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Home My WebLink About20161781.tiffEXHIBIT INVENTORY CONTROL SHEET Case USR16-0009 - 7N, LLC, C/O EXTRACTION OIL AND GAS Exhibit Submitted By Description A. Planning Commission Resolution of Recommendation B. Planning Commission Summary of Hearing (Minutes dated 6/7/2016) C. Planning Services PowerPoint Presentation D. Alan Herman SPO Letter of Objection E. Maydean Worley SPO PowerPoint Presentation and Articles- Objection F. Bernadine Barea WC School District 6 Suggested Mitigation G. William Shell FWD Letter to COGCC from the Sierra Club- Objection H. Therese Gilbert Fracking Study- Objection I. Karen Speed Email/Article- Ob ection J. Applicant PowerPoint Presentation K. Wendy Highby Letter and Article L. Amanda Harper Letter M. Bill Jerke Health Indicators N. Karen Speed Article O. Anne Curry Sanchez Drilling Studies P. Barbara Flores Letter Q. R. S. T. U. V. W. 2016-1781 .. . , - - . .. . � . - � � � - ; ♦ �, ' . . . ' � �'. . � . � �.. � . .. � - �.� ♦� � �' . ' � i. - - - .r,r ^ . �s� ... . 1� , . ' " . _ � : � _ .� i; ' . , . , .c, r. ... '.: �' ., . 'T' �. � .• . � � � ' ,i.,,� �. .. _ �' , � ' � �• . ^ y� 7' � , r,�„�,, ._ � _.: z . ,.,�c, __ ..� „ls,,; . ti - 'r - - �• . «� � ' ��w��r� ' � �� '�f 1 r� »y.� _ ' ...h �y' � '.�� .i . • y- ,r � Z� � l- • r� �l� � �r, . . : r � ,'S., '^ �7'�.�r . `�W Y '.�.. • � V _ .. � `. �, . r : �•.._ a � a � � . . � y' tis �.��➢M�� y,� ��Y . , 1�1.,�'��lYiW�� l�4� ' . , i � f .w. . �.: . w�'`y ' r � i��` = Y. ��; � � '' 1 • � �� J � ` J , - . � ��. ��?�a"a � ..:.� .. . , � " .-�+ • �, `^ ` r.r _ • �� , ' Pubhc hean�gs concvrni�g this property will be heard 4etore the . ��"'` " ' . __ . ; , . � �-r ., Counly Plannmg Comm�ss+on o-ind � . � ' � � �.. _ . �. ' � . -� • �, , , Board ot Coimty CommissionArs y��a.. ` •.. ` -� `� :_ • ` . � ! � +M � - � Both 17raarukas wdl be held at � , � � �.. - < � = : ' � '�1 � �i . t. .. - .,* , y�," _ r ,, WELD COUNTY ADMINISTRATION BUILDING . '' • � � •� �r - •- -" � � 1150 " O" Street • Greeley, CO 80631 � �� d ,,�,�.` � �-' :- :. �"� ' E. ' . _ �-+i� ,:" , . � '.,,�p . �,;n� � P�anrnng Commiss�on Heanng wdl be held on � '�'`�,�� '�, '�a ,..t . . .. . . , - , ..a_. �. e J . � _ � � + �„� 'h+" - : � �UnP � 20�: at _�IY11 '�G: '+S°- 3��. �j�.r�1 .1 ! . � ` . . '�,.i . � ' � i � � . .. . . � � �„a" ' ' .+�'t� . ;.• � � -.� . ,� �y,:�� Board ut County Commissroner Heanng wHl be held on ,. y � �, , � 'f �- , " r 1?�^ . :,_� -�- , 5 _ �e . ' ..r . � ' s. " yhtt� � 20�: 8l' 10d�A1'� ,;`5''"' •�... + ._._ - "'+K.e� ,. _ �, .: �r��ds,,,� ' � - • �� _ 4 . . r. r -� � _ T �,�,.z 7N LL � �x�c�► nn' l��os ;�� . • . . � .�, .. q �- APPticaM: C n � .� t + - ` ,�,.. r,. • � .. •.. • " • ' • �� « � ' .�L`�'��-y"+s.�_-� ��^� I , .. Requ�ifi ' _ �h.'l+��` v� . y .-:.i1C`. — -- - � � -T :Jy. . . + . � �� .. . Y �. • � � . . - - A Site Speclt�i Dovelopment Pian and Use by Spac �ai . s . ' . �' � � T l � � -. n � .1 � � - - Revlew Permit for Oil or Gas Production FacillUes 12a � '� _ � .y::. �, '�'�!i — wells. l8 otl lanks. 2 water tanks. 24 separetots. 2 - , ' . . � -t „ � , meter houses. 4 vapor recovery umts. 8 emissron �j I control dewces and 2 vapor recovery towersl in the y�-�* � � i • = ti�� N , ., �t . � _ R- 1 (low Dc�islty Residenlial� Zonc Dislnct ��T Y ^r � � '�� , � ..,, Z , . . , ; ,,,R i,� - - _ _ _ } , � ;�ar ._. v ' A+�� *.� . . ' � ; y ' � �� ; ; t� •. Case Numher: U. 1`�,f f�-CYY�? Acres: ��J ,-'i _ __ + � �. � � ,� �,�� T r , � �. � , ;'r �' � �`i }� • FOR nFURTHER IIVFORMATION PIEASE CQNTACT � { '-" a .�}lfl� tY� AT THE WELD COUNTY �EPARTMENT OF � V.. . PIANNING SERVICES. AT 970-353�6100. eM.�� ,. .. , . . . 5�• � � � Fpr AddiUonsl In(ormallon vis,l www wala;ou�typlamm�gcases ory .�,` 1�!, . � - ,_ ,+ � t . . • . . .. � . • . . . . .. r .. _ , i � m�rnr � W .nM rr�.. r'I . . . � . . � � . . viY•. . . . •• • � VI\Ptir X . . :.4 . �� ( -. . � � _ � . � � !, - - -- - - - " � i '_ I ' ExHOBir '� ,, ;� �' :,,� , _ �. , � s . . p 4 " � i/ J � � � . .. � 7 1 : . l�. ��\ Y � . v 1 I+. 1, , - �' ` i ` . •� , ' . JMr� . � .�� ' ^� •7*�:` . R • "' 1 0 r♦ :i � � ( 1 � ♦1�. � � 1 � �� i � y1 y�"\�]� � t�4 i �� l .� � ♦ �l~ 'l : '� 1'• ,. f •. �^y. J .. , ` � � � .�1q 'V i 1 � . `f� � .�-b � � � , � . �� r �; ��y ' ' � ~ � 4 � �i� b-, L•A :a ` . �, '� , �' � " = :, � <�5`i �.. �f�C . i � ' � t� '' ' 'a�. ' ' wf �' = � � ' � � , �� -� �� ,. � ^ . h� M1 � �. � . �+I'rf : � �A�t �'i` �: � �� i yl ��4� ,, �. . ,�. , .:,. .�4s. '3 � , . — � - : 46 .� , � .�. . - ,at � . . t' ;, .SY� �L�S,tur. , ax • . a . + . . . � . ' " " " . . . . . . . . - . . - � _ ��-`- - t^ _ . - ' . ' - . . _ • - . . _ - - . . . . -. .. _ - . _. _ . . - � _. - ' ' � 'ni - - " '. -z�.��`ie.- - : . r a e-.-- _ � � -` � . '�_a. � v.i " _ . . . �� . rC S c . . . _ ! C ' _ _ - � (�'� � s i` . a y �1 �'L .. , � Y 1 ' Y�� -� . � \/ .. [ L � ' •M. +-y� Il�. . .�J_l . �i ` �. V_�a . . �. . � . J' ._ _ _ �s y� � . .` � w � . _ ' �� - r. C T^' � ti - _ sY_ �> _ �. - • - -. i � �" _ t. Punlic hea�ngs cortcerning th�s property wfll tle heard Uefore thv -'F �- - � - � - . � _� , Counly Planning Commiss+on antl ��- - �� ' �- v Bo2rA of Counry Commissioners. � ��-+ � � _ � • �- -� � '�' Bolh heannys wdl Ue helA ai � � • K� J 'C � . WELD COUNTY ADMINISTRATION BUILDING , - 0. _ " , � . _ ,-� - - 1150 "O" Street - Greeley, CO 80631 � r .,.�:..` - '' � j�� ._ „� � Planninq Commission Hearntg w�ll be helA on �- . '� . ,r - . - _ � '�� - . � � .� �y } � �Y�: .' {� �i. . . �.,_'1-�. _ ' � . �Ul�P ( 20�: aY �_ _ bY � �� . ` x .m .• . . {' _ ' " -.. � ' _ ` � ,� �, : {� r�1'�� Board Of County Commisswner Hearing will be held on �J � '} '`� � 'r y .. ...- �,. .f_�� ' � �J1 . _ _ �-c� �. �� .. �� _ � ittiL�� 20�: at: � Q.�A� � � . +:. � _ � -. � ' ^ - ' 'lKa= =�- - .�1 , d6�� _ � / � - .._ �1'k ♦ T '��t � � (� � a� � ' �_ Y . -- � - t- " �. �+PPlicanl�. N I _I C %�' FX�Ct�`�1!`(1 `- �` � � 'l7la�, ,� 4- - x� . . - •. .. 1�, •-. .� _�iV� ` Y _ �I • � _ _:. : � RequP5:. �' _ ` .;a .^ _ _ �.Jk'• �'"'- - . �c . ra- - . �� -- — — - � � -� �. _ _ . � - - A Srte Speci(ic Devalupn+enl Plan anA Use by Speciai , � � � ' - Review Permit for Oil or Gas Pioduction Pacillbes 114 ' n - � , . ��'�r� - - wells. 18 oil lanks. 7 water tanks. 24 separators. 2 , - -_� - - - � --�-_' metor houses. < vapor recovery umts. 8 emisvon � . , „� } �f;"- ♦y� ' �' ` �� E _ �"`- _�� conVol devmes and 2 vapor recovery towers) In the u q.� 9 � \ � R-1 !Low Um�s�ty ResWeolial) Zonc Dis�ntl { . l ' , t = - y , , ' � c, � ' � Ilri� � 1 � :i=4. >� - � ' � . . ' CaseNumCer ( ),SR �f�lYYf-� Acres: +i�3.r-� �+� ^ ~ �rT ti" � . tir ' -"+ ..f - . ' FOR FURTyHER INFORMATION PIEASE CONfACT � � . ; .�j�pm.�a � AT THE WEL� COUNTY DEPARTMENT OF' �= - � ! , r PLANNING SERVICES. AT g]0353-6t00. ezt. . .-�� _ . . , ; u g, ' � /. 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Y 1i ♦ � . � 4� � �� .�. � �' View looking southeast Esther Gesick From: Alan Herman <alanherman2011@gmail.com> Sent: Tuesday, June 21 , 2016 9:44 AM To: Esther Gesick Subject: Weld County USR Hearing Vetting Wells Attachments: 2016-06-21 ( 1 ) ( 1 ). png EXHIBIT � 9 � 1 o Whom It May Concern, .iune 20, 2016 `� l ' �00 My name is Alan Herman, and I have lived at 1321 East ?4th Strcct ii� Greeley, Co 806� l , but l actually live in Weld County. I ha��e lived at this address for over 50 years, and my dad lives directly east of ine. 1 attach a map so you can sec my localion more easily. My family has lived on this property and improved it. We have restored a barn Yrom 1913 , built t�vo houses on the property, and now when I look out my sliding glass door I can only imaginc seeit�g the entire view taken up with wells, dust, and oil field trucks. Out my front door, facing south, in the past few years I often watehed oil tield lowbeds careeuing around a 15 mile an hour curve going 30 miles an hour along E 2dth strcet right before the intersection with Cherry Avenue. The center line oCthis street is �bout 90 feet from my f�ront door. The power pole has been knocked out several times, and you can call public service on that. We' ve even run down the peoplc to tell authorities, but nothin� mucl� has ever happcned except that we have our power down for 9 or ] 0 hours. I can ouly imaaine �chat this situation will be like if E�traction is able to put 24 wells in directly north of my property. Truck tralfic �vill greatly i��crcase right in front of my property and my dad' s house. I heard that Extraction promised the Triple Creek neighbors on the west side of Grecley that they would put in pipelines to pipe [he oil out, but now that the price of oil has droppcd. the}' won' t do it. We can' [ [rust that this company will come throtigh on a promise to be piping the product out of the Vetting site either. "Chey can � t even keep the weeds cut! Without pipelines there would be too many trucks coming and going every day during the drilling and co�upletion stage of the project. At the County Planning Coinmission hearii�g June 7, Blane Thinglestad, tl�e petroleum engineer for �xtraction, said the two major phases would take about 240 days each but later, during the sau�e hearing, he said it could take up to 325 days each. This is almost two full years of high volume oil field truck Craftic ! � Also, E. 24th Street, east of Cherr}� Avenue, the unimprovcd road is too narrow to accommodate heavy truck traffia lt has potholes, has no paverncnt markings, and does not have enough room to designate lanes. The City of Grcelcy just put recycled asphalt down, and this has helped keep the dust down, but it really wasn 't even i paced. 1 worked for 17 ycars for the City of Lvans in the Street department, and I know ihat tl�e cxisling road � is below standard for this kind of I�eavy truck traffic . It' s dangerous to have even two cars pass each other on this road, let alone irucks ! Extraction has gone back and forth oi� how they' would access this site, from Cherry or old highway 3dt, but the idea of all this truck traffic just �von ' t work. I don ' t want to hear more promises about how they will make good on this — again, the}' aren ' t cven taking care of the weed problem. l�ll in all, the peace and quiet of this beautiful agriculwral neighborhood ti�ill be changed forever. It' s not only about the roads, iC s the lifc my Camil}� and neighbors ha��e enjoyed for dccades that will be scarred i forever. Extraction will come and go, but the destruction of the peace and beauty of this area will be gone forever. Please consider my thoughts before you accept this permit. I truly appreciate your consideration. Thank you. Alan Herman 1321 E. 24th Street, Greeley, CO 80631 Tisa Juanicorena From: Sent: To: Subject: Attachments: Esther Gesick Tuesday, June 21, 2016 5:01 PM Tisa Juanicorena FW: Vetting/Bella wells--USR 16-0009 Limit Noise to Boost Your Childs Brain Power.docx; noise.a danger to our children.doc; Have You Heard.Noise Can Affect Learing.docx; ATT00001.txt; FossilFumes.pdf; ATT00002.txt From: Maydean Worley [mailto:mamworl@gmail.com] Sent: Tuesday, June 21, 2016 4:39 PM To: Esther Gesick <egesick@co.weld.co.us> Subject: Vetting/Bella wells--USR 16-0009 My suggestion is that drilling noise would greatly reduce students ability to learn, especially second language learners. 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'�'�} N-�Jf11�''L�i�=G . a9b�^t�R ' � � ..� � 4C6 ` �� .^��1�..� J. ,.� '.� y�v;�(-` �• I� 4. { � P n . f 11 . _ \� � TASK FORCE Alliance of Nurses for Healthy Environments Fossil Fumes: A public health analysis of toxic air pollution from the oil and gas industry Lead Author Lesley Fleischman, Clean Air Task Force Contributing Authors Jonathan Banks, Clean Air Task Force John Graham, Clean Air Task Force Supported by: CLEAN AIR TASK FORCE Alliance of Nurses for Healthy Environments EARTHWORKS © JUNE 2016 This report is available online at: http://www.catf.us/resources/publications/view/221 Contents: Page f 2 Abbreviations 3 Executive Summary 6 Introduction 6 7 8 The National Air Toxics Assessment (NATA) Toxic Emissions Sources in the Oil and Gas Industry Pollutants 10 Results 10 National 11 Pennsylvania 12 Texas 13 Colorado 14 Further Considerations for NATA Results 16 Technologies and Practices to Reduce Toxic Pollution 18 Appendix 18 A: Counties with Cancer and/or Respiratory Health Risk above EPA's Level of Concern: In order of population from most populous to least populous 20 B: Counties with Cancer and/or Respiratory Health Risk above EPA's Level of Concern: By State 21 C: Calculating 2017 Cancer and Respiratory Health Risk 24 References Figures and Tables: Page ammi 2 Map ES -1: National Map of Risk Level by County 3 Table ES -1: List of Oil and Gas Hazardous Air Pollutants 4 Table ES -2: List of High Risk Counties 9 Map 1: National Map 10 Map 2: Pennsylvania Map 11 Map 3: Texas Map 12 Map 4: Colorado Map 14 Map 5: Intra-County Variation: Weld County, Colorado 14 Map 6: Intra-County Variation: Bradford County, Pennsylvania Clean Air Task Force Fossil Fumes 1 Abbreviations HAP Hazardous Air Pollutant LDAR Leak Detection and Repair NATA National Air Toxics Assessment NEI National Emissions Inventory PM Particulate Matter RfC Reference Concentration URE Unit Risk Estimate VOC Volatile Organic Compound Clean Air Task Force Fossil Fumes 2 Executive Summary As the United States works toward implementing ambitious climate goals, methane pollution from the oil and gas supply chain has received increased attention, and for good reason — methane is a greenhouse gas 87 times more potent than carbon dioxide in the near term, and the oil and gas industry is the largest U .S. source of inethane pollution . But methane is just one harmful air pollutant from the oil and gas industry. This report sheds light on the health impacts of hazardous and toxic air pollutants that are often emitted from oil and gas sites alongside methane, including benzene, formaldehyde, and ethylbenzene. These hazardous toxic air pollutants harm the health of people living near oil and gas facilities such as oil and gas wells, compressor stations, and processing plants. This report presents estimates, based on recent analysis carried out by EPA, of the cancer risk and respiratory health risk to residents of every county in the United States that can be traced back to air toxics from the oil and gas industry. Specifically, the analysis here is based on EPA's most recent National Air Toxics Assessment ( NATA) analysis updated to reflect the latest emissions data from EPA's National Emissions Inventory ( NEI) . Map ES-1 : National Map of Risk Level by County a � • . li . . i . . . , . . � , � • ,� . . - . . . . �� . , .. . . . . . , Hlgher Risk The 238 counties that face cancer risk above EPA's 1-in-a-million level of concem are red , or dark red. Above EPA's Level of , Concern Lo+ver Risk Clean Air Task Force Fossil Fumes 3 The analysis finds: • 238 counties in 21 states face cancer risk that exceeds EPA's one -in -a -million threshold level of concern; • These counties have a population of over 9 million people; • 43 counties face a risk that exceeds one in 250,000 and 2 counties face a cancer risk that exceeds one in 100,000; • 32 counties also face a respiratory health risk from toxic air emissions that exceeds EPA's level of concern (hazard index > 1); and • The areas with the greatest health risk are generally located in states with the greatest amount of oil and gas infrastructure including Texas, Louisiana, Oklahoma, North Dakota, Pennsylvania, and Colorado. The NATA assessment only takes into account the health impacts related to toxic air emissions from the oil and gas industry, i.e. it does not account for the health impacts from particulate matter and ozone - related air emissions, and it does not account for the health impacts of water contamination caused by oil and gas development. As such, NATA is an underestimate of the full health impact of oil and gas operations. Table ES -1: List of Oil and Gas Hazardous Air Pollutants Hazardous Air Pollutant Tons Emitted Per Year from Oil and Gas Industry Health Impacts Formaldehyde 22,082 Cancer and respiratory symptoms Benzene 20,221 Cancer, anemia, brain damage and birth defects, and respiratory tract irritation Acetaldehyde 3,863 Cancer and respiratory irritant Ethyl Benzene 2,235 Respiratory and eye irritation, and blood and neurological disorders Hazardous air pollution is emitted from dozens of types of equipment and processes throughout the oil and gas sector, such as wells, completion operations, storage tanks, compressors, and valves. Many proven, low-cost technologies and practices are available to reduce these emissions, while also reducing emissions of methane, the main constituent of natural gas. Thus, policies that aim to reduce pollution from the oil and gas industry will help protect the health of local communities while addressing global climate change. In their Waste Not report, CATF, the Natural Resources Defense Council, and the Sierra Club called for EPA regulations to cut methane emissions from the oil and gas industry by 50 percent. These methane standards would also significantly cut toxic hazardous air pollution. In addition, stringent standards specifically for toxic pollutants emitted throughout the oil and gas supply chain are also needed to ensure compliance with the Clean Air Act and to protect public health. Clean Air Task Force Fossil Fumes 4 Table ES-2: List of High Risk Counties * : Also above EPA level of concern for Respiratory Hazard Counties with Cancer Risk Above 1 in 100,000 Risk (county-wide average respiratory hazard index is equal ITX, Gaines* TX, Yoakum* to or greater than 1). Counties with Cancer Risk Ahove 1 in 250,000 CO, Weld ND, Mountrail TX, Crane* TX, La Salle TX, Ward * WV, Lewis* LA, De Soto ND, Williams TX, Crockett* TX, Martin* UT, Duchesne* WV, Lincoln LA, Lafourche NM, Lea TX, Dawson* TX, Midland * UT, Uintah * WV, Mingo* LA, West Baton Rouge OK, Coal* TX, Ector* TX, Mitchell WV, Calhoun* WV, Ritchie* ND, Divide TX, Andrews* TX, Glasscock* TX, Reagan* WV, Doddridge* WV, Tyler ND, Dunn TX, Borden* TX, Hockley* TX, Scurry WV, Gilmer* WV, Wetzel ND, McKenzie TX, Cochran* TX, Kames TX, Upton* WV, Harrison Counties above EPA Level of Contem for Cancer Risk (County-wide average cancer risk is equal to or greater than 1 in 1 million) AR, Van Buren LA, Cameron OK, Beaver OK, Texas TX, Johnson TX, Upshur CO, Garfield LA, Claiborne OK, Beckham OK, Washington TX, Kent TX, Webb CO, La Plata LA, East Feliciana OK, Blaine OK, Washita TX, King TX, Wheeler CO, Phillips LA, Jackson OK, Caddo OK, Woods TX, Lavaca TX, Wilson CO, Rio Blanco LA, La Salle OK, Carter PA, Armstrong TX, Lee TX, Winkler* CO, Yuma LA, Morehouse OK, Cotton PA, Clarion TX, leon TX, Wise* ID, 8ear Lake LA, Ouachita OK, Custer PA, Fayette TX, Liberty TX, Zapata IL, Clay LA, Red River OK, Dewey PA, Forest TX, Limestone TX, Zavala IL, Crawford LA, St. James OK, Ellis PA, Greene TX, Live Oak VA, Appomattox IL, Edwards LA, Terrebonne OK, Garvin PA, Indiana TX, Loving VA, Buchanan IL, Fayette LA, Union OK, Grady PA, Jefferson TX, Lynn VA, Dickenson IL, Gallatin LA, Webster OK, Grant PA, Washington * TX, Madison WV, Barbour IL, Jasper MI, Montmorency OK, Harper TX, Bee TX, Marion WV, Boone IL, Lawrence MI, Otsego OK, Haskell TX, Burleson TX, Maverick WV, Braxton IL, Marion MS, Jasper OK, Hughes* TX, Caldwell TX, McMullen WV, Clay IL, Piatt M5, Wayne OK, Jefferson TX, Chambers TX, Montague WV, Jackson IL, Ri�hland MT, Fallon OK, Johnston TX, Colorado TX, Newton WV, Kanawha IL, Wabash MT, Richland OK, Kingfisher TX, DeWitt TX, Panola WV, Logan IL, Wayne MT, Roosevelt OK, Latimer TX, Dickens TX, Pecos WV, Marion IL, White MT, Sheridan OK, Lincoln TX, Dimmit TX, Refugio WV, Marshall KS, Woodson NC, Iredell OK, Love TX, Fayette TX, Roberts WV, McDowell KY, Floyd ND, Billings OK, Major TX, Fisher TX, Robertson WV, Pleasants KY, Johnson ND, Bottineau OK, Marshall TX, Freestone TX, Rusk WV, Putnam KY, Knott ND, Burke OK, McClain TX, Frio TX, Schleicher WV, Roane KY, Letcher ND, Golden Valley OK, Mclntosh TX, Garza TX, Shelby WV, Taylor KY, Magoffin ND, Renville OK, Nowata TX, Gonzales TX, Stephens WV, Upshur KY, Martin ND, Slope OK, Okfuskee TX, Gregg TX, Sterling WV, Wayne KY, Perry ND, Stark OK, Osage TX, Hardin TX, Stonewall WV, Wirt KY, Pike NM, Eddy OK, Pittsburg* TX, Harrison TX, Sutton * WV, Wyoming LA, Assumption NM, San Juan* OK, Pontotoc TX, Hemphill TX, Tarrant WY, Weston LA, Bienville OH, Carroll OK, Roger Mills TX, Howard TX, Terrell LA, Bossier OK, Alfalfa OK, Seminole TX, Irion TX, Terry LA, Caddo OK, Atoka OK, Stephens TX, Jasper TX, Tyler Clean Air Task Force Fossil Fumes 5 Introduction The National Air Toxics Assessment ( NATA) In December 2015, the U .S. Environmental Protection Agency ( EPA) released the results of its National Air Toxics Assessment (NATA) for 2011, based on air pollution estimates collected through the National Emissions Inventory ( NEI) . 1 The purpose of NATA is to identify and prioritize air toxics, emission source types, and locations that are of greatest potential concern when looking at overall health risk in populations . NATA calculates risk estimates for two types of health impacts that can result from toxic air emissions: cancer risk and respiratory health risk. The metric for cancer risk is the number of cancer cases per million people exposed; areas with cancer risk above 1-in-a-million are considered to be above EPA's level of concern . For respiratory health risk, the metric is the hazard index; areas with a respiratory hazard index above 1 are above EPA's level of concern for potential harm to the respiratory system, including breathing problems, harm to the lungs, or other respiratory diseases. Details of the National Air Toxics Assessment The 2011 NATA represents the fifth installment of the national assessment, building on earlier years of 2005, 2002, 1999 and 1996. Each update included improved modeling protocols and expanded coverage of hazardous air pollutants (HAPs). The 2011 NATA modeled 180 air toxi� �ompounds from dozens of separate emissions sources, including point sources (large, distinct facilities such as power plants), non-point (the large number of dispersed smaller facilities), various classes of vehicles, non-road mobile sources (such as construction equipment), fires, and biogenic sources, including species formed in the atmosphere and transported from distant emissions regions. These emission data were collected as part of the NEI. Then, NATA estimated both the cancer and non-cancer effects of 138 air toxics (for which health data based on chronic exposure exists). The 2011 NATA relies on two air quality models, AMS/EPA Regulatory Model and Community Model for Air Quality, to determine the ambient disiribution of air toxics. The models incorporate emissions information with meteorological data to determine the dispersion of pollution and chemical transformations that result in estimated annual concentrations at the census tract level across the United States. The modeled ambient concentrations are then used in an exposure model to estimate population exposure to the pollutants. The EPA developed NATA to inform national and local data collection and policy efforts. However, the agency emphasizes that because of data quality issues and uncertainties in the model, the data should be used cautiously—it should be used to screen for geographic areas with high risk, not as a measure of actual risk in specific locations.' In addition, there are other limitations including incomplete assessment of emissions, limited ability to evaluate threats to vulnerable populations, and reliance on potentially outdated health thresholds. ' In this study, we focus on toxic air pollution sources in the oil and gas industry, and we explore the health impacts of these emissions in the latter sections of this report. This assessment characterizes potential public health risk due to inhalation of air toxics including both cancer risk and respiratory health risk. This report focuses on toxic air emissions from the oil and gas industry: oil and natural gas production and natural gas processing, transmission, and storage, including major sources like large compressor stations and gas processing plants, and dispersed sources like wells.' The results presented here are ` Throughout this report, we refer to 2 types of oil and gas sources: major sources and dispersed sources. Major sources are also known as "point" sources; these sources have the potential to emit 10 or more tons per year of one HAP or 25 or more Clean Air Task Force Fossil Fumes 6 estimates for the health risk from oil and gas that communities will face in 2017, based on the NATA report for 2011 and EPA's predictions of the changes in the level of HAPs released by oil and gas sources between 2011 and 2017 (see Appendix for a discussion of our methodology). Toxic Emissions Sources in the Oil and Gas Industry Raw natural gas (i.e., gas as it is produced from underground formations, before significant processing is done) usually contains significant amounts of volatile organic compounds (VOCs) and toxic hazardous air pollutants (HAPs), though gas varies in composition from source to source.4 The HAPs in raw gas include hexane, benzene, and other aromatic chemicals; poisonous gases like hydrogen sulfide can also be present! These pollutants are also emitted from crude oil production operations. Recent work indicates that emissions from oil and gas operations are resulting in concentrations of toxic HAPs that could harm the health of people living and working in and near oil and gas production areas.' While natural gas processing plants separate much of the toxic components from raw natural gas, some of those pollutants remain in the gas even after processing. As such, emissions from facilities further downstream in the natural gas supply chain, like transmission compressor stations and local distribution equipment, still include some toxic pollutants. There are four segments of the oil and gas industry, and hazardous toxic air pollutants are emitted from each one, though in varying amounts: Oil and Gas Production: The oil and gas production segment includes many diverse activities, such as production of hydrocarbons from underground geologic formations; separation of natural gas, oil, and, water; and collection of gas from multiple wells through natural gas gathering pipeline and compressor systems. These activities in turn involve processes such as well drilling, hydraulic fracturing or other well stimulation, and well workovers; and they require equipment such as tanks, piping, valves, meters, separators, dehydrators, pipelines, and gathering compressors. Natural Gas Processing: Gas processing plants separate raw natural gas into natural gas liquids and processed natural gas that meets specifications for transport in high-pressure pipelines and consumption in furnaces and power plants. Natural gas liquids are hydrocarbons such as propane, butane, etc., which are valuable products of gas processing. The processing removes most of the toxic components from the gas, but some toxics still remain. Transmission and Storage: Natural gas transmission pipelines carry gas from production regions to markets. This segment also includes facilities where gas is stored, either underground or in tanks. Compressor stations along pipelines maintain pressure and provide the energy to move the gas. tons per year of some combination of HAPs. Dispersed sources are also known as "non -point" sources; these sources are expected to emit less HAPs than sources emitting above these thresholds. See https://www3.epa.gov/region 1/eco/airtox/glossary.html. ' Hydrogen sulfide is not included in EPA's list of Hazardous Air Pollutants due to a directive from Congress. See https://www3.epa.gov/airtoxics/pollutants/atwsmod.html. This does not reflect a determination that hydrogen sulfide does not have toxic properties. Clean Air Task Force Fossil Fumes 7 Natural Gas Distribution: Finally, natural gas is delivered to customers (residential, commercial, and light industrial) via low-pressure underground distribution pipelines. Pollutants Natural gas development and transmission release a host of pollutants—toxics, smog forming pollutants, and greenhouse gases —that take a toll on our environment and our health. In this analysis, we focus specifically on toxic air pollutants, i.e. those pollutants that are known or probable carcinogens or that cause other serious health problems through either short-term or long-term exposure.6 More specifically, we focus on the toxic air pollutants that are responsible for elevated cancer risk and increased respiratory hazard. The pollutants of greatest concern are benzene, ethylbenzene, and formaldehyde. Benzene: Benzene has been linked to cancer, anemia, brain damage, and birth defects, and it is associated with respiratory tract irritation.' Over time, benzene exposure can also lead to reproductive, developmental, blood, and neurological disorders. A 2012 study estimated a 10 in a million cancer risk for residents near a well pad, attributable primarily to benzene.8 According to the NEI, over 20,000 tons of benzene was emitted by oil and gas sources, accounting for 32 percent of the elevated cancer risk and 19 percent of the increased respiratory health risk from the oil and gas industry (see Appendix C). Benzene is a constituent of raw natural gas, so leaks and deliberate releases of gas (venting) are the primary source of benzene pollution from the oil and gas industry. Ethylbenzene: Exposure to ethylbenzene has been associated with respiratory and eye irritation, as well as blood and neurological disorders.9 Over 2,000 tons of ethylbenzene was emitted by oil and gas sources, accounting for 71 percent of the increased respiratory health risk from oil and gas. Like benzene, ethylbenzene is a constituent of raw natural gas and leaks and venting sources are the primary sources of ethylbenzene. Formaldehyde: Formaldehyde has been linked to certain types of cancer, and chronic exposure to it is known to cause respiratory symptoms.10 Nearly 22,000 tons of formaldehyde was emitted by oil and gas sources, accounting for 59 percent of the elevated cancer risk and 7 percent of the increased respiratory health risk from oil and gas. Formaldehyde is primarily emitted from combustion sources such as flares and compressor engines.* Other oil and gas industry toxic pollutants were also emitted in lower amounts, including acetaldehyde (a probable carcinogen and respiratory irritant"), 1,3 -butadiene (increases risk of cancer and cardiovascular diseases12), and polycyclic organic matter (a carcinogenl3) t In addition to being directly emitted from oil and gas engines and flares, a much larger amount of formaldehyde is formed when other pollutants from oil and gas (VOCs) are broken down in the atmosphere. However, the NATA process does not attribute this second, larger quantity of formaldehyde to oil and gas. Therefore, NATA underestimates the impacts from oil and gas formaldehyde. Clean Air Task Force Fossil Fumes 8 Some of this pollution is emitted from major facilities like gas processing plants and large compressor stations. But the majority of this pollution comes from the large number of dispersed smaller facilities located, such as well sites, tank batteries, and small compressor stations, in communities throughout the country. In 2011, on a toxicity weighted basis, cancer risk from oil and gas is 41% from major facilities and 59% dispersed facilities. Respiratory health risk is 13% from major facilities and 87% from dispersed facilities. Clean Air Task Force Fossil Fumes 9 Results National Using projections of toxic air emissions from EPA's National Emissions Inventory ( NEI ) for 2017, we estimate that 238 counties in 21 states face cancer risk above EPA's 1-in-a-million level of concern due to toxic emissions from oil and gas operations ( National Map) . Of these counties, 43 counties face a risk that exceeds one in 250,000 and 2 counties face a cancer risk that exceeds one in 100,000. In addition, 32 of these counties will also face an elevated respiratory health risk from toxic air emissions. �� The total population of the counties above EPA's level of concern is over 9 million (see Appendix A) . The areas with the greatest health risk are generally located in states with the largest amount of oil and gas infrastructure including Texas, Louisiana, Oklahoma, North Dakota, Pennsylvania, and Colorado, and they include cities such as Fort Worth, Texas; Shreveport, Louisiana; Greeley, Colorado; and Charleston, West Virginia . Map 1 : National Map � • � . . � : � . � . � . # . ; . � . . . � r . „ � - . . . , HIghO� RiSk The 238 counties that face cancer risk above EPA's 1-in-a-million level of concern are red , or dark red. Above EPA's Level of , Concem Lower Risk " The U.S. EPA considers cancer risks over one-in-a-million, or a respiratory hazard index greater than 1, to be above its level of concern. Clean Air Task Force Fossil Fumes 10 Pennsylvania According to the NEI, over 1,300 tons of hazardous toxic air pollution —benzene, formaldehyde, and acetaldehyde—were emitted by oil and gas facilities in Pennsylvania . Furthermore, oil and gas production has increased significantly in Pennsylvania since 2011; oil production increased by 112 percent between 2011 and 2015, and natural gas production increased by 264 percent.1° As a result, toxic air pollution from the oil and gas industry is becoming a greater and greater concern, and it is important to incorporate EPA's projections of emissions growth between 2011 and 2017 emissions into the analysis. Based on EPA's projection of 2017 emissions, eight counties in Pennsylvania will face a high cancer risk due to toxic emissions from oil and gas operations—Armstrong, Clarion, Fayette, Forest, Greene, Indiana, Jefferson, and Washington counties. The counties above EPA's level of concern have a population of over 625,000. ( Pennsylvania Map) . Map 2 : Pennsylvania Map � : __ Y �� r r ;:: -.n -�,; � -. �..� . . � � � � . �, � � . � r�••...�.��.�� ,,,� ' � �� . . . . . • _ - . , Highef Risk The 8 counties that face cancer risk above EPA's 1-in-a-million level of concern are red or dark red . , Above EPA's Level of , Concern Lo�ver Risk Clean Air Task Force Fossil Fumes 11 Texas According to the NEI, over 8,500 tons of hazardous toxic air pollution — benzene, formaldehyde, and acetaldehyde—were emitted by oil and gas facilities in Texas. Oil production has increased significantly in Texas— by 139 percent between 2011 and 2015, and natural gas production has grown moderately— by 11 percent.ls Accordingly, EPA projects that the volume of benzene, formaldehyde, and acetaldehyde emissions from oil and gas operations in Texas will grow 136% between 2011 and 2017. Based on that projection, 82 counties in Texas will face elevated cancer risk due to toxic emissions from oil and gas operations ( up from 50 counties in 2011) . The 82 counties above EPA's level of concern have a population of over 4. 1 million (Texas Map) . Map 3: Texas Map � �� '}Tai�. � • . . . � � �� ■�� f�.- M�r �� n � �� ■�■ ■ � ■�� ■ ■ � ; �r�� r� � � ''��■� ��.�� a��♦� � �� `� �� 1 � � , . . � � � ��i , � � ��L�� .: 1 � •� \ Hiqner Risk The 82 counties that face cancer risk above EPA's 1-in-a- � million level of concern are red or dark red. Above EPA's Level of � Concem Lower Risk Clean Air Task Force Fossil Fumes 12 Colorado According to the National Emissions Inventory, over 3,300 tons of hazardous toxic air pollution — benzene, formaldehyde, and acetaldehyde—were emitted by oil and gas facilities in Colorado. Oil production has increased significantly in Colorado — by 202 percent between 2011 and 2015, and natural gas production has stayed approximately level . 16 Based on EPA's projection of 2017 emissions, six counties in Colorado will face elevated cancer risk due to toxic emissions from oil and gas operations—Garfield, La Plata, Phillips, Rio Blanco, Weld, and Yuma. The counties above EPA's level of concern have a population of over 410,000 ( Colorado Map) . Map 4: Colorado Map - r � r _ f _ _ i � ' JI _ _ � , i�'^f. . •�� '�I IIILI � � �!III `_ �JJII � � � � � . � • �� • � � G� • � � � �� \ Higher Risk The 6 counties that face cancer risk above EPA's 1-in-a-million level of , concern are red or dark red. Abeve EPA's Level of , Concern Lo�ver Risk Clean Air Task Force Fossil Fumes 13 Further Considerations for NATA Results NATA is an underestimate of overall health impact from oil and gas for a variety of reasons: • First, the results represent just a portion of the full impact of oil and gas operations on respiratory health: it only accounts for the respiratory health risk from toxic hazardous air emissions. Oil and gas infrastructure is also responsible for particulate matter (PM) emissions and emissions of chemicals that create ozone. Both PM and ozone exacerbate respiratory diseases, including asthma and chronic lung disease, but these risks are not included in the current analysis. Silica dust from hydraulic fracturing and sand mining operations can also cause lung diseases. • Second, NATA only accounts only for risk associated with inhalation of these pollutants —the exposure risks from water contamination may also be relevant for communities living near oil and gas facilities. • Third, we only included health impacts directly associated with oil and gas facilities. Oil and gas development may also entail increased truck traffic and changes in land use, neither of these are accounted for in the present analysis. • Finally, NATA and the inventories it relies on may underestimate the total emissions of toxics from oil and gas.17 The geographic distribution of health impacts changed between 2011 and 2017, while the total number of counties with elevated cancer risk grew from 206 in 2011 to 238 in 2017. These changes follow the growth or decline of the oil and gas industry in different geographical areas, but the industry grew in many more locations than it shrank, as it grew nationwide. For example, the 2011 data indicates that 50 counties in Texas had elevated cancer risk, while 82 Texas counties will face elevated risk in 2017. In addition, there are many communities affected by oil and gas toxic air pollution that are missed when we look only at county -level risk results. In many places, the county -level average impact may be moderate, but individuals living in close proximity to oil and gas infrastructure will face elevated risk of both cancer and respiratory hazard.tt NATA did present data on health impacts for geographical units smaller than counties (census tracts), but because of data limitations, we were not able to produce estimates of health impacts at the census tract level for 2017 (see Appendix C). However, census tract level data does demonstrate that some areas within counties experience higher impacts than the county as a whole. Two counties illustrate this: • In Weld County, Colorado, there is a high overall county -wide cancer risk from oil and gas sources. Within the county, there are 77 individual census tracts, and the cancer risks calculated in those tracts range from 1/5th of the county average to over 3 times the county average -22 census tracts have a risk above the county average and 55 have a risk that is lower than the county See Oil and Gas Threat Map for more on population living in close proximity to oil and gas infrastructure. Available at: http://oilandgasthreatmap.com/. Clean Air Task Force Fossil Fumes 14 average. However, even among the tracts below the county average, all but one still have a cancer risk above EPA's level of concern . (Weld County Map) Map 5 : Intra-County Variation in Cancer Risk: Weld County, Colorado � c ' Note: Tract level assessments based solely on 2011 data for non-point source emissions, and do not include point sources and growth of emissions from 2011 to 2017. • In Bradford County, Pennsylvania, the average county-wide cancer risk from oil and gas sources is below EPA's level of concern . However, one census tract in the western part of the county does have a cancer risk above EPA's level of concern, and other tracts may also have a higher risk if major sources and the 2017 emissions projections were taken into account. ( Bradford County Map) Map 6: Intra-County Variation in Cancer Risk: Bradford County, Pennsylvania �- � � _ I � � � � � � .�t��j� � ��1�� Note: tract level assessments based solely on 2011 data for non-point source emissions, and do noT include point sources and growth of emissions from 2011 to 2017. Clean Air Task Force Fossil Fumes 15 Technologies and Practices to Reduce Toxic Pollution As outlined in the 2014 report Waste Not, readily -available technologies and practices can cut methane emissions dramatically in just a few years.18 These technologies and practices will reduce the total amount of natural gas that leaks and is released from facilities throughout the oil and gas supply chain. Thus, these policy recommendations will also reduce emissions of hazardous toxic air pollutants from the oil and gas industry. As such, these measures would have important benefits for air quality and public health in and downwind of oil and gas producing areas. • Finding and Fixing Leaks: Unintentional leaks of natural gas from static components such as connectors, valves, regulators, and hatches throughout the oil and natural gas sector are widespread. Leaks will eventually occur at all oil and gas facilities; failing to fix them in a timely manner is a wasteful and harmful practice that leads to clearly avoidable emissions. Leak emissions can be reduced with rigorous leak detection and repair (LDAR) programs. These programs require frequent, regular surveying of facilities for leaks using instruments that detect methane and other hydrocarbons in natural gas. • Reducing or eliminating venting from natural gas -driven pneumatic equipment: Gas -driven pneumatic equipment uses the pressure energy of natural gas in pipelines to do work, such as control, open, and shut valves, or operate pumps. This equipment is ubiquitous at oil and gas facilities, and emits natural gas to the atmosphere by design. Replacing high -emitting pneumatic equipment with low- or zero -emitting equipment will greatly reduce toxic emissions. • Controlling Emissions from Oil and Condensate Storage Tanks: Storage tanks are used to hold oil, condensate, and produced water from oil and gas wells. During normal operations, toxic pollutants such as benzene, methane, and other light hydrocarbons separate from the liquids and, if not controlled, vent into the atmosphere. Tanks are a very large source of toxic air pollutants — we estimate that tanks are emitting over a quarter of the toxic pollutants from the oil and gas industry.tt Control measures such as vapor recovery units (small compressors which capture these vapors and inject them into natural gas pipelines) can greatly reduce emissions of these toxic pollutants. • Reducing Compressor Seal Emissions: Seals on the moving parts of natural gas compressors are a significant source of preventable toxic emissions. These emissions can be very large when the seals are not regularly maintained or replaced, and when operators use older designs for certain compressors. Fortunately, these emissions can easily be reduced or eliminated by employing a mix of modern seal design, capture of gas that escapes from seals so it can be utilized, and proper maintenance practices. • Reducing Dehydrator Venting: Dehydrators remove water from the natural gas stream. When their emissions are not controlled, dehydrators vent large amounts of pollution alongside the $$ Calculations based on the US GHG Inventory and ratios of voC to methane and toxic air pollutants to methane from various emission streams from US EPA Regulatory Impact Statement. Clean Air Task Force Fossil Fumes 16 water they are intended to remove. They are very large source of toxic air pollutants — dehydrators are the source of about a third of the entire oil and gas industry's toxic air emissions .