Markham in 2008.  Gasland came out in 2010.  The COGCC speaks to the "before and after" claim as follows:

 

"Finally, the (Gasland) website asserts that the water in the Markham and McClure wells deteriorated after drilling and hydraulic fracturing occurred nearby.  However, COGCC records indicate little or no temporal relationship between the Markham and McClure complaints and nearby drilling and hydraulic fracturing activities, which occurred several years earlier and in most cases many years earlier."

 

In this willingness to misinform Gasland's viewers by leaving out information that is inconvenient to his fear-mongering advocacy, Mr. Fox is exhibiting behavior that seems common among those involved in the anti-fracking industry - when the findings of government scientists agree with them, they're viewed and published as accurate and the scientists hailed as heroes; when these same government scientists make findings that don't agree with them, they're accused of being "bribed," "bought off," "in the pocket of industry," and so forth.  Even when it is the exact same scientists!

There are many more inaccurate claims made by Mr. Fox and the anti-fracking industry, which we will continue to discuss here at cst.net in the future.

 

2011 Updated Pennsylvania Water Code for Gas Drillers

There has been a lot of discussion around the internet regarding wastewater handling from natural gas drilling operations in Pennsylvania, and many people seem to be thinking about this issue using outdated information.  There is a great deal of outdated information still posted on anti-fracker websites all over the internet.  The fact is that much progess has been made and many of the complaints from earlier days have been resolved and are no longer a problem.  It turns out that much of this change was at the behest of the gas drilling industry itself, who realized that continuing with lax and poorly written wastewater regulations was going to result in a backlash against them.  As the Huffington Post reported back in April:

"While the movement to end the wastewater discharges followed years of environmentalists' criticism, the most influential push may have come from within the industry itself."

"John Hanger, Krancer's predecessor as Pennsylvania's environmental secretary, said that as early as 2008 he had been approached by two of the state's most active drillers – Range Resources, of Fort Worth, Texas, and Atlas Energy, now a subsidiary of Chevron, warning that the state's permissive rules had left rivers and streams at risk from the salty dissolved solids, particularly bromides, present in produced well water.

"They came to me and said, if this rule doesn't change, there could be enormous amounts of wastewater high in (total dissolved solids) pouring into the rivers," Hanger said."

So now we have the following new changes to the PA code.  You can find them on the Pennsylvania Code site, but I've isolated the important new parts of the code that deal with wastewater from gas drilling and fracturing operations here:

 

(b)  Operations with wastewater resulting from fracturing, production, field exploration, drilling or completion of natural gas wells shall comply with the following 
requirements:

(1)  Except as provided in paragraph (3), there may be no discharge of wastewater into waters of this Commonwealth from any source associated with fracturing, production, field exploration, drilling or well completion of natural gas wells.
(2)  A wastewater source reduction strategy shall be developed by the well operator by August 22, 2011, and submitted to the Department upon request. The source reduction strategy must identify the methods and procedures the operator shall use to maximize the recycling and reuse of flow back or production fluid either to fracture other natural gas wells, or for other beneficial uses approved under Chapter 287 (relating to residual waste management—general provisions). The strategy shall be updated annually and include, at a minimum, the following information:
(i)   A complete characterization of the operator’s wastewater stream including chemical analyses, TDS concentrations and monthly generation rate of flowback and production fluid at each natural gas well.
(ii)   A description and evaluation of potential wastewater source reduction options through recycling, reuse or other beneficial uses.
(iii)   The rationale for selecting the source reduction methods to be employed by the operator.
(iv)   Quantification of the flowback and production fluid generated by each well which is recycled or reused either to fracture other natural gas wells or for 
other approved beneficial uses.
(3)  New and expanding treated discharges of wastewater resulting from fracturing, production, field exploration, drilling or well completion of natural gas wells 
may be authorized by the Department under Chapter 92 (relating to National Pollutant Discharge Elimination System permitting, monitoring and compliance) provided that the following requirements are met:
(i)   Discharges may be authorized only from centralized waste treatment facilities (CWT), as defined in 40 CFR 437.2(c) (relating to general definitions).
(ii)   Discharges may not be authorized from a POTW, as defined in §  92.1, unless treatment at a CWT meeting all of the requirements of this chapter precedes 
treatment by the POTW.
(iii)   The discharge may not contain more than 500 mg/L of TDS as a monthly average.
(iv)   The discharge may not contain more than 250 mg/L of total chlorides as a monthly average.
(v)   The discharge may not contain more than 10 mg/L of total barium as a monthly average.
(vi)   The discharge may not contain more than 10 mg/L of total strontium as a monthly average.
(vii)   The discharge complies with the performance standards in 40 CFR 437.45(b) (relating to new source performance standards (NSPS)).
(4)  Deep well injection of wastewater resulting from fracturing, production, field exploration, drilling or well completion of natural gas wells shall comply with 
§  78.18 (relating to disposal and enhanced recovery well permits).

