Residual Waste (Marcellus Brine) Tankers
Decisions about ‘brine’ toxicity: who makes them, when and how
By S. Tom Bond, Retired Chemistry Professor and Resident Farmer, Lewis County, WV
The need for this article was brought out by an article forwarded by Debbie Borowiec. The kicker in that one was the statement that the Pennsylvania Department responsible for regulating the use of fracking “brine” on roads didn’t keep records or understand the potential effects of it until Newsweek got in touch with them.
I have reasonably good “credentials” for discussing this. I have a Ph. D. in Inorganic Chemistry, and was a teacher rather than a researcher. At one point I was preparing for work in Industrial Hygiene, so I took the American Chemical Society course in Toxicology, received a lot of literature on it, and took several courses relating to Industrial Hygiene at the University of Pittsburgh. With this background, I believe that almost all decisions involving toxicity are made by people who are just about as knowledgeable as someone picked off the street at random.
The way toxicity is handled is a kind of fundamentalism, with a set of written rules that are supposed to be capable of interpretation by someone with no training. These are put into law in such a way they are easily used in court proceedings by reasonably able people (lawyers) who don’t know (in principle) BaCl2 from KCl unless it is spelled out in writing. These compounds are barium chloride, a deadly poison, and potassium chloride, a substitute for table salt.
What the rules do is specify is a tolerable limit of exposure for a 40 hour work week for an average person. They are intended to protect a person who comes in contact with them while working in a typical job. I will not try to explain how these quantities, defined as safe, are arrived at. It would take a book or two, and the procedure is very, very expensive.
Now I will describe some details about sensitivity in the real world. The research almost always deals with a single, pure compound. People are frequently exposed to mixtures, and, as with medicines, effects are known to be enhanced by mixing in many cases. Fracking exposures are always mixtures, with many components. Second, the published values are for 40 hours a week. People working on rigs are exposed 84 hours while people living in the vicinity 168 hours a week. Water exposure limits work the same way. The more you ingest or the more it comes in contact with your skin the more effects there can be.
Third, some poisons, like carbon monoxide, activate a process in the body to remove them, so that if you survive the dose for a few hours, the effects go away. Others, like the dread heavy metals, are not removed from the body, they are cumulative. You may receive a small dose continuously for most even a number of years before they show effects. Mercury put in the air by coal burning is often given as an example of this type of poison.
Fourth, the limits are set for working people. They do not apply to old or sick people or to fast growing children, babies in utero or the early years of life, or to asthma victims or many other categories not in the prime of life but who comprise part of a normal population. Fifth, no one knows (except the toxicologist who runs the experiment to determine the toxicity) how much more the effects are increased by some incrementally higher dose, say a quarter more than the specified quantity. More to the point, how great are the effects from two or three times the legal exposure limit, as often occurs in the real world?
The rules often don’t resolve real world situations. Many severe exposure situations end up in court where experts for victim(s) try to convince the jury against the company army of “in house” experts.
Sixth, there is a “chain of command” for the samples taken of materials to be analyzed for chemical content. That is, everyone from the various persons who take and analyze the samples to the person(s) who makes the decisions are ethically constrained. If only one in the chain is inclined to cheat (for the sake of the organization, of course), the result is not dependable. Integrity is a big deal when you are teaching chemical analysis as there are many ways to get it incorrect results. Was the sample taken in such a way it is representative, or off in some corner where the concentration is more dilute than that to which the victim was exposed? Was the container properly handled – left open for a time, for example; or was it spilled and a substitute put in its place, heaven forbid?
That is why dependable third parties are so important. That is why the bureaucracy of government, and time consuming nature of enforcement, forced on the system by drilling interests works against citizens.
In fact the “brine” that is hauled around in big trucks that comes from Marcellus shale wells is composed of many salts and many other compounds as well. You don’t want most of these compounds in your water supply or the streams you fish in! And it is obvious the people who made the decision to use such “brine” aren’t adequately educated to make such decisions.
As I said to Debbie, “The investors don’t know toxicity, the executives don’t know about it, the bosses on the job don’t know it, the workers and truck drivers don’t, and a horrifyingly large portion of the REGULATORS don’t know anything about it.”
The weight of big money is a great motivator for quick decisions that may not be in the public interest. Ethics, the other guy’s rights, the necessity of consideration of all the effects of such decisions, are not priority considerations. “First do no harm” is for physicians.
See also the following interesting reports:
(1). Marcellus-Shale.us: “Photos of Brine and Water Tankers”
(2). US-EPA: “Drinking Water Contaminants”
(3). US-NIEHS: “Radionuclides in Fracking Wastewater: Managing a Toxic Blend“
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