§§ There are a number of approaches to reducing emissions from dehydrator venting, such as adjusting circulation rates of the glycol fluid; routing the vent gas to a burner used to heat the glycol, so toxics are combusted; and routing emissions to a flare or incinerator. • Reducing venting from oil wells: Venting of gas during completion of oil wells, following hydraulic fracturing, can be a significant source of toxics. In 2012, EPA established standards to address emissions from gas wells during flowback after hydraulic fracturing or re -fracturing requiring operators to flare or capture the gas,*** and in 2016, EPA issued standards that will extend this requirement to hydraulically fractured oil wells.19 Some oil well operators also vent off the "casinghead" natural gas, which they may consider to be an unwanted by-product of oil production; this venting is another significant source of toxics. • Reducing venting from gas wells during liquids unloading: When water from the underground formations that produce gas accumulates in a mature gas well, it can slow or stop gas production from that well. In order to maintain production, operators remove, or "unload", liquids through a variety of methods, some of which vent natural gas to varying degrees. While a variety of technologies and practices can reduce or eliminate this venting and the resulting pollution, some operators forego these proven, affordable approaches and crudely "blow down" the well by opening it to the atmosphere. This approach is inefficient, as it vents large quantities of gas, including toxics, while only removing a small portion of the liquids in the well.2° §§ Calculations based on the US GHG Inventory and the ratio of toxic air pollutants to methane from various emission streams from US EPA Regulatory Impact Statement When a well (gas or oil) is hydraulically fractured, large volumes of water and other substances are pumped down the well to break up (fracture) the rock holding the gas / oil. After fracturing is completed, the water is allowed to flow back to the surface during the "flowback" phase of well completion. Natural gas, including toxic species like benzene, from the fractured rock mixes in with this water, and if not controlled, will be vented into the air. Clean Air Task Force Fossil Fumes 17 Appendix A. Counties with Cancer and/or Respiratory Health Risk above EPA's Level of Concern : In order of population from most populous to least populousZl State County Z�14 State County Z�14 State County 2014 population population population TX Tarrant 1,945,360 PA Greene 37,843 LA East Feliciana 19,813 CO Weld 277,670 OK Mdlain 37,313 TX Freestone 19,762 TX Webb 266,673 UT Uintah 36,867 TX Lavaca 19,721 LA Caddo 252,603 TX Howard 36,651 TX Gaines 19,425 PA Washington 208,187 TX lasper 35,552 TX Montague 19,416 WV I<anawha 19Q223 WV Logan 35,348 IL Crawford 19,393 NC Iredell 166,675 OK Lincoln 34,619 TX Frio 18,531 7X Johnson 157,456 TX eee 32,863 TX Andrews 17,477 LA Ouachita 156,325 WV Marshall 32,416 TX Scurry 17,328 TX Midland 155,830 ND Williams 32,130 TX Burleson 17,253 TX Ector 153,904 ND Stark 30,372 WV Taylor 17,069 PA Fayette 134,086 OK Custer 29,500 TX Leon 16,861 LA Bossier 125,064 OK Caddo 29,317 AR Van Buren 16,851 NM San Juan 123,785 WV Jackson 29,126 WV Barbour 16,766 TX Gregg 123,204 OH Carroll 28,187 T% Lee 16,742 LA Terrebonne 113,328 KY Perry 27,597 MS Jasper 16,601 LA Lafourche 98,020 OK Garvin 27,561 IL Wayne 16,543 PA Indiana 87,706 LA De Soto 27,142 IL Lawrence 16,519 TX Liberty 78,117 LA Morehouse 26,760 TX Robertson 16,500 NM Lea 69,999 WV Mingo 25,716 IL Piatt 16,431 WV Harrison 68,761 TX Shelby 25,515 WV Lewis 16,414 PA Armstrong 67,755 OK Seminole 25,421 LA Claiborne 16,412 TX Harrison 67,336 LA West Baton OK Marshall 16,182 25,085 KY Pike 63,034 Rouge IL Richland 16,061 TX Wise 61,638 TX Fayette 24,833 LA Jackson 15,994 CO Garfield 57,461 WV Upshur 24,731 WV Wetzel 15,988 TX Maverick 57,023 MI Otsego 24,158 TX Pecos 15,893 WV Marion 56,803 TX Panola 23,769 KY Knott 15,892 WV Putnam 56,770 WV Boone 23,714 OK Kingfisher 15.532 NM Eddy 56,395 OK Beckham 23,691 VA Dickenson 15,308 TX Hardin 55,621 TX Hockley 23,577 VA Appomattox 15,279 CO La Plata 53,989 TX Limestone 23,524 TX Karnes 14,906 TX Rusk 53,923 KY Letcher 23,359 LA La Salle 14,839 OK Grady 53,854 KY lohnson 23,262 WV Roane 14,664 OK Washington 51,937 VA Buchanan 23,106 WV Braxton 14,463 OK Carter 48,821 LA Assumption 23,034 IL White 14,374 OK Osage 47,981 WV Wyoming 22,598 TX Zapata 14,319 TX Wilson 46,402 LA Union 22,539 TX Newton 14,138 PA Jefferson 44,638 IL Payette 21,870 LA Bienville 13,885 OK Pittsburg 44,626 OK Texas 21,853 TX Madison 13,861 OK Stephens 44,493 LA St. James 21,638 OK Hughes 13,806 WV Wayne 41,122 WV Lincoln 21,561 OK Atoka 13,796 TX Upshur 40,354 TX Tyler 21,418 IL Clay 13,520 LA Webster 40,333 TX Colorado 20,719 TX Dawson 13,372 TX Caldwell 39,810 TX DeWitt 20,684 KY Magoffin 12,913 PA Clarion 35,821 MS Wayne 20,490 OK Haskell 12,896 IL Marion 35,571 TX Gonzales 20,462 T% Terry 12,739 TX Chambers 35,145 WV MCDowell 20,448 KY Martin 12,537 KY Floyd 38,108 UT Duchesne 20,380 TX Zavala 12,267 OK Pontotoc 38,005 OK Mcintosh 20,088 OK Okfuskee 12,186 Clean Air Task Force Fossil Fumes 18 State County 2014 population TX Live Oak 12,091 TX Ward 11,625 MT Richland 11,576 IL Wabash 11,549 OK Washita 11,547 MT Roosevelt 11,332 OK Johnston 11,103 TX Dimmit 11,089 ND McKenzie 10,996 OK Latimer 10,693 OK Nowata 10,524 CO Yuma 10,202 TX Marion 10,149 WV Ritchie 10,011 OK Blaine 9,917 ND Mountrail 9,782 OK Love 9,773 IL Jasper 9,623 TX Stephens 9,405 MI Montmorency 9,300 OK Woods 9,288 WV Tyler 9,098 TX Mitchell 9,076 WV Clay 8,941 LA Red River 8,669 WV Gilmer 8,618 WV Doddridge 8,391 TX Yoakum 8,286 TX Winkler 7,821 OK Major 7,750 State County 2014 population WV Pleasants 7,634 PA Forest 7,518 WV Calhoun 7,513 TX La Salle 7,474 TX Refugio 7,302 WY Weston 7,201 CO Rio Blanco 6,707 LA Cameron 6,679 ND Bottineau 6,650 IL Edwards 6,617 TX Garza 6,435 OK Jefferson 6,292 OK Cotton 6,150 ID Bear Lake 5,957 WV Wirt 5,845 OK Coal 5,807 OK Alfalfa 5,790 TX Lynn 5,771 TX Wheeler 5,714 OK Beaver 5,486 TX Martin 5,460 IL Gallatin 5,291 TX Crane 4,950 OK Dewey 4,914 OK Grant 4,501 ND Dunn 4,399 CO Phillips 4,363 TX Hemphill 4,180 OK Ellis 4,150 TX Sutton 3,972 State County 2014 population TX Fisher 3,831 TX Crockett 3,812 OK Harper 3,812 OK Roger Mills 3,761 TX Reagan 3,755 MT Sheridan 3,696 TX Upton 3,454 TX Schleicher 3,162 KS Woodson 3,157 MT Fallon 3,108 TX Cochran 2,935 ND Renville 2,587 ND Divide 2,432 ND Burke 2,245 TX Dickens 2,218 ND Golden Valley 1,825 TX Irian 1,574 TX Stonewall 1,403 TX Sterling 1,339 TX Glasscock 1,291 TX Roberts 928 TX Terrell 927 ND Billings 901 TX McMullen 805 TX Kent 785 ND Slope 765 TX Borden 652 TX King 262 TX Loving 86 TOTAL POPULATION 9,013,075 Clean Air Task Force Fossil Fumes 19 B. Counties with Cancer and/or Respiratory Health Risk above EPA's Level of Concern : ey State Arkansas Louisiana (cont.) Oklahoma (cont.) Texas (cont.) Texas (cont.) Van Buren Union Parish Harper Freestone Terry Colorado Webster Parish Haskell Frio Tyler Garfield West Baton Rouge Hughes Gaines Upshur La Plata Parish Jefferson Garza Upton Phillips Michigan Johnston Glasscock Ward Rio Blanco Montmorency Kingfisher Gonzales Webb Weld � Otsego Latimer Gregg Wheeler Yuma Mississippi Lincoln Hardin Wilson Idaho lasper Love Harrison Winkler BearLake Wayne Major Hemphill Wise Illinois Montana Marshall Hockley Yoakum Clay Fallon McClain Howard Zapata Crawford Richland Mclntosh Irion Zavala Edwards Roosevelt Nowata Jasper Utah Fayette Sheridan Okfuskee Johnson Duchesne Gallatin North Carolina Osage Karnes Uintah Jasper Iredell Pittsburg Kent Virginia Lawrence North Dakota Pontotoc King Appomattox Marion Billings Roger Milis La Salle Buchanan Piatt Bottineau Seminole Lavaca Dickenson Richland Burke Stephens Lee West Virginia Wabash Divide Texas Leon Barbour Wayne Dunn Washington Liberty Boone White Golden Valley Washita Limestone Braxton Kansas McKenzie Woods Live Oak Calhoun Woodson Mountrail Pennsylvania Loving Clay Kentucky Renville Armstrong Lynn Doddridge Floyd Slope Clarion Madison Gilmer Johnson Stark Fayetie Marion Harrison Knott Williams Foresi Martin Jackson Letcher New Mexico Greene Maverick Kanawha Magoffin Eddy Indiana McMullen Lewis Martin Lea Jefferson Midland Lincoln Perry SanJuan Washington Mitchell Logan Pike Ohio Texas Montague Marion Louisiana Wrroll Andrews Newton Marshail Assumption Parish Oklahoma Bee Panola McDowell Bienville Parish Alfalfa Borden Pecos Mingo Bossier Parish Atoka Burleson Reagan Pleasants Caddo Parish Beaver Caldwell Refugio Putnam Cameron Parish Beckham Chambers Roberts Ritchie Claiborne Parish Blaine Cochran Robertson Roane De5omParish Caddo Colorado Rusk Taylor East Feliciana Parish Carter Crane Schleicher Tyler Jackson Parish Coal Crockett Scurry Upshur La Saile Parish Cotton Dawson Shelby Wayne Lafourche Parish Custer DeWitt Stephens Wetzel Morehouse Parish Dewey Dickens Sterling Wirt Ouachita Parish Ellis Dimmit Stonewall Wyoming Red River Parish Garvin Ector Sutton Wyoming StJames Parish Grady Fayette Tarrant Weston Terrebonne Parish Grant Fisher Terrell Clean Air Task Force Fossil Fumes 20 C. Calculating 2017 Cancer and Respiratory Health Risk The results of our analysis are based on the modeled cancer and respiratory health risk presented by NATA in its 2011 risk assessment. We made two adjustments to this data to more fully reflect the true impact of the oil and gas industry: we incorporated EPA's data on toxic emissions from Oil and Gas "point" sources, and we updated the results using EPA's 2017 emissions inventory projection to estimate 2017 health impacts. The NATA results as presented only include non -point emissions sources in the oil and gas industry — these are the large number of relatively small and dispersed facilities and oil and gas activities, such as oil and gas well pads and smaller compressor stations. The cancer and respiratory health risk figures by tract, county, and state can be downloaded directly from the EPA website.22 These results represent the impact from non -point sources, which make up the majority of toxic emissions from the oil and gas industry. However, emissions from the less numerous but larger point sources are also significant. To determine the full impact of the oil and gas industry, we estimated the impact of emissions from oil and gas point sources and added that to the impacts from non -point sources. Since the NATA calculation of point source cancer and respiratory health risk lumps all industry segments together, we used the following methodology to estimate the cancer and respiratory health risk specifically from oil and gas point sources: • Download data from the National Emissions Inventory by pollutant for Oil and Gas Point sources and All Point sources by county.23 o Point source emissions are not available at the census tract level, so we could not do this analysis at the tract level. o As downloaded, the Oil and Gas Point Source data includes a number of facilities that we do not consider to be part of the natural gas supply chain. We removed a total of 11 facilities with the following "facility source descriptions": ■ Coke Battery ■ Electricity Generating via Combustion ■ Hot Mix Asphalt Plant ■ Landfill ■ Coal Gasification Plant ■ Gasoline/Diesel Service Station ■ Petroleum Refinery ■ Petroleum Storage Facility • (Note: we made similar adjustments to emissions in our 2017 inventory to keep the inventories consistent.) • For each point source data set (Oil and Gas, All) we multiply pollutant tonnage by pollutant toxicity to get the weighted sum of toxicity for each pollutant from each county. For cancer, we Clean Air Task Force Fossil Fumes 21 used Unit Risk Estimatettt ( URE) as an estimate of pollutant toxicity, and for respiratory health risk we used Reference Concentration### ( RfC) as an estimate of pollutant toxicity. The EPA uses the URE and RfC concepts in its dose-response assessments for chronic exposure to toxic air pollutants, and it periodically re-examines and updates the values for individual substances as knowledge improves.24 The same pollutant has a different impact on cancer and respiratory health, so we calculate two weighted toxicities, one for cancer and one for respiratory health risk. • For cancer risk, subtract out risk from Coke Ovens from All Point source risk, because EPA modeled emissions and impacts from coke ovens as a distinct source type.Zs • We can calculate the percent of point source cancer and respiratory toxicity in each county that are from oil and gas facilities by taking the ratio of weighted oil and gas emissions toxicity to weighted toxicity of emissions from all point sources. • Multiply this percentage by the total respiratory health risk or the total cancer risk minus risk from coke ovens. This is the estimate of cancer and respiratory health risk from oil and gas point sources. • Add the estimate of risk from oil and gas point sources to the cancer or respiratory health risk for oil and gas non-point sources that was presented directly by NATA. • This is the total estimate of 2011 oil and gas cancer or respiratory health risk. The total estimate of 2011 oil and gas cancer risk, as calculated using this methodology at the countywide level, averaged 24% higher than the risk from non-point sources alone. As a result of adding in oil and gas point sources, the number of counties exceeding the threshold of EPA's level of concern for cancer risk for 2011 increased from 106 to 206. Next, we know that the oil and gas industry has changed substantially between 2011 and today, both in terms of the volume of oil and gas being produced and the geographic distribution of oil and gas production . For example, oil production has increased 67 percent, from 2,058 million barrels in 2011 to 3,442 million barrels in 2015 .26 Gas production has increased 16 percent, from 38.48 trillion cubic feet in 2011 to 32 .96 trillion cubic feet in 2015 .Z� Thus, a risk assessment based on 2011 emissions does not accurately reflect the current realities of emissions from the oil and gas industry. We used NEI's 2017 projection of air toxic emissions to estimate cancer and respiratory health risk in 2017, and NEI's inventory of emissions in 2011, to estimate the change in risk between 2011 and 2017 . • We downloaded EPA's 2017 projection of toxic emissions by county for both oil and gas point and non-point sources.§44 """ "The upper-bound excess lifetime cancer risk estimated to result from continuous exposure to an agent at a concentration of 1 µg/m3 in air." See: https://www.epa.Rov/national-air-toxics-assessment/nata-Rlossarv-terms. ___ "The reference concentration is an estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups that include children, asthmatics, and the elderly) ihat is likely to be without an appreciable risk of deleterious effects during a lifetime." See: https://www.epa .Rov/nationa I-ai r-toxics-assessment/nata-Rlossa ry-terms. §§§ Using the 2011 NEI v2 as a starting point, the U.5. EPA developed a 20ll future case by projecting population and production growth as well as the impact of federal emissions regulations promulgated by December 2014. The emissions model used for this platform is the Sparse Matrix Operator Kernel Emissions (SMOKE) model version 3.7 commonly used by Clean Air Task Force Fossil Fumes 22 o 2017 projected toxic emissions are not available at the tract level, so this analysis cannot be done at the tract level • We calculated weighted toxicity for oil and gas in each county for both point and non -point sources (using same URE and RfC factors and method as above). To simplify analysis, we focused on only the most consequential pollutant species: benzene, formaldehyde, and acetaldehyde. These three pollutants account for 93% of national cancer risk and 27% of national respiratory hazard risk in the oil and gas sector (Note: ethyl benzene accounts for 71% of national respiratory hazard risk in the oil and gas sector, but it was not reported as a separate pollutant species in NEI's 2017 projections, so we did not include it in our analysis. However, ethyl benzene emissions will closely track benzene emissions, and benzene, which is reported separately in NEI's projection, makes up most of the remainder of the national respiratory hazard risk.) • For each county we compared total 2011 toxicity for the 3 pollutants (benzene, formaldehyde, acetaldehyde) to total 2017 toxicity for the 3 pollutants, and calculated percent increase or decrease for cancer and respiratory toxicity. • We multiplied this percent increase (or decrease) by the 2011 oil and gas risk estimate for both cancer and respiratory health risk. This is the 2017 risk estimate. As a result of the 2017 update, the number of counties exceeding the threshold of EPA's level of concern for cancer risk increased from 206 in 2011 to 238 in 2017. (60 counties shifted from below to above the threshold, while 28 counties fell from above to below the threshold as a result of the 2017 adjustment, for a net increase of 32.) the EPA for emissions processing. EPA, 2015. Technical Support Document (TSD), Preparation of Emissions Inventories for the Version 6.2, 2011 Emissions Modeling Platform. Office of Air Quality Planning and Standards, Air Quality Assessment Division. See: http://www3.epa.gov/ttn/chief/emch/index.html#2011. Clean Air Task Force Fossil Fumes 23 References US EPA. 2011 National Air Toxic Assessment. Available at: https://www.epa.gov/national-air-toxics-assessment/2011- national-air-toxics-assessment. 2 US EPA. National Air Toxics Assessment: NATA Limitations. Available at: https://www.epa.gov/national-air-toxics- assessment/nata-limitations. National Research Council. Science and Decisions: Advancing Risk Assessment. Washington, DC: The National Academies Press, 2009. doi:10.17226/12209. Janssen, Sarah, et al. (2012) "Strengthening Toxic Chemical Risk Assessments to Protect Human Health." Available at: https://www.nrdc.org/sites/default/files/strengthening-toxic-chemical-risk-assessments-report.pdf. Brown, H.P. (2011) "Composition of Natural Gas for use in the Oil and Natural Gas Sector Rulemaking." Available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2010-0505-0084. Adgate, J.L., B.D. Goldstein, and L.M. McKenzie. (2014) "Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development." Environ. Sci. Technol., 48, 8307. DOI: 10.1021/es404621d. Available at: http://pubs.acs.org/doi/abs/10.1021/es404621d. 6 http://www.epa.gov/national-air-toxics-assessment/nata-glossary-terms. US EPA. Benzene Hazard Summary. Available at: http://www3.epa.gov/ttn/atw/hlthef/benzene.html. 8 McKenzie LM, Witter RZ, Newman LS, et al. (2012) "Human health risk assessment of air emissions from development of unconventional natural gas resources." Sci Total Environ 424: 79-87. Available: http://www.ncbi.nlm.nih.gov/pubmed/22444058. 9 US EPA. Ethylbenzene Hazard Summary. Available at: https://www3.epa.gov/airtoxics/hlthef/ethylben.html. 10 US EPA. Formaldehyde Hazard Summary. Available at: http://www3.epa.gov/ttn/atw/hlthef/formalde.html. 11 US EPA. Acetaldehyde Hazard Summary. Available at: http://www3.epa.gov/ttn/atw/hlthef/acetalde.html. 12 US EPA. 1,3 -Butadiene Hazard Summary. Available at: http://www3.epa.govjttn/atw/hlthef/butadien.html. 13 US EPA. Polycyclic organic matter (POM) Hazard Summary. Available at: http://www3.epa.gov/ttn/atw/hlthef/polycycl.html. 14 US Energy Information Administration (EIA). Pennsylvania Field Production of Crude Oil. Available at: http://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=pet&s=mcrfppal&f=a. US EIA. Natural Gas Gross Withdrawals and Production. Available at: http://www.eia.gov/dnav/ng/ng prod sum a EPG0 FGW mmcf a.htm. 13 US EIA. Texas Field Production of Crude Oil. Available at: https://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=pet&s=mcrfptxl&f=a. US EIA. Natural Gas Gross Withdrawals and Production. Available at: http://www.eia.gov/dnav/ng/ng prod sum a EPG0 FGW mmcf a.htm. 16 US EIA. Colorado Field Production of Crude Oil. Available at: https://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=pet&s=mcrfpcol&f=a. Clean Air Task Force Fossil Fumes 24 US EIA. Natural Gas Gross Withdrawals and Production. Available at: http://www.eia.gov/dnav/ng/ng prod sum a EPGO FGW mmcf a.htm. 17 Many peer -reviewed studies based on independent measurements conducted in both oil and gas producing basins and urban areas consuming natural gas have concluded that official emissions inventories such as NEI underestimate actual emissions from oil and gas. See Waste Not, pp. 9 — 11. More recent work, including work carried out in cooperation with the industry, has come to similar conclusions. See Harriss, R., et al., (2015) "Using Multi -Scale Measurements to Improve Methane Emission Estimates from Oil and Gas Operations in the Barnett Shale Region, Texas," Environs Sci. Technol. 49, 7524-7526, and references therein. Recent work to update and improve emissions inventories, particularly for methane, is improving this situation. EPA Office of Inspector General (2013), "Report: EPA Needs to Improve Air Emissions Data for the Oil and Natural Gas Production Sector." Available at: https://www.epa.gov/office-inspector-general/report-epa-needs- improve-air-emissions-data-oil-and-natural-gas-production. Although the methane inventory and the NEI, which NATA and our analysis are based on, are developed separately, it is likely that the NEI underestimates HAP from oil and gas just as the GHG inventory underestimates methane from oil and gas, for similar reasons (underestimated emissions factors and undercounts of equipment). 18 McCabe, David, et al. (2015) "Waste Not: Common Sense Ways to Reduce Methane Pollution from the Oil and Natural Gas Industry." Available at: http://www.catf.us/resources/publications/files/WasteNot.pdf ' US EPA. "Final Rule: Oil and Natural Gas Sector: Emissions Standards for New and Modified Sources." Available at: https://www3.epa.gov/airquality/oilandgas/may2016/nsps-finalrule.pdf. 20 US EPA. "Lessons Learned from Natural Gas STAR Partners, Installing Plunger Lift Systems in Gas Wells." Available at: http://epa.gov/gasstar/documents/II plungerlift.pdf. 21 U.S. Census Bureau, Population Division. (2015) Annual Estimates of the Resident Population: April 1, 2010 to July 1, 2014. Available at: http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk 22 US EPA. 2011 NATA: Assessment Result. "2011 NATA natl cancer risk by tract source" & "2011 NATA natl respiratory health risk by tract source". Available at: https://www.epa.gov/national-air-toxics-assessment/2011-nata-assessment- results 23 US EPA. 2011 National Emissions Inventory (NEI) Data. Available at: https://www.epa.gov/air-emissions- inventories/2011-national-emissions-inventory-nei-data. 24 US EPA. "NATA Frequent Questions, Q10: How does EPA estimate cancer risk?" Available at: https://www.epa.gov/national-air-toxics-assessment/nata-frequent-questions. 25 US EPA. (2015) "Technical Support Document EPA's 2011 National -scale Air Toxics Assessment." Available at: https://www.epa.gov/sites/production/files/2015-12/documents/2011-nata-tsd.pdf. 26 US EIA. U.S. Field Production of Crude Oil. Available at: http://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=pet&s=mcrfpusl&f=a. 27 US EIA. Natural Gas Gross Withdrawals and Production. Available at: http://www.eia.gov/dnav/ng/ng prod sum a EPGO FGW mmcf a.htm. Clean Air Task Force Fossil Fumes 25 Limit Noise to Boost Your Child's Brain Power WRITTEN BY: NEUROSURGERY Wednesday, May 18th, 2016 http://share.upmc.com/2016/05/kids-and-noise-pollution/ Excerpts: The World Health Organization defines noise as "unwanted sound"...Noise pollution refers to excessive community noise, which has been shown to have negative effects on children's brains... Children are particularly susceptible to the effects of loud, constant noise. Children exposed to consistent noise whether from devices, school, or living near an airport or busy highway have more trouble with tasks at school. A study found that reading attention, problem -solving, and memory are most affected...Exposure also affects speech perception and listening. [ The inference is that fracking noise during school time is injurious to children. The inference is that children whose second language is English are more at risk than other children.] Noise: n Danger tu Our Children Arlinc L. E3ronzaft. Ph. D . � "A quierer. more serene home fosters healthy child de� efopmenf�. sacs Arline L. Bronzah. Ph. D. fier research into noise pollution and children' s well -being has unco��cred some alarming information which she has sum�narized here. One out of ece � ei �ht children in the United States bctwe n � �� ry � e thc, a�es of 6 and 19 has a noise- � related hcaring problem. (Niskar, et aI . ?001 ). "I'his alarming statistic is most likely the result of � exposing our children lo very� loud soimds in their homes, at schools. and in recrcational settings. Children attend movics that arc too Ioud. plac cideo �amcs with loud audio attachments, set their ' headsets at high Ievels, spend time in loud video arcadcs, eat in loud school lunchrooms and play in loud gymnasia. Even at �cry� }°oun� ages, children play with tocs that have been measured at � exceedineh� loud levcls. . . Noise hns been frequentic associatcd with loud sounds but sounds need not be loud [o be disturbing. intrusivc, and bothersome. Rather noise sho�ild be detined as imwanted. uncontrollable � and unpredictable sounds that intrudc upon our acticities. In the book. 1 Iandbook of Em�ironmental ' Psychology� ( ?002 ), the chapter eutitled Noise Pollution : n [ lazard to Phvsical and Vlental Wcll- Beint„ �critten bg [3ronratt, cites many studic�s that have examincd impacts of intrusive noises on children=s decelopment. �'uises in the hoine can delay cognitive and language dc��elopment and , noise exposure in the dassroom can impair reading and learning skills. Evans and Lapore ( 1993 ) found that children li �ing near or attendin�, school near a major airport were more likely to have � elevated blood ressure. The ecidence is lentif I � � � � � � � ' p p u thnt childre n nce,d I�ys noise and more quict in their li ��cs. Parents should Aturn do�cn the colume ! @ The� should procide quiet places forchildren to rcad. study. and think. ' �hcy should not purchase luud tocs; they should encourage yuieter acti��itics such as reading books, doing puzzles. playing hoard games, and ��isitin� museums thec should have famil� meals with no tele��isions or radios play�ing in thc background so that thcre is greater � opport�mit}� for family discussions. Such discussions also prumote better parent-child relationships. School adminishators should seek uut school designs that emphasize quieL With so many� schools located near noisy highways. railroads, and airpores, they should become advocates for lessening thc noises from these outside sources. So manc uf the noises that intrude upon us stem from a lack of respect for thc ri�hts of others to quieL Cllildren should be taught to respect oU�crs b�� encouraging them to turn do�m thcir home stereos. TVs and computcrs, and speak softiv in thc schuol hallways and classrooms. When students lower their ��oices, teachers have less need to shout or usc loud whistles and bullhorns tc� bc heard by thcir students. �l'his does nut mcan that students can nevcr raise their ��oices at school games as they root for the home team: there are indced times �hen bein� somewhat louder is tolcrable. � The Lca��ue tiir the Hard of Hearing=s St� the 1v'oise program and dieir viewcr-friendl� website ' ( www. lhh.ora/noise) with educational materials that can be printed for distributiun should be very helpful for both parents and teachers to educate children about the pusitive eflects uf quiet in their � lives and the haz�trds of noise. vlc children=s book_ Listen to the Raindrops, illustrated h�� Steven Parton, teaches voung children about the bcauty� of good sounds and the dam�ers of noise as highlighted on the I.eague site. l�his huok can sen e as a tciching aid at home, in the classroom and ' schoollibran�. Parents, educators, and caring citizens must join together in abating the noises that are engulfing our children. Then all of us will reap the benefits of a quieter, saner and healthier environment. Arline L. Bronzaft has her Ph.D. in Psychology from Columbia University in New York. She works with Noise Watch, an anti -noise group in Toronto (http://www3.sympatico.ca/noise). Arline has appeared on several television shows in Toronto, including Marketplace. She is the author of Listen to the Raindrops, a children's book about the hazards of noise. Her research on the dangers of noise can also be found at www.lhh.org/noise. Where to find out more information:. Bronzaft, A. L. (2002). Noise pollution: A hazard to physical and mental well-being. In R.B. Bechtel and A. Churchman (Eds), Handbook of Environmental Psychology, N.Y.: John Wiley & Sons, Inc. Evans, G. W. & Lapore, S. J. (1993). Nonauditory effects of noise on children. A critical review. Children=s Environments, 10, 31-51. Niskar. A. S., Kiezak, S. M., Holmes, A.., Esteban, E., Rubin, C. & Brody, D. J. (2001). Estimated prevalence of noise induced hearing threshold shifts among children 6 to 19 years of age. The third health and nutrition examination survey. 1988-1994. Pediatrics, 108, 40-43. Bronzaft, A. L. & Parton, S. Listen to the Raindrops. New York: League for the Hard of Hearing, www.lhh.org/noise. Have You Heard ? Noise Can Affect Learning ! http ://www.educationworld.com/a_curr/currO l l .shtml ) une 21 , 2016 A handful of research studies confirm that noise has a negative effect on a child ' s ability to learn. Also, " noise education " should be part of the school curriculum ; kids should know how to protect their ears from harm . Children in schools bombarded by frequent aircraft noise don 't learn to read as well as children in quiet schools do, say Cornell University researchers. And those researchers have discovered one major reason: kids tune out speech in the racket. "We've known for a long time that chronic noise is having a devastating effect on academic performance of children in noisy homes and schools, " says Gary Evans, an environmental psychologist in Cornell 's College of Human Ecology and an international expert on noise, crowding, and other forms of environmental stress. Evans and his collaborator, environmental psychologist Lorraine Maxwell, compared children in a noisy school (in the tlight path of a major international airport) with similar children in a quiet school. Their study, which will be published in Environment and Behavior later this year, compared a total of 116 first and second graders from two elementary schools. One school was battered by peaks of up to 90 decibels of' noise from low- Flying planes every 6.6 minutes. The other school, closely matched for ethnicity and percentage of children receiving subsidized school lunches and speaking English as a second language, was in the same urban area but in a quiet neighborhood. The study's findings were significant for speech perception amidst noise, states a summary of the research. "This implies that language acquisition is an underlying mechanism that accounts for some of the noise- reading deficit link, " says Maxwell. Evans and Maxwell also suspect that other factors may be at work in noisy schools and neighborhoods, such as teacher and parent irritability and their reluctance to talk as much, use as many complete sentences, and read aloud as often as other teachers and parents do. The research was supported by the Cornell College of Human Ecology; the National Heart, Lung, and Blood Institute; and the U.S. Department of Agriculture. Tisa Juanicorena From: Sent: To: Cc: Subject: Attachments: Esther Gesick Thursday, June 23, 2016 4:52 PM Tisa Juanicorena BBAREA@greeleyschools.org; Commissioners; Diana Aungst FW: Letter from Weld County School District 6 Board of Education Letter to Weld County Board of Commissioners.pdf Tisa, Please see the attached for addition to the file. Thank you, Esther E. Gesick Clerk to the Board 1150 O Street/P.O. Box 758'Greeley, CO 80632 tel: (970) 400-4226 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Bernadine Barea [mailto:BBAREA@greeleyschools.org] Sent: Thursday, June 23, 2016 4:51 PM To: Esther Gesick <egesick@co.weld.co.us> Cc: Mike Freeman <mfreeman@co.weld.co.us>; Julie Cozad <jcozad@co.weld.co.us>; Barbara Kirkmeyer <bkirkmeyer@co.weld.co.us>; Steve Moreno <smoreno@co.weld.co.us>; Sean Conway <sconway@co.weld.co.us> Subject: Letter from Weld County School District 6 Board of Education Hi, Esther — Thank you for your assistance. Attached please find the letter from the WCSD6 Board of Education for the Commissioner's meeting on June 29, 2016. Thank you! Bernee Bernee Barea, Executive Assistant I Superintendent/BOE I Weld County School District 6 1 , 1 <� � ' s �� ;,; � � �. � ��' � �� _ —_ ��- l 025 NINTH AVENUE , GREELEY , COLORADO 8063t 970 - 348 - 6012 W W W . GREELEYSCHOOLS . ORG June 21 , 2016 To the Weld County Board of Commissioners: The Board of Education of Greeley-Evans School District 6 is elected to oversee the largest school district in Weld County. Our responsibility is to educate, engage and serve the more than 21 ,000 students who attend our schools. i As stated in Innovation 2020, the outline for the District 6 strategic plan, we value and believe in the importance of healthy and safe schools. In fulfilling this responsibility, the District 6 Board of Education respectfully submits concerns with the Vetting 15-H Well Pad proposed near the site of Bella Romero Academy 4-8 campus, located at 1400 East 20th Street. The Board asks the Weld County Board of Commissioners to consider mitigation measures that will address safety concerns. I The primary concern of the Board (Schooi District) is truck and other heavy equipment traffic to and from this site on Cherry Avenue and East 24th Street, which could create a serious safety issue for the students and families who walk to and from school from residential areas between 1 st Avenue and Cedar Avenue, and East 24th Street and East 25th Street. A significant number of school-age children live in this area, and for some, walking is preferred over district provided transportation. Because of existing safety issues in the area, District 6 does offer and provide transportation to students at Bella Romero Academy 4-8 campus, but some students and families still choose to walk Since there is no sidewalk on Cherry Avenue, increased truck and heavy equipment traffic fn that location could create an additional safety hazard for those walking to Bella Romero Academy K-4 campus from those neighborhoods. It is our understanding pipeline for transportation of product and electricity have been secured at this site and will help mitigate noise and traffic in the area. it is our hope this will be a condition of this proposal . If this development is to be approved, the Board of Education is asking the Board of Commissioners to consider one or more of the following actions to mitigate the potential danger to students and their families along Cherry Avenue: • Delay action on this proposed development until a comprehensive traffic study is completed and the Colorado Department of Transportation rules on the request made by the developer to access U . S . Highway 34 for truck traffic from this project. . Require the developer, Extraction Oil and Gas, to limit any and all truck and heavy equipment tra�c to and from the site to hours that would have the least likelihood of foot traffic on Cherry Avenue, avoiding at least one hour prior to the start of school and two hours after school is dismissed • Require the developer, Extraction Oil and Gas, to construct a pedestrian sidewalk along the west side of Cherry Avenue from East 20th Street south to East 24th Street. ;ate . ::: a , ; ; ,� _ :cir The Board of Education also respectfully asks the Board of Commissioners to ensure other safety measures if this site is approved, including adequate fencing to keep students from entering the site, emission controls, berms and landscaping to reduce noise and other measures to limit the impact on Bella Romero students. families and staff. We would like to thank Extraction Oil and Gas for working so closely with District 6. for being responsive to District 6 questions and requests. and for taking into consideration the safety and education of our students. Thank you for your consideration of this request. Respectfully, Board of Education Greeley -Evans School District 6 Engage, Empower, Inspire District 6 provides every studbnt with a personalized, well-rounded and excellent educatidn in a safe. caring environment. ' Tisa Juanicorena From: Diana Aungst Sent: friday, June 24, 2016 8:05 AM To: Tisa Juanicorena; Karla Ford Cc: Tom Parko Jr.; Michelle Martin Subject: FW: Final Filed Greeley Comments Attachments: COGCC Vetting Comments_FINAL_062216.pdf I think this shou !d be added as an exhibit Dinncr ,aunK.s[. .41C 'P. CFM Planner ll Weld County Department ol Planning Services 1555 N. 17th Avenue - Greeley, Colorado 80631 970-400-3524 Fax: (970) 304-6498 daunqst a�weldoov. com www. we/dqov. com i ~1 �. �'. ' . � �� • � � � Confidentialiry Notice: This electronic transmission and any attached documen[s or o[her writings are in[ended only for the perwn o� entity ro which it is addressed and may contain info�mation tha[ is privileged, confidential or otherwise protected from disdosure. If you have received [his communication in error, please immediately no[ify sender by return e-mail and desvoy the communica[ion. Any disdosure, coOYing, distribution or the [aking of any actiom m�cermng the mnten[s o� th�s mmmvnlcation orany at[achments by anyone other [han Ihe named reciplent is slficUy prohibited. From: William L Shell [mailto: redtruck@q .com] Sent: Friday, June 24, 2016 8 :03 AM To: Diana Aungst <daungst@co .weld .co .us> Subject: Fwd : Final Filed Greeley Comments Diana, You should bc a�care of this. Vetting/Bella is becoming a national issue. ' Respectfully, Bill Shell EXHIBIT b Sent from my iPhonc � �-- Begin forwarded messagc: �,1, L - From : I�herese Gilbert <tg?birue�hotmail .com> � Date: June ? 3 . 2016 at 9:4� : 10 PM MD"I� Tu: Fred Cleaccr <fredclea��er a�comcasLnev. Wendc [ li�*hby <�chighbv nJ,Qmail .com>. Anne i Curry <aecommon(a�aol .com>. Kobert Winkler <robertrwinklerxx'avahoo.com>. William L Shell <redtruck� .com>. Sara Barwinski <sarabarwinski a hotmail.com>, Maydean & Lloyd Worley <mamwod(a�gmail .com>, Kristina Bain <ieff kristina(�a access4less.net>. Paula Powell <ppowellJ6� �mail .com>. PATRICIA CnLIFANA <pat �y�msn.com>, CI [ARLGS � TURNER <chuck4juttanmsn.com>, Carl Grikson <cberickson1958(a� �mail .com> Subject: FW: Final Filed Greeley Comments Ok - thought I forwarded this to all . COGCC got it today - thank Sierra Club for organizing � this ! I [ think we 'shuuld post it on our website. t�lso. Montc Whaley interviewed Barbara Flores - neighbor Bella - today . He wants to do a big piece on this From : karenkdikenn gmail .com Date : Wed, ?2 Jim 2016 15 :47 : 37 -0600 Subjecr. Fwd : Final H'iled Greeley Comments l'o: carlislesharon57na�gmail .com; speedkaren a�maiLcom; ksfissin ��c(�i msn.com : i olvnmawr!imsn.com; cberickson1958nagmaiLcom; t 2btrue�uhotmail .com; razz(c�frackfreecolorado.com; micah(cr�350colorado.ore; paddy,�verdedenver.com; maria.orms a email .com Here is the final . Thank you everyone . -------- r�orwarded message ---------- From : Eric Huber <eric. hubercnisierraclub.or�> Date: Wed. Jun 2?. 2016 at 3 :38 PM Subject: Fw�d: Final Filed Greeley Comments I'a Karen Dike <karenkdike!ri �maiLcom> Karen - attached is the final comment we tiled with COUCC today. Please distribute this to everybod}� who signed on and give them our thanks. I will be in touch soon on next steps. ' �i � � ; i �.,� . �lana� ir.,� V- Sierra Clab I ; �: nr�,� �: i �<i�� i .n� �'i , ,,:� n 16�0 ; 8th St. Stc. 102w - I3ou(dec CO 80301 �_30> > �ay-s� y ; e��. toi (303 ) 1a9-65 ?0 � lax) C'ONP [Df:v' T ( -AL LEGAL CO�I �IUVICAI�IU� ��'ORK PRODI;CT I '.� i � ��mail ma�� c��ntain nricil ��rd and contidential communication, andiorconfidential attorney � ' �- � � � � � � � � � � � � ' �� .id � �rt�ntly . plc�isc reply anei notily thc sender and . � : z Karen Dike karenkdike@gmail.com 720-363-7119 303-834-8252 3 �' � S � � � � � 1650 38`� Street Suite l0W C L U B Boulder, CO 80301 303 -449-5595 � TO: John Noto, COGCC Oil and Gas Locxtion Assessment Supervisor Email : john.noto(a%state.co. us Doug Andrews, COGCC OGLA Northeast Location Specialist Email : dou�. andrews�dstate.co.us FR: The Sierra Club; Weld Air aud Water; Our Health, Our Future, Our Loug�nont; Windsor Coimnuuity Rights Network; Coloradaus Resisting Extreme Euergy Developmeut; Coloradans Against Fracking; Protect Our Loveland; 350 Colorado; North Metro Neighbors for Safe Energy; FrxckFree Colorado; Wall of Womeu; and Eco-Justice Ministries. UT: June 22, 2016 RE : Coimnent ou Extraction Oil & Gas LLC 's Form 2A Applications, Nos. 400940497 and 401051216 Dear Colorado Oil and Gas Conservation Commission: These comments pertain to each of the above-referenced Form 2A applications. We are addressing these together because they are related, and filing them in duplicate so they will be iu the record tor each applicatiou. The coutent of this ]etter will be sub�nitted on the COGCC website and a hard copy of this ]etter as well as a CD (Exhibit 3) will be nuiled to Mr. Noto and Mr. Andrews. These comments are submitted on behalf of the Rocky Mountain Chapter of the Sierra Club; Weld Air aud Water; Our Health, Our Future, Our Loug�nont; Windsor Co�mnunity Rights Network; Coloradans ResisTing Extreme Energy Developmeut; Coloradaus Against Frackiug; Protect Our Lovelxnd; 350 Colorado; North Metro Neighbors for Safe Energy; and Eco-Justice Ministries. All the groups signi�ig on in support of these comments do so in support of the children who attend Bella Romero Academy and nearby residents affected by this proposed massive drilling project. � � The Sierra Club is the nation's oldest grassroots environmental membership organization. The Sierra Club has a Rocky Mountain Chapter, with more than I5,000 ineinUers in Colorado, including members who live and work in Greeley and Weld County near these proposed locations. Weld Air & Water is a nonprofit commm�ity-based organization that promotes the social and environmental welfare of our comm�uiity by serving as an information clearinghouse, au advocate far healtli and safety, aud a com�nunity organizing too] for citizens of Weld County, Colorado in relation to oil and gas development in the County. Windsor Community Rights Network is a grassroots organization working with the Colorado Comnlunity Rights Network to get an initiative on the Colorado ballot to amend our constitution to give the people the power to override state exemption. Eco-Justice Ministries is a Denver-based agency working with cliurches to increase awareness aud action related to matters of ecological sustainability and 1 We urge the Colorado Oil and Gas Conservation Commission ("COGCC") to deny the Form 2A location assessment applications for Extraction Oil & Gas LLC's Vetting 15-H pad and Vetting Facility until such time as the operator has complied with all COGCC regulatory requirements. We are very concerned about the 24 wells that will be sited only 1,360 feet away from Bella Romero School and 509 feet away from homes. We are also concerned about the production facilities, including 18 oil tanks, that will be sited only 1,364 feet away from Bella Romero School and 771 feet away from homes. We believe that, given the proximity of the wells and production facilities to Bella Romero Academy, a grade 4-8 school, and numerous homes, and the potential impacts of this activity on the public health and the environment, the permit should be denied. At a minimum, additional setbacks and mitigations are required. Extraction Oil & Gas LLC's location proposals are inappropriate based on the size of the proposed operations and its proximity to neighboring buildings. Further, the locations do not comply with COGCC regulations because there are other locations available that are farther from Bella Romero School and residential homes. We request that the COGCC 1) reject the applications based on the information submitted; 2) allow additional time for public comment if complete applications are submitted; 3) require hearings on the applications to be held in Greeley; and/or 4) if the permits are issued, require additional mitigation to reduce the impacts these facilities will have on neighboring land uses if the COGCC believes the applications meet the requirements of the COGCC Rules. 