Greg Ball's anti-gas drilling "Property Owners Bill of Rights" - a job killing mashup part I

NY State Senator Greg Ball has submitted legislation that is a de facto ban on developing natural gas resources in the State of New York. The bill is:

S5879-2011: Provides for the regulation of the conducting of hydraulic fracturing

I'm going to try to wade through this labrynth of unfocused and contradictory writing posing as legislation.  In this article, I'll expose the glaring errors and dire consequences I believe the legislation has for the citizens of New York and development of natural resources in the state. It will take some time and space so I will break up the analysis into pieces and try to focus on one or two problems with the bill per article here at cst.net.

The first thing I noticed upon reading the bill is the contradictory and incorrect definitions of hydraulic fracturing contained in the bill, which amends the environmental conservation law by adding two new titles, 15 and 16 to Article 23. Under one of these definitions, hydraulic fracturing is defined so broadly as to put anyone who performs typical chemical treatments on a producing well - whether hydraulically fractured or not - under the punitive regulations described in the bill.  This is extremely detrimental to gas production in New York and, in my opinion as a geologist with oil production experience, (I am not a lawyer) will eventually result in currently producing gas wells being shut in. Again - regardless of whether they are hydraulically fractured or not. In fact, whether they are vertical or not, and under some interpretations, it appears whether they are gas wells or not! Let's take a look:

Title 15 of the bill:

Defines the disclosure of composition of hydraulic fracturing fluids. This title includes definitions, the type of information submitted that is considered public, service company disclosures, operator disclosers and defines what use of service of non-complying service company is prohibited.

Section One:

Defines "hydraulic fracturing treatment" as the stimulation of a well by the forceful application of hydraulic fracturing fluid into the relevant geological formation for the purpose of creating fractures in the formation in order to facilitate production of hydrocarbons.

-OK, so for disclosure purposes, THIS is the definition of hydraulic fracturing used. Now let's look at the next part:

Title 16 of the bill:

"describes the regulation of hydraulic fracturing, which includes definitions, concession of liability and agreements with property owners and damages."

Section One, Title 16 states:

"defines "hydraulic fracturing" as the use of chemicals, water and other substances injected or pumped into a natural gas well to stimulate the extraction of natural gas well to stimulate the extraction of natural gas."

Let's ignore the confusing word repetition at the end of the definition for now. So for regulation purposes, THIS is the definition of hydraulic fracturing used - one entirely different from that used for disclosure purposes!  THIS DEFINITION OF HYDRAULIC FRACTURING IS FACTUALLY INCORRECT AND COVERS STIMULATION TREATMENTS NOT RELATED TO HYDRAULIC FRACTURING!

So here we have, in one bill to regulate hydraulic fracturing, TWO different, conflicting definitions of what hydraulic fracturing is.

Worse yet, under the second definition of hydraulic fracturing in the bill, that in Title 16 which covers regulation of the process, my reading is that anyone who injects chemicals, water, or other substances into a natural gas well to stimulate the extraction of natural gas will be covered under these regulations. Producing wells are commonly subjected to a variety of non-fracturing stimulation treatments throughout their lifetimes.  Treatments designed to clean up the well and/or formation, dissolve and/or remove materials blocking the well or porosity, and etc.  All of these treatments involve injecting some substance into the well! So under this definition in Sen. Ball's bill, ALL GAS WELLS IN NEW YORK THAT RECEIVE ANY KIND OF DOWNHOLE TREATMENT WILL BE SUBJECT TO THESE REGULATIONS WHETHER THEY ARE HYDRAULICALLY FRACTURED OR NOT!! In fact, by this definition, thousands of older, vertical gas wells that may have been producing gas for the people of New York cleanly and peacefully for years will come under the punitive regulations of this bill, if they ever receive any kind of downhole stimulation treatment. Yes - to repeat: this means that wells that are ALREADY in place previous to the lifting of the hydraulic fracturing ban will come under regulation by this bill as they undergo stimulation treatments that are normal in the lifetime of a well.

That is not the only problem regarding what wells are covered under the Ball bill. There is no differentiation in the bill between horizontal wells and vertical wells. This means that vertical gas well drilling which has been going on continuously in New York since the first gas well was drilled in the state, successfully regulated under long-standing rules of the NYSDEC, will now come under the new regulations of the Ball bill. My reading of the bill says that since ALL drilling involves injecting "chemicals, water and other substances" into a natural gas well to stimulate extraction of natural gas, then ALL gas well drilling - vertical or horizontal, hydraulically fractured or not - will come under the regulations in Title 16 of the Ball bill. Yes - that includes gas well drilling that is currently not under the state's moratorium on hydraulic fracturing!

So now we have ALL new gas well drilling in New York, and ALL gas wells currently in production in New York, eventually coming under the regulations in Title 16 of the Ball bill. Because by definition, any "use of chemicals, water and other substances injected or pumped into a natural gas well to stimulate the extraction of natural gas" will be covered, and that is ALL gas wells.

And the regulations these wells will be subject to are extreme, punitive, and unreasonable to the extent that I believe that no responsible company can operate under them. I will cover that issue next, in part II.