1) The Form 2A applications should be rejected by COGCC because the locations are not in compliance with COGCC Rules. The Form 2A applications are incomplete and should have been rejected by COGCC staff. They do not comply with Rule 604.c.(2)E.i., which requires: "Multi -well production facilities shall be located as far as possible from Building Units."2 A. Form 2A No. 400940497 Extraction O&G proposes to site 24 wells and 2 modular large volume tanks 509 feet from a Building Unit and 1360 feet from a High Occupancy Building Unit. This places the proposed location within a Designated Setback Location and as a result, Extraction O&G should have completed the section, "FOR MULTI -WELL PADS AND PRODUCTION FACILITIES WITHIN DESIGNATED SETBACK LOCATIONS ONLY" on page four of the Form 2A social justice. The agency has a long record of involvement on issues of climate and energy, with a special emphasis on the impacts of such issues on the poor and communities of color. 2 This rule applies to "any Well or Production Facility proposed to be located within a Designated Setback Location (Rule 604.c(2)), the definition of which includes High Occupancy Buildings and "Buffer Zone Setback," which in turn includes "Building Units" The Form 2A for the wells and production facilities here indicate they are within a Buffer Zone. Therefore, Rule 604.c(2)E.i applies. 2 application. The 2 modular large volume tatilcs fall under COGCC 's definition of production facilities and as such, Extraction O&G must comply with Rule 604.a(2)E.i. and provide a "sitiug rationale" to support its determination that Yhe production fiacilities are locxted "as far as possible from Building Units." ' However, this form has no siting rationale attached. This missing infonnation is a fundamental deficiency in the application — requiring the application to be rejected. There is no justification given that the ]ocation chosen is "as far as possible" from homes and schools. B. Form 2A �Yo. 401051216 Extraction O&G proposes to site 18 oil tanks, 24 separators, 4 vapor recovery units, 4 water tanks, 1 LACT unit, 6 ECD's, and ] maintenance tank 771 feet from a Building Unit and 1364 feet from a High Occupancy Building Unik Although the company checked the box ou its Forni 2A application indicating it is "as far as possible from Buildiug Units," the compauy failed to supply aray documentation that the location is in fact "as far as possible" as required by the COGCC rule. The applicant's "siting rationale" required Co support its Rule 604.c(2)E. i. determination is totally conclusory. It lacks any infonnation on alternate sites, the ability ofthe company to access the oil and gas through use of longer horizontal directional drilling or longer laterals, or place the production facilities further away. Judging by the Form 2A and attachments, no alternate sites were identified for review. This is a fundamental deficieucy in the application — requiring the application to be rejected. In its Form 2A application, the coinpany attached no documentation to justify its proposed location but merely stated in its siting rationale: The facility for the Vetting 15-H well pad has been positioned to meet COGCC setbacks from both Building Units and High Occupancy Building Units. The facility is located over 1 ,300 feet from the closest high occupancy building unit and over 700' from the two closest building units. Additionally the facility has been located to achieve the greatest setback possible from the limits of the school property located to the northwest, yet as far as possible from the residential homes located to the south aud east. The facility has beeu designed to use the least amount of equipment yet maintain safe operations and will employ numerous best managetnent practices to �ninimize impacts to surrounding land owners, induding � The definition of "Production Facilities" includes "all storage . . . and other equipment directly associated with oil wells, gas wells, or iujection wells." Therefore, the water taiilcs are included in Production Facilities that uiust be sited as far away as possible froin Building Units. The COGCC "Policy ou the Use of Modular Large Volume Tanks in Colorado," dated June 13 , 2014 does not change this because it notes these tanks "meet the ] 00-series regulatory definitioi� of an Oil and Gas Facility"; and any exemption for tanks would be in conflict with the definitions of the regulations, and pre-date the current re�ulations. According to the policy, there were five catastrophic failures of such tanks iu 2011 - 13 . 3 use of a lease automatic custody transfer (LACT) meter to load trucks on this location.4 The siting rational goes on to describe the benefits of a LACT meter, which is wholly irrelevant to the company's determination that the production facilities are located "as far as possible from Building Units." This siting rationale with only two -sentences on setbacks is telling. Extraction O&G either did no analysis of other properties or it is avoiding revealing it, which does not meet the requirements of the rule. As COGCC is aware, surface wells can now reach subsurface minerals from great distances, as much as two or more miles from the resource. This placement does not interfere with an operator's ability to efficiently extract the resource; rather, it aids in efficient and increased production. Therefore, it is both feasible and desirable for an operator to locate wells and production facilities at distances of up to two miles or more from the subsurface minerals so that drilling can achieve the greatest output. The COGCC should require the applicant to demonstrate whether such other sites are or are not possible, and not merely accept a conclusory statement in the siting rationale.5 C. Form 2A Conflicts with Rule 604.c.(2)E.i. The Form 2A application section, "FOR MULTI -WELL PADS AND PRODUCTION FACILITIES WITHIN DESIGNATED SETBACK LOCATIONS ONLY," on page four is inconsistent with Rule 604.c.(2)E.i. The application allows companies to: Check this box if this Oil and Gas Location has or will have Production Facilities that serve multiple wells (on or offsite) and the Production Facilities are proposed to be located less than 1,000 feet from a Building Unit. (Pursuant to Rule 604.c.(2)E.i., the operator must evaluate alternative locations for the Production Facilities that are farther from the Building Unit, and determine whether those alternative locations were technically feasible and economically practicable for the same proposed development) The statement in parentheses is not supported by Rule 604.c.(2)E.i., which states: 4 Although the applications include some aerial images showing Building Units, there appear to be no tax assessor map screen shots, flood plain maps or property surveys. The COGCC alternative location analysis (siting rationale) has been defined by COGCC staff to require operators to provide such documentation. See June 9, 2015 email from Rebecca Treitz to Callie Fiddes, attached as Exhibit 1. Moreover, there is no such documentation for any alternate site, which indicates none were considered by the applicant. 5 Attached as Exhibit 2 is a map showing the proposed site and additional radii of 5,000 ft. and 10,000 ft., which indicate the areas from which the minerals might be accessed using longer laterals. A valid siting rationale should address whether there are available alternative sites within these radii. 4 Where technologically feasible and economically practicable, operators shall consolidate wells to create multi -well pads, including shared locations with other operators. Multi -well production facilities shall be located as far as possible from Building Units. In other words, the technologically feasible and economically practicable limitation applies to wells rather than to production facilities. Rule 604.c.(2)E.i. only requires that multi - well production facilities be located as far as possible from Building Units, with no qualifications on "as far as possible." The COGCC should amend that section of Form 2A to read, "Pursuant to Rule 604.c.(2)E.i., the operator must evaluate alternative locations for the Production Facilities that are farther from the Building Unit, and determine whether those alternative locations are possible for the same proposed development." Approval of the project based on this Form would, therefore, be contrary to the regulations, and it should be denied. 2) In the event the required siting rationale is submitted, the COGCC should provide additional time for public comment on that new information. Assuming that the COGCC will require Extraction O&G to submit an "alternate location analysis" or substantive "siting rationale" prior to deciding whether to approve the applications, we request additional time for public comment on that new information. To approve an application without this information would be arbitrary and capricious. We believe that the company's justification for proposing its multi -well industrial area in between a school and residential neighborhood is the most important component of Extraction O&G's applications. If the required materials are ever produced, we request an additional 20 days to review the document. The 20 -day comment period should be open to a further 20 -day extension if requested by the Town of Greeley. 3) The COGCC should require a public hearing on the applications to be held in Greeley. What Extraction O&G has proposed is a major industrial operation with all the accompanying ramifications. Approving an industrial use in an existing residential area in Greeley would typically require at least two public hearings (planning commission and Town Board). Accordingly, we request that COGCC hold a public hearing on both Form 2A applications.6 The COGCC and the State Attorney General have taken the position that the Town of Greeley cannot turn down the proposal once it has been approved by the COGCC. Since the decision will be made by the COGCC, basic due process should allow the neighbors of the 6 In addition, we request that the undersigned be allowed to intervene and present evidence at the hearing. 5 proposed multi -well industrial area, as well as the parents of Bella Romero School students, the chance for a public hearing before the decision -making body — the COGCC. Information presented at such a hearing would be informative to the COGCC before it makes a final decision on this proposal. This is warranted especially in this case because the school's ballfields are within 1,000ft of the proposed site. When setbacks for the well pad and the processing facility are taken together almost the entirety of school grounds are within 1,000ft and the school itself lies only 1,300ft from the pad. In addition, drilling near Bella Romero is an environmental justice issue, as its student population has some of the highest minority rates in the county and are amongst the poorest. According to coloradoschoolgrades.com, Bella Romero is 89% Hispanic or Latino and 3% African American whereas Greeley as a whole is 79% White. 92% of Bella Romero's students are from low income families. Furthermore, according to the EPA's Environmental Justice Screening Tool, which is used by the agency to assess high risk populations and environments, the community surrounding Bella Romero is within the 90-95% percentile range nationally for linguistically isolated communities. 4) If the applications are deemed to comply with COGCC regulations, the COGCC should require mitigation to reduce the impacts this facility will have on neighboring land uses. We believe that the COGCC rules require this proposal to be rejected. In the event the COGCC decides instead to approve the wells and facilities, we request the following mitigation requirements as conditions to the permits. A. Remote Hydraulic Fracturing As discussed above, it is possible and economically desirable to drill up to two miles away from the resource. In connection with the Governor's Oil and Gas Task Force in 2015, several members toured an Anadarko remote hydraulic fracturing site near Firestone, Colorado. Anadarko reported that this technology allows hydraulic fracturing, and all the associated traffic, noise and vibrations, to be located as far away as one mile from the well location. Utilizing this technology would allow nearby neighbors to eliminate the three months of nuisance and other impacts from hydraulic fracturing. This technology should be required when drilling so close to schools and neighborhoods. B. Remote Production Areas One of the best ways to limit impacts on residential areas, schools, and other occupied areas is to locate the production areas away from them. If the drilling locations have to be near Building Units, the industry can still locate the production equipment farther away from homes and schools. Piping the gas and produced fluids away from the selected well pad would allow a more appropriate location for the tanks, separators, dehydrators, etc. — further away from homes and schools. C. Increased Air Quality Protections 6 Oil and gas production facilities located on the selected location should: a) be subjected to an instrument -based leak detection and repair inspection at least once a year; b) employ VOCs destruction or control technologies with at least 95% efficiency on all tanks capable of emitting over 2 tons of VOCs annually; c) require repair of any leak over 10,000 ppm hydrocarbons no later than 24 hours after discovery. If a repair is not possible within 24 hours, the well should be shut down until a repair can be made. If shutting down the well will not stop the leak, efforts should be made to minimize the leak within the first 24 hours and it shall be reported to the Town of Greeley as well as the Local Government Designee; and d) apply technology that would allow for tank unloading without opening the thief hatch. D. Require Use of Electric Equipment Extraction O&G should only use electric -powered engines for motors, compressors, and drilling and production equipment and for pumping systems in order to mitigate noise and to reduce emissions. The company has proven that using electricity from the grid for these purposes is technologically feasible and practicable. E. Water Management. Water necessary for drilling and hydraulic fracturing shall be piped to the location if water is available. This will eliminate more than 1,000 water truck trips per well for drilling and hydraulic fracturing. 7 F. Mitigation of other Harms The proposed location near homes and the school will transform this into a heavy industrial area. Drilling is a source of loud noise and excessive vibration. Even after the wells are drilled, the location will be a source of constant noise. The 24 -hour truck traffic will provide 7 A recent comprehensive 2013 study by Boulder County, Colorado of the impacts of fracking- related truck traffic (hereafter "Boulder Study") is available at https://www.bouldercounty.org/doc/landuse/dc 120003oi1gasroadwaystudy20130114.pdf that is incorporated herein by reference. That concluded that the hydraulic fracturing process for a single well would require an average of 1,400 one-way truck trips just to haul water to and from the site (Boulder Study at 8). Using national data, the study also finds that taking into account the full development process (construction, drilling, and completion), the average fracked well requires 2,206 one-way truck trips (Id. at 10). This figure does not include production phase trips, which could add an additional 730 truck trips per year depending on various factors including the success of the well and whether it is re-fracked (Id.). 7 continual noise. Also, the road accessing the well site is used by students to walk to the school where there is no sidewalk, which creates a dangerous situation. An engineered noise and vibration study and mitigation should be requu�ed to reduce these impacts as much as possible. And, these activities should only be allowed during daytime hours - 9:00 AM to 5 :00 PM . 5.) The Permits are not consistent with the COGCC's duty to protect health and the environment. Under the Colorado Oil and Gas Conservation Act, COGCC's duty is to "[fJoster the respousible, Ualanced development, productiou, and utilizatiou of the natural resources of oil aud gas in the state of Colorado in a manner consistent with protection of public health, safety, and welfare, including protecfion of the environment and wildlife resources; . . . C. R. S. § 34-60- 102( 1 )(a)(I) (2014)(emphasis added). And further, "[i]t is the intent and purpose ofthis article to pennit each oil and gas pool in Colorado to produce up to its maximmn efficieut rate of production, subject to the prevention ofwaste, consistent with the protection of public health, safety, and welfare, including protection of the environment and wildlife resources . . ." C.R. S . § 34-60- 102( 1)(b) (2014)(etnphasis added). Applying these standards, COGCC should deny these permits altogether. In particular, we question whether COGCC adequaYely assesses the health impact of these pennits and their siting. Has COGCC analyzed how many people live, work, and/or recreate within a certain distance of the proposed oil and gas facilities, the wind patterns there or the exposure risk to thein associated with types, amount and distance of the chemicals etnitted by the proposed operations'? As COGCC is aware, there are numerous studies regarding the health impacts of fracking operations. For example, a September 2010, Colorado School of Public Health report on a prospective Health Impacts Assessment of proposed natural gas development in Garfield County found that it "has the potential to create a variety of stressors that can impact health." The researchers reported "These stressors include air e�nissions, water and soil coutaminatiou, traffic, noise/vibration/light, co�nmuniry wellness, economic/employrnent changes, health infrastructure stress, and industrial accidentshnalfunctions." See also, The Endocrine Disruptioi� 8xchange. (Undated). Chemicals ln Natural Gas Operations: Health Efjects Spreadslleet and Surnmaiy, available at: http://www.endocrinedisruption.con�/chemicals. multistate.�hp; EPA, Health Effects of Ozone in the General Pop�ulation, available at: httn://www.epa.gov/apti/ozonehealth/�opulation. limil; and Theo Colbom et al. , An explorato�y study of'air quality near raaCural gas operations, HUM. ECOL. R1SK ASSESS (Nov. 9, 2012), available at httu ://endocrinedisru�tion.or�/assets/mcdia/documents/HI� RA l2- I 37NGAirOualityManuscriptforwebwithti �ures. ndf The Colborn paper (2012) reveals that over the course of the year, 61 cheinicals were identified in air samples near oil and gas operations, including seven chemicals that were detected in every sample: toluene, formaldehyde, acetaldehyde, naphthalene, ethane, propane 8 and methane. As reported in the Colborn paper, a search of the government and scientific literature on health effects of chemicals identified in the air samples revealed that more than half of the 61 chemicals can affect the brain and central nervous system, the liver and metabolic systems. Half of the chemicals can also affect the endocrine system, with impacts on reproductive health, development in the womb, and other endocrine related endpoints. Nearly half were found to affect the immune system, the cardiovascular system, the skin, eyes and other sensory organs, and the respiratory system. Many of the chemicals are carcinogens. Colborn, et al. (2012) also discuss that the levels of polycyclic aromatic hydrocarbons ("PAHs") found in Garfield County were over three times higher than were found in the New York City cohort. Scientific literature indicates that children exposed to higher levels of PAHs in utero were more likely to be born preterm, of low birth weight, and with smaller skull circumferences. As the children grew, they showed effects on mental development, IQ, attention and behavioral problems, and obesity. The effects of living near gas operations during prenatal development were demonstrated in a recent study of 124,842 birth records from 1996-2009 in 57 rural Colorado counties (McKenzie, et at, (2014)). In addition, in Colorado, symptoms reported in the state's inspection/incident database by residents living within a half mile of well development included headaches, nausea, upper respiratory irritation, and nosebleeds. Another Colorado example is J.B. Gilman, et al. (2013). There, an extensive set of volatile organic compounds (VOCs) was measured at the Boulder Atmospheric Observatory (BAO) in winter 2011 in order to investigate the composition and influence of VOC emissions from oil and natural gas (O&NG) operations in northeastern Colorado. BAO is 30 km north of Denver and is in the southwestern section of Wattenberg Field, one of Colorado's most productive O&NG fields. The analysis of tower data filtered by wind sector reveals a strong alkane and benzene signature in air masses coming from northeastern Colorado, where the main activity producing these compounds is related to oil and gas operations over the Denver— Julesburg Basin. In Colorado, symptoms reported in the state's inspection/incident database by residents living within a half mile of well development included headaches, nausea, upper respiratory irritation, and nosebleeds.8 Residents living S'/2 mile from wells are at greater risk for health effects from unconventional oil and gas development than are residents living >'/2 mile from wells.9 Because infants and children are more susceptible to health impacts from unconventional oil and gas operations, studies recommend minimum setbacks of one -mile from occupied dwellings, schools and hospitals where they might spend a substantial amount of time. I° 8 Roxana Z. Witter, et at, The Use of Health Impact Assessment for a Community Undergoing Natural Gas Development, FRAMING HEALTH MATTERS (2013). 9 McKenzie LM, et al, Human health risk assessment of air emissions from development of unconventional natural gas resources, Sci Total Environ (2012), doi:10.1016/j.scitotenv.2012.02.018. 10 Ellen Webb, et al., Potential hazards of air pollutant emissions from unconventional oil and natural gas operations on the respiratory health of children and infants, Rev Environ Health (2016). 9 These are just a few of the available studies that indicate the hazards of exposure to oil and gas operations. In addition, many studies across the country indicate that the science on the impacts of fracking on human health are incomplete, and in the process of being developed. A summary of this additional information and studies and reports on health impacts from fracking and related activities are provided on CD as Exhibit 3, with the hard copy of this letter for your consideration. CONCLUSION Given the proximity to residences and a school we believe the company has failed to demonstrate that the proposed locations are as "far as possible" from them. Moreover, we believe that COGCC has not adequately assessed the risks to public health and welfare, and issuing these permits is contrary to COGCC's duty to act consistent with protection of health and the environment. We therefore urge you to deny these permits. Sincerely, G Eric E. Huber Managing Attorney, Sierra Club Carl Erickson Chair, Weld Air and Water Kaye Fissinger Director, Our Health, Our Future, Our Longmont Joan Stephenson President, Windsor Community Rights Tricia Olson Executive Director Coloradans Resisting Extreme Energy Development Karen Dike Spokesperson, Coloradans Against Fracking Sharon Carlisle Director, Protect Our Loveland 10 Micah Parkin Executive Director, 350 Colorado Maria Orms North Metro Neighbors for Safe Energy Razz Gormley FrackFree Colorado Paddy McClelland Wall of Women Rev. Peter Sawtell Executive Director, Eco-Justice Ministries enclosures Tisa Juanicorena From: Esther Gesick Sent: Sunday, June 26, 2016 8:05 PM I To: Tisa Juanicorena; Karla Ford Cc: tg2btrue@hotmail.com Subject: FW: [tem for review Attachments: fracking_study (1).pdf Hi Tisa, Please see the message below and attachment for Wednesday's hearing. Thanks ! Esther E. Gesick Clerk to the Board ll S0 O Street� P. O. Box 758� Greeley, CO 80632 tel: (970) 400-4226 Cori�dcnt�alrty Notice�. -his ele�tranlc Iransmission and any attached documents or other wntings are intended only for the person or entity m whlch It is addressed and may contain informa[ion tha[ is privileged, ronfidential or o[herwise protected from distlosure. If you have received t6is communication in error, please immediately no6fy sende� by return e-mail and desiroy the rommunica[ion. Any disdosure, co0v�ng, distri6ution or the taking of any actiom m�ceming the mntents of [his mmmunication or any attachmen[s 6y anyone other than the named recipient is sirictly prohibited. From : Therese Gilbert [mailto :tg2btrue@hotmail .com] Sent: Sunday, June 26, 2016 4:23 PM To: Esther Gesick <egesick@co .weld .co .us> Subject: Item for review Hello Ms. Gesick. [ would like the couaty commissioners to have this stud}' before hearing docket # 2016-49 regarding Extraction's planned development ( USR16-0009 ). I am deeply concerned about the health effects this project would have on the students at Bella Romero and thos� living within 2500 feet of these gas wells. Thank you, Therese Gilbert EXHIBIT � V�. [ � i DE GRUYTER Rev Environ Health 2016; aop Ellen Webb*, Jake Hays, Larysa Dyrszka, Brian Rodriguez, Caroline Cox, Katie Huffling and!Sheila Bushkin-Bedient* Potential hazards of air pollutant emissions from unconventional oil and natural gas operations on!the respiratory health of children and infants DOI 10.1515/ reveh-2014-0070 Received October 12, 2014; accepted February 8, 2016 Abstract: Research on air pollutant emissions associated with unconventional oil and gas (UOG) development has grown significantly in recent years. Empirical investiga- tions have focused on the identification and measure- ment of oil and gas air pollutants [e.g. volatile organic compounds (VOCs), particulate matter (PM), methane] and the influence of UOG on local and regional ambient air quality (e.g. tropospheric ozone). While more stud- ies to better characterize spatial and temporal trends in exposure among children and newborns near UOG sites are needed, existing research suggests that exposure to air pollutants emitted during lifecycle operations can potentially lead to adverse respiratory outcomes in this population. Children are known to be at a grcater risk from exposure to air pollutants, which can impair lung function and neurodevelopment, or exacerbate exist- ing conditions, such as asthma, because the respiratory system is particularly vulnerable during development in- utero, the postnatal period, and early childhood. In this article, we review the literature relevant to respiratory risks of UOG on infants and children. Existing epidemi- ology studies document the impact of air pollutant expo- sure on children in other contexts and suggest impacts near UOG. Research is sparse on long-term hoalth risks associated with frequent acute exposures - especially in *Corresponding authors: Blen Webb, MPH, Center for Environmental Health, 42 Broadway, Suite 12-140, New York, NY110004, USA, E-mail: ellen@ceh.org; and Sheila Bushkin-Bedient, MD, MPH, Institute for Health and the Environment, 5 University Race Suite A217, Fensselaer, New York, USA. E-mail: sbushkin@nycap.rr.com ke Hays: PSE Healthy Energy, New York, NY, USA Larysa Dyrszka: Physicians for Social responsibility -New York, White Lake, NY USA Brian Rodriguez and Caroline Cox: Center for Environmental Health, Oakland, CA, USA Katie Huffling: Alliance of Nurses for Healthy Environments, Mount Rainier, MD, USA children - hence our interpretation of thesofindings may be conservative. Many data gaps remain, but existing data support precautionary measures to protect the health of infants and children. Keywords: benzene; formaldehyde; ozone; particulate matter; silica dust; UOG. Introduction Hydraulic fracturing (fracking) and other technological advances have enabled the extraction of fossil fuels from previously inaccessible geological formations (e.g. shale), leading to the rapid and extensive spread of unconven- tional oil and gas (UOG) development in the United States since the mid -to -late 2000s. UOG technologies and prac- tices are now also being considered in a growing number of countriesoutside of North America. Astheshaleoil and gas boom continues, policymakers, citizens, and scien- tists around the world have started to pay more attention to the potential public health impacts of this emerging industry. The scientific literature on environmental and public health impacts associated with UOG development has grown significantly in recent years. While the rapid growth of this industry was undertaken without substan- tial public hoalth research, there are now numerous pub- lications clarifying health risks and, increasingly, health outcomes. At the time of this review, there are nearly 700 peer -reviewed publications that assess various environ- mental and societal impacts of UOG, and of these, more than 80% have been published since the beginning of 2013. In particular, there has been a wave of research on air pollution in arcaswith high levels of oil and gasactiv- ity, such as Texas, Colorado, and Pennsylvania. These investigations have focused mostly on the identifica- tion and measurement of air pollutant emissions as well as the influence of UOG on local and regional ambient air quality. Hazardous air pollutants (HAPs) such as 2" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER ground -level ozone precursors (e.g. nitrogen oxides or NOx), particulate matter (PM), silica, aromatic hydrocar- bons, and volatile organic compounds(VOCs), areemitted throughout the lifecycle of UOG development, including well pad construction, drilling, completion, production, midstream processing, storage, and transport. The respir- atory health impacts of these pollutants are well known and documented in the scientific literature. Concurrently, there isinterest in the potential impacts of UOGactivitieson vulnerable populations, such aschil- dren and newborns (1-4). A large body of research sug- gests that children are at a greater risk from exposure to environmental pollution due to various biological and behavioral factors (5-8). A significant number of epide- miological studies have examined health outcomes in children and newborns from exposure to various air pol- lutants. Some of these pollutants, including ozone, PM, silica dust, benzene, and formaldehyde are associated with UOG activities. This review considers the potential impacts of air pol- lution from UOG operations on the respiratory health of children and newborns. We add to the growing body of scientific literature by reviewing recent studies on UOG air pollution as well as the respiratory health outcomes associated with five specific air pollutants associated with UOG development: tropospheric ozone, PM, silica dust, benzene, and formaldehyde. The primary purpose of this review is to highlight how certain vulnerable populations (children and newborns) may suffer disproportionately from health risks from exposure to air pollutant emis- sions from UOG development. Our intention is to high- light many of the unknown exposure risks and the need for more stringent control of health -protective measures based on the evidence to date about the risks of air pol- lution to children's respiratory health. In this review, we also identify future research needs and make general policy recommendations in light of the identified hazards and risks to these populations. Methods For this review, we focused on the scientific literature relevant to the potential respiratory health impacts of UOG emissions on chil- dren and newborns. This required reviewing four di! erent types of research, including studies of 1) UOG air emissions and atmospheric concentrations; 2) the potential respiratory health impacts of air pol- lutants(ozone, PM. silica dust, benzene, and formaldehyde); 3) health outcomes from childhood exposure to air pollution; and 4) health outcomes associated with UOG. We synthesized the information in a narrative form and did not include a formal quality assessment of the literature. Additionally, although we primarily focused on infant studies, we also referred to some adult studies when appropriate to understand potential implications for infants and children. This review is not intended to provide a formal risk assessment that would characterize the exposure levels among children to our pollutants of concern. At present, there is not enough data to under- stand how much UOGemissionscontributeto exposure level samong populations. Instead, we review studies that measure UOG air emis- sions and atmospheric concentrations of our five pollutants of con- cern. When provided by the literature, we also note if concentrations exceed relevant air quality standards or guidelines. Our methods are intended to help identify exposure pathways, potential health risks, and to promote research to measure the likelihood and extent of childhood exposure to various air pollutants associated with UOG development. This review drew from the poor -reviewed scientific literature with a few exceptions. For instance, we cited toxicological data for various air pollutants from several government sources, including the Agency for Toxic Substances and Disease Registry (ATSDR) and the United States Environmental Protection Agency (US EPA). Other government reports were cited where appropriate. Of note, the term UOG is used in many contexts and may refer to a number of modern oil and gas development techniques. some of which are beyond the scope of this review. UOG generally refers to oil and natural gas produced from atypical reservoir types. UOG development isa broad and complex term. We limited our review to research pertaining to onshore oil and gas development from shale and tight formations (i.e. low permeability) and did not include stud- ies of coalbed methane, oil sands, or o! shore oil and gas develop- ment. Some of the common technological features of these types of oil and gas development include high volume hydraulic fracturing and directional wells. Hydraulic fracturing is defined asa well stimu- lation technique where highly pressurized fluid consisting of water, sand, and chemicals is injected into a wellbore to open cracks in low permeability rock formations in order to mobilize oil or natural gas. Higher volumes of fluid are used in the type of hydraulic fracturing employed for shale oil and gas development. Directional wells are defined as those that deviate from the original vertical wel I bore at a high angle to target a specific location (e.g. vertically and then later- ally into a shale formation) (9). In our discussion of the health impacts of air pollution, we focused on five particular air pollutants of concern: ozone, PM, silica dust, benzene, and formaldehyde. These five pollutants have received considerable attention in the oil and gas air quality litera- ture. There are numerous studies on atmospheric concentrations of ozone in aroas of highly concentrated oil and gas development, such as Wyoming, Utah, Texas, and Colorado (10-14). The Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) have studied respirable crystalline silica in the context of worker safety and hydraulic frac- turing operations (15). Numerous studies have measured quantities and types of VOC emissions, and benzene and formaldehyde have often been a particular concern, in part because of their carcinogenic e! ectson humansand animals. PM isalso commonly associated with UOG operations due to diesel emissions from truck tra" c and onsite equipment (e.g. generators, pumps, etc.) (16). The potential health outcomes of the five air pollutants included in this review are well known and have been studied in a variety of other contexts (Tabled). This review employed several search methods, including key- word searches in three science databases (PubMed, Web of Science, DE GRUYTER Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health$ anS 3 Table 1:" Summary of respiratory health effects associated with pollutants of concern,d and the studies in which the health effect was reported. Pol I utant Associated respiratory health outcome Range of emissions Ozone Particulate matter 0 .. and &* xm) Benzene Formaldehyde Systemic, respiratory tract, and lung inflammation (&' -&( ) Feduced lung function as measured by FEV& () * , ) &) Increased susceptibility to infection and decreased immunity () ) ) Asthma () +) Reduced lung function as measured by FEV& () . ) Lung injury via oxidative stress () , ) Pulmonary and systemic inflammation 0' , ) / ) Asthma via oxidative stress and inflammation () ( ) Increased coughing and wheezing (+* -+) ) Asthma (++) Reduced lung function as measured by FEV& (+- , +. ) Bronchitis and pulmonary infections (+, , +' ) Chest discomfort, difficulty breathing, and wheezing (- &) Acute respiratory tract illness (- ) ) Reduced pulmonary function (- +) Asthma(- - --, ) ,' -&*' ,_,_bvb()-) ' -&, * ppbv` (&) ) N/A * , ) ppbv (+/ ) * .+-& &ppbv (+( ) &-- .( ppbva (&+) * *, -&., ppbv(-*) * - ( ppbv (+/ ) * .+-) ppbv (+( ) This table also summarizes the range of emissions for each pollutant. Studies with an indicate ranges corresponding to a 25th -75th quar- tile range. Studies with a b indicate a range increase in daily max 8-h average concentrations for a 6 -day period. Studies with a C correspond to a 6 -day period between February 28 and March 5, 2011. dSilica dust was not included in Table 1 due to limited peer -reviewed literature concerning respiratory effects in children. ppbv, parts per billion by volume. and ScienceDirect) and in existing collections of scientific literature on this subject, including the PSC Healthy Energy Citation Database on Shale and Tight Gas Development as well as the Marcellus Shale Initiative Publications Database at Bucknel I University. Additionally, we complemented our search using the NYU Ehrman Medical Library database and Google Schol ar, aswell as manual searches of the refer- ences included in many of the studies identified. Results Sources of air pollution from UOG UOG operations emit air pollutants linked to adverse res- piratory effects throughout their lifecycle (16, 47). Sources of air pollution include emissions from the extraction and processing of natural gas, as well as the transporta- tion via natural gas infrastructure components including compressor stations and pipelines (48-50). Pollutants can be emitted during venting, flaring, production, and leaks from faulty casings (51). In addition, truck transportation of materials to and from well pads and vehicular equip- ment use during construction and maintenance generate air pollution from particulate matter and diesel exhaust. These processes reloose numerous contaminants into the air, resulting in elevated concentrations of polycyclic aromatic hydrocarbons (PAHs), methane, ozone, NOx, and VOCs like benzene, formaldehyde, alkenes, alkanes, aromatic compounds, and aldehydes (10, 13, 38, 52-58). Many of these pollutant groups have been recognized by theATSDR, Centers for Disease Control (CDC), EPA, OSHA, and National Institutes of Health (NI H) as hazardous res- piratory pollutants. Health effects of air pollution and childhood vulnerability Air pollution can cause a range of reactions in the human body, from acute to chronic effects (59). A number of health impacts can result, including respiratory irritation, heart disease, lung disease, and increased susceptibility to acute and chronic infections (59). The developing respiratory system is vulnerable to air pollution for a number of reasons. First, children's respir- atory systems are growing. At the time of birth, the human lung has about 24 million alveoli (60), which represents a fraction of the remaining alveoli needed to develop to allow for a completely functioning respiratory system. It has been estimated that approximately 80% of the alveoli are developed postnatally and continue to develop throughout adolescence (61). The first years of life are con- sidered to be an especially vulnerable period of time (62). From birth to age four, the alveolar count in the human lungs is estimated to increase from roughly 24 million to 257million (60). 4" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER Second, due to their smaller size, children's develop- ing respiratory systems are more exposed to air pollution. Children have a larger lung surface area per kilogram body weight ratio than adults (60). Third, they have nar- rower airways, which also contributes to their increased susceptibility to irritation by air pollution (63). Fourth, children are shorter and thus inhale a greater concen- tration of particulate air pollutants and dust (63). Fifth, children have an increased resting respiratory rate com- pared to adults. Finally, children spend more time out- doors where the concentrations of some air pollutants are highest; and active outdoor play increases ventilation rates, thus incroasing exposure to air pollutants relative to adults (60, 64). Tropospheric ozone Exposure standards and ozone levels near UOG sites During the hydraulic fracturing process, diescl-powered trucks haul millions of gallons of water, chemicals, and tons of silica sand to and from the well sites (24, 65, 66). Diesel engines reloase exhaust containing NOx and VOCs (13, 24). The use of diesel -powered trucks, then, becomes Ozone level reported, ppb 200 180 160 140 - 120 100 80 60 40 - 20 0 UBUT, Utah 140 11 important because tropospheric or ground level ozone forms when NOx react with VOCs in the presence of sun- light (13, 24). Moreover, the reloase of NOx and VOCs also occurs with the use of diesel -powered equipment during site preparation, drilling, extraction, transportation via pipelines, at compressor stations (24, 65, 66). The federal government sets standards, like the National Ambient Air Quality Standards (NAAQS) for cri- teria pollutants based on levels esti mated to pose a health risk. Thesestandardsareintended to protect public health. A number of field studies and air quality models have reported ozone levels exceeding the NAAQS of 75 ppb (10, 12-14). For example, Schnell et#al. (10) assessed winter- time air quality near a gas field in the Upper Green River Basin, Wyoming (UGRB), and found 8-h ozone average concentrations exceeding 120 ppb. Oltmans ettal. (12) also reported winter -time ozone 8-h average concentrations up to 120 ppb. Because high ozone production is considered an urban summer -time phenomenon, the levels reported in these field studies throughout several winters is highly uncharacteristic (12, 13). These winter -time ozone events are likely occurring near other sites with similar topogra- phy (12, 13). Reference exposure levels (RCLs) are guidelines and are intended to describe concentrations to which one can 1-h and 8-h ozone average measurements compared to NAAQS and REL "UGRB. Wyoming March, 2011 120 Helmig et al., 2014 UGRB, Wyoming 2011 166 `UGRB, Wyoming February. 2008 122 Oltmans et al., 2014 Rappengleuck et al., 2014 Study name Schnell et al., 2009 I 8-h NAAQS standard —s— 1 h OEHHA REL Figure 1:" Held study measurements for ozone near UOG development sites. Locations with * indicate an 8-h average. The red line indicates Office of Environmental Health Hazard Assessment (OEHHA) Acute (1-h) REL Critical effects above this level include (1) eye irritation and (2) minor changes in lung function tests. The orange line indicates 8-h National Ambient Air Quality Standard (NAAQS) for ozone. DE GRUYTER Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health$ tins 5 be exposed for an hour without developing adverse health outcomes (Figure#1). Two studi es have reported 1-h average ozoneconcentrationsabovetheCalifornia'sOfficeof Envi- ronmental Health Hazards Assessment's (OEHHA) acute inhalation RD_ (13, 14). Modeling studies in the Haynes- villeand Barnett Shales have also reported increased NOx and ozone levels in UOG regions (11, 67), and increases have been measured in active production areas in New Mexico (47). In Wyoming and Utah, local ozone emissions resulted from oil and gas production (12). Acute respiratory symptoms (shortness of breath, wheezing and cough), airway inflammation and pulmonary function Several studies have focused on the impact of ozone on the respiratory system of infants (68). Changes in respira- tory epithelium and hyper -responsiveness due to ozone exposure has been reported (17). Studies have also shown that breathing ozone can load to the initiation of systemic inflammatory processes (18) and respiratory tract and lung inflammation (19). Although the newly proposed NAAQS for ozone is set to be lowered to 0.70#0pm (70 ppb) in 2017 [currently, it is0.7545pm (75ppb)], exposure concentrations as low as 0.08#0pm (8 ppb) have been reported to result in significant increases in inflammatory markers (i.e. neutro- phils, prostaglandins, and inflammatory proteins) (19). Other studies have implicated ozone exposure during childhood with reductions in lung function. Forced expira- tory volume (FEV1) and pcak expiratory flow (PEF) have been used to assess the effects on lung mechanics from exposure to ambient ozone and can be used as markers for reduced lung function. Kinney et#al. (20) determined that children exposed to ambient ozone experienced decrea,es in FEV1. A number of other studies have also reported an association between ambient ozone and decreascs in lung function particularly in children and adol escents (20, 21, 69). Immune response and infections In addition to causing changes to the respiratory system, ozone is believed to affect immune response leading to more lung infections. Studies have reported an associa- tion between ozone and an increase in susceptibility to Influenza A infection due to alteration of the pulmonary protease function (22). Specifically, ozone appears to be able to injure the respiratory system and airway epithelial cellsresulting in reduced microbial clearance and incroas- ing susceptibility to infection (70, 71). Studies of adults 65#oars and older demonstrate an increase in hospitali- zations due to pneumonia and exacerbations of chronic obstructive pulmonary disease when environmental ozone levels increase (72); data in children is currently lacking. Asthma Some evidence from studies suggests that ozone is impli- cated in the induction of asthma in children (23). As part of the Children's Health Study (CHS) study, McConnell and colleaguesfollowed 3535 children (9-16/t'earsold) with no previous diagnosis of asthma at baselinefrom 1993to 1996 in 12 communities across California and reported that where levels of ambient ozone were in the "maximum" range there were 259 newly reported cases of asthma (23). Other studies have shown that chronic exposure to ozone can cause an increase in respiratory symptoms and exacerbation of pre-existing asthma (73-75). Ground -level ozone concentrations tend to be the highest on warm and sunny days. It is also during these times that children are more likely to be outdoors playing (60). An association between ozone exposure and hospi- talizations for adverse respiratory health effects has been reported (76), particularly for an increase in emergency department (ED) visits and hospitalizationsdueto asthma (77-81). The Study of Particles and Health in Atlanta (SOPHIA), which was conducted during the time period between 1993 and 2004 in metropolitan Atlanta, Georgia, evaluated morethan 90,000 pediatric ED visitsfor asthma in relation to air pollution (including ozone). After con- trolling for confounders, ozone was associated with ED visits for asthma during both warm and cold months of the year (80). School absenteeism In addition to ED visits and hospitalizations, a significant relationship between high ambient ozone and an increase in school absenteeism has been reported (82). Gilliland et#aI. (82) investigated the relationship between ozone and school absenteeism in a cohort of fourth grade schoolchil- dren who lived in 12 communities across southern Cali- fornia. An increase in ozone concentration of 20 ppb was found to be associated with an increase by 62.9% (95% a, 18.4%-124.1%) in rates for absence due to illness, 82.9% (95% a, a9%-222.0%) for respiratory illnesses, 45.1% (95% CI, 21.3%-7a7%) for upper respiratory illnesses, and 173.9% (95% CI, 91.3%-292.3%) for lower respiratory ill- nesses and cough in children 9and 10#(iearsold. 6" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER Particulate matter Exposure standards and PM levels near UOG sites Ambient particle pollution including PM10 and PM2.5, is commonly released into the surrounding air during UOG operations, especially where there are diesel emis- sions (16). PM2.5 in particular poses a significant health concern and interactswith airborneVOCs, thus increasing their impact (83). To our knowledge, there is little avail- able field study data about PM levels near UOG sites and further research is needed. Acute respiratory symptoms (shortness of breath, wheezing and cough), airway inflammation and pulmonary function PM is complex mixture of small particle solids, droplets, dust particles, hoavy metals, radioactive materials, and/ or other organic chemicals that have become suspended in the air and are small enough to be inhaled (27, 59). The most health -damaging particles are those with an aerody- nami cdiameter of 10 ccm or less, ($1M10), becausethey can penetrate and lodge deep inside the lungs (84). Particles with an aerodynamic diameter of 2.5-10 -km are consid- ered coarse; those with a diameter smaller than or equal to 2.5 xm are considered fine particles. It is important to consider particle size because hoalth impacts are influ- enced by this factor. For example, particlesizedetermines where parti cl es are deposited in the lung. Coarse particles (2.5-10 gym) are usually deposited in the upper respiratory tract and large airways; fine particles ($$.5 -nn) may reach terminal bronchioles and alveoli. Moreover, compared to large particles, fine particles can remain suspended in the atmosphere for longer periods and be transported over longer distances (8). PM affects more people than any other pollutant and contributes substantially to negative impacts, includ- ing respiratory and cardiovascular disease and prema- ture mortality (85). Children are a particularly affected subgroup, especially when they are physically active, as breathing faster increases the particle intake. In addi- tion, children's lungs are still developing, and, they are more likely to get respiratory inflammation and infections infections. These conditions are exacerbated when envi- ronmental PM concentrations are high (86). Particulate pollution is linked to a variety of health effects including onset and exacerbation of asthma (87), irritation of airways, coughing, wheezing, chest tight- ness, and shortness of breath (88). High concentrations of particulates are of concern because they absorb airborne chemicalswhich deposit in the lungsand can lead to local or systemic diseases (83). The International Agency for Research on Cancer (IARC) has recently classified the particulate matter com- ponent of outdoor air pollution as a class I carcinogen. Considering the 10-20 year latency period for cancer, it is reasonable to say that childhood exposure to PM plays a role in the later development of cancer (89, 90). Particulate pollution affects respiratory hoalth, lung development, and lung function in children (as meas- ured by FEV1$torced expiratory volume in 1 second and PEFS15eak expiratory flow) (25, 91, 92). As part of CHS, Gauderman et#al. (25) studied lung development in chil- dren living in 12 southern Californian communities from age 10 to age 18 and correlated the findings with expo- sures to ambient particulate matter. Exposure was asso- ciated with clinically and statistically significant deficits in the FEV1 attained at the age of 18 years. In all 12 com- munities, a low FEV1 was positively associated with levels of exposure to pollutants including PM10 and PM2.5(25). In an experimental study of rat lung tissue, oxidative stress responses to ambient particles from motor vehi- cles were evaluated, and a significant increase in lipid peroxidation (an indicator of oxidative stress) was seen in lung tissue immediately following 20th of continuous exposure, but not following a 6-h exposure or intermittent exposures (93). As with ozone, children's higher ventila- tion rates and increased lung surface area may make them moresusceptibletooxidativestressresultingin inflamma- tion, airway injury, and disease (26). Long-term exposure to PM is associated with airway remodeling and chronic inflammation (27 28). Immune response and infection Pulmonary inflammation resulting from PM exposure may trigger systemic inflammation through the action of cytokines and other mediators which enter the general circulation from the lungs (94). Coarse particles deposit in the lung and then subsequently cause the release of cytotoxic and inflammatory markers in plasma (e.g. inter- leukin-6 and interleukin-8). The bone marrow releases leukocytes and platelets in response to the lung inflam- mation and is an important component of the systemic inflammatory response (95). In response to lung inflam- mation, leukocytes and platelets are released from the bone marrow, stimulating further immune responses. Studies have reported that PM can increase bron- chitis symptoms (96) and hospitalization rates for severe DE GRUYTER Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health$ $ 7 respiratory infections (97, 98). Components of PM2.5 have boon associated with hospitalizations for several child- hood respiratory diseases including pneumonia, bron- chitis, and asthma. PM sources include diesel exhaust, motor vehicle emissions, and fuel combustion processes (97). Positive associations between PM exposure and hos- pital admissions for respiratory infection are supported by animal toxicological studies. Research demonstrates reduced clearance of bacteria (Pseudomonas, Listeria) and enhanced pathogenesis of viruses[influenza, respira- tory syncytial virus (RSV)] asa result of PM exposure (99). An increase in hospitalizations due to respiratory infection for children has also boon documented (98). Lin ettl. (98) examined the association between ambient air pollution and respiratory infections in children under 154/ears in Toronto, Canada, between 1998 and 2001. Even at low levels of air pollution (under many standard guide- lines), levels in the study were shown to have a significant effect on hospitalization rates due to respiratory infection. Outdoor air pollution could contri bute to respiratory infec- tious disease in infants by causing ongoing inflammation in the lungs. Sheffield et#al. (100) looked at several air pollutants, but specifically at fine particulate matter and ozone, which arethepollutantswith thestrongest evidence linking them to adverse respiratory outcomes and found an association between these pollutants and hospitaliza- tion. Their findings support the hypothesis not only that short-term exposure to particulate matter (the one -month average) is associated with more severe bronchiolitis, but also that longer exposure duration - the average over the lifetime of the infant - shows a stronger effect. Respiratory symptoms and asthma Both the onset of asthma symptoms and diagnosed asthma have boon associated with exposure to ambient particulate matter (101). Peak concentrations of ambient fine parti culates have boon associated with early increases in bronchodilator use and urinary leukotriene E4 levels among children with persistent asthma (102). A recent systematic review reported that ambient PM2.5 levels have also been found to be associated with an increase in asthma ED visits (103). Mar et#al. (104) studied asthmatic children and adults in Spokane, Washington. Increases in PM were strongly associated with cough (104). When all lower respiratory tract symptoms (wheezing, cough, shortness of breath, sputum production) were grouped together, positive associations in children were reported for each 10#7g/m3 increase. Sputum production and runny nose were associated with PM10 and coarse fraction. However, no association was found between increases in PM and the presence of any respiratory symptoms in the adult subjects, suggesting that children are more sensitive than adults to the effects of increased levels of PM air pollution. In the National Cooperative Inner -Qty Asthma Study (NCI CAS) (105), for the three urban areas with air quality data, each 10 cxg/m3 increase in the mean of the previous 2days' PM10 value increased the risk for morning asthma symptoms. Particulate pollution may also playa role in the exac- erbation of pre-existing asthma (96). A meta -analysis found that there can be an aggravation of health effects among asthmatics exposed to PM10 (106). An increase in symptoms (cough and phlegm production) and lower pul- monary function among asthmatics has been reported (96, 106-108). In CHS, children with pre -diagnosed asthma had greater lower respiratory tract symptoms (bronchitis and phlegm production) if they resided in communities where therewere higher levels of PM10 and PM 2.5(96). In addition, there was an increased risk for bronchitis symp- toms in children with asthma when there was a 19 fg/m3 increase in PM10. Exposure to an increase in PM10 of 10 rkg/ m3 i n 1 day reportedly l eads to an increase i n severity of asthma symptoms and an incrcase in adverse respiratory function in asthmatic children (109, 110). Exposure to ambient particle pollution may cause asthma by inducing oxidative stress mechanisms and pul- monary inflammation. Exposure to particulate matter can cause the development of lung injury via oxidative stress mechanisms and pulmonary inflammatory response (27 29, 111). Specifically, oxidative stress mechanisms cause epithelial cells in the airway to express inflammatory cytokines (29) and chronic inflammation resulting in asthma. Silica dust Exposure guidelines and silica dust levels near UOG In the UOG industry, huge quantities of silica sand are used. Tons of silica sand are added to cach UOGwell site's fracturing fluid during each `frack job', which may be repeated at intervals. Silica sand is used in hydraulicfrac- turing in order to prop open fissures in theshaleand facil- itate the flow of trapped natural gas (112). Silica occurs in two general forms, crystalline and amorphous. Crystalline silica is generally considered to be more toxic, although health concerns exist for both forms. Silica sand used in fracking is crystalline silica. Transport and use of sand 8" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER during fracking emit respirable particles of silica into the air at fracking sites, particles that are small enough to be breathed dccp into the lungs (112). Exposure to fine respirable silica can occur even before the drilling process, when the sand is being mined and extracted, transported in trucks to the distant well pads, or during the process of blending the sand with other hydraulicfracturefluid ingredients(16, 112). Several studies have focused on silica dust dispersion in air and concern for workers near well pads and UOG sites (15, 113-115). Crystalline silica air concentrations have boon reported above occupational health standards at oil and gas sites (15, 115). A NIOSH study documented that worker exposure to silica dust used during UOG opera- tions exceeded occupational health standards at every site tested. Some exposures exceeded NIOSH standards by a factor of 10 or more. Esswein and colleagues col- lected air samples from 11 sites in five states to assess worker exposure levels. More than 50% of the samples collected indicated that silica exposures were higher than OSHA permissible exposure level (PEL) and 68.5% indi- cated thattbxposures were higher than the NIOSH REL of 0.05t#mg/m3 (15, 116). Furthermore, NIOSH (112) showed that even those workers not working directly with silica were still exposed to respirable silica sand. This is because silica particles become airborne and high concentrations were found in places that were downwind of operations involving silica sand (112). Given the focus on worker health in relation to silica, very Iittleisknown about safeexposurelimitsfor children. The health risks associated with silica dust The hoalth risks of silica exposure are related to the oase with which thetiny particlesof silica dust are inhaled and are able to reach the deep alveolar recesses of the lungs (15, 112, 117). Respirable silica dust can damage respira- tory cells resulting in scarring and subsequent irreversible chronic pulmonary fibrotic disease or silicosis (118). Silica dust can also lead to lung cancer and to an increased sus- ceptibility to tuberculosis (15, 119-122). Silicosis Silicosis has only boon linked to silica dust particle expo - sure and not to any other common respiratory irritants or toxins, such as environmental tobacco smoke. Symp- toms of silicosis include dry cough, sputum, shortness of breath, and reduced pulmonary function (117). Silicosis can be categorized into three types: chronic, acute, and accelerated. Chronic silicosis develops over a course of more than 10%earsof exposure, whileaccelerated silicosis develops over 5-10A/ears of exposure (117). Acute silicosis is less common than the other forms, but develops over the course of a few months or a few years of exposure to very high levels of respirable crystalline silica, and frequently results in death or disability (112). Silicosis is often called a silent killer, because any symptoms associated with it might not be obvious until a thorough medical examina- tion is done (112). There is no known effective treatment for this lung disease (123). Potential implications for vulnerable populations Silicosis is often described in the scientific literature as an occupational disease because most existing epidemio- logical studies have focused on populations of workers employed by industries that mine or use silica. However, there is also concern for potential exposure and similar health outcomes for local residents who live in close proximity to these industrial sites. This includes children whose homes, backyards, and school grounds are located noar UOG sites or silica sand transfer stations. Because silica dust particles are easily dispersed in the air (15), vulnerable populations such as children may be easily exposed and are especially at risk. Oven the long latency of developing silica -related health problems (10#years or more), it may be years or decades before adverse health effects become apparent. Interestingly, Kanatani et#al. (124) reported that fine desert dust particles can cause asthma exacerbations and an incroased risk of hospitalizations for asthma in pediat- ric populations. They reported that desert dust includes quartz, the most common form of crystalline silica. Future research should focus on enhancing knowledge concern- ing long-term effects of silica dust on children. Benzene Exposure standards and benzene emissions from UOG VOCs can be released during many stages of the UOG lifecycle (40). Benzene, toluene, ethylene, and xylene (BTEX), a tetrad of VOCs, are commonly found in petro- leum products such as gasoline and diesel fuel, and are also found to be associated with UOG operations (125). Oil and natural gas operations al so rely heavily on the use of diesel -powered equipment and transportation in each step of the process (16, 40), releasing VOCs. DE GRUYTER Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health$ An$ 9 Table 2:" Inhalation MRLs for benzene at different exposure durations. Benzene inhalation minimum risk levels (MRLs) Exposure duration M RL, ppm MRL, tag/ m$ Acute (°/ days) Intermediate (&. -+, - days) Chronic (°/d, . days) ( Benzene conversion factor: 1!ppm94%26 mg/ m3 at 20"C. aATSDR's inhalation MRLs provide estimates of daily human exposure to a hazardous substance at or below which that substance is unlikely to pose a measurable risk of harmful (adverse), noncancerous effect. MRLs are guidelines, not standards like Pas or NAAQS. The threshold for developing an adverse health response is significantly less for people experiencing chronic exposures. Individuals residing near UOG sites may more likely experience chronic exposure and be subjected to emissions up to 24!h a day. Benzene is both a petroleum byproduct as well as an organic compound that occurs naturally in shale rock and other hydrocarbon deposits and is released into the air throughout the UOG development. Benzene emissions Benzene level reported, ppb 3.5 3 2.5 2 1.5 1 0.5 0 A _ UBUT. Utah 3.1 are released from wells, production tanks, compressors, and pipelines(38, 52, 115). Anumber of UOGstudieshave identified benzene as a potential hoalth risk (2, 13, 38, 53, 126). Exposure to benzene can occur through inhalation, oral, or dermal exposure, and benzene can volatilize into the air from water and soil (127 128). Concentrations have been reported near UOG sites that significantly exceeded the minimal risk level (MRL) established by the ATSDR (Table/2) and were associated with health impacts on resi- dents (Figuret2) (38). Acute respiratory symptoms (shortness of breath, wheezing, and cough), airway inflammation and pulmonary function The health effects of benzene are well -described in the literature (15, 33, 112, 117, 118, 120, 121) and epidemiologi- cal studies have documented the relationship between ambient benzene and respiratory hoalth in children (33). In addition to being a carcinogen (122), benzene is also Benzene levels reported compared to chronic effects screening level —A— Chronic effects screening level by TCEQ Washington county, Pennsylvania 1.8 Helmig et al., 2014 Macey et al.. 2014 Study name Figure 2:" Held study measurements for benzene near UOG development sites. Helmig et!al. reported average benzene levels based on 330 measurements (13). Macey et!al. reported one measurement for Washington County, Pennsylvania (38). These values are compared to the chronic effects screening level guidelines set by the Texas Commission on Environmental Quality (1.4 ppb)*. *Effects screening levels (ESLs) are guidelines and have been used as a reference point in studies (13). They are not enforceable and are established by the Texas Commission on Environmental Quality (TCEQ). 10" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER Table 3:" Inhalation MRLs for formaldehyde at different exposure durations.' Formaldehyde inhalation minimum risk levels (MRLs) Exposure duration MRL ppm MRL, Ltg/ m5 Acute (To% days) Intermediate (&. -+, - days) Chronic (°/ . days) * * Formaldehyde conversion factor: 1 ppm%%24 mg/ m3 in air at 25VC. (=ATSDR's inhalation MRLs provide estimates of daily human expo- sure to a hazardous substance at or below which that substance is unlikely to pose a measurable risk of harmful (adverse), non- cancerous effect. MRLs are guidelines, not standards like Pas or NAAQS. The threshold for developing an adverse health response is significantly less for people experiencing chronic exposures. Indi- viduals residing near UOG sites may more likely experience chronic exposure and be subjected to emissions up to 24 h a day. a respiratory irritant and can pose serious risks to res- piratory health (129, 130). In children, benzene exposure has also been associated with adverse respiratory health outcomes, including increased occurrence of cough and wheezing (30-32), and increased incidence of airway infections and bronchitis (36, 37). Two studies have also assessed lung function in rela- tion to ambient benzene exposure (34, 35). Martins et#bl. (35) evaluated the relationship between individual total exposure to air pollution and airway changes in 51 chil- dren with wheezing in school settings (classrooms and courtyards) as well in their place of residence. Respira- tory effects were assessed four times over a 1 -week period. Benzene was associated with a significant decrease in FEV1 (95% a, -713 to -1.53), FEV1/FVC (95% CI, -3.24 to - 0.18) and FEF (25%-75%) (95% CI, -10.16 to -1.62) and an i ncroase of L FEV1 (95% G , 0.92-4.65) (35). VOC mixtures may also be responsible for increased lung inflammation. An inflammatory response and a sig- nificant increase in inflammatory markers was observed in#a study which assessed indoor exposure to VOCs (25#ng/ m3 total hydrocarbon) in men (131). Immune response and infections In addition to acute respiratory symptoms, chronic bron- chitis and pulmonary infections have been reported to be associated with benzene exposure (36, 37). The Leipzig Allergy High -Risk Children Study (LARS) assessed indoor chemical exposure on the health of infants with a risk for allergic hypersensitivity. The study followed 475 pre- mature infants for 1 year and evaluated associations between VOC exposu res and infections. Twenty-fiveVOCs were measured in infants' bedrooms using passive air sampling for 4 weeks following birth. Ambient benzene at levels greater than 5.6 ocg/m3 increased the risk of pul- monary infections in babies 6 weeks old (95 % CI, 1.28- 4.48) (36). Respiratory symptoms and asthma VOC ex posu res are associated with an increase in respira- tory symptoms. Ware and colleagues assessed the rela- tionship between effects of ambient VOC exposures and respiratory symptoms in 8549 children living in Kanawha, West Virginia, a chemical -manufacturing region. The VOCs were found to be associated with an increase in res- piratory symptoms in relation to VOC exposure (132). Asthma is associated with exposure to ambient benzene. (30, 33, 34, 133-135). Several epidemiological studies concerning the relationship between benzene air exposure and respiratory health among children and adolescents found significant associations between benzene exposure and asthma (33). These included both an increase in asthma symptoms (135) and an increased risk of developing of asthma (134). Formaldehyde Exposure standards and formaldehyde emissions from UOG Another volatile compound associated with UOG is formaldehyde. Formaldehyde is produced at numer- ous points during the UOG lifecycle and is commonly emitted from compressor stations. Formaldehyde can also form from the chemical reaction caused by sun- light interacting with NOx and VOCs (39). Formalde- hyde has been found in air samples in a drilling dense area in Garfield County in rural Western Colorado and near residential sites (39). Concentrations have been reported near UOG sites that significantly exceeded the MRL (Tablet) established by the ATSDR. ATSDR's MRLs are estimated guidelines that describe daily human exposure to a hazardous substance that is likely to be without appreciable risk of adverse noncancer health effects over a specified duration of exposure. Macey etllal. (38) found formaldehyde levels in three coun- ties that exceeded ATSDR's MRL for chronic inhalation ($365 days) (Figure#3). These levels were associated with health impacts on residents (38). DE GRUYTER VVebb et!al.: Hazards of UOG emissions on children's and infants' respiratory health$ $ 11 Formaldehyde level reported. ppb 40.0 35.0 30.0 25.0 20.0 15.0 10.0 5.0 0.0 Formaldehyle levels reported compared to chronic inhalation minimum risk level (MRL) Park county 37.5 4 Wyoming *Faulkner county 29.1 Arkansas State *Cleburne county 24.8 Arkansas Macey et al., 2014 —A— ATSDR Chronic Inhalation MRL A Figure 3:" Reid study measurement for formaldehyde reported in Macey et!al. (38) compared to chronic inhalation rak5 days) MRL of 8 ppb. Values with * indicate levels for which averages were taken. Macey et!al. reported a single value for Park County. Acute respiratory symptoms (shortness of breath, wheezing, and cough), airway inflammation and pulmonary function In children, formaldehydehasbccn identified as a respira- tory tract irritant (119, 136-140). Exposureto formaldehyde can lead to respiratory symptoms (e.g. chest discomfort, difficulty breathing, wheezing, etc.) (41), reduction in pul- monary function (43, 141), acute respiratory tract illness (42), and asthma (44-46). Formaldehyde initiates inflammation by induc- ing oxidative stress in lung tissue (142). The pulmonary inflammatory response mechanisms are then responsible for the development of lung diseases and reductions in lung function (45). Immune response and infection Formaldehyde also appears to inhibit beneficial immune responses. A significant increase in immune biomarkers in children exposed to high levels of formaldehyde was found in one study (143). Both animal and human studies have indicated that formaldehyde impairs the develop- ment of an allergic response in the lungs (142, 144). Asthma Studies have suggested a link between inhalation expo- sure to formaldehyde and the development of asthma (45,#140, 145). Rumchev et#al. (140) reported that their casc control study of children residing in Australia indi- cated that formaldehyde exposure was associated with asthma. McOwin . (46) conducted a systematic review and found a positive association between formaldehyde exposure levels and childhood asthma. In a cross-sec- tional study on indoor formaldehyde exposure in Swedish schools, re.carchers reported that there were more stu- dents with current asthma in schools where there were higher levels of formaldehyde and other VOCs (146). Di scussi on Based on the literature indicating adverse impacts from air pollution on children's health in other contexts, there is potential for adverse respiratory effects in infants and children in the context of UOG. Our review shows that at least five of the pollutant groups used and/or produced by UOGprocesses have well-known respiratory health effects for infants and children. 12" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER Health risks identified Our review found that these five pollutants are associated with increased respiratory problems in children: asthma prevalence and incidence, chronic and acute respiratory symptoms, adverse lung function and development, and airway inflammation. It is also reasonable to conclude that young children with fragile, developing respiratory systems who experience frequent exposures to these pol- lutants are at particularly high risk for respiratory tissue injury leading to irreversible pulmonary damage and chronic respiratory diseases. General policy recommendations Emission reduction standards In order to ensure public health and safety, especially for infants and children, we recommend federal stand- ards that reduce air pollutant emissions from oil and gas development, including methane, VOCs, PM, and ozone. The EPA's proposed measures to cut methane and VOC emissions from the oil and natural gas industry will not only address climate change, but also reduce the expo- sure of nearby communities to these pollutants and the subsequent risk of health effects, including respiratory morbidity and mortality. The proposed rule is projected to prevent between 170,000 and 180,000 tons of VOCs and 1900-2500 tons of HAPsfrom new sources in 2025(147). At thistime, the proposed rule only addresses new and modi- fied sources and further steps will be required to address existing sources. Many practices and technologies to reduce emissions already exist and their implementation is not only feasible, but cost-effective as well. Increased setbacks from sensitive receptors Setback distances from UOG development are intended to protect the health and safety of residents (148), includ- ing infants and children. Many states establish setback rules with an average distance of 100-1000 feet from a permitted well and sensitive receptors such as schools, hospitals, churches, and other occupied dwellings (149). However, the majority of municipal setback ordinances are not supported by empirical data. Established setback ordinances are typically the result of negotiation between stakeholders (e.g. residents and municipal policymakers) (148). Calls for increased setback distances are due to the potential health risks associated with residing or working in close proximity to UOGdevelopment. Individuals resid- ing within close proximity (less than or equal to % mile) to high -density drilling areas are at greater risk for health effects from exposure to natural gas development than those living greater than % mile from wells (53). A recent report documented that approximately 53,000 children residing in Pennsylvania under the age of 10 live within a mile of permitted well sites (150). We recommend that at a minimum, one -mile setbacks should be established between drilling facilities and occupied dwellings such as schools, hospitals, and other dwellings where infants and children might spend a substantial amount of time. Strengthening standards for tropospheric ozone Our review found that levels of ozone pollution is a leading contributor to asthma exacerbations and has been linked to a range of other respiratory impacts, and infants and children are disproportionately affected. We know from air monitoring research that ozone levels near UOG sites of oil and gas development can exceed regula- tory limits. Both public health professionals and environ- mental advocates support strong national standards for ground -level ozone. In 2015, the EPA's Clean Air Scientific Advisory Com- mittee (CASAC) Ozone Review Panel recommended low- ering the standard to 60 ppb. A health protective level of 60 ppb would begin to address some of the hoalth risks facing children living or attending school near oil and natural gas development. Despite the recommendation put forth by CASAC, in October 2015, the new threshold for ground -level ozone was set at 70 ppb (to go into effect in 2017). This new standard falls short of what many envi- ronmentalists and public hoalth experts recommended. Ozone often triggers asthma attacks, coughing, wheezing, and increases emergency room utilization for severeasthmaticexacerbations. It has been estimated that had the standard been set at 60 ppb this action: "Would prevent up to 7 900 premature deaths and 1.8 million asthma attacks and 1.9 million school days missed in 2025, for all counties in the US expected to meet the standard that year" (151) Reducing ozone levels near UOG potentially improves children's health and decreases school absenteeism. In the C -IS, the largest long-term study of the health effects of children's chronic exposures to Southern California's air pollution to date, reductions in ambient ozone levels in Southern California between 1990 and 1999 reduced school absences by 2.8 million (152). A more recent DE GRUYTER Webb et!al.: Hazards of UOGemissions on children's and infants' respiratory healthS gnS 13 estimate found a reduction of 1 million absences annually if more strict ozone standards were put in place (153). A stronger ozone standard would also have provided significant public health protections for children and the elderly, those most vulnerable to the ozone's impacts. OSHA standards for respirable silica dust Approximately 1.7 million workers in the United States are exposed to respirable silica dust every year (154). In 2013, OSHA proposed new rules for occupational expo- sure limits to silica dust. The recommended permissible exposure limits was set at 50 ricgl m3 for an 8-h day. OSHA estimates that the proposed rule will save 700 lives and prevent 1600 new cases of silicosis annually (155). New protection standards were announced in March 2016. We support the finalization and enforcement of these new rules; the protective standards will protect not only workers, but also infants and children living noar UOG sites who are often in their house or yard for almost the whole day. EPA New Source Performance Standards (NSPS) for methane In August 2015, the US EPA announced new NSPS for methane and VOCsfor new and modified sources of release from UOG. These new standards will significantly reduce methane releases by 40%-45% and are estimated to reduce VOCemissions by up to 95%. This will improve air quality and decrease ground -level ozone, which, as shown in theliterature, can be problem for infants and children. We recommend these standards be finalized and that this NSPS be expanded to cover existing UOGfacilities. The health burden and economic impact of childhood asthma Asthma affects over 71 million children in the United States under 18%earsand isthethird cause of hospitaliza- tion among children under 15 yours. In 2010, there was an estimated 640,000 emergency room visits due to asthma for children under 15 years. Asthma is one of the leading causes of school absenteeism, and in 2008, asthma was responsible for an estimated 14.4 million lost school days in children (156). The annual direct and indirect cost (i.e. lost days of productivity) for treating asthma in the United States is estimated to be $56 billion (156). Policies to reduce the asthma burden created by UOG are an impor- tant part of reducing these costs. Transparency and disclosure: clinical implications We strongly recommend policies that strengthen disclo- sure and transparency about chemicals used in UOG. Due to the 2005 Energy Policy Act, a number of chemi cal s asso- ciated with UOGarenot reported to the public. Disclosure of chemicals is critical to be able to understand the full scope of respiratory health effects for infants and children. In a 2011 study by Col born ettl . (157), the authors evalu- ated possible health impacts of chemicals used in UOG and found that over 80% of these chemicals are linked to negative respiratory impacts (n$$53). However, the study was limited because of the lack of transparency about the chemical mixtures used in the UOG process. Precautionary approach In order to protect the health of children and wellbeing of families, state, federal agencies, and authoriti es should adopt a precautionary approach when establishing per- mitting rules and standards for UOG development and production. Thisalso applies to enforcement of standards for air emissions near UOG sites. The federal government sets standards for many air pollutants, based on an esti- mated risk of health effects at a certain level. Currently, the EPA uses a narrow view of variability and vulnerability in their risk assessment caused by differences in genetic makeup, metabolism, and age of exposures. Therefore, current risk assessment practices provide inadequate pro- tection to the most vulnerable populations, such as infants and children (158). Even when air pollution meets current regulatory levels, adverse respiratory health effects have been reported in children and adverse health effects have been identified at levels once considered safe(159). Research needs Improved exposure assessment While we strongly support a precautionary approach that prevents children's exposure, we recommend that well - designed biomonitoring studies should be undertaken to moasure existing exposures to pollutant groups associ- ated with UOG. Currently, only a small number of studies document a causal relationship between pollution created by UOG operations and undesirable health outcomes. 14" Webb et!al.: Hazards of UOG emissions on children's and infants' respiratory health DE GRUYTER Better population exposure assessment is needed to docu- ment these relationships. The most accurate way to obtain information about human exposures from environmental pollution is through well -designed biomonitoring studies. Air monitoring and modeling This review documents that air pollution can present sig- nificant health threatsto infants, children, and otherswho live near UOGsites. Identification and quantification of air pollutants is an essential part of demonstrating success- ful risk reduction and ensuring compliance with national standards. There are a number of different methods used to capture air quality data, from community monitoring to remote sensing of regional emission concentrations. UOG companies should fund better real-time monitoring of air pollutants near UOG operations. Models need to be developed that can account for simultaneous exposures to multiple pollutant groups. Synergistic mechanisms and bioaccumulation of air pol- lutants are important when assessing respiratory health outcomes. Review limitations and considerations This review is not exhaustive in scope. We focus on five particular air pollutants of concern and do not discuss a number of other air pollutants, such as hydrogen sulfide, polycyclic aromatic hydrocarbons, NOx, and naturally occurring radioactive materials. The studies we reviewed evaluated exposures in a variety of settings. For example, some of these studies assessed pollutant atmospheric concentrations while others assessed urban- and traffic -related pollution. We also examined exposures from some of these pollutants in both indoor and outdoor settings. The relevance to expo- sures near UOG sites varies. Additionally, we were restricted in our assessment by current understanding of some respiratory health effects and their relevance for children living near UOG areas. There remains a dearth of information about UOG i mpacts on children. Respirable silica is an example where little data about children exists. There is scientific consensus that 1) silica dust causes silicosis and that 2) exposure to quartz dust can lead to an increase in hospitalizations for respiratory illness. But the long-term effects of silica dust on children residing near UOG operations remain to be determined. There isa long latency period for silicosis, lung cancer, and some other respiratory illnesses, so it may be decades before we can document these relationships. We also did not explore alternative energy sources that may provide a solution to our energy needs without the negative health impacts found with UOG. If we move away from UOG, we need to be cognizant that our energy needswill not go away and that we should support health- ier energy choices. Conclusion We conclude that exposure to ozone, PM, silica dust, benzene, and formaldehyde is linked to adverse respira- tory health effects, particularly in infants and children. However, the scientific literature examining the direct impact of shale gas and oil development on children is just starting to emerge. In the absence of direct evidence on levels of expo- sure and adverse health outcomes among infants and children due to UOG air pollution, our focus on key air pollutants and the vulnerability of children serves to identify potential health risks as well as to promote additional research in this area. Research indicates elevated air pollutant emissions and/or atmospheric concentrations in areas with UOG development as well as increased health risks, driven by pollutants such as benzene. Meanwhile, a growing number of epidemiologi- cal studies indicatethat oil and gas development isasso- ciated with adverse health impacts, such as increased birth outcomes, hospitalization rates, and reported health symptoms per person (2, 160, 161). These initial results are consistent with the existing body of epidemi- ology that observes the impact of air pollutant exposure on children more generally. Webelievethat protecting children's health isa social, scientific, and ethical priority. Large-scale and long-term epidemiological studies are needed but we strongly rec- ommend precautionary moasuresat this time, in order to protect the health of infants and children. References 1. Hill EL Shale gas development and infant health: evidence from Pennsylvania. Charles H Dyson School of Applied Economics and Management, Cornell University, Working Paper Available at [Internet]. 2013 [cited 2015 WI 13]; Available at: http://www.ncsu. edu/ cenrep/ workshops/ TRFF/ documents/ Hi II . pdf. 2. McKenzie LM, Guo R, Witter RZ, Savitz DA, Newman LS, et!al. Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado. Environ Health Perspect [Internet]. 2014 Jan 28 [cited 2014 Oct 171;122(4). 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Available at: http://aspe. hhs.gov/ sp/ asthma/ appxh.pdf. 142. Lino dos Santos Franco A, Domingos RV, Damazo AS, Bre- ithaupt-Faloppa AC, de Oliveira APL, et!al. Fbduced allergic lung inflammation in rats following formaldehyde exposure: long-term e0ects on multiple e0ector systems. Toxicology 2009;256(3):157-63. DE GRUYTER Webb et!al.: Hazards of UOGemissions on children's and infants' respiratory health$ An$ 19 143. Erdei E, Bobvos 4 Brozik M, Paldy A, Farkas I, et!al. Indoor air pollutants and immune biomarkers among Hungarian asth- matic children. Arch Environ Health 2003;58(6):337-47. 144. Ezratty V, Bonay M, Neukirch C. Onset-Guillossou G, Dehoux M, et!al. EOect of formaldehyde on asthmatic response to inhaled allergen challenge. Environ Health Perspect 2007;115(2):210-4. 145. Daisey JVI, Angell at Apte MG. Indoor air quality, ventilation and health symptoms in schools: an analysis of existing infor- mation. Indoor Air 2003;13(1):53-64. 146. Smedje G, Norback D. Lolling C. Asthma among secondary schoolchildren in relation to the school environment. Olin Exp Allergy 1997;27(11):1270-8. 147. US EPA. Regulatory Impact Analysis of the Proposed Emission Standards for New and Modified Sources in the Oil and Natural Gas Sector [Internet]. 2015. Available at: http://www3.epa.gov/ airquality/ oilandgas/ pdfs/ og_prop_ria_081815.pdf. 148. Fry M. Urban gas drilling and distance ordinances in the Texas Barnett Shale. Energy Policy 2013;62:79-89. 149. Richardson N, Gottlieb M, Krupnick A, Wiseman H. The State of State Shale Gas Regulation [Internet]. 2013. Available at: http://www.r0.org/files/ sharepoint/ Worklmagas/ Download/ Id i -Rot-StateofStateFegs_ Report. pdf. 150. Rdlington, Dutzik T, Van Heeke T, Garber A, Masur D. Danger- ous and Close: Fracking Near Pennsylvania's Most Vulnerable Residents. 2015. PennEnvironment Research & Policy Center, Frontier Group 2015. 151. US EPA, O1 ceofAirand Radiation, O1 ceofAirQuality Plan- ning and Standards. Fegulatory Impact Analysis of the Pro- posed Revisions to the National Ambient Air Quality Standards for Ground -Level Ozone [Internet]. 2014. Available at: http:// www.epa.gov/glo/ pdfs/ 20141125ria.pdf. 152. Hall J✓, Brajer V, Lurmann FW.. Economic valuation of ozone - related school absences in the South Coast Air Basin of Califor- nia. Contemp Econ Policy 2003;21(4):407-17. 153. Berman JD, Fann N, Hollingsworth .111V. Pinkerton KE, Rom WN, et!al. Health benefits from large-scale ozone reduction in the United States. Environ Health Perspect 2012;120(10):1404-10. 154. NIOSH. CDC- Silica, Ceneral Publications - NIOSH Workplace Safety and Health Topic [Internet]. 2015 [cited 2015 II 30]. Available at: http://www.cdc.gov/niosh/topics/silica/. 155. Occupational Safety & Health Administration (OSHA). Crystal- line Silica Rulemaking [Internet]. 2014. Available at: https:// www.osha.gov/ silica/ index. html . 156. American Lung Association. Asthma & Children Fact Sheet [Internet]. American Lung Association. 2014 [cited 201511 30]. Available at: http://www.lung.org/lung-disease/asthma/ resources/facts-and-figures/ asthma-children-fact-sheet.html. 157. Col born T, Kwiatkowski C, Schultz K, Bachran M. Natural Gas Operations from a Public Health Perspective. Hum Ecol Fisk Assess 2011;17(5):1039-56. 158. Janssen S, Sass Li Schettler T, Solomon G. Strenghtening Toxic Chemical Risk Assessments to Protect Human Health [Internet]. 2014. Available at: http://www.nrdc.org/health/files/strength- eni ng-toxi c-chemi cal -risk -assessments -report. pdf. 159. Km it American Academy of Pediatrics Committee on Environmental Health. Ambient air pollution: health hazards to children. Pediatrics 2004;114(6):1699-707. 160. Rabinowitz PM, Slizovskiy IB, Lamers V, Trufan Holford! Ik, et!al. Proximity to Natural Gas Wells and Reported Health Status: Fesults of a Household Survey in Washington County, Pennsylvania. Environ Health Perspect [Internet]. 2014 Sep 10 [cited 20151n 4]; Available at: http://ehp.niehs.nih. gov/ 1307732. 161. ,bmielita T, Orton GL, Neidell M, Chi llrud S, Yan B, et!al. Unconventional gas and oil drilling is associ- ated with increased hospital utilization rates. PLoS One 2015;10(7):e0131093. , Tisa Juanicorena From: Esther Gesick ' Sent: Tuesday, June 28, 2016 1134 AM To: Tisa Juanicorena Subject FW: Weld County Commission Land Use Case++ USR16-0009 Esther E. Gesick Clerk to the Board I150 O Stree t/ P. 0. Box 758� 6reel e y, CO 80632 tel: (970J 400-4226 V _c^��.tlw,ba�ity Noh<r�. This electronic [ransmission and any at[ached do[umen[s or other writings are intended only for the person or entiry to which it is addressed .��:•.a r�..�v mr,ta�n Info�ma[ion that is privileged, <onfidential or otherwise protected From disdosure. If you have received Ihis commun¢ation in error, please �mm�dialely notiFy sender by retum e- mail and destroy the mmmunication. Any disdosure, ropying, disVibution or the faking of any action con�prninR Ihe mntents of (his tommunication orany a[[achments bY anyone o[her Uan the named reuoinnt iti sVictly prohi6ited. From : Karen Speed [mailto:speedkaren@gmail .com ] Sent: Tuesday, June 28, 2016 11 : 18 AM To: Esther Gesick <egesick@co.weld .co. us> Subject: Weld County Commission Land Use Case# USR16-0009 http:Uecowatch.com/2016/06/ 17/fracking-waslewatcr-sewaee-treatment/ Esther, I would like to forward this recent article regarding the disposal of produced water in the fracking process. This question was asked by Joyce Smock ( 1 think that is her name) at the Planning Commission meeting on June 7. 2016. �I�hey also had concerns regarding ��here the tailin�s were being disposed. I would hope that NoRhern i Colorado is no longer placing this production water in any w�ater treatment plant cycle nor watering crops with I contaminated waste Natec � My concern is that as there are excessive chemicals including radioacti �e materials in the wastc water, it would be fair to say ttiat somewhere in the area there is excessice contamination accruing. Even if it is being forced into a disposal well , that is still contaminating tl�at space and could cause future issues when that well leaks. Thank you for y�our consideration. Karen Speed EXHIBIT a �9 �� 2 ' � Q� 1 EPA Bans Fracking Wastewater from Sewage Treatment Plants Environment America � June 17, 2016 8 : 50 am � Comments The U .S . Environmental Protection Agency (EPA) has banned fracking wastewater from public sewage plants, citing the inability of these plants to handle toxic and radioactive pollutants. Clean water and public health advocates, along wzth more than 30 , 000 Americans , had submitted comments in favor of the EPA rule, finalized earlier this week. ' 1. � : �I � � ..� � kl'L \ � �yP ��f��v�RfJV . IR.. � ! ti bu �I K� F . � Fn �J L` ' . �� . . i� .� . �M1`_ . T : �y '4 t � ^ �� r ._yl0i&p .�y 2� .Tin�.�� ,�� . �-.t�R��P _ �� ' �~��.} +� �.� y � ...�Y1ii � �. � � �.}�. . C �1'��i . � . I��/ Q� a�. . . ♦ � � �� s. X / y . lM.v � . L. .. � �: J � . . , . . .� �. � � , \` � ��y�'� � n . . \ . . = F ' �.��S� .T/�/ � `\ \ \ �\ � �ti.,� i� .. '� � �� ' . ; � � Yrx�- ✓ �� --,_., �:-� +,�� -w- _ , � - � .. � . �� ..�� _ s _ � L � �! ` _ � 2O� . 1. k ' .• �� .. :� ��Y� �� v��`�� ,�.._ YL �1 .?�.:� w bs� �: '..<>.�r� � . �� ' -.-` a '�'�..��1�d� ` . v��y^,. s nin�C ��^ '- t.. /R' i 1l� L � '�L. " J �a..'l ♦ ♦ �. vl Y-qi 't.� °� o-� V`� � . in.t t _ . �' �c+ �� . � . _ � t y�_�-. .M. : , ` . . _. � '.z.-�i..}..ti.'g .nC,r .a... :`'`'�+�` .�;- �. ,i�, . :� 1; . I : C1 � IlI 'iflUliliC� I11 � 1 � L � ! � �l '.� I ' i � � �) BL�I ] Ii ilit' 1 �l\ i`- i � �l1 � � C � tlilil' ��i � E � I �l �� U [ Arkansas. Photo credit : Bill Cunningham / USGS "Allow�ng toxic, radioactive wastewater to be treated at the same place as dirty bathwater defies all logic," Rachel Richardson, Stop Drilling Program director for Environment America , said. "This is a commonsense step to help protect our water and our health from the dangers of fracking . " The tinal rtile formalizes a practice in place since 2oii , ��-hen fracking chemicals were detected in some Pennsylvania rivers and officials ordF� red i5 treatment plants to stop accepting and treating fracking waste . Fracking or hydraulic fracturing, is the process by ti�hich large volumes of water along w-ith sand and toxic chemicals are injected underground to extract shale gas . Much of this fracking fluid mixture returns to the surface as toxic waste��ater, often w�th radioactive elements . Municipal water treatment plants, which treat waste and then release it into drinking water supplies , aren't suited to treat such hazards . The mixture of bromides in wastewater and the chlorine used at se��age treatments plants also can produce a toxin linked to bladder cancer, miscarriages and still- births . Even under the rule issued this week, fracking wastewater disposal still presents a conundrum for public health and safety. Plants designed to treat fracking waste are far from foolproof, as Duke University researchers found in Pennsylvania. Waste often spills into rivers and streams during storage and shipment. And studies show injecting the waste deep underground is likely causing carthqual<es. While no known municipal treatment plants currently accept fracking waste, the option could have become more attractive to drillers as standards tightened on other waste disposal methods . " Fracking wastewater is a big problem for which there is simply no adequate solution , " Richardson said. "We applaud EPA for taking this step to protect families on the frontlines of fracking. To fully protect our drinking w�ater and the health of our families, w�e need to ban this practice altogether and transition to ioo percent dean energy. " i ; � Vetting Pad � ; .�. EXTR GTIQN Dil c'3c Gas EXHIBIT a �a � - G Extraction � il and Gas Extraction strives to be the safest and most responsible operator in , Colorado , while providing the , energy we all need ' Y - , r . : . _ Our operations defines us . We are � " committed to : � „�� > � •: t � Embracing and driving change � �' • through innovation '�'� - �} ! i ' ' , . � • �- _ � Being accountable for the , ��w� ` ' ,�,� � �- work we do �, ° ,^� F � .t�- .- . ` ��. ' � � Building open and honest , ��',� ' �, � ; `� ` ' `� �; �� — '� a�� i F � � + ��° � �— � .. ;� � i , , ,e � , � v, � t „ . relationships ; ', �;� ' „�� ,� � ; y ' ' l�'� ,''� � ',, � ' t' ��\ � l , , K � �' � �. , .�� i, ' 4r �� 2 1V�^ �. i ,.� /� �� , � "' if � � ;1 ' � �� `� � � � � , M1 ,�� , y-� � , � �� f , �� . � 4i , ,� , � �,. j � i i , , ti � ` ` � , �,� „r � f�'�, � � ; '� ' , ��I�.� � � ';' � � ',. � �� ' �/ / . � � 1 �1 �1 A1 � �l � ��.'�� v/_ �� !r � �1 .�� A ./ 1'��fl1�N � �4 � ��`iSi � � ! P, ��, `� 1`S�U \ � �1'� �l� E7CTR � �TIaN ou a ca. Regulation Oil and natural gas production is highly- regulated by municipal , state and federal agencies, rules and regulations . ► Key Federal Regulations ► Key State Regulations � Clean Water Act � Permit Review and Approval � Clean Air Act � Well Design, Location and Spacing � SafeDrinkingWaterAct � DrillingOperations � National Environmental Policy Act � Water Management and Disposal � Resource Conservation and Recovery Act � Air Emissions � Emergency Planningand Community Right- � Wildlife Impact to-KnowAct • Surface Disturbance � Endangered Species Act � Worker Healthy and Safety � Occupational Health and Safety • Inspection and Enforcement 11.5. flFP1UlN1EM Of lllF INIFRIOR o a �ZED S Tq fuvlauorLLNQrnu�u��awEM , � ,J{� TFS, �.; � ): z' � '>z GRQUNDWATER • -� � � �..��' - ' o �/� Q ColoradoDcparcmcnt Z2iF;�1�'\= ` �` • • • ofl'ublicHealt6 q'r4� PRO,��G� and �nvirmm�en� U.s. N'ltiH .Y�W lLUL1N'15 GF.R��('F: ��'''''' �' Occupationa� � C O L O R A D O � Safery and Health �� Department of Natural Rcsourccs �J Adminiatration � , � . J< ��} ��. ,µ4fi``�' E7CT R �TIaN ou a ca. Greeley Development - What ' s In the Plan � � __ R o�_� A-� � �o� } r + � , ' _ _ _ � - �:YYe+4"��a'l�. _ . . n�,; . �.;' .: � . „ Ground Water Noise Mitigation Protection , ;:�. �° ,. �� . , � � k �� ` � � . . . . ..� , � � � � �� '. ; ,' � Water Air Quality Monitoring Quality x Monitoring " fi `u��. �.#��,�:1 * , ` C�i � 4 ` � � t ' � ' � ,� .. � � . � W � i �.�9 4 y i 74 + ' ' " f U ',�,, i � � �.,�,�+" � iur �'c�, �� x, , �:: �,� ' � , • ��. S. , Reclamation E3CTR �TIaN ou a ca. The Drilling Process � �� - � _ , �� - , - - - �� r ��. � . t_ _ _ .� _: �� . . . �_ , _ _ _, , � , ,. ,. _�- ;,_ , � �� . � � � , � � � � �t'�. � � � , - - � _ ; �--- _ � , i .. i � � � i � i iil _ _ -- -- � ; I _ � -- - -� . --`� p � � . '�: �_�' � .. `""'�r � � . : 1 1.-_ -:l - _ � - - - II--_- _ _, � �� — — . .i.k' � --- � 1 �; � � `_ �-�- W, , � � - ,dr � � � . � - - -� ' I � -� --� I- --- _ _ — - - �e�-•�- - `� . .� . . _ . . .- z . �`�q t„ ^ e . I . . ._ . � ,�.�- _ wsxy,s.r � . , . , .;a„ `z` "�,"vr__:4e�t..��e. . . �T / .�,;� ' .I ' . P \ � , S" '� ^l. Y tV ' ' �� S Y< F r' lJW, �} e�i�' .�� •:• ' t v2�^ �.vy 4 ` YYf � _ � � ' . ` ' � �yJ � % t _ �I�^"�lian � . + T . - L �� .. � . [ � �ti�[�� '� . ! p� �� IY�} � `� . y. � R � Z � e � 1�T � � _ . . . . -M . �'I �i�� ' ' � . ♦ Sound wall during drilling phase '� �" _ _ , — " -�� - �. - ' �- - � . :. - �:.,� . ...___ _ . _ •- - — - � . -�,. : , ._ . , Typical Drilling Rig E7CTR � �TIaN ou a ca. Horizontal Drilling • What is a horizontal well? � A horizontal well starts out like an ordinary vertical well , but as you approach the target formation , the MULiIPiE VERTICAL WEY.iS drillers turn the drill bit to drill horizontally ( i . e . parallel ) to the � � � � "' �' ��'' m � �` '' � � �� ' � ground in the target formation , � , , -� 3 � , 1 � e which is typically over a mile (5 , 280 - - _ . � feet) below the surface of the • ��`�� .� �- • ,� , '�"�`�` � ' ` � "'' � � ' i ; earth . _ - � " __ — "Y � i � _ � �{`� e-- - _ � " " `3,a..��'Y.\"5. �� -� -` 1 ' e - a Y- �. " - . . � � �` �� F� ��_r1rt��S@' � �Si �f`�-��h��+a'�y �t.�v {� CF�KTi`��j' n anM/az ina « � v � �11�' '.L�a+ "'::,L lt � . �"� '�'-� ' � � � t i �f^ "�-. .uY i`. . �^ . "A�!'J�- �� What are the benefits? � Recover greater quantities of S � NGE� WORIZDNTAL WELL _ American energy using less wells � * r � � � � � � , �� ffi � �, � � .;.F '�� Reduced number of wells reduces � . e, ; - *: amount of land needed � � , � ' � _ �� '��. � - : .� _ .�.�,:,�t .�,, _. ,_ ,_� ._ , t C _ �F - c � ' — ��. Y .AJ�� .� . - .� . ' - . . � . . .Y � v � . . . �� . -I I } ' .! ••�\� �.'M —f�� .+fi'.I.. _ _�..�f '-1I��-J�v � .__ ! � ' � y �. _.�! } . .:.3. � ' � S `��~ $_� ._ �y {�� Fy��Y rJ]!�_ IYx ' a�� .. . �s�'ii� `- � . `�� a-Y'�'L T`- a�i�� - fBCCe_9. . t ��"a � �ai4 � -� � '-- � . I � ! ' 1`- . ��Y�'�� E7CTR � �TIaN ou a ca. Hydraulic Stimulation ( e . g . "fracking " ) � Components � Involves injecting a mixture of water and sand (99 .5% ) and additives into target formation creating small � 1 J , w_�_HEa� � „ „ fractures (G)eaterthan 6, 000 feet �___� below surface � �� _ r�. � — - � F. , � � N , � Purpose , � : ,- � � ' � Fractures provide pathways for oil I ; „ and gas to flow to wellbore , that ` � � � , would otherwise be trapped • - - �"" .:. -�� . . � ' ` � Closed-Loop Process � , , . , � Components are left in formation (i . e . "sand") or recovered and processed , often reused in future , operations (i .e. "recycled water") ��r�= - � Duration � 3 to 6 tlays per well I I � Continuous monitoring � Pressure at surface is continually �'� �� ,�� r � monitored during and after � �.�� ,��6 d�BW�� . ,, �� stimulation to confirm wellbore integrity E7CTR �TIaN ou a ca. Completion Improvements � ,. ; �..s . � , �Y�:terStvrageTanks � � IQnd�ers lh'�If'�� Sand6ax�es � � , , , _ e_ ,; . ; �+f' � � , . . � , � , fa , s • ►�4 µc � , ♦� . ' . , . — . � , � � � . . ,.�� '�: � . � ` � ' . r' ��,•`� _ �: � . '4 v.� ' Y �I � P �� {� ! ��_.!+". d • ' � �� . . �I�I T' , ��-'^ � � �•Ij � f + - � � � -N .e ._. � � � ♦ � I . �'� L� M� e�..� .T � � ' � � �� .� . `A �. ��.��p,iw�y 4 x �_�� ' .� f ,,:_ . ��ort.# ^ � ; .. ��l,,+l�.�'��'"1� ,�� :. � M1�' �/'w� D. � Y W� � �1 ` e� ( �.�j'��z.� • � � . �� " �,°�'� ' �-�'' �,, . � �" - � ' '� -.::�... , `' ., r -ti, . • �� , t . - .� , .,. : r . , Pa�mp � rs � �' " � � w ' u _ - '5 � _ `'-. ; _ _ . _. _ _ _ . e ,_ . .� �� ` �� ir , � . _ 4 - _ -- . / -... �a�d T�t � � �: � . . . � � - � +` __ � � � + � , a ' - . � •. ° �;-. � , .� �� ... - : ', t � " .• _ ' . _ . � ! � � . l . � /. ' - '� ��JM ` } . . . ��. � � • / � �` � � �� • �3t� Nirrrt�tta�Nn� Trtiec.k � � 5tora�e T� ; , � . . - .�, . ��- � � 1 ] �I��-1 ' _��I�� 1� ��1� I -I �� _,-�� + �RII � � � �III�� 1 l� -, I � , Mr.�"' � � �� , ��.��.�. , � , ,:. Y — . . �I� � , y. _ . �tr. .�, � ��'�7�� . , � _. ,�K., �' ' ' _ _ _ .. . . ._. _ . . E �CTR �TIaN ou a ca. � es � ir� � I � ss ! . . � � . . . . . . . . . . . 1JAPOR YVATER � r RECOVERY R � �:� uNE T��S�a . . TOWER � �� (1/RT1 1 ''— � . . ` � , * _ _ � � ' ' � — � � * � r � . r � � ��„ LACTTO PIP � �� -� � �; - - � xtr ra _ _ �'.Wst' .� y. • -� ' �, L � �� .- _ . .�_ . P�.� �� . _ . . �✓ . . i . � � v �� . •� . • . V.�l.J � . �� , . . ' � �fr - � ' . . _ _ E �CT F� rCTIC] 1'�I C3[i & Gas Air Quality Protection COLORADO HAS THE MOST COMPREHENSIVE AIR QUALITY PROTECTION RULES W THE UNITED �`` ,.� �r ...�,:.• STATES �� Vapor Recovery Units ( VRUs ) �`"�.,�� `�. ' :� ., � � « �� . �� r„ � : � Capture vapors from storage tanks �,,yp_' � k " . .� .�.. .� r�, � Vapor Recovery Towers ("VRTs" ) k ' � Eliminate vapors from oil storage tanks , ,, , � Automated measurement and transfer of �*� � , (° LACTs" ) �'"� � Eliminates emissions from measurement and loading I �� Leak Detection and Repair (" LDAR" ) � � � inspections - ; , , � ... � Continuous monitoring of facilities to detect and ' "� eliminate emissions otherwise invisible to naked eye F �' � ��; . .y . � _ ' � . � � .� "EPA and the federal government is taking the lead from what ' Colorado was able tn do[.]" -Dan Grossman, Environmental , Defense Fund �- , � _�, Colorado Publie Radio, 2015 ' " �ti� :. ; , . _ _ � . E7CTR � �TIaN ou a ca. Vetting Location Drawing .�.�.,+ �� —�. 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Potential Tax Revenue TaxArea - „6&85 � ��-.,.-`_t --�� .�- _ - :_..v. . _9632..�--_ . - ..�_ ' - . 0 Tax Area ' - �� . . 0804 -� -- � - ' TaxArea . ..� �.TaxArea �-":;.. '_ 0685 • • • • .�.��__. _ 0685 .� Potentially $ 70 million in tax 600 - , - - ,�,� revenue to help build roads, ~ ~Tao63� � � bridges, and schools . , ,, axA.rea " � , Ofi93 ��`' , 'iH 9£�. i C. T�xA�e� Help fund affordable higher �a 0604 Tax Area ` - °�85 '�� education . — - - s,.. — Tax Area -� Tax Area _ : . 0600 . . . . 0685 •, � Tax.Af.ea� '- TaxArea �°^- 0600 Tax Area 0G83 Taz Area � YaaArea ; Q600 Ofi43 .._._Ofi00 . .... .� �ea TaxArea TaxArea � � Ta�c C7istrict - 0693 Authorrlw Cod€: Authoritv hiame ft+lill Levy oioo ��o courary is.an0000 62U6 SCHODL �I57 #E�REELEY 3fi�.043900 0341 NORTHERN COiORADO 4V0.TER {ryCWJ 1 .9d}D�00 0.3fY2 CENTRAL COLORA�O WAT€R (CC4VJ 1 .533900 0399 CENTRAL C6L6RA.d0 WATEfi 8U9DISTRICT 1272fl00 (CCSJ �519 Y4E5TERH MILLS FIRE 10�.338000 0706 AIhY5 .IUNI�OR CdLLEGE fi.325400 1050 HIGH PLAINS LIBRARY 3.3Qd600 f260 4VE57 GREELEY CIJNSERVA710N C1.a26400 � E �CTR �TIaN Total Levy i6.00500Q o,eaca. Truck Access _ �,y� p �.2•--��'1 -.., , feraa„v � —'- ; - - � ��eT�";� � C'� v Y K � �YUR.'i/R4��j'.�� E _' ♦ ' � t r • y ; I � � .�� I �^� � Yaf �' WI � ". Yf . J �. Vy� � f � r 5 �,�,� r �,. . ��erT �' 1 � � ` �'- ��G �j i �,�' . � '��I ii vw . � -\ �� C Ilinll � �: � � � In � `�.. 4 � � II � Xi 1 I i �� r� .. iuni e. l I � �� •� � �� I��}Ip.+yD. � . � . a ry u.m�.e _ �af n Y � I IIR`Wgy �� ' � � %�fC� � I I� �. I� I r m � � � �.tJ �� i i�� °e� . � i ' � , � ' � �" � ^ �;� ; e . �� " � � ' : � � i � rry ��r/ " { d' i � 7U'i e� . �.c �r /F 'z ., � I G��n � � � l ;. � � � �_. ♦ , R. tl �{� . � I 1 _ �. , � .. � x -- z�, ��/y��^;-.. � d'' ` � f�� `MA ,ft 1 .. � . � 4 : . � yqy � 1 � j��''v'� ` � �w k I e � /' '_:n0 � .. .- —,� .F I ... _ . . . . : � -�. j.4 �r . ^ .�.,� _ '4. � :� � W.6 e y�. > '. i _ .. � ' . , . k': �.- _ �� . i " �J �!i;iP � � . . �. � I �. ;. w . YZ.� . . . 4� � � ' 3� � � q� � F: § �; �� . ' ' .. _�, . --�`� I I' I ! � . � i ` ��: °�-��, M1 � 1 . � �a'� " � I ,�� — --' ' ��"P� , •� ,, rh,-'., . . y �. .. x:. �/ � r � � 1 �`11j�' �3 �J` � y � . ... y„f� -=t I 1 d �'Jn2� 's / . .� �„ � .�� • 1 'yN. s'. I�J1Fy ' :. ,$ � y �W 4 ..,5'q�' J • s � A� ,..�` ' ft lx � ' ''�' � � � -c. �;'s;� '` ' -�!'`�` p �y. '�:;�''u � � ` ' ' � .. . � � �I� ux i y ' �� y �� / � . ._ �.. s-rfi� ` i\ � . ,�- ./T =_. -. -_ .r��T�.--�at _ Q� c r• � !M� K"-:. :I � . ..• v - 4 I � � �� f � f � :� �� _ � \ _ _ . . �� • • �. � .. n � �� FT � � �i F N ��`it.. (nt �,r � ;":, ♦ `] � . n . ' ` �y� .�� . �- Y� ! L ' �F1� � � � � � i�� .' • _ �:� i a � y-Y�S ��' W � �� '� �t f .� . . - � ,m1 JN� I r 1 ' I . � I� � Y �� `4Y-.\'i. � y �,` � + R`mul� �l�'.a.�{� /l�F �.1.�. nr x," : �ri�.�� "res�-i.�YaY'v ��i . a '�nnn� 1 -.a E7CTR � �TIaN ou a ca. Questions ? ,� � �'ELr� �oUNTY � � �� -- _ � � , , � �. 1�} aF, ; Gr�eley Ewans -� ::� � F A I R a; '` . � �'I WELD C{7U�VTY SC�HO(]� QI�TRICT b y 4 \ T Weld Foad Bank �� A� � �FOR LIFE � �� LI � E L� hIITED 7HEWO/ ^N� IEN 'S . � � ��J � �JIt'FiD ((N '\'IV. I\T�. . � .. � m^�so�.c^ 'c.'t'reCo�mm�� nGa::on }er, �, : -� . _ - � � � =. r . r � ll�nited Way nf Weld County u��t4away.we«. r�r� . E7CTR �TIaN ou a ca. Subsurface Layout L-'� :iTREET - ��w�owu vomr ircicn� I .�� y �' � — —$ �m �¢mnE3-�e-�e � � �m¢W��m � I ( . x aixuQ[. �- =_�e Y � 40' I � ' I M-LOl � �Y': I � ' 1 iM t ] ' I � � . ' '�I-15 (S-Ib-'.� I gqp5]Ylll ITB:I.]P �� r-�: :�a--,. vi I siqruE �acnncx . �s I rr Lc f-�a-ia �. �� mnRib_1u11m_ — _ I _ —i•• — — — i _IS��_`��\\ -��— � _ � - — I _ _ ' d` i �a � vr-ns r,+iF��tl � . :• ovufzN iazrv' �e•� J� � � I vr-ss �-� ia ut L raexri V ma�.+ �-�s�n ' e�e��sv �eruau� I � � � '.HT. C+Ib-+C '� I ' 1 I' !16' . Yi�llF51-16-If i LL�N��4�N113A1.i]' L11 s[cnaH te'r5N F� � �'� ��,�Mz� . ..r ,k.,.,� '��'�n �a l5X Resw �•ro _ _ . scnon �sQr.n xssw � �- _ - on5nu i� swvt� v �ass u3 _T` _.TFFET 2iRLl4VcNl1E i 11THAN=NIJE I . +enru u'in�vim � . �'� y . � � l N. �� uvM7�x � � � � � v rv3 m v n�v imm• 8 � v nl n yYNY W ye ! � I I �, Ip I I ' I nwx'. �x I ' axre 'nMlnw.n' . —P�, ' b� . •kTlrvi. �ro d g'L'IeMPY T 'Y� :� I — — I — . I � •r�� . �,�nIw m a euw mzu� i �to�� I �� I � I �Ei�lxc :� 3na'Y�wvne.n' � '�vf rc 32 I fevP'h� f I' �� nnrcm mu'e�Ynw. • .1-F.F.Y' A�'✓ENU- � a : v. � wwe. ' � i n� � � i � � III F�:'rR :l,� �'I� Lv I ' � � s�vkio`n meaY ' • ..' itil HJCVUC � I ` I I A ' I � ��., � � — ` — . .. — — � _ � � _ . . _ . _ . _ I . . ' � — " - - �'_ _ � , �, � —�I,— — _' — . — — _.�� ,` . . ' S'. , I � FTH AVFNVF � UNE A6LE L1ME T0.9LE I ' � LWE R DIPE[TION LENCiH LWE p pIPEtTI]N LEN4iH � � �� t � �� ' u �s 6v-1 � mn' u3 mn x�M .�xn' SELT�M IY 1]N RWM SFCR]X ]Oll]II ROSN _ � _ . _ L nsvn.c•'� am.a/ LY Sa�c� )eM �ai,i]��' � T II � — •• I L Xlk�nY 19n .[Y LIS SIE 9M e�LLutl' � L4 n 5x�'.SY JBIl1s L16 ]lln YVM +SLL5]' L6 M1Y0�ST� Je 'm L�� J 5 • `�L'J' Lr M1B]i 'SM ID �9 Ue 4 u ! 3 :�9' N M19�� Y 565 . U� ]6 NM ty 69' � � ' M � � I ' _ — — — _ 4 { � .. i - � - � .m •� �`� V X951q1 366.W: I]o yN sY }56.]6' _ _ _ _ _ _ _ _ _ �� _ '$� B� � � u saa .�ti 5sea u� azv� m vmy' LIO m� l] aM1 n�i �-: L]d 5 i M Sm:FY � . � '. � JJ L �n i -A' �ui LSS ]( �-aM IIJY.�.r _'AE' = I :I(.. L@ craC.tl �.rte! I]� nc]"�-M �.a•y �I� LAMP RYNEAAS � N �, � 5 ��>�� a� �.�„e � z� �� F Fonf�llirs �n8n5�y 9 ti'z23.P979 F 'VIULTI—WELL PLAN www LRA Irc.cum V=TTINC 'ISH ar�m M � h r�rww�c M VM^� - w¢ �w�wr [caa un PLr rmAtivn NJ'•V ExVvac'iaP EK4 W�5W5,q0 2 26 �L e � � �. � c E7CTR � �TIaN ou a ca. Groundwater Protection TREATABLE lvfl� NICIPAL 'Jt+ATER PRIVATE WELL ► Applied in all shale, tight rock formations GROUNaWATEft b"�ELL: et ,C70�U FT. � Developed in 1947 AQUI � � R5 � ` _ ` � ' � Applied to 1+ Million Wells in the U .S. `��_ �� "� � � Applied to 95% of All Wells in Colorado � : • - ► Occurs More Than a Mile Below Surface � :, ;;�� . kl �aciitioiial sttiel 4 w`.��` �asin� anr� cemeFzt � �,��-�� ,�,�-� � , ' Miles of Impenetrable Rock Acts as Barrier FO �]t�CVCr3t '�' "� . t4r��"f�" -. �.3+�-k . '� � °• � -� ► Wellbore Construction Protects Groundwater ire, � i , r9 . :r, .� � � , , � : i� �f : .-i. :•. ittni-i „ ; ;,�� ;_ � � �Three layers of pipe and cement � ,k . . . .� i p A . ,:y , ra,, � � ��"a � Routine integrity testing and inspection . . ; , �4 y� � y. r 1 � _� ,. � ..Trd •�: � ��w,^ s . � � - -: ,� ' 1 ..: , , . . 4� � � � ..) .. J� ._J � y ,n� , . � . ' a . f �. ,I ! � _. � ,bE' �.y . 1�, : .. ' . . �. . . . .. . . ':.p _ ' : ..' � . � � ' : . �. �.. .e .. • _ui ' �'iil.' I '[ i rl �� l : � . , f� �.�. . � � J � � r',- z - . ` A. { w 'rr I4 *� l � . '. �.. . � .-��y� Y ..�+Cei . .. I n 4y�� I . . I . fj y ! '..� � \ � 7'y� � •i } ,. i r . '.� s K � " _c. ''l.] .A.f^:': E . M � �� a � i;uti -, , � . +' ,� �t �w"3� . Si��le� Fr.�ctu � ��, , �.�{ , e , ` ,� t, � � k` Y� ��YC : .� „ . .. .� r,s y . � :�Y I . Y/� • -? 11�� !. \ . . � .-�i . � � . �a. � � f.. .4N�T4'd a . . . �Y. � � - ' - � � I � . .,_: ,� . -. �, . ' � 5 ,t� � ' - . ��. . P . ' -: 1y , � ' y� .: . � � �{ 1 �� . � '_ �. � . ._..f�"''..r-_ � „ �f ��: � Y � ♦ T� �� y� i F � ., s 1Pi��: i z �, • 4 Jk � _ . . la f i � .• l� . � �i� .GSi� ' ! *i. _ }[�y/�� " � , 1 'C� " � ✓4Tl�LL �� fJ{�e (�i . F . � �� `� � h � 1 /Y g,� 14 I . - � � Y ��iSI.��y *� S� � N �Y��. ' A� :.• • � `_ �� • . ' • , ', � .� E7CTR �TIaN ou a ca. . �� A� ^• ^• �• �� . TD�Ar�TI ^ n�i rn�� nni Qri n �ei cTA�TC�C �,^ ^�� n,�n*� nc STATE- WIDE EMISSION FACTOR5, CONOENSATE 1 z ■ Colorado Air Requirement ■ Extraction Oil & Gas Emission Dperations r, ., 1.0 0.8 � a w ? w 0.6 a � z 0 � o.a m 0 o.z � o � � o � m o � � � , � . � � � � � o.o — 20D2E4UIVALENT VRT/VRU OILTANKCONTROLS WATERTANKCONTROL3RUCKLOADING CONTROLS LACT E7CTR � �TIaN ou a ca. What is ` Frac Fluid ' ? a � , Helps dissolve minerais Acids and iaitiate fkssure In Swimming pool cleaner � rock I pre fracW re) i ' � Allows a rlelayed . . Sodium Chloride 7reakdown of the gel Table salt � � � � PolYmer chains Polyacrylamide Minimizesthefriction Watertreatment. soil 6etween fluid and pipe eonditioner � ' , PreventsscaledeposlCs Automotiveanti#reeze, . , , EtNylene Glycol in the pipe deicing agenL hausehalcl ' cleaners MaintainsFl¢idvlscosiry Laundrydetergent, hand Borate Salts astemRerature Increases seaR. cosme[4cs q Sodium/Fotassium Mzintainseffectiveness Washingsada. detergent, � "� �� hle.��'� � r &� it �ai ,a.9� �t�.� a �' �!'A."�Fr�' .. n� • • � � pf9FIl8fWI11�.101lB11i5, Sqdp, WdtEY5�fiEflEf, � Cal'dona'te suchascrossdinMers. glass, ceramics � l y F4�� a`.x�'l�aa��u:a '�AIL,..'A. '4.�." ?4��aw � � ' Eliminates bacterla In Disinfectant, sterilization ` Glutaraldeh de of inedlcaland denta� � � � "<ia '� + �'" �. " " i`� . " .„ 4'a . � e � ' • � � thewater �quipment � � � � � � � � ThlcKensthewater [o Thlckenerincosmetics, Guar Gum suspend ihe sand baked gaods, ice cream, toathpaste, sauces By Colorado law, the industry is required to F�,�„e�tsP,e�;�;iat;o„ of Foo-daaa;t��e; roo� a�a disclose all of the ingredients used to hydraulically c'�"` ""a �»eeai ox�a�s aeve��ges; iema� iwee fracture each well on the Groundwater Protection CounciPS Ollllfl@ Pl1bIIC RB915Yfy: Usedtoincreasethe ciass �iea�e�, Isapropanol viscosity of tlie fracture antiperspirant, hair � www.fracfocus.org fi,��tl �oio��ng r. eo�� oo ,r� rW^�: .n�. oFr�omz�-rmEi-n=eo�a�:r.F�imrimc�� E7CTR � �TIaN ou a ca. Water Use in Context • . • . . ' . . �:��.r _ ,_ , , 4 �, � ° � ', �. • , : Shale Gas 2 . 3 gallons " • � " Coal 5 gallons - • " • - " Nuclear 11 gallons Biofuels Over 2, 5dfl gallons {y h � I f I G � �.l � � I I � � � ;'� hy�Jr �ulic f uc:uririg i � � requi �Fs aLout daur �riiliion gallo��s L f I �� I V of water, srr eaeJ �ut ower sereeral days Fn �,-� r..nrn,�ae isun�. � � � � , `' I' � . �� „� ,,�, � � � �I i -_ n,Sns � (� �� I �, k�i;l�'�,I� . �'"" -� � � New 1�vrk City C�7115�VrT125 �9!!r FO;�f �„711IIpf1 rJiII0 �5 "5 ZF14Jt � . � J41S'� PI1B 4F {Flb � S� �SB gPI� rr.illicn _yall�ns of ��aler �evecy 6 percent � f lh��e carn �a�� il [�f w.�r: ier e4urses� ac:e; ss :he Uni �ecl �la;es minutis. used in �ar wrshes euery day_ use; =au• r�i nn yallans af •.:� at�r ii7 less than 4ne s�ammer month E7CTR � �TIaN ou a ca. Good morning and thank you for the opportunity to speak today. My name is Wendy Highby. I am a resident of Greeley, a co-founder of Weld Air and Water, and I am a mineral rights owner. Reluctantly I leased my rights, as I would have been force pooled anyway. I chose to accept the signing bonus and donate it to Energy Outreach Colorado. I am opposed to having this development so close to a school. Toda�/s Denver Post business section had an article about this proposed development. In it, Extradion was quoted as offering to tutor Bella students about engineering. I think that is a lovely idea and it got me to thinking about wha�a�e teaching by example and what we should be teaching the Bella students as this process unfolds. Are we teaching them to honestly acknowledge risk, look at all aspects of risk, and manage it in a fair and participatory manner? Unfortunately, I'd say we are faliing short. We are ignoring the public health risks and we have ignored the rights of the parents of 8ella Romero students. LeYs turn this situation into many more positive teaching moments. Not only should we tutor Bella students in engineering, but we should tutor them in health science, meteorology, and political science. Students and parents will need to learn about possible health impacts and symptoms. According to the Fact Sheet for School Nurses prepared by the Environmental Health Projed of SW Pennsylvania, here are some of the emissions to be aware of and symptoms to watch for (see attached sheet http://www .environmentalhealthproiect. orK/dl/11). Students and parenu will need to learn more about the weather. In a study published on March 3, 2015 in the Journal of Environmental5cience and Health, PartA, "Human Exposure to Unconventional Naturel Gas Development: A Public Health Demonstration of Periodic High Exposure to Chemicai Mixtures in Ambient Air" ( http ://www. ncbi . nlm . nih .�ov/pubmed/25734822). David R. Brown, et al, found that particulate and chemical air exposures vary widely depending upon weather conditions and occur across many stages of oil and gas development. The authors strongly recommend that individuals living in oil & gas i development areas "monitor weather conditions to understand when the air is likely to be particularly polluted and when it is likely to be less polluted. This can provide some small measure of control and warning." The results of this study lead me to conclude that the micro-climate around Bella Romero Academy would need to be vigilantly monitored and just as we have "snow days", we would have "high poliution" days, or some type of pollution lockdown, because, unfortunately, we can't control which way the wind blows. And students and parents will need to learn more about emergency preparedness. . In the peer-reviewed journal Environmental Health Perspectives, in an article entitled "Adequacy of Current State Setbacks for Directional High-Volume Hydraulic Fracturing in the Marcellus, Barnett, and Niobrara Shale Plays;' Dr. Marsha Haley of the Universiry of Pittsburgh, and her five co-authors, study a range of setback distances from 150 to 1500 feet. They conclude that "based on historical catastrophic events, thermal modeling, vapor cloud modeling, and air pollution data, these distances do not appear sufficient to protect public health and safet�' (page 21). [The articie can be accessed at this URL: http ://ehu. niehs . nfh .�ov/wp-content/uploads/advpub/2016/�/ehp. 1510547 . a¢o. pdf]. And with regard — - to participatory democracy, here are hallmarks of effective processes that we shouid be modeling for Bella students: 1. representation and inclusivity: representation of all affected and removal of unnecessary barriers to participation 2. fair deliberetion: interactive deliberation that develops mutual understanding 3. access to resources: sufficient resources for effective participation 4. transparency and accountability: transparenty about objective, boundaries, and relationship of participation to decision making 5. learning: enhancement of social learning for all involved 6. independence: use of independent, unbiased methods 7. efficiency: a cost-effective and timely process (Julia Haggerty, Journal of Rural Studies, 43 (2016) access at this URL: https://www.research�ate.net/profile/Julia_Haggerty/publication/283710559_Does Local_Monitorin� Empowe r_F racki n�Host_Com m u n ities_A_Case_Study_from_the_G as_Fields_of_Wyom i ng/I i nks/569e3 43008ae16fdf07c3db5.pdf EXHIBIT � � Facts for ENVIRONMENTAL HEALTH School Nurses Things to consider if your school district has shale gas actiuiiy . Common air emissions All shole gos octivities ond � Children are (ocilities generote emissions — ' �"�'�y,,, at Higher Risk [his includes construction of • Children have hi her si[es, drilling, flaring, and 8 trucking to and from the we/l / / respiratory rates and as a pad, the operations of � result, childre� exposed to compressor stotions, metering ` air Contaminants breathe stations, and processing plants. � in more toxics per pound If children live or go to school \ �J of body weight than neor any of these focilities they � adults. will be exposed to emissions. exposures can cause acute eye . Children accumulate and respiratory tract irritation, more toxins in their bodies _ ParYiculate Matter ( PM ) is allergic skin reactions, generated at all phases of the headaches, dizziness, visual than adults. Their bodies shale gas development process. are still maturing and they disorders, fatigue, loss of Particulate matter is a complex coordination, and memory cannot metabolize some mixture of extremely small impairment. Possible long- toxicants as well as adults. particles and liquid droplets. term effects include damage to They don't detoxify as The size of the particles is the liver, kidney, and central efficiently. linked to their potential for nervous system . Some VOCs causing health problems. Fine are known or suspected • Children spend more particulate matter is capable of carcinogens. passing through the nose and time engaged in vigorous throat and can penetrate deep , activity outside . Emissions - and chiidren s inside the lung. It can cause exposure to ihose emission � - • Children's brains are conditions such as decreased can be intermittent and still developing. Many lung function, nonfatal heart varied . Sta es at the drill ad attacks, and high blood g p toxic agents are known pressure. PM inhalation can vary and, as a result, their to interfere with emissions vary (content as well developmental processes aggravate asthma symptoms. as amount) . Also, facilities within the 6rein . such as compressor stations � �� olat: le Organic Compounds and metering stations do not (VOCs ) are a varied group of vent consistently . Periodicolly, thei� exposure may be more compounds, such as benzene there moy be dangerous spikes limited. Students may be and formaldehyde, that are of emissions. So sometimes exposed to emissions both at released from unconventional children may be exposed to home and at school and from natural gas development high concentrations of oir multiple shale gas related ( UNGD) . Short-term , high �ontaminants while other [imes sources . eon[inued on o[her side Symptoms in chiidren that Children may react similarly to rnay result from exposure . Be the same exposures as adults aware that the symptoms a do. They may also react to AdgotelL, Golds[ein 80, McKenzie LM. Potentiol public heaith hozords, student presents may be the parents who are feefing exposures, ond healih effeds from resuk of air or water especially anxious or stressed . umm�venr�o�o� �or�roi yas contaminants. Documented deve/opment. Environmental5cience transient effects of SGD, such What you can do �i5).8307-8310. Z014; as as rash, headache, nousea, • Keep an eye out for an increase in symptoms or for Colbwne 1, Schukz K, Herrick L , asthma incidents, nosebleeds, Kwiotkowski C. An explarotory 5Wdy and eye, nose, throat ond /ung unusual symptoms ir your ofairqusrlityn?wnoruinl gas student bod Note whether operations. Humon ond Ecologlcal irritation, are not unique to Y' Risk Assessment. 2014; 10(1):86-105. r exposure to shale students' symptoms ( even for common com laints like LeitbSl, CorpenterDO. Speciol development emissions. p vulnerability of children [o As a nurse, you are likely to congestion and sinus pain ) go environmentot exposures. Reviews on on for longer than you would Environmenta/ Health. 2012; z� see some of these symptoms la):isia. in yourstudents anyway. Bear expect or occ� r in patterns that youwouldn�t2%peCt. McKenzieLM, WitterRZ, NewmanL5, in mind, however, that they AdaatelL. Humon neolth risk may be the result of sporadic • Keep a log that includes not nssessment oJair emissions from Ofl� 5 I'TI tomsbutwhether developmentofunconventionol or chronic exposure and may V Y P noturalgos �esources. Scienceojthe point to a larger risk for the those symptoms developed Total Environmerrt. 2012; 424:79�87. student. Persistent or since the siting of a nearby RabinowitzVM, Slizovskiy IB, Lamers recurrent symptoms are signais fp��fY V. et al. Proximiry to naturol qas that there mi ht be chemical or • Note whether students are -4'ensondrePonedneatrnsmrus: g Results of a househofd survey in PM exposure. missing more school than Woshing[onCounty, Pennsylvanio. Environmentaf Nealth Peapeciives. USUaI . 2p14; 113(1�:11-6. Fatigue, anxiety, and stress • If you are seeinq anvthin� of _ have been documented in "��„^�;;, ��, � ��r°� �, �f��^�; ;•��. partlCUlaf ConCePn In yoUf Environmentalpubiicheaftb adults livine in dose oroximity � �.� � � i�. .iim?ncinncnfchnlpnndtinhtnnc StuOerit5 eiui�r fnulviuudiry0i develo menL fnvironmenmlHenfth to shale gas development. as a group, report these Perspe�tivet. 2014; 111(8): 787795. There are many reasons for concerns to the relevant health this: noise and light intrusion US fnvironmentol Pro[ectionAgen[y departmentandeducational discussionofhealtheffectsfromoil make it difficult to sleep or deoartment. Be sure to include ond notural gas p�oduttion, even relax when at home; concrete information ou have specijicaiiynworavusoi� poiiuiunis concern about the otential Y �HAVsJ pnd volotite orgonic p collected that led to your comPounds Ivocs), con be found ot health effects can raise adults' �oncern . nrrP://www.ePa.9o�/ooqpsooif anxiety and stress levels . Some community/details/oii- chemicals are known to • Keep in contact with parents 9as_oddi info.html. roduce s chiatric and with their pediatricians, if US Environmen[al Prote[IionAgency P P Y � discussion of heaRh effects of it is appropriate . psychological effects such as a particuloie matter (PMJ con be found at httP://www.epa.gov/Pm/ vulnerability to anxiety. nealrn.hrm�. ENVIRONMENTAL .} HEALTH F� I ]T�iw� 1iC'! � �]i f1�7OY�7�L� (IL=Ii Ll.�, .�' S �'' '.. C l` . '� ' SOUTHWEST PENNSYLVANIA ENVIRONMENTAL HEALTH PROJECT 2001 Waterdam Plaza Drive, #201, McMurray, PA 15317 • 724. 260. 5504 www . environmentalhealthproject. org • info@environmentalhealthprojectForg ' EXH�BIT � Hello Commissioners. What interests me at this hearing is this : What are the underlying truths of the situation being presented at this Hearing today? As usual, a disproportionate amount of time of this meeting was spent listening to the Oil and Gas Industry giving us all a Hydrofracturing 101 Lesson. We've all heard it over and over, it's a way to stall and flatten out the building momentum of communities who are in a fight to save their neighborhoods, their lives, their property values. It is ingratiating to hear the same speeches from these Industrializing Mega Corporations over and over, for hours, while your constituents, the citizens of Weld County, who come here to fight for their rights to a safe, healthy, clean environment, a quality of life chosen, often long ago, to live in an Agricultural Landscape - to make them wait through the PR and lies from the Industry- and then get dismissive attitudes from Commissioners - while they try to protect themselves, for 3 minutes. These citizens, they had to wait for over an hour, again, to express their distress and concerns about losing their quality of life, their property investment based on that quality of life and sadly, these concerned individuals are granted a mere 3 minutes to express the stories that often reflect a lifetime commitment to a landscape, a way of life and a quality of life . This situation is severely out of balance . Ultimately why I have come to the podium today is to express what i see as the Primary issue - a zoning issue. As you know, the Weld County Code has been altered little by little throughout the years, unbeknownst to most Weld Citizens, from its original mission to protect the Agricultural Heritage that has been in place for over 100 years. The original intent of the zoning code was designed to protect the nature of this agricultural county but in the last decade has been severely altered, within its entirety. Agricultural, small and large residential zoning areas are now infused with Oil and Gas Zoning exceptions. The Zoning that used to protect Weld Citizens from Industrialization, the part of the code that was committed to the maintenance of Agricultural Landscapes and the quality of life that comes from that commitment, has now been completely overridden . For the last 60 years, until 2009, Oil and Gas extraction was a pump jack, or one I fracked well, which in the big scheme of things, did fit in with the diverse landscape and economy of Weld County and the zoning code changes didn't impact citizens too much, it was mostly expected for Agriculture and Oil and Gas extraction to live in proximity. Now however, with multi-well pads such as the order of magnitude of the Bella Wells proposed pad -22 wells and all of the associated Industrial Facility infrastructure - the agricultural open spaces and any open space even in small neighborhoods is at risk to becoming Industrial Zones. The truth iabout the fundamental problem here today is this : you 5 commissioners choose to believe and act like the entirety of Weld County is a Sacrifice zone for Industry, be it Oil and Gas or Asphalt Plants and that because of the altered Code you believe a legal right to Industrialize any neighborhood . The deeper truth of this situation however, is that the basic constitutional human rights to health, safety and welfare supercede and preempt your greed to and intent to Industrialize Weld County. You 5 commissioners have approved, again and again, to Industrialize neighborhoods — rural, small and large scale residential — it doesn't appear to matter to you that: the citizens of Weld County are people living in homes and going to schools who express to you over and over. Meanwhile while you appear and act completely unfazed by their dismay, distress and hopelessness about the onslaught of Industrialization coming to their doorstep, about the inherent dangers of industrialization within % mile of their lives. When the Oil and Gas site plans 4 or more wells and the associated Industrial infrastructure within %: mile of any home, school and any sized neighborhood - the site that has been approved will cause harm to those people therefore you have knowingly and intentionally caused harm . Industrialization inherently increases the order of magnitude of risk logarithmically: risks for fires, spills, well head explosions, VOC leaks and continuous methane emissions (5% of all emissions from millions of barrels of oil will amount to millions of tons of VOC and methane pollution in the Bella Romero neighborhood and let's think about inversions and these weight of these VOC's ), it makes the truck traffic and the associated diesel fumes that contain cancer causing benzene — an everyday all day all night reality in these people's lives for years, for over 30 years. You must know that Extraction is creating a PR picture here today attempting to create a `tolerable' pretty picture while minimizing and distorting the images of the impacts that these people, this entire school and rural and residential neighborhood folk would have to endure : It is a lie that you can reduce the impact of this scale of sight with changing distances by 100's of feet — With pads and facility sites this large 1,000 feet is 1200 feet is 1500 feet is 2000 feet for sound, truck traffic, VOC emissions blowing in windows onto other people's properties, visual impact. 100's of feet are an illusion that the extraction industry and the COGCC like to propagate. I beseech you to not believe it — these are major Industrial sites and need at least %: mile in between homes, school and the site. It is simply a lie that there will be a pipe line before these wells would be drilled . It is simply a lie that it will be (only ! ) a 450 day travesty of truck traffic and 24/7 drilling and 60+ decibel noise into their lives their windows, their views and their roads being overrun and ruined with heavy semi-truck traffic. The egregious inappropriate industrial activity that goes with a Major Industrial Site will never go away for these people. Never. It will continue for 30 years, into the lives of next generation of children living in this area ! If these wells are approved, the nature of the neighborhood would become Industrial . Therefore I see this as both a zoning issue and a moral issue, a human rights issue. The question about whether or not to destroy the Bella Well neighborhood should not even exist here today. Bella Romero neighborhood, the people in neighborhoods matter more than a corporation, Bella Romero is not zoned Industrial . With the approval of these wells could you guarantee that all of ihe residents of Bella Romero would be 100%risk free from all health and safety hazards at all times? Can extraction prove 100% safety from these large scale Industrial Sites? Of course not. My recommendations to you Commissioners: Number 1 : I challenge you to remove all of the Oil and Gas drilling and production Exemptions from the Weld County Code, to preserve the Agricultural Heritage of this County, to protect your constituents from the large scale Industrial operations of today's world. Number 2: I challenge you to answer a few pressing questions here today. The real questions in the queue right here and now before the eyes of these citizens and all concerned supporters are these: Will you commissioners, will you choose to Industrialize the Bella Romero neighborhood? Or will you do the right thing and reject Extraction's proposal? Do you understand how the decision you make here today will show whether you have allegiance to the people of Weld or to the Oil and Gas Extraction Industry? Do you think you have a moral obligation to protect these citizens here today by not allowing this order of magnitude of Industrialization into these people's neighborhood? We are all watching what happens here today — Where does your allegiance lie? � ' • • . • • ' . • . • EXHIBIT f � � Larimer Weld Boulder Denver Colorado Population (2014) 315,988 269,785 330,048 649,495 * 5,355,866 Square Miles 2,596 3,987 726 153 303,642 Adive Oil and Gas Wells (2-2-15) 257 22,088 % 316 52 53,174 Health Incidents: - Asthma (> 18 yr. old) (2011 - 2012) 6.9% X 7.6% 7.7% 7.0% 8. 5% - Cancer (2008 - 2010) 0.4096 x 0.41% 0.43% 0.45% 0.44% - Birth Defects (2030 - 2012) 6.34% 6.01% 5.8% x 8.0% 6. 31% - Infant Mortality (< 1 yr. old) (2030 - 2012) 0.42% X 0.67% 0.47% 0.53% 0.44% - Low Birth Weight (2030 - 2012) 8.2% 7.9% 7.7% X 8.9% 8.8% Source: Colorado Department of Health and the Environment, Coloredo Health Indicators htto•//www chd dnhe state co us/Healthlndicators/Indicators asox?dID-S&sdlD-43&cID-69&rID 2 � . . . • � ANAD� � � ROCKIES TEAM ]:. EXHIBIT = - � 'P. -� i ..,,.t� .�, i • � �� g _ ......r.._. _.- . � j�� - � �`. _ .. r� _ . >:_�,,.- , � ^� � .. .. 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'= � �:� -: ::. ; : , a ; _ y � _ � ' _ ., '.�n, _ .. � �J _ .: \n� J � �x , � i t �� , � 1 �. . ♦ �� . . ;��„� ,, , . �. - z .; • ��.. . _ r,.. :t� � � \� � �• ' . � .�. e`� ':�f - . ..r `�;�. . � � Y � ' -:o"r'r .{`. �i== � . .. ,(' .�4 � - .,,x,m _ . .r • . .,� :- � �� . i 1 � `t � '.` JI. � � ! ' . � ' � i- - �.. Authors Elizabeth Crowe Sharyle Patton Deborah Thomas Beverley Thorpe With assistance from: Carolyn Cox Carol Kwiatowski John Fenton Jessica Roff Miriam Rotkin-Ellman Ted Schettler Kim Schultz Wilma Subra Eric Whalen Editor Maddy Cobbing Design David Gerratt NonprofitDesign.com The findings, conclusions, and recommenda- tions in this report are those of the authors and sponsoring organizations and do not necessarily reflect the views and opinions of the contributors, reviewers, or funders. The authors and sponsors accept all responsibility for any errors or omissions in this work. The report is available online at http://comingcleaninc.org. org. For more information related to this report, contact Coming Clean at (802) 251-0203 or 28 Vernon Street, Suite 434, Brattleboro, Vt 05301. Published June 2016. Cover Photos TOP: Gas well pads, farms and homes in Pavillion. c Jeremy Buckingham BOTTOM LEFT: Study participant samples the air for VOC emissions at a produced water tank "thief hatch." Wilma Subra BOTTOM RIGHT: Study participant using a summa canister to grab an air sample at a gas separator in Pavillion. Wilma Subra This report is a collaborative effort of Coming Clean and the partner organizations and individuals listed on page 5. Coming Clean is a national collaborative of diverse organizations and experts working to achieve safe chemical and clean energy solutions that protect public health and the environment, allow sustainable economies to flourish, and secure justice for all. Special thanks to the V Kann Rasmussen Foundation for its financial support of this project. TABLE OF CONTENTS � � 3 Executive Summary ; ,. " F � � �y- _� Q J CHAPTER ONE • - `r� � '�'� _ '�' 7 Introduction Y + 1 `� ` � . 4.�,T . , 7 Welcome to Pavillion � ,, .� � 8 Purpose of the Project f '��- . . � 10 Project Partners �'_ CHAPTER TWO J^' � i � . Il� �....�. , . :;.�"4, 11 Why Study VOC Emissions and Hazards? ;';` ' i '.',� �, ..:,�i� -� � :. CHAPTER THREE 2 15 Description of Study Methods " CHAPTER FOUR -�.y. - j . . 17 Monitoring Tools, Sampling Methodology and Key Findings ` _ < .. kr.: , �� 1.: � ��r-;� 17 Air and Bio- Monitoring Tools �!::i��'�y�,` 19 Air and Biomonitoring Methodology ,_ _ - " _ : 23 Key Air Monitoring Findings �,�;: , 25 Key Biomonitoring Findings � � 1 " � CHAPTER FIVE • m � � ^ 27 Oil and Gas Chemical Hazard Assessment Method .,, - �_ ,. � : _ 9 �i,r, � 3 27 GreenScreen ' for Safer Chemicals Method �«. 1 ( i 28 Hazard Assessment Findings ��I = � , CHAPTER SIX 29 Conclusions and Recommendations APPENDIX 1 32 Professional Research and Laboratory Services APPENDIX 2 35 Application of Environmental Screening Levels to Levels of VOCs Detected in Air Samples Collected in Pavillion, Wyoming i t APPENDIX 3 38 VOCs and Metabolites in the Urine of Residents of Pavillion APPENDIX 4 40 GreenScreen' Assessments of Chemicals Found in Urine of Study Participants, Pavillion FIGURES, TABLES AND BOXES FIGURES 9 Figure 1 Pavillion Area Map of Gas Wells and Residences 22 Figure 2 Illustration of Pavillion Area Air and Biomonitoring Study Method TABLES 23 Table 1 24 Table 2 24 Table 3 26 Table 4 37 Table 5 39 Table 6 Timeline for Gas Air and Biomonitoring Methods Development — One Example, August 6, 2014 Levels of 10 VOCs of Concern Due to Hazard in Summa Canisters (15 minute grab samples), Aggregated Data Levels of 10 VOCs of Concern Due to Hazard in Sorbent Tubes Worn by Participants (1 hour sample), Aggregated Data Levels of Chemicals in Urine Samples of Pavillion residents, Wyoming (August 2014), pg/g Creatinine, Selected Findings Levels of 10 VOCs in Summa Canisters and Sorbent Tubes, Compared to ESLs VOCs and Metabolites in Urine Samples of Pavillion Study Participants, Compared to the General Population BOXES 13 Box 1 How Are Toxic Chemicals Emitted at Gas Well Pads? 17 Box 2 Air Monitoring Devices Used at Pavillion Area Well Pads 19 Box 3 The Sampling Process in Numbers 28 Box 4 Fracking Chemicals and GreenScreen 2 WHEN THE WIND BLOWS EXECUTIVE SUMMARY , ;� _ _ _ -- --._ .�__ , �_ '"� .:_ ► � - - - - - - aiw:-s.. � _.., _ . ��•� .. ' ' - .- . ' .;._- M1./ \� wr- � ''f..;v- - _ _ �� - a . �� F - T� �. s � � � _ - ��AQf.. • • ' ' i � , ' •.LL4 � , �. ✓,�..� . _ �. / _ ♦ � _ _ _ _ � ' .i .1.� / . ` ��L"j.�D . �... . . - ...�"v' . ._ -. • _ ' .— _''_ . T � � � � � r +� � � •� ti . _ �'4� .i • � . � .� ��. . �� • • '� ,, . . l!. �: �� • - . • .. ' y „ _ _ ` � _ � . . . ,_ � � > / , -/ � � Y � +l�� Y. �w �� ` . � a _ �,,, .�. `� �.� � � , . _ _ - , � F ' � � - . " ' �� ` �. . `rY�� x ' :� . `\ -a-� . :. �� 1 •. � . � ♦ • v . � 4 f ♦ � � A.' ♦ � !.: h � ._ . � r ' � � � � � S � � „ �� '� � � , �.',i � - .� � i � v _ y . � . . n � r � v� • 1 � ..� _ � - �� .: � itl�7 .� � � . ��y7j �fi �j ._ 1 i � t, Y�� i a � 4 i ' v ` � i�� Q� � h�`� L� 1� . `v � � . � I V° �._. 6 `v :. � � � � `�w�{.Y`�� A��'�\ �' • W � ��a� ♦ '. � n . , laA � \ .1 � r � _ �Z},�� V � � �\ ., ` l� �r �� Il �� n � �♦ �� • . � : V � � John Fenton points to Pavillion farms and gas development sites. ❑ 2014 a team of residents from che area of Pavillion, extracred in the Pavillion area, is primarily mechane,'- a Wyoming, science and heal�h exper�s, and environmen- po�enc green}touse gas that is linked ro climace change. tal healdi groups, collaborated on a project co test the air and residencs' bodies fo� chemicals luiown to be linked ro oil and �as produccion. 'Ihis is the first study " I F YO U R D R I N K I N G W AT E R I S which combines enviro�mental sampling wich the moni- toring of body tissues or fluids (biomoniroringi) of commu- C O N TA M I N AT E D wi [�l c�leiTt1C31S, yOl1 niry members in very close proximiry [o gas production 171i�}lt be' 1h� e CO Illa�ie C{O wiCh aflOihei equipmen[ and ac�ivicies. , . . , ,�� urce. Bu � if vour a� r is toxic, you can t We began this research because the people living and Choose ro bretl [he sonlew}lefe else . . . .�� working in the Pavillion area reported healch mnditions they fear are rela�ed co coxic chemicals from che gas wells ��b ��o77rrzs, .S��I�eT'est they live with. Raw, unprocessed nacural gas, such as that I Riomoniroring 'u �he idrn�ificaiion of level� nl chemical ruhneances or �hcir hrcakduwn pmdun (metabuli�es) in boJy �iwues or Huids. _' Gilman, I H. Lemrr, ft 41. Km�eq W C dc Gou�e I =1 (?0111. Sourcc 1i�n.�nuc ot Ablacik Ory,'vnie CompounJs I�om Oil and Nami�l Gas Operaeions in Noahcas�em (ulomdu�. GnvimnSci �cchno1. :0131rb � i331�, I ?9?-305. <Ioi: l0J021 /e. 30q119a. Epu620131�n _'? . . . i . . . . � . , -�S� � . � . . . �, . . � �. , . . � i �, . . �, � I �. , , 3 Bu� gas is also comprised oFother volacile organic wm- times the health based exposure standards ser by the pounds (VOCs) . The purpose of thz project was to evalu- United States Environmeneal Proeection Age�cy (EPA) ate che extent �o which VOCs are presenc in the air nexc and d�e Agency for Toxic Substances and Disease Regiscry co and downwind from gas produccion sites; thac people A"f'SDR) .' "Ihese levels were higher chan chose found in living and working nearby these sites are dierefore exposed other states. Data trom that air monitoring research was m air concaining VOCs and chat we would 6nd evidence published in [he peer reviewed journal Envh�onraerttal of �hose VOCs in cheir bodies. Healtfi' and in a report called Warning Signs.� Toxir Po[lution Identlfzed at Ozl and Gas Sites. ' VOCs are oil and gas by-products, which evapora�e easily and are commonly released into �he air near oil and gas 7hrough rhis research project, we designed and tested sires as well as found in many consumer produccr, they mechods for environmental moni�o�ing and exposure are associaced wich a range of differene immedia�e and assessment in people living near oil and gas fields. We long-�erm healdi problems, including damage ro the liver, did chis by using a variety of air moni�oring tools wich kidney and central nervous sysrem, with some VOCs �he capaciry to tes� for VOCs, which are a large group co�sidered m be carcinogens. of carbon-based chemicals that easily evaporate ac coom ceinperamre. VOCs can be bo[h namrally occurring and "Ihe project had three disrinct elements: 1 ) develop methods man-made. For example, many chemicals manufacmred Fo� combined air moni�oring and biomoni�o�ing for mxic by �he pecrochemical induscry a�e VOCs; [hey are also chemical emissions ac oil and gas development sites, 2) associa�ed wi�h oil and gas produc[ion sites. VOCs are assess �he healch and environmencal harards of the chemicals found in numerous household produccs, so for our study found in air and biomonito�ing and 3) provide research par�icipa��s were given a list of produc�s and ac�ivicies and policy recommenda�ions based on �he moniroring and (includin� exposure �o cigarette smoke) �hat might be hazard assessme�� da�a, for the pro�eaion of wmmunicies alcernative sources of VOCs to avoid during the sampling, and workers from che i��herent hazards of oil and gas so that any VOCs fowid in [heir personal air samples, developmenc. urine or blood samples, miv�ht be more direcdy attrib- ucable �o �heir proximiry ro gas well pads than ro This study is a follow up �o resea�ch conducced in 2013— household products and aaiviries. 14, in which [he group Pavillion Area Concerned Citizens and ninereen o[her organizarions in six stares participared Among che VOCs we cesced, we looked for a sec of VOCs in a community air moniroring program, led by the na- called the BTL' X (Benzene, "Ioluene, Ethylbenzene, and tional environmentul heahh organizarion Coming Clean, Xylene) chemicals, which are presen� in che mixture of co decermine which harmful chemicals might be emitted hydrocarbon liquids in raw natural gas produced from from oil and gas sires. 17ie resul�s were alamii�g: highly many nacural gas fields, known as condensa�e.e BTEX coxic chemicals were presen� ac many sites and levels of chemicals are frequendy identi6ed and measured at oil some chemicals in the Wyoming air �vere up co 7,000 and gas producrion sires.' During the week [hat we col- 3 Pollwan� levels were compered io rsposurc s�andards se� by �he lederal Agenq- 1or �lbxic Subs�ances and Disease Rrgis�ry (ATSDRI, hor healrh effecrs oche� rh�an wncer, und ehe EI'A�s Inmgramd Risk Intomiation $vseem (IRIS) th� cancec See endnore IC in Cuming Gean and Global C:ommunin� ,�Aonime (2014). 4 Marey, (; P. 8rerch. R. Cha�naik, M, Cox C. larson, U. 'Ihwn:u, D, Oarpen�er, D O (2014). Air Cuncrnva�ions ul'Vulatile Compounds Near Oil and Gas Pmductiom A Community-bueed Explo�umry Smdy. Environmenral Heal�h 20141 7:82, DOI: I0J 18G1147G-069X-I;-82. C� Muav er al.: limnsee 6ioMed Cencral L�d. ?0I4. PublL�hed: 30 O¢ober Z014. � �n � , . . i ._ . ilo ! % , . . . . • . . ? Coming Clean and Global Communiry Mnnim� Q014). Warning Signs: 'losic Pnlluiinn Ideniified :v Oil .ind Gae Ji�es. Resulrs fmm Communiry Air Monimr- Ing Reveal Chrmicals I.inked m Heel[h Hazards Ocmber201h. -�� - �. - ��/e+:� — _ . . - C Namral-�s mndensaee is a low-densiiy mixwre ol hydrocarbnn Ilyuids that �are preern� as guseum componrnrs in raw nxmml gus. Some gas species within �he raw namral gu wlll condenre m a liquid s�aee iFthe reinperamre is reduced to bel��w �hr hyJrocarbun drw puint tempe�amee ut a set p�essurr. For fuahe� inFormarinn sce: CONCAWE, Envimnmen�el science for the refining inAux�n�: -� �.,nv_ . .. _ i ��ii�i . . .r� - 1'.r• r.r' � ,;i� � -��;.1,-. u. � _'�n!�-n � �n r . 1�..�„1�� Impu�icicv suc6 av BTF.X chemicals am presen� in �he rondensate ponion o(namrnl gxs, ir is no� refined ow and remains ln �he n.�mnl gu dis�rlbwed m gas fired faciliiles �nd for home use. B I'F.X d�emicals nre also mntaintd in oil condensa�e and cuntinue m be present in cmde oiI refincd mvcc�iaL�. , Mwee, C W, Zielinska. R, Jacksun, R B, (20 f 3). Aie Impvca af Shale Gas Exaaction and Disc�ibution, Descrt Rescaech Iastim[c Drvieion ok Atmosphe[ic Science, Renq :VV; Duke Univeairy, Nicholas �chool of rhe Emimnmrnt and C.eneee on Global Changc Durham, NC 27705 . . . . ,. , i .,vl, n�r...>,. a�i.,i � .. , . � l� .q,: . ."� � ;:' andpresenracion6rChnsMooreMny3U 201i , , _„ . i rnn,. .�;,.. �r:,,, i ., � - , rn. ' �,,;, . 4 I WHEN THE WIND BLOWS also presenc in the bodies of che Pavillion area residents V O C 5 A R E O I L A N D G A S B Y - who participated ii� this study. P R O D U C T S which :lfe �1sSOCi3[et{ wi [�� ;� ' Fight chemicals chac were detecred boch in �he air near Pavillion and in che bodies of projec� parcicipants are Iange Of c�t�eCE'riC liTlfCledl�l[e �lI1C� jO11f�-CeI'ITl linked m chronic diseases such as cancer or ocher illnesses heald� problems, including damage to the ��dudl�g reproducei�e or de�elopR,e�,cal disorders :ind ro health problems such as respirarory difticulties, � iver, �<idney �lnd cenir�l� nervoLls syste[n , �t'irl� headaches, nosebleeds, skin rashes, and depression. some VOCs cotlsi(�e1'ed [o be c3ici �logens . ' �e resulrs from both human and air moniroring indicate tha� scud,v parcicipancs during che week of moni[oring were in�ennittentty exposed �o complex mixmres of chemical subscances associaced wi�h oil leaed air samples, we also cook urine samples from people ��d gas production. who live and work in dose proximiry co che gas well pads I.evels of some ha7ardous VOCs in air boch near the where air samples were caken. � gas production sices and cha� seudy participants were brea�hing exceeded one or more Environmental Screen- We then used �he GreenScreen� for Safer Chemicals �ng Level (ESLs), which are the levels of toxic substances (GreenScreen)' method ro identify �he inhere�c hazards of that public health agencies and environmental regu- the chemicals Found in �he air emissions and in the bodies �ators have de�ermined as warning signs for risk to oE smdy participants. GreenScreen is a globally recognized ��ii��an heal�h. 1° chemical hazard assessmene eool �hac companies, govenr Hazardous breakdown products of VOCs were present ments, sciencises and health advocares use to identify the � . in che urine of smdy parcicipancs a� much higher levels pocential environmental and human health impacrs of �han those found in the �eneral population, with one chemicals. example up ro cen times higher. �Ihe results are a new da�a se�t which combines air moni- �ur aim is thac the daca and protocols es�ablished in roring, biomonicoring and hazard assessment findings. �his study be used co: 1he new data set provides a more comprehensive undeo- standing of whac Pavillion area residents am breathing and • inform and engage Pavillion area residencs and mm- wha� healch outcomes mighc result from these chemical mun�ty members who live near oil and gas develoPment exposures. Specific resulcs from mulciple air monitoring ihroughout the US and internauonally in decisions �ools, the biomo��imring da�a collecced from eleven com- �hat affecc their healrh; muniry residenrs, and GreenScreen chemical hazard • encourage legislators a�d government regulamry agenaes assessmen [s show: ro make precau�ionary decisions tha� pro�ect the public trom exposure co mxic oil and gas-rela�ed chemicals • Toxic chemicals presenc in the air near Pavillion, and from inherendy hazardous oil and gas produccio�; WY, including BTEX chemicals, are consis[ent wi�h ��spire further research by other community scientists chose associated wich oil and gas production and ics � and researchers, who could use, adapc and improve associa[ed infrasaucture. This finding is consistent �he study pro�ocol �o continue [o monicor exposure to with o�her air moniroring findings from the Pavillion chemicals associared with oil and gas production and area as well as addi�ional oil and gas produc�ion sices becter underscand cheir impact on worker and public in Wyoming and in the US.'' health; • Haza�dous breakdown products of BTEX chemicals and other VOCs associated oil and gas production are ft GreenScreen' For Sater Chemiralx we6sue. - .� , . , �:� �� .. �. . .� . . .. -. 9 Mncey er.al. Q0141. op.d�. und Coming Clean anJ Globnl Community Monl[or (1A74). op.dr. 10 ESIs are h�ased on daia concerniug heal�h effeas, �he po�emial fo� odnrs m be a nuisance, and eHeas on veger.aio�i. . .. Ifpredicred ambien� levels oFmnstiments in ai� ezceed the screening levels, ii does no[ necessarily indica�e a problem hut ra[he[ ¢i�a�s a revieu' in more deprh. Huth shu�r and Inng-eerm ESLs am lisrsd un thc F.tiL List. 'Short-terni' gene�ully indicates a ono-hou� aveevging pe�ind . . . "Long-mem" indicates an annuul averaging penud � - �:z; � �r u, . .� -,�. � n,ei�nG,� . � 1 , :,. , .... i P.ACI�IPIi - T _� � I �._ �= V- E��IICAL5 ! N ; �,� FI [ L_' � 4NG IN1P � TFC �:GMP�IIJMTIE5 � 5 "BASED ON THESE RESULTS and those from the increasing number of studies in areas under development, gas production is proven to be an inherently hazardous process. Residents are exposed to hazardous chemicals throughout exploration and development. Gas production is not a safe or clean source of energy." — Deb Thomas • reinforce our long term goal of transitioning our economy to energy sources that will not harm local communities and the environment. Based on the monitoring research findings and the GreenScreen hazard assessment results, we recommend the following: • Encourage further biomonitoring research and use results to effectively prevent exposure. • Investigate the harmful impacts of cumulative exposure to multiple chemicals and how their toxicity may increase when they interact in mixtures, especially chemicals with endocrine disrupting effects, which may act at low levels. • Implement precautionary regulations, ensure disclosure and transparency. • Promote clean renewable energy sources and stop promoting natural gas as "clean" and "safe." • Provide ongoing monitoring, health evaluation and site remediation to protect people already affected by oil and gas production. 6 WHEN THE WIND BLOWS CHAPTERONE INTRODUCTION W E LC O M E TO PAV I L L I O N which they believe are linked to toxic chemical emissions associaeed with the fossil fuel extraaion, processing and avillion is a small, rural ranching communiry situ- was�e. 'Ihese healrh symptoms indude headaches, as[hma ated in north central Wyomin�. The mwn is home and ocher respiramry illnesses, bloody noses, kidney prob- to around 240 residents, with approrimately 200 lems, loss of smell and tatte, cancer and cogni�ive disorders. '� more people living in che area east of Pavillion, in a Aker more dian ten years of asking the State of Wyoming communiry of small family farms and ranches that and the operating companies to investigate rroubling prima�ily produce alfalFa, hay and cattle. Although gas changes in d�eir wa[er wells and receiving inadequate exploration began here in the 1 )�0s, che Pavillion area has answers, area residents turned to the Environmental seen subscan[ial increases in developmen� over the last 10— Pro�eccion Agency (EPA) for help. 20 years. As the industry increased the number of gas wells in che PavillionlMuddy Ridge field, chis development has In early 2008, rhe EPA conducted site visi�s in the Pavil- expanded onto fa�ms and encroached closer ro homes. The lion area and began an ofTicial invescigacion in�o residents' field currendy consis�s of approximately 1G9 active vertical concems in September. ' ' �Their draft report, " Investiga- gas production wells and cheir associa�ed in&as�mcture (see cion of Groundwa�er Contami�ation near Pavillion, Figure 1 , Pavillion area map ofgas wells and residences) . Wyoming,r " released in 2011 , linked the contamination oFgroundwacer with benzene, inethane and other hydro- Although the Pavillion/Muddy Ridge field is comE�rised of carbons ro oil and gas developmen� in �he Pavillion area. comention.il vercical wells, ot6er unconveu[ional processes Also in 20l l , che Wyoming Deparcmenc of Environmen- induding hydraulic fracturing have been used ro stimulate r.tl Quality (WDEQ) placed a mobile air monitor ro gas produccion. " �" Hydraulic fracmring enrails rhe use of derermine ambienr air qualiey near ehe Pavillion gas field. � a large number of chemicals in the drilling process, many 7lie moni �or measured ozone, nivogen oxides (NOx) , of which have been identified as substances of high hazard methane and particula�e ma�tec Non-methane volatile to both human health and the environmen� (see Box 4) . organic co�npounds (VOCs) were induded in the Howevec, ehe predominant methods of gas producrio❑ WDEQ's da�a, and al�hough che cumulacive amounts used in the Pavillion gas field are convencional which also were measured, che monicor did nor identify che air con- i�volves the release of hazardous chemicals inherenr ro cencrations of specific VOCs being emi¢ed i� rhe densely gas production. developed gas field, which is in the farm fields where peo- ple work and close ro homes. Even chough residents re- Pavillion area residencs have lived wirh gas development quesred d�a� the Stace conduc� addi�ional monitoring i❑ for decades. Many residents experience healdi problems, these vulnerable areas, ehey were reFused, despite �he faa 1 I Conventional gss d�illing techniquc �escrves of gasare essily accessible us'mg vertical drilling. Umm�ventional drilling technique: �he g�,ts is �rapped in layea accessible anly by hocizontal dcilling. For muce inFormation see: UK Hoaa�s nf Padi�amen�. Umm�ventinnal gas, Numbcr 37A April 2011 . .-� �!� , n '•.iuini�.ci' rioo��m ,�i��,�r/nmtF,n.� -.rrnm��,nr<zr�,e i ;�d/ "Both mmemional and wsonvtntional oil and ges operarions involvc hcury indnsaial pm�rsses, which by e. � � i defi�itionreleaeravarieryofheuldi-harmingpollur�nn i '�, �i. .� .. -, ih,.r.� � . "�n .. i � �,n��;e„_ � ,�,i . , �,�,i .: ��,n�m n/� i��i,c d�vr( lr-. liJ'�l �Yul�;rNl � 1 ? The LATimer repora diat verti<al frucking occurrcd amund L00L See Sou�ceAY/a¢h R01G), Wyoming and Feacking, las[ modihed on I S Febrt�aq� 2016, at04:21 / ��l ;, r�� .. �i � . �rl�m,,L»d�. � �_ , lr.,��, , „i0,t{�u;,, 1 3 Macey ecal. (2014), op.�it. and Coming Clean vnd Global Communin• iblonimr (201 A), up.cit. and Agency fo� fnxic tiubs[ances and Diseme Reg'utry IKGSDR): Toximinglcal pmfilc hnp: �u ,. r :+ .�,� � , ,�, �„lil., 14 Sepmmbcr 2008, under aurhoriry of che Comprehensive Gnvironmental RUponse. Compensa�ion, anA Liability Aa (CERCLA). I ��_. I< Ild .. .- I ", I '. Ifi .- i _ � ' Inif-I� I . '.. ' f �" ifllli:_'�, 7 JOHN FENTON , WHO FARMS IN THE PAVILLION AREA , EXPLAINS : " ��1y wife's family has been here for over 40 ye.trs . When 1 first came to the fann there were t�vo gas wells on i �. Over the next I � years, 22 more �vere drilled . In Z006 , we began ro recognize chat much of che water in our area is coneaminated and tha� roxic air emissions are affecti��g our health . Our family has experienced pha� tom odors, rashes, hair loss, respira �ory conditions, neurological problems, epileptic seizures, cancer, and huge hics ro how we think and reason— our cogni �ive skills. �Ihe biomonitoring project was an opporniniry ro hnd out if �he chemicals we know are in the air, are also in our bodies." thatlocalpeoplewereincreasinglyconcernedthat PURPOSE OF THE PROJECT their health sympmms were due to che toxic chemicals in the aic The purpose of die projea was m evaluate the excent to which VOCs are present in the air next ro gas wells and In 2012, Pavillion Area Concerned Cicizens was one of downwind; that people living and wo�king �earby are 20 organizacions in six sta�es tha� par�icipa�ed in a com- therefore breaching air which concains VOCs; and chac munity air monirori�g program with ocher local and na- VOCs are also found in their bodies. VOCs are associa[ed tional pa�mers, led by the national environmen[al health �vith a tange of different immediate and long-term health � organizacion Coming Clean, co decermine which hamiful problems, including damage ro rhe liver, kidney and chemicals, induding VOCs, mighc be emicted from the central nervous system, wich some VOCs considered oil and gas sites. The resiilts"' were alarming: highly toxic to be carcinogens. chemicals, induding BTEX chemicals, were presenc in che Wyoming air, some at levels up co 7,000 �imes the healch The projece had [hree disrinct elements: 1 ) develop inechods based exposure standards ser by che EPA and A'I'SDR. ' ' for combined air monit�oring and biomonimring for coxic chemical emissions ar oiI and gas developmenc si�es, 2) [� is because of chis previous air monicori�g by rhe commu- assess rhe heal�h and emironme�cal hazards of the chemi- niry in Pavillion, along with the groundwarer contamina- cals found in air and biomonitoring and 3) provide research tion investigacion by the EPA and heal�h issues experienced and policy recommenda�io��s based on die monimring and by residents, that in 2014 Coming Clean began coordi- hazard assessment daca, for the proceccion of communicies nating an air and biomoniroring study in che Pavillion an� wo�kers from rhe inherent hazards oFoil and gas area. Tn lig6t of che failure by bo�h �he Sca�e and Federal developmenc. authorities to perform more comprehensive monitoring, community members waneed ro parcicipa�e in chis smdy lhis projea is the firs� smdy chat acremp�s m combine in order to get answers to their questions about which environmental monicoring samples wi�h biomonitoring chemicals thzy are breathing and ro explore current tech- samples from communiry members in very closr proxim- ❑ologies that could measure the levels of those cheinicals iry co gas produccion equipment and activities. We began in �heir bodies. I i DiGiulio, D G, Wilkin RT, Mille� C, Ohedty G. (201 I1. Investiga�ion ot GrounJwamr Cuntaminatiun near Pavillion, Wyomin�; CS Enrlmnmcneal Pmtcainn AGency, National Risk Mnnagement Labo�amn' & Region R; 8PA 600/R-00/000 December 201 I -��. i��i and �nr/•�: . � . � a � � . . _ . �;.:. Inuaqi l l I.. p. �.up � � 1/i,�c 11 � ' i , . . 16 Macey et.aL Q0141 op.cic and C;oming Clean and Glohal Communiry Moniwr (2014), op.ci�. 77 Cnming Cle�an anJ Globul Communiry Munimr (?014), np.cic. 8 I WHEN THE WIND BLOWS F I G U R E 1 Pavillion Area Map with Residences and Oil and Gas Development Sites . 4- - � 'f" � ; . 1 • � • • N•11�i -ti + � .. �'� " a \ �� \ �;. {' � ' � , ' �.�. : � �� • �� «� �t • \ ` l '. ; . ' �` ' • \ • • • '� �\+ 1 "� � ~A 1� �, ' � � • • � � .... �_ .. ��}. . ` �r:� � '� • • • � . t.. -s•� � � •. � t, > � • „ ..: 1 k.:.�� _�� . . � \ , �1' � ' ` . , � �� ) y� � _ � � . . ..� '1 .� � � O �. .� 1 _ �. � :•, � � � � • ` `� �s _ ^ s� � , � �� r,a p y � , � ,. � . , 'I �� i m , m �4" -`-i � . � -« : �� YJ � � » . ; ��a e • �. �� .' � • t . ' , ' A � o . ; , � �; :� —� • T�O� 1 � � . - . � , ��• i P ., � � ' � �. �ll. ., c . . �. ., - � ,�, � . . - . �..v_' � / . A � ' ..�.::h . �' t �.. ��` � . � � • �� -. , .� �.� � . � .. � ..,_ - � ' \. �v�. , o� a •. ., � �� . �:. ' - 0 e �� .� O ir.' ' �` . �, i ~l� � � �` � Z� � �i[a.- . ., � � . ','('� g�r. �, � s . . ,.. r �. � � sr - � ". • A � �Al w . ��/ . \ . �. .� . . • � � � �� - ' . �_} ... ' �� ^ L � � '�i; t1 ' � ^ e.. 1•; JO � �/�� L. . . � �� a . . I . \�� • . '1 � �, �' q . Fn . ` .. , � �L \ .�9 ` , . � , `� � � �^ �� ' w • � � �t � �: � . �. . 1 � �� —...� b ` ' .-� .,� �r Ns�.,� �, �'�� t..� . < �� _�r- � � �� `?. . "'� . b . �►._. �,. � DevelopmentSi [e - Residence o os i zn�ies Author Caitlin Kennetly, Source: Garmin eTrex Venture, Source'. National Atlas, Source, Fremont County Asseswrs Office. Source: EPA Pavillion Area Workin9 Group. Data Frame: NA Equidistan[ and Equal Area Conic. Geo9raphic Prolection�. NAD 1983. Date created'. Fall 2012 and Winter 2013. this research because the people living and working in Our uim is chat �he da�a and prorocols be used �o: che Pavillion area reporced heal�h coi�ditio��s �hey Fear are relared [o toxic chemieals from the gas development they • inform and engage Pavillion area residents and eotu- live wi[h. muniry membea who live near oil and gas develop- ment throughout rhe U.S. and in�emationally; Pavillion area communiry members hope ro use die • encourage legislac�rs and governmen� regulacory monieoring resulrs ro e�courage legislarors and regularor}' agencies m make precaudonary decisions thac prorea agencies ro prorecr residencs' healch and ro help o[her the public from exposure �o coxic oil and gas-rela�ed communi[ies facing exiscing or new oil and gas develop- chemicals, and from inherendy hazardous oil and ment avoid ehe health challenges tha� Pavillion area resi- g:is produccion; den[s are Facing. A precaurionary approach to decision • inspire fitrther research by other communiry scientis�s making is cricical if we are �o truly pro�ect public health and researchers, who could use, adapt and improve and the environmen[. For communi[ies impaaed by die study protocol [o con[inue to monitor exposure existing oil and gas developmen� this needs co happen �o chemicals associa�ed with oil and gas produaion now a�d it is no� coo late to prevenc fumre damage in com- and betrer understand [heir impacc on worker and municies which are �hreacened wi�h new developmen�. public healch; TRACKIPII �J>.I �_ �HCMICALS li I b =5 FILLDS AfdG IMf'-��_ � � L �Uf IDIUNI I lic 9 • reinforce our long term goal of transitioning our economy to energy sources that will not harm local communities and the environment. PROJECT PARTNERS Corning Clean is an environmental health and justice campaigning collaborative focused on protecting public health and the environment from toxic chemicals and pollution, and promoting clean energy and safe chemical solutions. Coming Clean provided the coordination leadership for this project, with the organizational and individual partners listed below. This report was written by the project leaders at the request of the Pavillion Area Concerned Citizens. Project partners were: • Clean Production Action, a non-profit organization that designs and delivers strategic solutions for green chemicals, sustainable materials and environmentally preferable products, including the GreenScreen® for Safer Chemicals hazard assessment method; • Commonweal, a non-profit environmental health research organization with expertise in biomonitoring as a tool for understanding how individuals and com- munities are exposed to chemicals; • Pavillion Area Concerned Citizens, a non-profit organi- zation of people interested in issues including oil and gas development which impact Pavillion, Wyoming area residents; • ShaleTest, a non-profit organization which collects environmental data and provides testing for families and communities that are negatively impacted by oil and gas development; • Wilma Subra of Subra Company, an award -winning chemist and microbiologist who for more than 30 years has researched the impacts of toxic chemicals on the environment and on public health. The science team that designed and implemented the study in collaboration with the Pavilion area community included: • Dr Robert Harrison, Director of Occupational Health Services at the University of California, San Francisco (UCSF); • Zachary Wettstein, University of California San Fran- cisco Medical Student. Study Assistant Science Advisor; • Caitlin Kennedy, Master of Science in Public Health in Epidemiology and Environmental Health, Rollins School of Public Health of Emory University; • Deb Thomas, Director, Shale Test; • Wilma Subra, Subra Company. Additional scientific expertise provided by: • Dr David Brown, Public Health Toxicologist, Southwest Pennsylvania Environmental Health Project; • Dr Detlev Helmig, INSTAAR Laboratories; • Mark Chernaik, Science Advisor, Staff Scientist, Environmental Law Alliance Worldwide. 10 WHEN THE WIND BLOWS CHAPTER TWO WHY STUDY VOC EMISSIONS AND HAZARDS ? aw, unprocessed nacural gas, such as dia� extracted in chroat i�ritacion, headaches, lower wgnicive function, bss the Pavillion area, is primarilv methane, ' " a potent of coordinacion and nausea, damage co liver, kidney and greenhouse gas chac is linked ro dima�e change. cen«al nervous sysrem, and some VOCs are considered But gas is also mmpriseci of othe� VOCs. Researchers ro be carcinogens. For example, benzene—a well-st�died have shown rhac oil and gas development uses or VOC—is considered by che lntcrnational Agency for emics hundreds of chemicals in the VOC family. " In our Rcsearch on Cancer (IARC) co be a group one ca�cinogen report we are concerned primarily with a fainily of VOCs and can cause leukemia." Peer-reviewed research indicates called B'I'EX (Benzene, loluene, Echylbenzene, and a link between exposure to oil arid gas chemicals and nega- Xylenes) which are an inherent par� of che mixture of na�- cive health effects on people who live and work close to oil ural gas, hydrocarbon gases, water and other compounds and gas development sires. Z` �^ Smdies also show elevaced that are pumped out of undergrowid reservoirs during gas levels of pre�erm bir[h and lower birch weighcs in places production, known as gas condensace.2° BTEX chemicals dosest co oil and gas developmenc" are also known to be hazardous co human health, even at low levels.�' One way ro assess die po�encial health hazards Non-cancer health effects that are significantly associ- of living and working near oil and gas sice is ro measure ated wi�h ambien� levels of exposure �o BTEX chemicals the presence of BTEX VOCs in the air and in our bodies. indude sperm abnormalicies, reduced fe�al grow�h, cardio- vascular disease, respira�ory dysfunaion and aschmas.'� VOCs are associared with a range of different immediace Several hormones may be iuvolved in �hese health out- and long-term health problems, induding eye, nose and comes, suggesting �hac BTEX chemicals and ocher VOCs 18 GiLn'vn, J li, Lernrt B M, Kus�re W C, dr Gouw, J A (2U13). Suivice sigmawre ul vul;uile o�gunic cnmpnund� Fmin oil ;md nwur.J �os npern�ions in nonhras�- ern Colo�adn: Enciron 5ci l'echnol. 2013 Fr6 5: 47(3): I297_iU5. dni: 10. 10] lles504119a. Epu6 2013 i�n 25. .n.*. . , � ; ; i i�2; � 19 7}�e VOCs emiaed will depend on va�iables mch u the specific rype of exaaction or pmduction aaiviry: stage of pmductiun; whut specihc mmpanies are io- volved and whae chemlesl `recipc they usc rhe mmp�nv involved; and diHeeences in geologic mnAitions ut difkrent sims (i.e. what chemical mixtuees are used acmrding m che tvpe of undergmimJ shale furmaciuns in whidi uil and �.ts are mnrnined). �vr,�. , , n,,, , i , , .. ... d n � „��v� �. . 'p/]ry!�/I v� 'f 811(� � . � ♦� 'i:U . � yP� � 20 Nauiral gas condensatr is a low-deneuy min[urc u( h}drocucbon Gqulds �hai .ae presene an gaseous mmponena in rew �omral gas Some gaF sprcies widiln the �aw namral gas will mndense m a liquid scace iFche �emperamm is mduccd m bclow che hyd�oe�rbon dew point [emperamrc ac a sec prcssu�c Fo� fuahcr infoo- mutiun ccc CONCAWE, Envirnnmcnmi scicncc Far thc refining industrv: ^r:n. � � � �n�.nir.,�� i '): . ".� t � . ru rin �� 1 :�•.0 � i � � i• :::�.�:'.. _'�q�N �inr� .' u! - ;,,ii Impuriciessuch as BTFX chemicals a�e presen[ in �hc mndensute portion ot namral gas it is not a:fined ouc and mmains in the nemral gus distributrJ m gas h�ed hcilitiev and toe home usr. 6TEX che�niculs am alw tontained in oil mndensate and cominue m be pttsent in crude oil refin�d matcrials. 21 Rulden, A I., Kwiatko�veki, C F, Culbum T (2015). New luuk �ar RTLX: Are Am6izn� Lzvels a Pmhlzm.' Fnviron Sei Ted�nol. ?015 Vla}' 5; A9(9):5261-7b. doi: I0. I02Ues505316E Epub 2015 Ap� li. '_'_ IARC Monogcaphs on the evnluatiun of carcinugenic risks tc� hunun, Vulwne 27 suppleniem 7. 23 Conamed Health Protessiunvls o( New York Q0144 Compendium ot $ciemific. Medic-al, and Medie Flndings Demonsiraung Risl:s �and Harms of Fncking (Umm�vemimial Gas and Oil Rxvac�inn). July 10. ?014 � , . . � rp,<. i, ,�G,ri�. '_4 Huys, J, Shonkoff, S [f C (201C). Toward an Undearanding of the Envimnmencal and Publit I Iealth Impaas of Umm�vencional Vacural Gas Devrlopmene ACategoncalAssusmentofthePeerReviewed5cientificLiteramre. '_0U9-3015, Apri1202U16: � . :c:L. � , , � li..�.�i,�� , .r- , n. !. � / �:.in.ir ,e�. ri � � 1n ;. This papee demorucraas cha� che weighe of che findings in �he sciemific limrawm indicaers harards and eleva�eA rinks m human healdi xs well as possible ad�erse healih outcumes aesociaced wieh L'VGD. 25 McKenzie. L ,N, Guo R, Wiaeq R Z, Saveiz, D A, Newmon, L S, AJgaze, J L (2014). Rinh Ommmes und Namral Gas Developmem. Environ Heah6 Perspecc � DOI: 10. 1289/ehp. 1408647R , -q,. : „ �,. ri.r.-� -:� �i: -�� and 8inh ou¢oines and ma�emal residen�ial proximlry m nam�al gas developmenc I in mral Coloeado Gnv�mn I lealih Penpea I ?�:412� 17 dui: 10. 1289/ehp. 13067�2 i �. , �,�r �; :'��. -_`,'. 26 6olden, A L, Kwia[kowski, C F Culburn, I�, (2015). op.cit Tf . _ iu^� � i ' _ . � � , ..l5lri . . . . . .rl! ) ih-iF � � _ ?� ri � lUr.IIIIE� 11 may have endocrine disrupcing (hormone scrambling) ; ; ; � � �/ �� " ? y�� properties as well.' Even very low levels of endocrine dis- ' ; j ? �' mpting chemicals (GDCs)'" are known ro contribure ro i � � � a range of health effects, in particular reproductive and devel- �� - opmental problems, at levels below exis�ing safery limi�s. � � . ��'j � � � � � � � � `. � �a ;. c . . People are noc only exposed co B�I'EX and other VOCs � � � - _ � �� - _ W ' , ; � � � '. _ � in proximiry [o oil and gas production. lhey are presenc 1 ��'� • ,�� in vehicle exhaus� fumes and cigarerte smoke as well as � . �� in everyday household produc�s made from derivatives of 4 �I -_ � � . , . .. :, ' ' �-- -- oil and gas.'� BTEX and ocher VOCs are found in a wide % " : " _ =__ � ' aaay of everyday producrs such as pain�s and paint scrip- ` �' ^' :;_- � - ' pers, solvencs, glues, deansers and disin}ec�an�s, children's �� " �' [oys, pes[icides, paincs and pro[eaive coarings, fingemail � � � -� � �� r�l ' , polish, gasoline, aerosol sprays, wood, fiberglass, Hooring % � ' ''� ' �' marerials, ofl'ice equipmenG PVC plastic, health and "' ^ 1� beaury produca and more. 7herefore people thac live ' �� ` next xo gas produaion facili[ies face greater poten[ial ' ir- exposure to VOCs from both gas production and ` �� `A 'i�� everyday products, �han �he general population. } . � `. ✓ , y . _ y � Of equal concern is rhe assessmen� of che rocal �oxiciry � � of VOCs in chemical mixtures. Litde informacion exiscs �•,� _ � abou[ how VOCs in mix[ures interact with each other and �� i�v �omn,oi, n�.usE, hold products contarn harmful VOcs. in �he human body, buc scientific research indica[es that VOGs mighc inreraa in ways chat ratche� up the risk of the presence oFsunli�ht ro create new chemical harm eo humans."' In addi�ion, VOCs in combination compounds considered ro be harmful ro human healch .'` wich other environmenral factors may resul � in increased risk. For example VOCs may inuease �he toxiciry of par- Many factors, induding the Level of exposure, peak ciculace marter in �he air (e.g. sooc)" which is emi¢ed by exposure, the lengch of time people are exposed ro chese oil and gas developmen� ac�ivi�ies.`' Smdies s6ow �ha� chemicals and �heir individual vulne�abiliry, inAuence how some VOCs may also combine wich nirrogen oxide in VOCs affec� healch. Governmen� agencies, induding [he ?% 6oldcn et. al. R0 U). op.cic ?S "Cnduc[ine disruptiun is the insidious rrespess o( man-made chemicals imo evrry vl�al nrgan rysrem in your budv thm comprises or is contmllyd by the endo- crinc rysmm, wth as the thymid anJ parachvmiA, pancrens, adrenals. [h��nas, male and femule repmduc�ive organs, thc hcare digrstivesysrem. and s-keletal sysmm—aIl the scs�ena thai panidpared in hov� cou werr mnsruaeA in �he womh and how you a�e functioning today' i,,,�. , �„n u::- ..'iP l � i.:d' r / � . �..�I�. r . . (/.. e I . . � . .� I I � l ' . .V � r vM1:l l tlq 'lT.�ryr �, ?9 Rauennan, timar[. Peng-Chlxo Su, ti6i I.i. Hhnmar �tukhe�jee. and Chumm�g JIa, Q014). Pcrsunvl Esposure co Mixn¢es of Volatile Organic Compounds: ModelingandFunherMalysisnftheRlO1!�ADan: ReportK: l9LPuFlicacionType: Rese�rd� Repor�i: 2014-0690, �arp:///mA � � ' � . �-..n. ��r;� iai ply.;id=i1? Knuppel, H, Schauen6urg, H (1989). Scmrning nt HuuseholJ Pruducti tor che G�nission ofVola�ile O�ganic (�mpnundz. Em�iroa Int. 198A IS (1—C). 411-41A. Wullace, L A, Pelli�zari. E. Lcaderer, B. 7elon, H. Shcldon. I. 119871. Gmissions oFVnla�ile Or�unic Compounds from Ruilding Ma�e�ials und Con- sumc� Products. d[mos. Envlroa 1987, 21 2), SB>—i9 i. Lhu, J, Cao, X L. 6cauchamp, R Derermination of Lbumxye�hanol fmissions tmm Srlratd Connumer Pmducu anJ iu Applia�ion in Assessinent uh Inhala�ion Exposurc Associatrd �vi�h Cleaning 'fasks. Ynvimn. Inc 2001 . 2G (7—R), j89-597. Nazaroff, W W, Wesehler, C J, 1?0041. Clevning pcuJuas and air hrcshrners I':xposurc io Printary and Second�.u'y Ai� Pollurams: Atmosphccic Envimnmcnt 3A Q004) 2R41- ZRGS. ' / . . . r �rfrvl.'.� l . . . . .I Ilil ) � � o � I � . i � l .�L�I . _ w_ 'll l. l C. I '-/ i �d � !l ? .ivF. 30 H:iuernwn. er al (20141. ��p.cit.. f3rown D. Welnherger C�. Lewic (:. fionaparre H. (2U14)- Understanding exposurt Irom namral gas drilling pu[s eurrent ai� etanda�ds m �he resq Rcv Environ He.Jth. '_014:29(41:277-92. doi: 10. 1 J1 >hcvch-2014-0002. 31 8ha�sviller, S, Lichtvcld K. Sexroq K G, Zuvala, J. Lin, Y H, Jvspen, 1, Jeffries, I-1 H QU 12). Gaseuus VOCs mpidly �nodify paaiculare ma¢e� and irs biological eHec[s—Paa L: Simple VOCs und mudel P,bl. Atmus Chem Phys Discuss. ?01 ?: 12Q):5065-5105. flpu6 ?012 Feb 14 / �i !h � � v!�r; � �..e�-=�� „!„n�.t_' r !' - . �r. � 33 Bmwn ei al (2014). uµcii. I 3 i Duyle. M, Sex�on. K G. Jel$ies, H, Bndge. K J:spers, I (?004). BHecrs of 1.3-Bwadlene, Isuprene, and cheir Phomchemicul Degradaciun Pmduns un Human Lung Cells. Environmenwl Nevlih Peespeccives. ?004; 112p 5): 1488-1495. doi: 10. 13R9/ehpJ022. 72 I WHEN THE WIND BLOWS US EPA, the US Agency for Toxic Substances and Disease _ . Registry (ATSDR) and the California Office of Environ- , . , . mental Heal[h Hazard Assessment (OEHHA) have estab- • . . lished regulations that set limits for acuce exposure to some VOCs (for example, high-level exposure from an accident) Toxic VOCs are emitted in a number oF ways in the oil or chronic exposures (for examp�e, lower level exposures and gas development process. The Pavillon area, with over the coucce of a work day or lon�er) in an atcem�t to its numerous gas production sites, became the basis prevent chemical-relared illness. However, no safety levels for our investigation. Each piece of equipment used at or around a well pad to extract, process and iransport have been established for �he majoriry of chemicals asso- oil and gas (induding diesel trucks, drilling rigs, power ciated with oil and gas production—which can number in generators, phase separators, dehydrators, storage �he hundreds. Even when safety levels have been set, they Water tanks, compressors and pipelines) is a potentia� typically do not take into account the exposure scenarios emission source for methane, VOCs and other 9ases described in Pavillion and other oil and 7as commtmities. or particulate mattec Emissions of VOCs may occur at any stage of exploration or production by way of Peo��e �iving near oi� and gas �roducfion activi[ies—as venting, flashing, or flaring which can also lead to fugi- opposed to workers who do not also live nearby—may tive or non-permitted emissions. when there are many be exposed [o complex mixtures of VOCs at un�crtown, wells in a small area, emissions from individual point flucmazing levels, resulci��g in chronic low level exposures sources can accumulate and become a substantial with periodic spikes at much higher levels, for 24-hours source of VOCs.'s a day, possibly for years or even for decades. There is no Storage tanks are just one example of how toxic chemi- current scienti�ic ana�ysis of the hea�th eE�ects that may cals are emitted at a gas well pad. Light hydrocarbons resul[ from such �on�-term ex�osures [o VOC mixtures including methane and other VOCs, natural gas liquids around oil and gas sices. Purthermore, there are currend,v and some inert gases are dissolved into condensate no ac�ec�uate methoc�s ro assess how the chemica�s in this during storage. These chemicals may Lhen vaporize or mixmre may in[erac[ synergistically or additively i� ways "flash out" and collect in the space between the liquid that may cause harm ro human hea�t�i.3° Lurrent research and the fixed roof of a storage tank and can be vented shows [hat [he effects of chronic exposures ro low levels to [he atmosphere as the liquid level in the tank fluc- of each of the BTEX chemicals, with periodic spikes, have tuates. among the vOCs emitted are chemica�s such been insufFicient�y incorPorared inro current safety stan- as n-butane, pentane, propane, hexane, for example." dards for chese chemicals (see Appendix 2, .lab�e 5) .j' BTEX chemicals are also contained in this condensate and although they may not in general be at the highest levels by volume in the condensate, they are a cause The scienti�ic comm�nity 6as exPressed concems a�ou[ for concern because of their well-established toxicity. its current incapaciry to address the �oxicity of mixmres. For example, reseatch �y Dr David Brown of Che South- The life span of a single gas well, such as those in the west Pennsylvania Environmental Health Projec[ has Pavillion area, can extend from 3O to 5O years. This documenred [ha[ emissions vary a[ each well pad due [o means that people living and working near these sites several factors, induding the type of gas being extracred, may be constantly ezposed to toxic chemicals for che mixture of fluids used, the quality of equipmenc as well many decades. as the methods of extraction and processing. He stares, 34 Maudedy, J L and Samee, J M (2009). Ls -Ihe�e F.ridrnce fnr Syne�gy Among .Gr Pnllutana in Causing Health Effcaa? Emiron H�al[h Peapar, DOL I0. 1289/ ch�. L1G$4 r � ��a.�; + � ;. rrin�. ud, i � , . . . � 't 'n_'-,ti� / 35 Kasmtis, C D, Tillia, D E, Lin, C H, McElmv. J A, Nagcl, } C (201G). Endocrino-disrupting C6emicals and Oil and Namrvl G�.ti Optrations: Potential Envimnmenml Conmmination and Rccommcndations m A.ssess Complex 8miconmencil Mixmres. Environ Health Pe¢pea 124:25�r264; i r �/il / / i ir' �n�i �-IU�)9 � S. C�1�. ��1�9).3�. 36 Gilman ec al R013). up.cit. 3� 'I.ielinska, B, fuli�u, E and Campbell, D (?01 I). ,'VlonicorinK of Cmie�sions from Bameu Shale Nan¢al Gas Produaion Facilicia tb� Populacion Fapusure Assecsmenc. Na[ional Urban Ai� �loxia Research Cemer (hl.'AI RQ. No. 19 201I . � r,:.:,, i , . :: ! � ', n,in".,1�� . -u � . . o� �i.pol. i�luore eiaL C013). op.cii. �, .. ., . � � . , . � � . . - ,� , � � �., �. . . �. � � � � � i I ;�, 13 � ' � � . . . i •� � � � ` --^ � • _ . � � \1 - i �Zl . \\ � 1 T t�� v;�, _ �� . �, Using a FLIR camere to capture toxic chemical emissions at a produced . . t. �, _ water tank in Pavillion. � � �� . �;�ti ,�: � _ i - i' 3 . !� r� - � - - - l � � �` ._ �r.�:a __ �.��': - � - _ , . . - --- - , i��;: ��-�-. _ _ ; : �t - - _�_ _ , .. } �`:�-� , � � -- - - ; ,- . -: , : : :`��' � f - - ��, , •I � . � 1 r . .n ` ♦ � ' � � � D' ' � i � 1� � �y .�.r� .` ^ a . ,. ;�ri �.�) �- � .�f r. �� +�f�' _ . `��i w-.��. aF � �� '1 i .. ( -.!, 7.� � + :w. _ . . � . . _ ' � . .. ._ _ � . - . . . - . ..SoS- .. _ .,. . - - . ,. Rchrrcn�c sr.in �� .ia�s .ira sc� in a torni ihai in�.iccura � cic tn c>tim:uc t6c E�otcniial ris�.s dur to c�E>� uurc Irom uuil- decerminea� healdi risk bccause �hey �lo not tull �� co�uider iiply diemic�la at �hc t:iine tiine, �vhid� m.i�� be highee �he pocencial synergiscic combinations of roxic air emissions:'38 Of special concem are chronic exposures ro low levels of chemicals as these occur in mixrures. A characceciscic of In addition, in 2012 che Air Pollution Concrol Division endocrine disrupcing chemicals is cheir capaciry to cause of che Colocado Depa�tmenr of Public Health and Envi- harm at low levels. Dr Chris Kassocis stares, "although ronment mnducted air sampling adjacent ro natural gas toxicological studies often assess adverse outcomes from well complecion accivicies in Grie, Colorado.39 The purpose high-exposure scenarios relevant to occupational exposure, of rhe sampling was ro measure air emissions thac may be endocrinological scudies �an assess ouccomes from low- associated with the well completion activicies. "Ihe audiors level exposure that may be more relevane ro humans living of the reporc mnduded "che concenva�io�s of various near oil and nacural gas operations.'�°° With approximately compounds are compara[ively low and are i�ot likely to 1 ,000 chemicals used in and produced by oil and gas raise significant health issues of mncern. However, it operations 01 there is a crirical need for methods to assess should be noted che currene sta[c of the sciencc is unable the EDC ac�iviry of �hese mmplex mixcures. 38 Rruwn n al (?01 �9). up.cit. 39 (�iloradn Depar�menr oFPublic Heal[h anA Envimnment fCDPHFJ Q072�. Ai� flmissions Case Smdy Hclatcd m Oil and Gas Devdopmen[ in 2�ie, Q�IoraAu; CPUHF. Air Pollwimi Conval Division. lechnical Service� Program. Decemhe� 5, 2012 � , �. : r . erd�,. ��,rr.i i . �ir. F ,l , r,i�,,,i:,,, �. ,�.Lc5n� i , , . - i . _ IY �-ui�. � i _. . .,. �pL ' �•,�( 40 Kassotic, C D. ct.al. (2016). op.cic. 41 US h:PA Q0157. Assessmem nf die Pomntiul Impecrs oFHyd�aulic Fracm�ing for Oil and Gas on D�inking Watee Resources (Extemal Review Deaft). EPA/fi00/R-IS/047.Washingron, DC: U5EPA. Avail�ble � •,, i;,l/ n ., . . i , �rn�,nL / l � � � , . ;./- '.o��,il 14 I WHEN THE WIND BLOWS CHAPTER THREE DESCRIPTION OF STUDY METHODS mplementing this innovacive methods developmen� The research team designed and implemen[ed [he study research projea—�o assess che pocencial exposure co d�e in xccordxnce wi[h Communiry Based Research Principles hazards of oil and gas producrion—required a variery (CBRY)"'' and in collaboration with che smdy participanrs of moniroring rools and methods. chroughout the process. Our research ceam knew from previous smdies char air In order ro determine which chemicals emitted from gas monitoring cools had been successfully used co decermine developmenc and produccion sices mighc be reaching local �hat exposure m �oxic chemicals in aic emissions from well residents' bodies, we began by sampling air emissions at pads was possible.'' We knew rhar exposure co chese emis- �he well pads. We used a variery of moniroring tools (see sions was likely for individuals living close m well pads."' Figure 5), while simulcaneously assessing weather condi- However, o[her chan smdies oEworkplace-relared chem- [ions, wind direc�ion and wind speed �o help determine ical exposures, very licde resea�ch had been conducted to whether these emissions might arrive in die viciniry of measure �he degree ro which people Living near oil and Pavillion area communiry tnembers who live near the gas well pads are being exposed. well pads. We then used [he air monicoring cools �o ces� for chemicals in �he areas downwind from the well pads, In chis smdy, we looked for the breakdown produc�s of during che cime we collecred air samples. Duri�g rhe air chemicals found in sampled air, by analyzing blood and cescing amund che well pads, we also cesced che air being urine specimens from local residents. Due ro limired financial inhaled by communiry members who �vere worki��g and resources, we could collect and analyze only a small uumber living downwind. Our final step was to collect blood and of air and biomonitoring samples (see Box 3; The Sampling P�ocess in Numbers) ; we did noc have enough gear ro utilize our complece array of moniroring rools at evcry " p E O P L E L I V I N G A N D W O R K I N G pad and wich every study pa�cicipant. However, even wich �hese limi�a�ions and �he small sample size, we were able I �l OI � �lild b3S fiZ�dS c{e5�Cve CO �nOw wh2t �o use a variecy of coofs [o indiai�e how VOC exposure �}7emIC1�s �I"oltl C�eVe�o�Jmen [ 3Ctfvtiies di'e parhways could be craced From �he poinc of emission, ro rhe air inhaled by a s�udy puticipan�, and �hen to chemical 1 [7 Cllell 6OC{ IeS. T}1e CeSC tneC}lOe�5 we uSec� lrt breakdown produca (metabolites) measured in urine when �hts F1fO) eCt COuld b� fUYC}1�C IeElfleC� CO Il2�p US diese chemicals were excreted. This sn�dy is �he fi�st time, as far as we are aware, [ha[ such an exposure pa[hway pro- «<�defSC117C{ Wh�1C CheIlllCa�S CheV �17e eXpO5el� cess has been developed in connectio� wir}i �as proc�uction. �p a�d EIOw, SO We C31] be[Cel" pCOteCC peO}Jl2 Aside from our research ream, eleven volun [eers, all of rrUm }l'dl'nl .�� — W/1t�12 ,S![�t'rY chem living in �he Pavillion area, parcicipated in chis smdy. �12 Macey eeal. 1�013L op_cie and Cmning Cle:�n anJ Global Communi�y Monlmr (3014)- op.eit. 43 Gilnwn ci al (201 3). op.ut. $ynwnskl. H L, Scock 1' H, 'I�ec P G. Chan (_'009): Dcmugraphin ResiJcntial, and Reh:rviural Deierminanu of I'levated I'xposures �o Henxene, �loluene. F�hylbenzene, und Xvlencs among the US Populabom Resulrs fmm I `)99-200U NHANFS. W J lbxicul Hnviron Health A. 2009; 72( 141:91 �24. doc I0. l0R0/ 152A73909�29i9�06 , �� .i. .. . �. / ".�� -n. '� � ' 44 Cu�nmunlry HastJ Reeearch Principlts procide a (rvmrwnrk fur nw�u�alh� benefici�al rehuionehl��v henveun rescacchers and rommunin' memhe�s. Sccforcxamplc ': � . . ,• . . , . , . . . . . . ( , . I , i . � � . . I �: . . . _ I . ii '_ �. " il I i :r I 7$ urine samples in people living and working in proximity to the well pads, at a time when airborne chemicals, inhaled by those people, might conceivably be "broken down" within the body and excreted. Once VOCs enter the body, they are either exhaled or quickly broken down and eliminated through the urine, usually within a few hours. Therefore we collected urine and blood from participants about four hours after we collected air samples at gas production activity sites and air samples from the immediate environment of the participant. In the Pavillion area, individuals and families are likely to live near more than one well pad, many less than a quarter of a mile away and some as close as a few yards. Seven biomonitored individuals live or work in an area with three natural gas production pads. Four biomonitored individuals live or work in an area with two natural gas production pads. While we monitored the air near gas "IT TAKES A LOT OF COURAGE for people to have their bodies tested for toxic chemicals. Thanks to these Pavillion study volunteers and our science collaborators, we have a new research method and test results that can help get their community, and other impacted communities the attention they need." Wilma Subra production related activities, we fitted study participants with personal air monitors attached to their clothing or accessories, to identify and measure levels of VOCS in the air in their immediate environment. 16 WHEN THE WIND BLOWS CHAPTER THREE MONITORING TOOLS , SAMPLING METHODOLOGY AND KEY FINDINGS AIR AND BIOMONITORING TOOLS chemicalsofconcemandno[ allchemicalscouldberes�ed tor at the same levels of detection. 1he selec�ed air moni- o measure harmful air emissions from gas develop- roring tools also ucilized differen� me�hods for capturing ment in the Pavillion area, we selecred an assore- aic Grab samples (30 seconds) were able co decea spikes ment of s[andard, scien[ifically-proven air monicor- (higher levels) of some chemicals whereas 24-hour and ing rools, each with a varying capaciry to rest for 8-hour air samples averaged out exposures so ehat inceo- the p�esence and levels of chemicals of concern; mitcent spikes were not capcured. Researchers collecced VOCs.45 There was some overlap in che lisc of chemicals air samples over a seven-day period in August 2014. each tool could �est for, but not all mols could test for all See Appendix 1 for pro�ocols and me�hods. , . . . . . . � Minirae 3000: an air monitor ��-:_'��-�� ' �R' . � ing device that measures the ��`= - �� \` total amount of VOCs present � ^ F�� I , in air while we were using the - ~� j "'� � � FLIR Gas FindlR camera � I � ., ��" around gas production related ' activities. A PID, or photoion- - � �' ization device, uses Wtraviolet '� "- 7 FLIR Gas FindlR infrared camera: rays to detect a broad range of � - an infrared camera or thermal . VOCs, such as benzene, meth- imager that is used to record gas ane, formaldehyde and other pmbient Weather Model WM-5, leaks and create video images of hydrocarbons which rypically V4: a hand-held weather station VOC emissions from equipment � occur in oil and gas drilling [o measure barometric pressure, and infrastructure used in petro- and refining �� ...,wane�o��a��.v�om tempereture, wind current chemical operations. direction and other information ��www IaOamtaryedwomen[mm important for determining • '�� how and where VOCs might Sorbent 7ube: an air monitoring device that can be ' travel in air currentr. wom by individuals. It measures levels of VOCs in , amn�e�� weamz, air directly surrounding an individual during the .� specific period of time. Participants in the study �� wore sorbent tubes for periods of one hour. � � � � -.. i; r� -r � ��i u = o o n; P a c e i a 45 US EPA (201 il. Volatile O�ganic Compounds (VOCs) in A�nbirnc Air using5umma Canister Sampling anJ Gas Chromacography (GC) Analvsn � � .. ,� .. . � r��; t�,:�r„m � . � i Oni.� , , ,. . � +.i/. Uti I?PA ( 1999). Demnninatiun of Volatik Organic Compounds in Amblene Ai� udng Acuve. Sampling mim Snrben� l'ubes. SecunJ I1di�ion� Compendiwn Mt�hoJ 'f0-17 , ,h . . .. , . � �r�.. , � 'r.�_ . .. i, i� US EPA (2009). Technlcal Assisranm Dncwntnt Ibr �he Na�ionnl Airloxict f�ends Siaiions Pmg�a�n Recisinn ?. April 2009 � �. r�.� ; . . + , . . . .. US EPA (1999u). Compendlum of btethods lor �he Dereunina�ion o('Ioxlc Organlc Cn�npnunds In Amblenc AI�, Semnd Edinon, Compendium Merhod TO- 15 Demrminatiov oF Volaeile O�ganlc Compounds (VOCs) in Aie Collected in Specivlly-prepared Caniseers and M�Ilzed bv Gas Chmmamgmphv/Mass Spec[mmetry (GCIMS) /":! � . � -omrt>.hunL Watsnn N M, and Cooper D. Tubc Sampling Vcrsus Oanlster Sampling—the Fros And Cons of Eath Appmuch Paper . #—POSTF.R, Markcs Inccrnvtional Ltd., Gwaun Elai. � I :_ IU :�I„ i �_ � . ' u � I :ISIG , i - 1 ,_ �fIDIF9P � I .��.;i" 11 ! ;dIIlES � 17 � . . . _ . . . . . i' �� J Aldehyde Badge: � HDS (helium diffusion an air monitor that (y sampling) passive measures chemicals � � � . II' I '. I � air monitor: an air "' other [han VOCs that � ! � „� � !� � i � . . monitor worn by study '`�� were sampled with - - participants which Ithe summa canister or averages out the levels sorbent tube. These of chemicals in air over � '' badges monitored air a specified period <in - for aldehydes over this case 8-how time an 8-hour period. periods). � wwwe��ernmsc��m + CM1emEvpress - ��;' � � � , Summa Canister. a stainless steel electro-polished passivated i vessel used to collect a whole air sample. The sample may then � be analyzed according to the EPA guidelines for the presence of VOCs. The canisters can be used to collect air samples for various lengths of time. In this study we used summa canisters to collect both 15 seconds "grab samples" and 24-hour ambient air samples. - wwwe„�ern��,smom The summa caniscers and sorbenc mbes, aldehyde badges Urine collection macerials were purchased as recommend- and HDS monitors were kepc in their shipping concainers ed by xhe sutdy's analytical laboratorizs and kept i� their in a designared s�aging area accessible only ro science ream shipping concainers in che holding area until use. The membe�s. Fll'�er summa grab samples were collected, and science �eam had also mnsulred wirh key scien[ific advisors che aldehyde badges, sorbent tubes and HDS monitors about rype of blood vacucainers, type oFscoppers and were utilized, chev were shipped overnigh� co �he appropri- necessary storage and shipping details to ensure the urine a�e laboratory. The science ream (Wilma Subra and Deb and blood samples would remain viable. Thomas) �rained cwo assisranrs in sample collettion, and supervised all air monicoring and sample shipping. "Ihey 1he science ream kept rewrds to� che tiine and locatio❑ also ensured �hac records were kepe aboue the time of sam- of ehe blood and urine samples collecred, along with ple collec�ion, che bcacion of sampfing, ,�nd [he rype and code numbers of �he vacutainers and the participancs. code number of �ool u�ilized, along wich code nwnbers All samples were double-wrapped in zip lock bags, placed and rhe bcacion of parcicipants who wore �he sorbent in ice chescs immediarely after collection, transferred to mbes and/or who were near or in a�eas where summa grab a hreezer and frozen for 24 hours before being placed i❑ samples were collec�ed. 7he science held �ea�n reviewed ice chesrs packed wi�h ice and shipped ro the appropriace records at the end of each day of moni�oring and trans- laboratory overnight. ferred ro a single compu�er accessible co only one of the ceam members aker review ro ensure entries were accurate. A �otal of l2 na�ural gas well pads in �he Pavillion area were monitored in are�s where bio-monirored individuals lived and/or worked. The pads contained one or more of che following cvpes of eyuipmenr. i 78 � WHEN THE WIND BLOWS • AIR AND BIOMONITORING METHODOLOGY : . . . . . We asked s[udy participants to avoid using products or 7 days of sampling, August 2014 engaging in ac[ivi[ies tha[ wou�c� orc�inari�y expose them ro VOCs, induding BTEX chemicals, in an atremp[ to 12 well pads isolare VOC emissions �hat migh[ only be coming from • FLIR camera documented real time emissions from bas sources. For example, we askccl each E?articipant to apparatus from the 12 well pads, induding separators, . avoid hlling car or �mck gas tanks, exposure to agareae produced water tanks and metering stations. smoke, bu�ning rrash, driving farm equipmen�, o� using • 4 PID (photo ionization device) readings at each of f�es[icides and o[her housef�olc� E�roduc[s con[aininK V(�Cs the 12 well pads, plus measurement of VOCs emitted for the dura[ion of the stuc�y. It is dif�icu�C [o avoid exf�o- from soil surrounding Ieaking well pad apparatus, . sures to VOCs because [hese chemicals are ubiqmrous, when leaks were identified by real-time FLIR camera but we wanred co eliminate as many ordinary daily ac�ivity images. exposures as possible, ro more direcdy atcribure any VOCs • At 4 of the well pads, selected for proximity to found in ambient air samples (those sam�les [aken from irrigation fields, we used summa canisters to capture . . . personal air momcormg equipment) or human biospeamens air samples to be analyzed for levels of individual . . . VOCs. to gas production ac�rnnes. • 6 aldehyde badges were placed overnight on Based on agreements wi�h �he smdy parcicipan[s, no se�ected wen pad apparatus. informa�ion in �his repo�t will link individual resulcs m individual participan�s or in any way identify individuals 11 individuals f�om Pavilllon community . . who parnapared in che smdy, or rhe location of cheir • 40 individual ambient air samples—both HDS ��nes anc� P�aces of work. 1he smdV team and commu- (helium diffusion samplers) and sorbent tube ❑�ry members agreed that the particiPa�us' Eirivacy and monitors, worn by participants. desired anonymity is excremely important. The identified • 27 urine samples and D blood samples from all individual study results are [he persona� property of each participants during the seven day period. �articipant and each participant is free ro decide how he or she may want �o discuss their own individual results wich ochers. The Pavillion participaats reviewed and approved che resulcs from �he study released in �his reporr. 1 . One or more wells; 2. Individual separaeor units `' serving each well; Only a limiced number of analytical labora�ories in the 3. One or more produced water canks"� (wirh and Unired Stares huve the capabiliry to �esc for VOCs at non- wit6ouc carbon 6lter drums) ; occupacional levels (tha� is, outside workplace environment). 4. One or more merering stacions with associaced The Tobacco Concrol and Research analycical laboratory methanol �anks. based ac the Cen�er For University of California, San Francisco based, headed by Dr Neil Benowitz, MD, cesced Ir's not always eary �o iden�ify the funetio� or hazards urine samples for �he presence of ineeaboli�es (breakdown diat mighe be associaced with well pad equipment. products) fo� some of �he VOCs that the study team had Because there is no excemal indicaror, some well pad identified as being of co�cern. llr Benowitz work has equipmen� such as separator units and wa�er �anks— centered on chemicals associared wieh cigareae smoking might Iook harmless but could he vencing highly toxic snd some of �hese chemicals (benzene, acrylonitrile) have chemical emissions a� any �ime. also been found around gas production sites. Dr Chung- Ho Lin at the Universiry of Missouri developed a new analytical me[hod co �esc che Pavillion participants' urine Sb Scpara[or L'�nir. a �rparamr Is a vesstl meJ �o ccp��a�c gaz �and liquid cumponrnu linm �he HuIAs cxcra¢cd fmm an oil o[ gas well. 4� Pmduced wamr is �catzr bruugh� �o �he suct3cc dunnQ ull �and gas exploniinn .�nd produaion. �This pmduced water esm m�rain salts, chemicals and �mtueally nccuc�ing c�dioactive maaciuls. Chemiidls are ¢.+nslen�ed �o ihc wamr t6ruugh lung-icrin cnnma wlch �hc uiI or K� or ure ehrmie�l addleives used durin� drilling ond opemtion o( the wrll. . . � , � - �.. �, � . _ . . _ �su �.•, � , . . . I C . 19 samples for a wider range oFVOCs and their metabolices Deseription of sample eolleetion protoeol and developed a new analytical method cha� could tesc samples for very low levels of chemicals oE concem (see lhe science team began the project b}' meecing with Appendix I for a description oF Dr Chung Ho Lin's community meinbers to explain the smdy and rhe benehes analytical method) . Although �here was some overlap, or disadvantages of participation. 7he eeam discussed these nvo laboramries did no[ test urine samplcs for the study prorocols and principles of communiry based same list of inetaboli�es. As stated previously, this study is participamry research,°8 emphasizing �ha� che communiry a mcrhods development study and as such, utilized several would maintain the auchority co release or not release analycical resting mechods for boch air and human bio- information about the srudy o� its resulrs to the general specimens in order �o assess die suitabiliry of various public. 'Ihe science ceam also made clear �hac individual methods for use in further research. participan �s would receive their own individual resulcs along with aggregaced results from the s�udy and would Blood samples were analyzed by NMS Laboratories. be able to meec wi�h �he s�udy's �rincipal inves�igacor co NMS Laboracories were unable to detecc levels of VOCs discuss their results. in our blood samples. Our assump�ion is �hac NMS proco- cols are unable co de�ea die low levels chat mighc have Many of �he residents in Pavillion have worked wirh oil been presen� in blood samples (see Appendix ] ). Alrer companies currendy engaged in gas production, or have ❑a�ively, VOCs may �o� have been presen� in �he blood kiends or relatives thar are employed by gas mmpanies. samples we collected, possibly because these chemicals 1he convening grassroots group, Pavillion Area Concerned break down quickly and are excreced in urine or no Ci�izens, is small and many of ics members have been recen� exposure had occurred. severely impacted by gas production activities, according co dieir accouncs. 'Ihe eleven individuals who volunteered Our methods development study design, as described �o par�icipare in this pibt study are deeply mocivated above, soughc ro develop a mechod which could link emis- by these experiences. sions of VOCs from gas aaivity sires to human exposure downwind by: measuring air emissions from the poine source 1 . lo establish background levels oE VOCs in the of emissions; assessing wind speed and direccion at the Pavillion area, we collected 24-hour air samples (which emissio�s source; measuring VOCs in rhe ambient air sur- averages out exposures) , using a summa canister, rounding individuals who were workin� downwind from which we Placed in [he ce�ter of the cesting area. emission sources at the time of air sampling; and finallv, 2. We mapped che areas where we wanred ro do air measuring VOCs in the urine of these individuals—who and human monirori�g, based on previous research may hatve been exposed co VOCs emic�ed from the nearby conducced by Shale lest and consulcations with com- well pad, which might be associated wich rhe VOCs iden- muniry members. We identified well pads where we �ified in che air samples chac were collected at emission would use air monicoring tools, which were locared sources and in the personal air monitoring devices. in areas where s�udy pa�ticipants were also working and living. Given che density ofwell pads in Pavillion, Our model, which utilized a series of tools, each capable we were able co identify areas where moniroring was of tes�ing for diffecing lists of VOCs and incorporacing most likely �o produce useful informarion. different methods for sample capture and analysis, provides 3. We developed a draft schedule for sampling, which an overview of possible mouiroring methods. Our pilot began wich air sampling around differenr pieces of smdy was in�ended to explore the methods and challenges eyuipment on our designa[ed well pads. At some well of evalua�ing exposures ro chemicals from gas produc[ion, pads we monimred air by using �he FLIR cainera to with a view to refining the methods used in fiitu�e projeas. detect emissions and the Minirae �o measure total The results of this inves�iga[ion mus� be viewed as a volume of VOCs. We used a porcable wea[her station s�iapshot ot air emissions from gas produccion si�es and ro indicace �he general speed and direction of the n dear waming sign of problems, noc as resulcs which wind. Ac other well pads we also urilized summa grab can be generalized. samples, which were used for 15 m 30 seconds, these 9N Communin' L1ast� Ita.aarch Principlcr, np.ci�. 20 WHEN THE WIND BLOWS Typical gas well pad in Pavillion with a well (center) and produced water tank (lefq. � �� --"-�� t 1� � ., ' �/� ''�} ' - ' - - . _a . .. , . � � r .._� . ,. ,��_ ._ _ . -� . � , — "__-�.,,. ' _� ' . ,�� .� � � _� ( . 1 . ;.�l.- " Ms . A � -� � . " - ' + _ + � i � • � � 1 � � :Y:uxi91161K �.j f �o:a: mu�iw : +4y �� . . 1!X Vf Y l}A I I : rilWltivllll � .'. tYR �MOYfIN j" L!H.�1.19JIM �' � � � • . . - - y � � / �i�� ✓ ' . . . s +�f. • � � �. - n � _ __ v . .. . . " . . .. 3 ' . . • � ' '. l�l . . � . . . " . � . . . . , i N N . . . • . � . - . � ' . ' 1. �. . . � . . . . �l � � L • A ' _ . • ' 'l f "i.. • . .- � . . . F . . D . ' ' " . . -' � _ . . -. 3 _ . . , " - ' . " ' . ' 3 . ' ' � . . . . - o �'9!'�^ ��fr.. :`.'. �` a-.�.�„� � �" '. . . � Z-7G` �"�"_�� e: � - �"S�Q - ' _. .� � - "�-` - '�ti. r � � -� " � � � Sampling for chemical emissions at a '� + " _ - ` A " � . . ; produced water tank carbon filter drum r ^ � ��7' - � ` -' t,i�f-�ir� - in Pavillion. Credit: Wilma Subra . �___'• - . �. �. , � ! � � � � ��.. . ��;rA��: 1�j� � � � �-11�' � 4. One or rwo hours after we collected air samples from � � - - � " ��'� ^ the well pads, we collec�ed pe�sonal air samples trom - �—�......>�.- ��+1Y�� scudy par�icipants who wore eicher sorbent cubes or � .� - - - �- HDS samplers pinned to their dothing. Pa�ticipants ' - 3:�+f , would rypically have been wearing �hese samplers for w.v.... " � : rY „ � .�.-, - .y `"""'�-- a.� an hour before collection. We were not always able € ><<Y ' _�-�• >, . -w , �. . . a y.., _ „ � , ,.,_ � � t�o maintain a dose schedule, mosdy because of the .,.. ._ . , ;. . - j9v � "� �. � � � z . _; , � - �� `' . y ; . . ❑p��f�IC[361�ICy Of f1RCf11[lV� ffCCIVI[lfS IlfffC WCl� �13d5� _ �, � � - +,��;�;.`_� such as [he irriga[ion of fields as well as rhe lengrh _ ��`Y ' a; � � LU .�".'_�• y '';'Y:- � of time chis cakes. _ , ,. ,- 5. We also collec�ed a small number of air samples, using were anal,vzed for rhe presence and levels of VOCs, personal air monicors, a[ nighG boch indoor and using an analysis called EPA-TO- 15 , which tes�s for oucdoor, to give us information thac might indicare over 200 VOCs. Ihe well pads ranged from a tew difterences bec.veen night-cime and daytime exposures. yards to approximately 50 yards away from homes 6. Approximacelv four hours after air samples were wl- and fields where nnchers would be irrigacing and lec�ed ac che well pads and from personal air monicors, engaging in other ranching activities. Our portable we collecred blood samples from participancs at our weather starions would indicace when ranching activi- mobile biomoniroring van. We also collecced spot ties might occur downwind from emission sources, urine samples froin parcicipancs at this time. (wind readi�gs were only �aken at well pads) but 7. First mornin� void urine samples were also collecred we knew cha� wind currents can easily vary and we from each participanc All human samples were imme- could noc be cercain that a rancher or a family would diarely placed in ice filled chests and transported �o a be downwind from emissions when we collecced freezer, and lacer inailed overnighc co the appropriare pe�sonal air samples. laborarory in an ice-hlled chesc. i r � zt F I G U R E 2 Illustretion of Pavillion Area Air and Biomonitoring Study Method - : . - l �. : ifx i: : •-� ; � I . • � • • • • • • • ' � • �t ;,::, ' ;;�•^' , .,_ . ; .�,� ' . `�`.' , � - -,° ' ' _ _ _ .. _ . .. _ — . . , �.�, i : t,-.,` . � - � . ., :- , . ' 'a� ,_ . y .�., , ..r, � . . � �.. . �}` 6. ` ,8 , j` • � - . . , _.: . .� . . •_ � � . ' �. � . �y ��(�t � �"t ) � '. � . . � �. • ' d` , � . t � . . '. � i l . � e: 1. • • `v�y.�'a� l y ` 1. I • ..' �'y �f�� ,1 �' • § �.1 � . � {�{{]] �� 1' . '` �� I � � � . . � � � � � ' � � � � � 0 I ti ' �. �� li+� ��i � � . A . . � �..• .a1�� . �� b . � S 'I A , � i �y,.4< �° � , r • g.�.l�� J '.7 �" .'.'a,.>_ r.�, . �',,��j�y�! � i • • I ' � �+ ' v' J'�r ' N <� Y� i ! 1' � '^ `�. : �.. 4 , J �Jtk i � �� '. � , , .';'�� '��f�r�� '. , , , �.r � �j "`',�� " , s a'��'4._ l'�:iw �. �f ♦ Y''',`� ' � ' I �. � �- y 1y+t . 1J ��L�,0..i.' l(�iTJ, -. Se` �L •�:a� 2 �� [ ' � . � r tµ ��i�i , V YI �I E 7� m ' T S 1i '1�. y��. y�! �'� n�[I��f[�� 1�' � 1 � S � Y • +� C � • y,' �( � 1 V v: � � � I y. ��i. ! �a < �`�l.'� 'b� �i 'LL I�� r�[I� ' � ti/�iayr�� ` ^ SA I,�•'� .epG� !. y��l.�.lS' 7 � � �)J:��l V �` �tl. ��. . Y� �. � . . `� ,�� 1 ��I �n� "D �"�` Ii ,�y , � Y . � l . �(�\ . i.�.'i � � ��s� J J•v . •\✓2 �� .�/4� ll • � � � � � 8: 14 AM 1 1 : 56 AM 12 : 20 PM 1 2 :39 PM 2 : 22 PM 2:34 PM 11 :00 PM Moniforing Monitoring Monitoring Monitoring Monitoring Monitoring Biomonitoring participant chemical separator separators produced participant parti<ipanf working in emissions ond produced and produced wufer tank working in previously fields near ot well pad water tonk woter tank fields near working in well pad at well pad ot well pod well pad fields near well pad 8. Financiul resources cons[rained [he numbn� ol per- 10. ('ommuniry members mec sepnra[elv [o discuss thr sonal air monicoring sorbenc �ubes, (�vhich rcquired possibili �v of releasing a public report about thc smdy. batreries) and rhe number oFavailablc summ:i �;rnh caniscers. All samples were handled a�rriah� acaxding Above i�� a sample chart illusvarin� our scudy design . . to protocol. lable 1 is an examPle of a daily monitoring schedide 9. Ten monchs afrer che sample collection ficld wurk was trom our Pavillion researdi projcct provides restdts of air completed and samples had been sent co laboratories analysis From using a FLIR cunera and a Minirae PID for attalysis, �he science tcam mee again wit6 commw at n well pad, summa canis�er For ambient air, sorbent nity paaicipana ro deliver ag�regated and personal mbes wurn by smdv par�icipan�s and the resultti of resulcs ac a closed meeting. Study participants wete anah��is uf urine speumens collecced from an individual encouraged co make an uppoincmenc ro discuss resula whu wus working in fields locaced near the well pad. � wich rhe s�udv Principal Investigator. 22 I WHEN THE WIND BLOWS TABLE 1 Timeline for Gas Air and Biomonitoring Methods Development—One Example, August 6, 2014 . . . . . . �� 8:74 AM I Fields near well pad. Sorbent tube worn by �' Sorbent tube found the fol- Toluene: 0.096 ppb ' �� study participant working lowing chemicals in ambient benzene 0.038 ppb I in fields. air collected in the early ', I moming. 8:14 AM— II Location central to well � Summa canister. I Average over 24 hours. � Toluene 0.090 ppb 24-hour 'I pads in order to mea- � , benzene <0.09 ppb . sample ��, sure background levels � i . �i of VOCs. '� — � -- -- -�—� . 11:56 AM Separator and produced FLIR camera and Separator leaking along top VOCs 17A [O 39 ppm ' water tank'v at well pad. Minirae PID. . of doors—VOCs from top of doors. Produced watertank— VOCs leaking at 3 locations. Thief Hatch (closed). VOCs 713 ppm Vent. VOCs 102.4 ppm Carbon Filter Orum. I, VOCs 107.4 ppm 1220 PM Separator and produced , FLIR camera readings, , Volatiles leaking out of VOCs 37.1 ppm i water tank at well pad. �' Minirae PID. ground adjacent to separa- �, � tor; Odors being released � Ifrom 9round nearseparator. I Volatiles being released out VOCs 482J ppm � of vent on produced water � . tank No emissions leaking � � out of hatch. �� - -� � 72:39 PM � Top of ihe separator FLIR camera readings, ; Separator 1. VOCs 9.5 ppm doors, well pad. Minirae PID . Separator 2. VOCs 33J ppm � Emissions visualized from two separators leaking VOC emissions from VOCs 58.8 ppm � � . from top of doors. production water tank leaking from vent. i 2:22 PM Produced water tank FLIR camera readings, Production water storage VOCs 72 ppm �, with carbon filter drum, Minirae PID. tank vent on top leaking . I� one third full, well pad Wind speed measured by VOCs on the ground. VOCs 02 ppm Strong Winds. portable weather station. Carbon Filter Drum. VOCs 4.0 ppm 2:34 PM � Fields near well pad, Sorbent tube worn by Chemicals found in ambient � toluene 0.46 ppb � same sWdy participant air collected mid-afternoon. �. benzene 0.091 ppb working in fields. '� I11:00 PM Participant previously Urine sample from same Metabolites oP chemicals I Toluene metabolite I �i workin9 in fields near study participant. were measured. hippuric acid 605 n9/ml' I well pad. � Benzene metabolite ttma � 543 ng/ml. ', ppb = parts per billion; ppm = parts per million ' ng/ml = nanograms per millilitre <the standard reporting method used by the CDC for biosamples) K E Y A I R M O N I T O R I N G F 1 N D I N G S detected in summa canis[ers, which can iden[ify specific From rhe samples taken with our variery of air monicoring VOCs and cheir concencrazions; and sorbent mbe samples [ools, laborarories identified a toral of 65 VOCs, induding whic6 indicare chemicals presenr in rhe immedia[e prox- BTF.X chemicals. Our findings reHect and complemen� imiry of the individual participan �s, which they were likely other air moni[oring srudies previously conduc�ed ac oil co 6ave inhaled. UnFormnacely che�e is �o way that� scien- and gas sires near Pavillion, and elsewhere in Wyoming ciscs can prove �hac chemicals dececced at an emission source and in rhe U.S. OEspecial inrerest are the chemicals are �hesame chemicals detected in che air immediarely � irp�_�IUfdl, � - i :- �. ] V: F'-�CAL� IM � _ := 1EL� ti -1M1JGINIF�.. I_ I �D =V�'�h1l1NITIE`� � 23 surrounding people." In addition, differences in rhe mon- T A B � E z iroring devices and laboratory techniques mean [ we were Levels of 10 VOCs of Concern Due to Hazard in Summa nor able �o make applerco-apples comparisons between Canisters (15 minute greb samples), Aggregated Data the sample resul�s. However �he intorma[ion is srill helpful VOC levels detected in summa caniste�s (in ppb) in esrablishing a me�hods for showing which chemicals . � _ were detected and where they were found, on che progres- ' ' ' ' " sion from emission source ro people's bodies, acetone BDL B�L BDL 2-butanone BDL BDL BDL Levels of VOCs in Air and Environmental hexane 0.67 3303 11000 Screening Levels (ESLs) � ' ethylacetate BDL BDL BDL Enviro�mencal Screening Levels (ESLs) are based on levels benzene • • : • of toxic substances [hac public heal[h a�encies ai�d envi- cyclohexane 0.66 3643 72000 ronmencal regularors have derermined as warning signs to�uene 0.3 �n9 2ao0 for risk to human health. "Ihe air monitorin� resul[s from �� ethylbenzene BDL 5300 1300 Pavillio�� have been analysed by Mark Chernaik wich refeo- I xylenes 0.4 : • • ence to these ESLs (see Appendix 2) . Fiatly ESLs apply � � to a specific dura[ion of [ime (from shor[ [o lon�-rerm naphthaiene BDL 147.5 270 exposure) therefore applying CSLs for long term exposure Key for Tables 2 & 3 to the VOC levels detected in air samples collected from ■ RED = VOC �evels that exceed a short-term ESL. Pavillion rec�uiret an assumpkon thrtt the ctn� sarnplzs rtre I vELLOw = vOC levels that exceed a long-term ESL. rePrerenhtCiue ofan+fiierrtaircoric(ttaons tliatgenera��y prevail � ORANGE = VOC levels thatexceed a level exposure which is estimated to increase a person's risk of cancer at the locatzon oa�er long periods oftime. Secondly, ESLs by more than t in i minlon. only exist for a limited number of VOCs; an ESL has BDL = below detection limit not been developed by public health agencies and envi- ppb = parts per bi�ron ronmencal regularors for 3G of che 46 VOCs chat were T A B L E 3 derecred in air samples collecred in sorbent mbes, nor Levels of 10 VOCs of Concern Due to Hazard have standards been developed tor mixmres of VOCs in Sorbent 7ubes Worn by Participants [o accoun[ for cumu�ative or syner�is[ic eft�ects. (1 hour sample), Aggregated Data VOC levels detected in sorbent tubes (in ppb) The following cables show che 6ndings for che 10 VOCs which l�ave ESLs and highlights where �he levels exceed � , any ESL51 (full references are in Table 5 , Appendix 2). The acetone BDL . 12.32 52.6 results show chac even the lowesc levels of benzene and che average levels of xylene de[ecred in che cumma canisrers �-butanone o.02 � 0.49 _ 2.45 �I exceeded the short-term ESL ('I'able 2) . �Ihe highest level hexane 0.02 � 1.19 6.14 , of benzene found i� [he sorben[ [ubes wom by partici- ethylacetate BDL I 0.97 �' 621 pants (Table 3) also exceeded che long-�erm ESL, while benzene Bo� 0.41 1.72 �he average levels of benzene and naph�halene exceeded eydohexane 0.02 � 0.84 6.27 che ESL for an increased risk of cancer. t � toluene BDL �� 1.44 3.73 ethylbenzene BDL 0.18 � 0.54 xylenes BDL I 0.84 2J5 — � naphthalene 0.01 � 0.08 0.36 �i9 A runk for warer used in ehe oil and gas producriun. 50 lhis can be Aone wi�h other techniques such y� la6rlled compoundx, hw �c.0 noi pncsible to� ehls smdv as thls methoJ was nut available. jl 'Ihese k'.Sls indude: I I ��'iinimal Risk Izvels (MRIs) developed by �hc CS. :lprn�v ForToxic Subscanecs and Disease Registry (ATSDRJ; 2) National Ambient Air Qualiiy ti�undardc INAAQti) �and Re�e�ence Concemradons pZ(G) devdoped by �hc U.S. �.nvlmnmeneil Pmmaion Agenq NSGPA); 3) Acuce and Chmnic Reference Exposure I cvcls (lik�ls) �nd Cancer Pomnry Pauors ICPFs) devclopcd by nc� Cvlifomia Oftice of Cnvimnme�ual Heal�h Hazard Asse�menc (OEHHA); and 4) Amblent AIr QuaGn� Guldcline Valucs do�cloped 6v the Wudd I lealth Organi[a�ion (WHO) 24 I WHEN THE WIND BLOWS KEY BIOMONITORING FINDINGS betweenairmonirorsandthebiospecimens. Manyofthe chemicals Found in air cannot yec be cested For in human A rotal of 1 G chemicals or their breakdown products biospecimens (al�hough researche�s are developing analycical (mecabolites) were found in the urine of smdy partici- rools d�at may solve this problem in che fumre) . Ic is also pants. Chemicals found in urine were: possible chac some of rhe chemicals found in the air may • benzene have dispersed beFore �hey could be caken in�o the bodies • mluene of partici�an[s. We know that air currents are constandy • 2-heptanone shiking and pareicipan[s were moving around; local resi- • 4-heptanone dencs and our �eam of researchers observed chis in che • naphthalene Pavillion area. Chemicals can also degrade or rransform � in�o o�her chemicals through photochemical or oche� Metabolites were tound in urine samples for the types oF reactions in the armosphere, wi�h some reac�ing following chemicals: more yuickly than ochers. In some casec, chemicals in • benzene participants' bodies may no[ have metabolized sufficiendy • mluene ro be excreted inro urine. Although researchers predic[ • methylbenzene chac VOCs will be excreced in a macrer of hours, chey also • sryrene know thac individual metabolism rares can vary. Las�ly, • xylenes in somc instances, perhaps che chemicals found in air • NMP (N-me�hyl-2-pyrrolidone) samples were eirher not taken into che bodies of par[ici- • 1 ,3-bu�adiene pan�s, or were noc able to be identified because levels • acrylonitrile, vinyl chloride and echylene oxide we�e �oo low ro be dececced. (same me�abolice) • acryloni�rile (me�aboli�e unique co acrylonitrile) Nevertheless, a comparison between che levels of VOC • propylene oxide ntetabolites in Pavillion area study participan[s and the • cromnaldehyde ge�eral population is very revealing. Mark Chernaik, • acryla�nide and acrolein study Science Advisor, has conducced such an analysis (see Appendix 3, Table 5) which finds that levels of [ra�s, Some metabolires are considered breakdown products for cransmuconic acid (c�MA—a marker of benzene exposure) more chan one chemical. For example che metabolices for are signi6cancly higher in che urine of Pavillion scudy benzene are also metabolites for other chemicals, so their par�icipan�s �han Ievels of �6is same chemical in che urine presence in urine may not indicate exposure to benzene. of �he general US population, as measured by the CDC Metabolites for benzene may also change as levels of expo- NHANES biomoni�oring prog�amme.53 In che case of sure increases, which must be considered when assessing aMA, levels in the urine of Pavillion residents smdied exposure co benzene." is 10 cimes highec than the median level in che u�ine of the general popularion, as measured by CDC/NHANGs 7here are a number of mmplexicies co account for, such programme, and higher even than the median level of as exposure paehways Erom well pads ro people, which c�MA in refinery workers in Brazil (post-shifc) .s^ might accotm� for differences in �he decec�ion of chemicals �? A'f5DR (3007)- loslcologir.J P�olile lo� He�acne /�u�i�a 2007; 'v . ._ . .. . �3 CDC 1?OI S). Fnurth Nabonvl Rcpoa on Human Fspoeure m F.mimnmcntal Chcmicals. Fcbruary ?015; uvr�� x(��.,�,.ndbm�mu rvr , ��,.ij;fb,rihKy�nri_ � nLn� � � '-, i. 'n � , �«r. (;p(; NHANES is �he Cenrc�s f-or Discase Contml and Pecvention National Health and Nutridon Examination $u[vey. �a Maruns, 1, and Siqucim, M E P li U (2004). Trans, 7rans-mumnicAcid in Urine Samples Collected in 'Ihree Pzriuds ftom Renrene Handling Workers in � 6rvzilian Refinery. Revisca Iir�sileir� de Cienciu Farmviceuticvs, 40(2). I`7?-201 . ��.III ! � . � � , � �; . �.J = � - .I � �_� iGIF-. _ . '� `�lf ' � PII �IE � 25 TAeLE 4 Levels of Chemicals in Urine Samples of Pavillion Residents, Wyoming (August 2O14), Ug/g Creatinine, Selected Findings . . . . Hippuric acid Toluene, cinnamaldehyde � 322,959 1,197,549 - � Mandelic acid Ethylbenzene, styrene ' 215 �j 2466 '. 4-Methylhippuric acid Xylene � 92 �' 1395 2-Methylhippuric acid Xylene 81 631 3-Methylhippuric acid Xylene 99 643 Phenylglyoxylic acid I Ethylbenzene, sryrene 53 �I 411 trans, transmuconic acid Benzene 369 _6 PMA (N-Acetyl-S-(phenyl)-L-cysteine) Benzene BDL 1.0 � MHBMA (N-Acetyl-S-(2-hydroxy3-butenyl)-I-cysteine) 1,3-butadiane BDL 0.8 HEMA (N-Acetyl-S-(2-hydroxyethyl)-I-cysteine) AcryloniVile, vinyl chloride 7.3 3.6 CNEMA/CYMA (N-Acetyl-5-(2-cyanoethyp-L-cysteine) '�. Acrylonitrile 13 31.9 3-HPMA (N-Acetyl-5-(3-hydroxypropyl)-I-cysteine) � Acrolein 388 7059 2-HPMA (N-Aceryl-5-(2-hydroxypropyl)-I-tysteine) Propylene oxide 35 162 AAMA <N-Acetyl-5-(2-carbamoylethyl)-I-cysteine) Acrylamide 99 799 HPMMA (N-Acetyl-5-(3-hydroxypropyl-l-methyp-Icysteine) Crotonaldehyde 235 630 ] VELLOW = Level that exceeds median in urine of general population �i] ORANGE = Level that exceeds 95th percentile in urine of general population ug/g = micrograms/gram 7he hig6 hazard of che chemicals emic�ed in�o �he air, thar action needs m be taken ro preven� exposures, together with the hndings diat the levels of certain VOC especially when all the limitations of the snidy listed metabolites in uriiie of the people studied are well above above are also considered. rhe levels in the general population, sends a dear signal 26 I WHEN THE WIND BLOWS CHAPTER FOUR OIL AND GAS CHEMICAL HAZARD ASSESSMENT METHOD hrough chis scudy we have shown cha� harmful percaining to a chemical's hazard induding the number VOCs are presen� in the air, and chae some of �hese of data gaps associated wich chat chemical. In addition �he chemicals are also presenc in �he bodies of people me�hod also considers the hazards of the chemical's break- who live and work in close proximiry ro oil and gas down produas resulting in a highly precautionary approach produaion. Numerous other smdies have detailed m chemical screening. Because GreenScreen provides a �he illnesses and diseases associaced wich exposure to rigorous and mmprehensive overview of a chemical's VOCs and ocher emissions (e.g. ozone and methane) ." hazard in a clear and easy co read fomia�, ic has become Federal VOCs regula�ions are designed ro prevenc expo- che rool of choice for highly informed decision making. sure ro "unsafe" levels of some of �hese chemicals, to pre- ventillnessanddisease. Howeverdieserisk-basedsran- GREENSCREEN ' FOR SAFER CHEMICALS dards may no� fully address the hazards of chese cheinicals, M E T H O D or combina�ions ofchemicals. Researchers are continuing [o develop methods for assessing chemical mix�ures, espe- GreenScreen ca[egorizes chemicals in�o four benchmarks; cially those mixmres chat occur around oil and gas produo- each benchma�k defines progressivel,v safer chemicals, cion accivities and in par�icular mixcures of chemicals tha� from Benchmark-1 'A:�oid—Chemicrzl of High Conrern " co are considered ro have endocrine disrupcion capacities."' Benebmark-4 'Prefe�Safer C6iemical. " A GreenScreen For many chemicals used in boch conventional and assessment is comprehensive and provides all [he I<nown unwnvencional oil and gas aaivicies, communities informa�ion abou� a chemical and its environmenral and researehers have li�de or no da�a.' bmakdown produccs, based on 18 hazard endpoints or categories of huma� health and environmental impact. We used rhe GreenScreenw for Safer Chemicals5e (Creen- In GreenScreen, a chemicaPs hazard characreristics are Screen) mechod co ge� a clear overview of the extent of the defined by its pocential ro cause acure or chronic adverse environmental and heal�h haza�ds associa�ed with oil and effects in humans, environmental fare and roxicixy, and gas chemicals. GreenScreen, launched in 2007, sets rhe ceaain physical/chemical propercies chat relaee to worker global standard for comparacive chemical hazard assess- saFery. Ic does chis by consolidating all che available data ment. Transparen�, scien�fically robus�, and publicly avail- on a chemicafs i�herenc characteristics in[o a table of able, GreenScreen is used by businesses such as HP and hazard endpoints, each ranked as high, moderare, or Nike ro help inEorm chemicals managemenc policies and low. A[ a glance, �he haz��d tables show, for example, to product design and by stare govemme��s sucl� as Maine whac degree a chemical can be considered a carcinogen, and Washington as par[ of altematives assessments to a reproductive coxican[, an endocriiie disruptor, or meec regulacory processes. GreenScreen is used in �he US's persiscenc in che enviromnent. largest green building standard set by the US Green Build- ing Council as well as the apparel industry's global Zero From there, the hazard evaluacions are h�rcher consolidated Discharge of Hazardous Chemicals initiative. The Green- in�o a single benchmark �hac provides an easy mea�s for Screen method requires detailed sau�iny of all inFormation comparing chemicals. GreenScreen is par�icularly valuable » $ce lor exvmple: McKenzie e�. aL (2014). op.ci�.. Bolden ec. aL (2015). op.ci�. �G Kasso�isa. :iL (20147. np.cic. >7 Holdcn m. al. Q0151. op.ci�. jR G�eenS<ree�i fnr $afer Chemicals, op.cit. �'-i � FlPli ii . '. i .. .. I_Sily . . .. � -llilhll ' . .: li. i ' iifllll ._i � 27 because Benchmark-1 dearly defines che cri�eria for • Grhylbenzene chemicals of high concern co hu�nan healch a�d che envi- • Acrolein ronmenc consisrenr wich in[emational regularions such as Europe's Registration, Evaluation, and Authorisation ot Two chemicals in urine were assessed as Benchma�k-U Chemicals (REACH) ." " Uiispecified Due co Lisufficient Data": • 2-hepcanone GreenScreen assessmenrs also idencify data gaps; i[ is • 4-heptanone jusc as importanc ro know when environmen�al or human health da�a do noc exisc for an endpoin�. Luck of daca does �e GreenScreen Hazard Summary Tables in Appendix 4 not imply safety. [deally there would be comprehensive p�ovide results for chemicals detecred in both urine and hazard data and knowledge oFfeasible environmental air sampling. The hazarcl table fo� xylenes represencs t�ansFormacion or breakdown produccs for all chemicals. m,p-xylene as well as xylene. The complere GreenScreen Unforcunarely, this is seldom the case in ei�her che chemi- assessmencs are available for do�l� nload . cal manufac[uring arena, or in regard �o fossil fuel chemi- cals.G° A chemical wich roo many data gaps is dassified as : . Benchmark-U "Unspecified Due co Insufficien� Data:' � • HAZARD ASSESSMENT FINDINGS — Evidencecontinuestomountonhealthandenviron- GREENSGREEN BENCHMARK SCORES mentalimpacisfromtheoilandgasindustryshydrau- lic fracturing (or "fracking") process use and release of GreenScreen hazard assessments of kev chemicals associ- chemicais."' However the toxicity of the chemicals used ared with oil anc� gas proc�uction—inclttding common is generally not well known; oil and gas companies' BTEX chemicals—showec� tha[ mam of these chemicals Confidential Business information (CBp requests shield " the companies from releasing that information. In 2O13, are highly toxic. GreenScreen Benchmark"' scores for Clean Production Action analyzed chemicals used in chemicals found through biomoni�oring are listed as follows: hydraulic fracturing in the U.5.62 An initial screening assessment of 11OO chemicals and full Green5creen 12 chemica�s found in urine were assessec� as �e�chmark- 1 assessments of 43 chemicals injected into fracking "Avoid (;hemical of High Concern'�: wells reveal that: 1) two-thirds of chemicals in wide- • Benzene spread use in hydraulic fracking have Iittle or no infor • �Poluene mation available on how hazardous they might be; 2) • o-xy�ene industry disclosure mechanisms are inadequate, while • m,P-xy�ene widespread use of 'trade secreY mechanisms ihwart • xy�enes which inc�uc�es m-, o-, or P-xy�ene (isomers) Public oversight; 3) the industry is usin9 more chemicals • Nap�ithalene than previously listed on government databases; and • Styrene 4) over 2OO of those chemicals assessed were identified � as substances of hi9h hazard to both human health 1 ,3 Butaciiene � and the environmen[. Acrylonivile • E[hylene oxide Although hydraulic fracking has been used as a method • ProPy�ene oxic�e for extracting gas in Pavillion, in general, gas production • Viny� ch�oride in the area uses conventional methods, where the concern focuses on the toxic VOCs that are inherent Two chemicak found in urine were assessed as to gas production. Bendimark-2 "Use bu[ Search for Safer Substimces": 59 Eumpean Cummission (2UIG). RHACH ReK��l�tion (GC 1707I200G): 'tio da�a no ma�ke2l che REACH Regulation places rr�punsibilio� on inAastry ro manage che risks irom che�nic,ds �and w providz s.aFe�y inlonnucion on ehe subscan«s � ,ip:Ph� , ,: =, i . i ' , .,;,�. . _ . : l,r.��. GU In the US, chemical menutaccurers are noe requl�ed m gencrare compechensive test date befure pu«ing a chemic:il nn �he marker, ehe vas� majodry of the more ihan 80.000 cheviicals on �he n�udeet have linueed in no publicly availablr test data. The simatiun is ch�anging in Europe sinre �he invoducuon nf REACH In 2007, but fo� now �vc live in a world of impertect and Inu�mplete diemical hazarA data. GI Ma«y c�.aL Q014). up.cit. anJ CuminK Qr�an and Glob:d C;omniwiiry Monimr (2014). op.cic, Concccncd Hcal[h Pmkssionals ot New Yo[k (201fl). op.cic. 62 Penaila rc uL (?0131. Submissiun: EPA Notice. Agency Information Collection Aaivitics, Prnpa�alz Submissions, and Appm�aLs: Inform Hyd�aulic Pr�cmring Retearch Rd-ated m Drinking Wamr Resourtc� %nq�,.;ii ,, , _ „ ..'d,"�rvnnu( �� i �-! 1 '.�� -llt�. uNl �. 'u, u i +. - i . : -�i, 28 I WHEN THE WIND BLOWS CHAPTER SIX CONCLUSIONS AND RECOMMENDATIONS his report shows chac che hazardous nanire of volatile exposure ro hazardous chemicals and ro be procected chemicals in gas condensate, which appears wi- from them. avoidable in natural gas prod�ction, indicates chaz produccion cannoc be carried o�c i� a man�er that Based on the monicoring research fi�dings and the tmly proteccs workers or the public. These chemi- GreenScreen hazard assessmeot resulcs, we recommend cals are present in air surrounding gas well head equipmen[ the following: and in the bodies of people living and working nearby. Maoy oFthe chemicals found in this study are chemicals • Encourage further biomonitoring reseazch and use of high concern and should be avoided. The high hazard results to effeaively prevent exposure. Air monimring of �he VOCs emicced inco the air, the tact thac chere are data from chis and �revious studies show irrefutably, several examples where �hese chemicals exceed che Envi- �hac oil and gas development is emirting highly coxic ronmental ScreeninQ Limits Eo� air, [ogether with �he find- chemicals inro the air that workers and families brea�he ings chat metabolires of some oF these chemicals were in each day. "Ihis daca irself makes the case �ha� people's che urine of rhe people scudied at levels �hat are well above health may be harmed. We have proven prorocols for chose in the gene�al popula[ion, is a cause for wncern . biomoni�oring: �he presence of che same chemicals in summa canisters, sorbe�t mbes and urine samples sig- We also observed chat che debace abouc oil and gas pro- nals chac air pollucants are getting inro people's bodies. duc�ion is ofcen focused on what can be done ro make it We believe [his study is the firs� mechods development safer, ra�her �han �aking a more precau�ionaty approach�' of its I;ind, which can be a basis for addi�ional research. where che intrinsic hazards of rhe chemicals being emitced • Addicional environmental moniroring and biomoni- are �aken inco accoun� (as in the hazard assessmenrs that �o�ing research by independenr instinaions should were done fo� rhis repor�), which asks whether or oot oil be conducred ro help identify and understand the and gas activi�ies can be carried out safely, period. ways in which people and ecosystems are exposed to oil and gas chemicals, in order to reduce these The Precaucionary Principle enables us ro make decisions exposures. based noc on irrefutable proof of cause-and-effect relacion- • Further research on the effeas of chemicals associaced ships buc on prevenrion and proteccion, based on whac we wirh oil and gas development will also help undeo- do know. The Pavillion study was not only an exercise in srand ehe complex healt6 im�aas of �hese chemicals. methods developmenr, for rhe people living in the Pavillion • Stare and federal age�cies should urilize resul�s from area, who have lived among toxic chemicals from oil and community-based research on �he exposure pa�hways gas development for decades, che study was a means of of roxic oil and gas c6emicals, m more effectively idencifying the presence of toxic chemicals in the air and reduce exposures and prevenc harm to wo�kers and in their bodies, which could lead co bec�er pro�ectio� of communi�y members from chronic, recurrenr expo- cheir healch and communiry. It is a basic human right for sure ro oil and gas chemicals and from oil and gas che communiry and for all people to be informed abouc developmenr as a whole. 63 A mmpreheml��e drfini�ion ul �he precautiunan' prindplr ie the Wing�prrad Sia�emeni on ihe Prrc.au�innazv Principlc kom �enuan� 1 )9H, �vhidi summvri�xs ihe principle this �vay "when :an aaivity r:�ises threa�s ol harnt m the enrlmnmene nc human health, precautionvp' mcusures should br cakzn even il sume cuuse and effea rela�ionships arc noi I1JIy es�ablished sciencihcally ' l�lri� . , � .� l �v,-�� - . �. � ii � � . .- � . � ,.; � , � _ _ � I � 1= ! p_ . " i li �"1=.- 29 �I hese s�andards shuuld epply not only ro "new" � ur "�nodified�� developmrnt acrivities but also Fenton home and gas <<� �•xisting development. development site. ' • Companies �hat explore lor, exvact or process fossil fiiels must fully a�d puhlidy disclose che chemicals used and emitted in all cxploration and produc�ion � accivities a� each phase ol uil and gas producrion . ( �overnmen� agenaes musc manda�e �hac oil and �;as cotnpanies disdose :�ll chemicals and constiuien�s I � i usrd in comentional .�nd unconvencional oil and r � �! � �:u developmen�. �,,.,, ,�'r-� � • ( �overnment agencies such as che US Environmen�al `'''`�' .� � � � . � ?ib� :p�� Protec[ion Agency ( EPA) mus[ ensure a [ransparen[ �.� � ,�! j. . , . . � � ^�� proci�ss, induding commun �ry involvemen�, for �he �-- : � � �'�:_ �, � n�� _ — rcview �nd assessmenc of}aentific info�mation and �� ',� � �S' ��, . datn when setting prorective standards. . � '. r. .i .r .,,.r . _ .,,, .. _ . ` • Promote clean renewable energy sources and stop promoting natural gas as "clean" and "safe." 'Ihc GreenScreen hazard assessmen � da�a shows cha< <he chemicals released during oil and gas produaion— • Investigate the harmful impacts of cumulative convenrional and umm�vention:il—pose high, inhcrenc exposure to multiple chemicals and how their to�c- ��,tzards to the environtnent and co people. Regulacory ity may increase when they interact in mixmres, improvements �o developmenc auivi[ies (i.e. zoning especially chemicals with endocrine disrupting setbacks, better induscry sakry praccices) may allevi;�re effects, which may act at low levels. some of these problems, howevcr fundamental h:¢ards • r\ddirional rescvch musc be conducied b}� indepen- �vill remain. Pro�eccing workers, communiry members den� scientisa, regulacors and heahh professionals m Furrher undersrand the harmful impaas of cumulacive exposures from oil and gus chemicals and ubiqui[ous chemicals from orher common �� O U R B A C K S A R E A G A I N S T A (e.g. household, H�orkplace and ocher indusvial air W A L L , so �ve'��e decide�l �o make a s�ai��l . emi�sions) , in ordrr tu bette� prorett public heal�h. I �m frcquendv asked why ] don�c leavc. • Implement precautionary regttlations, ensure "'�• �) lll � C Olli h0 [llt' �vl [�l Ollf O\t'R �l�1Rc{5; diselosure and [ransparenry. Hi�hlv mzic chemiails �resen[ in [he �avi��ion srea indica[e tha[ n� rrcnt OUf �lC1I'CS �fe III (�le ��llll{. EOSSI � Fl1e�S environmencal regulations are not adequntcly prorect- • � dev�lupment �s a prohlrm we can r run from . ing communiry mcmbcrs tiom harm . Whilc :idditional research can he helpfiil, regulacory agencirs alre:�dy :� ftet' [�':tve� in� �tcross the �15 3nd [he ��;1neG have enough emissions data available to justify swik I �� scen the same problems caused b�� du action to protecr public heal�h and rhe environmen�. ' • Statc and fec�cra� a�encies mus[ a�ressive�y im��emen[ IllVtiSl011 Of Ch� fOSSI � fUf�S II1C� llSCC}�, [ fCfUSI' more prorective, precautionary srandards for chemical , • �, �o hc .i cost of doin � business. emissions, (c.g. for methane and VOCs; oil and gas ` frackin� diemic;als in warer, and for mxic emissions fo�/tt Fe7ltOlt, �ocAl l'e5/G�PYtt at all phases of exploration and developmenc) . of ( �.��ncemedHeal�hProfessionalsofNrwYnrkl _'�II -n. ��p.. ii . 30 I WHEN THE WIND BLOWS and che public from these hazards requires a comprehen- oil and gas development in rural and urban areas�" sive change in our eners�ry system. poses a healdi chreac ro residenes and die public. The • U�ilities, governments and businesses must inves� Pavillion/Mudd,v Ridge gas field consiscs of ageing in aggressive energy efficiency measures and dean, and inadequarely conscructed wells, de�erioreting infra- renewable energy sources �o meet our nariods energy s�ructure and known contaminaeion that poses an even needs. Workers, small businesses and community greater hazard 'as the field ages. The lack ofgovemmenc members can work rogether ro design and imple- regulacion and induscry praccices �o address che legacy ment solutions rhac fos�er a heal�hy environment, of concaminacion is a warning sign for ocher commu- safe jobs and strong economies so �hac communicies nitics living wi�h development and facing future �hac are a�rrenrly economically dependenc on fossil developmenr. fuels are able �o effeaively [ransi�ion �o u 21st • Monicoring must continuc through development cenrury sustainable economy. and �roduaion, when wells are slwc i� and afrer • US and inrerna�ional goveming institucions such wells have been plugged and abandoned, to ensure as the Uniced Nstions musc stop promoting naniral �hac che developmenc no lo�ger poses a hazard to gas as "dean" energy or a safe bridge fuel o� alcerna- the environment, people who live and work nearby cive co ocher fossil fuels such as coal. The US and and die public. o�her wodd govemmencs should instead invesc in • Induscry should be financially responsible for reme- dean energy solucions thar prorecc che healch and diatio� of oil and gas developmenc and production well-being of all people. sites, as well as associaced impac�s and contamina- tion off site, during drilling and produaion, when • Provide ongoing monimring, health evaluation and wells are shut in and aker wells have been plugged site remediation to protect people already affected a��d abandoned. Communities must not bear ehe by oil and gas Production. The mmbination of moni- ongoing burden of environmental cont�amination toring duta and hazard assessmen� da�a indicares tha� and toxic diemical exposures from industrial long-rerm and legacy contaminacion from long-cerm develop�nenr. ,� � _� , _ , _ - _ _ _ ., - . ,_: . ."��,�.�- , ,� �! �.;�a�.:*f � . . 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P ~ yJ .�i.: � �'-' � �.� � . � � , .,. �� 4 y �y t�„ . �`. i w _. � ..4�- r .v . . �� l�y� ' � .« ll �' � �1y�x`��[i5A!'f� �� TM �- � � � .:� ;� W . .'�� ' e+ . � ' � . .:rhJ. � r.: .Y' a r : � T. � .Ia."� r �.41�!!�'/ � ._ 1 ._r?W r . � ,� ' -_ e `�.- �". . ♦ � . (v • �Y : Er s � _:. • � ' K . .— . - � . r. . a�e� .'. ��[ rf�` �.'IM'nr' . . _, . � ! ti'Y'P . � ? � . � i�`, t �4 � � Y � I . � ♦ I �� 1IOI� � T � - � e.v JL�,1 'F. . n � "'�./ T'w� '�Nt � • Jv �� i /f� a w �� ny'Y�� w�: � r� i . . ._ 1� �. t . S r�:. .. . ( �. �� -� .��1�_�� l.�u�Z3'� Wyoming wind turbines generate clean energy. . , . .�. . � . � � . . . . _ . � � 37 APPENDIX 1 PROFESSIONAL RESEARCH AND LABORATORY SERVICES Professional research a�d laboratory services were provided functions of a mass spearometer, and rhe associa�ed by a number of laborarories The various analytical tech- components, are: niques which were used are lisred below, followed by details of rhe laborarories and chei� mechodolo�vy. 1 . A small sample is ionized, usually ro cations (a posi- tively charged ion, i.e. one [hat would be attracted ANALYTICAL TECHNI ('� UES USED [othecathodeineleccrolysis), bylossofanelectron. 2. 'Ihe ions are sor�ed a�d separaced according to their Headspace Gas Chromatography (GC) mass and charge. A technique used for the co�cenrracion and analysis 3. `ihe separaced ions are chen measured, and the of volatile organic compounds. A headspace sample is results displayed on a chart.`'`' ❑ormally prepared in a vial containin�, �he sample, rhe dilucion solvenc, a matrix modifier and the headspace. U�ine Analysis Protoeol: Volatile components From complex sample miumres can Dr Chung-Ho L'I (Unlverslty of MI55ou11) be excracted from non-volarile sample components and isolaeed in the headspace or vapor portion of a sample Analysis of VOCs by SPME followed by GC-MS vial. An aliquor of che vapor in rhe headspace is delivered To quancify che volarile organic compounds (VOCs) co a gas chromacography system for separation oEall in t�he urine samPles, including benzene, toluene, xylene, oEthe volatile components. rrimethylbenzene, che coluene-d8 was spiked inro the samples as che intemal scandard, the VOCs were �[racred Gas Chromotography by a headspace solid-phase microexcraction (SPME) using "lhe separation and analysis of different substances accord- a 85mm carboxen/polydimerhylsiloxane fiber followed by ing ro their differenr affinicies for a standard absorbenr. In che analysis wich an Agilent 6890N gas chromacography the process a gaseous mixture of che subs�ances is passed coupled wich an Agilent 5973N quadrupole ntass through a glass cylinder containing the absorbent, which spectrometer (GC-MS) . may be dampened with a nonvolaeile liquid solvent for one or more of the gaseous components. As che mixture Malysis of Hydrophobic Metabolites by Liquid-Liquid passes through die absorbent, each subscance is absorbed Extraction followed by GC-MS eo a different exren� and Iraves a characcerisric pigmenc. The hydrophobic me�abolires in the urine samples were The bands of differenc colors IeEc when all the gaseous extracred by a warer.dichloromechane ( L l , v/v) liquid— mixture has moved through the absorbent constituce a liquid procedure described by Lin (2007 and 2008) . chromarograph for analysis. 1he identification and quanrification of t6ese metabolites were performed using a Varian 3400cx GC wich a Hewlec� Mass Speccrometry (MS): Packard cross-linked mediylsiloxane DB-> capillary column In order ro measure che characteris�ics of individual (30 m x 0.25 mm I .11.) coupled wi[h a Varian Sa[urn molecules, a mass specaometer comer�s �hem ro ions 2p00 ion-t�ap ntass selective detecror (Varian Inc., so that they can be moved abou� and manipula�ed by Walnu[ Creek, CA). external eleccric and magnetic helds. Thz three essentisl G� (n.dJMot6Yr .'�Irrlin+lDlctimwry. AtLrdltim+- ( '_0091_ 66 fv14U. wih.I�e. .�tascS�+ea�omeiiy. Secr.�mpledi.¢t> undcr ?. 'IheNuwrc �d ,A1.u. S�ictri '� . � . ._ � . . 32 WHEN THE WIND 8LOW5 Malysis of Polar Pollutants and their Metabolites by Liquid Chromamgraphy Coupled with Tandem O U R P I L O T S T U D Y �t-��s i �1re�lt�ec� Mass Spectrometry ro explore the methods and challenges of Ihe concentrations ofpolar compounds and �he mecabo- li[es in the u[ine samples, suc}� as 2-hydroxy-N-methylsuo- CVfl� U�lCltlg eY�lOSul'eS CO CheIl11C1�S fiO1T1 �1S cinimide, 2-mechylhippuric acid, pheitvlglyoxylic acid and �� roC� uCtiOn , �vit�l a vlew to feFtlltnP� [}le trans, [ransmuconic acid, were decermined using Waters Alliance 2695 HPLC system coupled with Warers Acquiry meChOC�s usec� ln future pCo) eC[s . TQ triple quadrupole inass spectrometer (HPLGMS/ MS) . The mmpounds were separaced by a Phe��omenex Kinetex C18 ( 100 mm x 4.6 mm; 2.6 mm parcicle size) Summa eanister air sample anatysis reverse-phase column using eleccrospray ionizacion in eicher posi�ive ion mode (GS+) or negacive ion mode (�� analytical laborarory �he sc�dy used does not give (ES-) wich a capillary voltage of 1 .5 kV. The molecular permission to be identi6ed by name in general to com- parent ions were screened and che producc ions used for muniry scieneist research smdy reports wirhouc additional �he quantificarions were derermined from the specva charges, which were noc included in the study's budget.) of anulytical standard solutio�s. Analytical data were pro- cessed using Wa2rs Em�ower software (Waters Cotp) . 'jhe method uszd by the s�udy's analycical laboratory co analyze air samples is described below: l . Lin, C H, Lerch, R N , Garrecc, H F,. George, M F: An Improved GC -MS/MS Method Eor derevnina- Summa Canister—EPA Method TO- 1 > is commonly cion of acrazine and i�s chlorinaced metabolites uptake ❑sed for the colleaion of volatile organic compounds by forage plants-laboracory and field experimencs. (VOCs) in ambient and indoor aic EPA Mechod TO- 15 Commu�ications in Soil Science and Planc Analysis is a procedure defined by EPA for air sample analysis ([he 2007, 38: 17�3-1773. Compendium of Mechods for rhe Determina[ion ofToxic 2. Lin, C H, Lerch, R N, Garrecc, H E, George, M F: Organic Compounds in Ambient Air, Second Edit�ion Bioremedia�ion of atrazine-contaminated soil by forage (EPA/625/R-9G/0106) , January, 1999) . This procedure grasses cransformation, upcake, and detoxihcaeion. (�;C/MS) is described i� labo�atory SOP VOA-TO15. Journal of Em�ironmental Qualiry 2008, i7: 19G-20G. (EPA/625/R-96/0106) NMS Laboratories Analysis: Method TO- 15 ucilizes a passivared (created so that [he Headspaee Gas Chromatography-2413B Inhalants canister inner service is nonreactive ro chemicals) s[ainless Panel, Solvents and Gases—Blood sreel caniscer (Summa canisrer) ro collect an air sample. 1hc Summa caniscers are cleaned, prior co sampling, down NMS did not derecc levels for any of �he VOCs tested fo� to the method reporcing limit Once �he air sample is col- in the Pavillion blood samples. This may be because NMS lected and shipped �o che lab fo� anal,vsis, ic is interfaced Labs reporting Ievels are higher chan �he levels of VOCs ro a whole-air preconcentraror, a component chae accumu- �ha� mighc have been present in blood samples. Commer- lares, concen«a�es a�d then releases �he concenrraeed air cial labs often use reporting Ievels rache� ehan Ievels of sample int�o the gas chromatograph/mass speetrometer dececcion. For example, NMS Laborarory reporting limit ��y��cal sysrem. for benzene is 0.050 mcg/ mL or 50 ng/mL. Sorbent Tube Analysis: 71ie median level for benzene in blood in �he US popu- INSTAAR Labs (Institute of Aretie and Alpine lacion (2001-2006) is 0.028 ng/mL, (CDC/NHANES Research—Dr Detlev Helmig) Fourth Report_Updared Tables 2015) , an amount belo�v NMS reporting level for benzene. INSI�ARR uses PID/M $ pro�ocols for VOC analysis in air samples collected in sorbenc tubes. FID (Flame Ioniza�ion Dereccor) is a mechod �hac can measure �ocal volume of ,, . . . . � . . . . u . . . � � , i � 33 VOCs in an air sample. MS is described elsewhere in appendix. Sorbent tubes are the most widely used collection media for sampling hazardous gases and vapors in air, mostly as it relates to industrial hygiene. They were developed by the US National Institute for Occupational Safety and Health (NIOSH) for air quality testing of workers. Sorbent tubes are typically made of glass and contain various types of solid adsorbent material). Commonly used sorbents include activated charcoal, silica gel, and organic porous polymers. Solid sorbents are selected for sampling specific compounds in air because they: 1. Trap and retain the compound(s) of interest even in the presence of other compounds 2. Do not alter the compound(s) of interest 3. Allow collected compounds to be easily desorbed or extracted for analysis Sorbent tubes are attached to air sampling pumps for sample collection. A pump with a calibrated flow rate in ml/min is normally placed on a study participant's belt or other clothing, and it draws a known volume of air through the sorbent tube. Chemicals are trapped onto the sorbent material throughout the sampling period. The absorbent tube is then placed in a heated chamber and purged with an inert gas. VOCs are thermally desorbed into a cryogenic trap, cryofocused onto the transfer line, separated by GC and analyzed by a positive ion electron impact Mass Spectrometer (MS). 34 WHEN THE WIND BLOWS APPENDIX 2 APPLICATION OF ENVIRONMENTAL SCREENING LEVELS TO LEVELS OF VOCS DETECTED IN AIR SAMPLES COLLECTED IN PAVILLION , WYOMING Environmental Screening Levels (ESLs) are based on or for roughly one hour (for samples collecred in sorben� levels of �oxic subscances rha[ public healch agencies and cubes). 1lierefore, application to VOC levels decected i❑ environmental regula�ors have derermined may pose a tisk air samples collec[ed Erom Pavillion of ESLs for bng-term to human health . These ESLs indude: 1 ) Minimal Risk exposure periods requires an assu»:ption tbat tbe air samples Levels (MRLs)` developed by rhe US Agency for Toxic nre representative of ambient air canditiora thatgenerally Subscances and Disease Registry (ATSDR) ; 2) National pr�evail at the location over longperiocG oftime. Ambien[ Air Qualiry S�andards (NAAQS)`'" and Reference Concentrations (RtGs)"° developed by the US Enviro��- Second, there is not an ESL for each VOC. Considering mental Protection Agency (USEPA) ; 3) Acure and Chron- thac chere are li[erally millions of VOCs thac might be ic Reference Exposure Levels (RELs)" and Cancer Potency presen� in the environment, public healch agencies and Factors (CPFs)" developed by the California Office of environmencal regularors prioritize [heir resources on Environmencal Heal[h Hazard Assessmen� (OEHHA) ; developing ESLs for VOCs diac are likely ro be �hc mosc and 4) Ambienr Air Qualiry Guideline Values" developed coxic. For example, of the 46 VOCs derected in air samples by the Wodd Health Organiza�ion (WHO) .`s collecred in sorbent tubes, public health agencies and environmen�al regularors have not developed an ESL When applying ESLs eo levels of volacile organic com- for che followi�g 36 VOCs: �ounds (VOCs) , it is impor[an< <o consider [wo factors. • propene • propane First, each ESL is developed to apply �o a speci6c dura[ion • isobu[ane of [ime, rangittg from sltort-rerm exposure periods (for • isobutene example, one hour or one day) to long-�erm exposure • dichlorodiHuorome�hane periods (for esample, one month, one year or a life�ime) . • 1 -burene USEPA Reference Concentrations and OEHHA Cancet • o-bur.�ne Po[e��cy Facmrs are examples of ESLs thac apply ro very • ethanol, isopen[ene long-rerm exposure periods. Air samples collecred in • [richloroHuoromethane Pavillion, Wyoming in [he latter half of 2014 are samples • I -pentene �ha� were collecred over very shor�-�erm peciods—either • 2-propanol instantaneously (for samples collecced in Summa canisrers) • pencane I b7 An MRL is "nn estima[t o��he daily human esposure m �a hazardous substance th�at it likely io he wl�hout appreciable rislc o(adverse non-cancer healrh effeets ovtr �a specified duracion af expowre . . . � .b:�d, .,, ,. - , 68 NMQS "pmvide pu6lic hcalth pmmcrion, indudln� p�oieciing ehe healch ot `sensltive" populations such a asehmaei�s, children. and the eldedy." ��l(�r�l�l. li N [� 1 �✓ti� Irli�'�p �pl-�u��plr ll / I . . C9 An RFC is the "con¢ntratiun o(u chemicxl �ho� one can breathe every dav for a lifetime that is no� ancicipaeed m causc hannFul nooeanctr healeh efiects" Lnpr/lnww�.��ri;n�'i.i.. �0 l.(�[�.'/i„il�l,.�..e.Qivmn,.dLe'l,burrl_ ' � / ��Unr �u .Jlr] r p��Fil�l�Ol� )Ol �r'.'.. . -�e •l��:bn � _ .. :1. I l4✓/Vdldi �� . i <:' i n � ./�I � �il I _ . _ � h:._'U�n � . ._, . -i � p��J:ru i ., i �,rn //J,rJ� ' :, ,_ ..��If�. �.. � . . ' I S �� !�l , -ic_� J �� I �� P-. _ �._ ' � I ; I I �_ �, 35 • sop�ene Highlighted in orange are levels of VOCs in excess of a • 2,3-dimethylbucane level of exposu�e which increases a persods risk of cancer • 3-mechylpe��ane by more chan 1 in 1 million. Application of chese FSLs • 2-mechyl-l -penrene to �he air samples colleaed in Pavillion also requires • methylcylopen�ane an assumprion that the air samples are representative • 2-mediylhexane oF ambien� air c4ndi�ions chac generally prevail a[ the • ❑-hepcane location over long periods of cime. • 4-mechyl-2-pentanone • methylcyclohexane Application ofES1s ro VOC levels in air samples collected • 2-mcthylheptane in Pavillion, Wyoming in August 2014 show that air qualiry • 2-hexanone was substantially impaired in the vicinity of the three well • 4-methylheptane pads (42x- 1 l , 22-] 2, and 14�03w) during chax �ime. • 2-hex�none • 3-methylhep�ane Levels ofbenune, toluene and zylenes in these sramples • octane exreed levels as,oci�:red iuirh adverse inipactc to tbe cenrral • uonane nervoaes systenz and the imrrzzene system fm- short-term • isopropylbenzene exporures. Levels of eyclohe�cane in two of [he [hree • 1-pinene samples exceed levels associated with adverse impaets • rnpropylbenzene on fetal developmenc for long-ternr exposarres. • ethylmethylbenzene • 13,5—t�imethylbenze�e Levels of ethylbenzene in nvo of �he chree samples exceed • 1 ,2,4—ttime�hylbenune levels associated wich adverse impaccs on kidncy Function • 1 ,2,3—«ime�h}'Ibenzene. fbr long-terrrr exposures. Levels of hexane and naphYhalene exceed levels associated with adverse impaccs co the cencral Therefore, the ESL rtrialysis ornits cliscusriori of rhe detected nervous system fnr Lang-term exposures. leveG of tbiese substanres. Applicatioo of ESLS [o VOC levels in air samples colleaed Table 5 below shows how ESLs were applied ro VOC in Pavillion, Wyomi�g in rhe larrer half of 201 G also show levels in air samples collec�ed in Pavillion, Wyoming in �ha� exposure of farmers ro carcinogenic levels of benzene August 2014. and naphchalene mighc present a public heal�h risk. All buc one of the levefs of benzene and nearlv half of the levels The findings highligh�ed in red are VOC levels chat exceed ofnapht6alene i� air samples collecred by farmers in sorbenc a short-term ESL, lliese are the most relevant m highlighc mbes exceed levels associated wi[h a more than 1 in I mil- since the air samples that were collecced in sorben[ tubes lion excess risk of cance� For long-remi exposure. However, or summa canis�ers represenc shoro-�erm air quality ic should also be nored thaz che average level of benzene conditions. in che air samples collected by farnters in sorbenc mbes (0.41 ppb) is consistenc with rypical levels of benzene in Highlighted in yellow are VOC levels �hac exceed a long- rural areas (0.47 ppb) .'' In contrast, che average level of term ESL. Applicarion of these ESLs m che air samp�es naphthalene collected by farmers in sorbent tubes (0.08 collecred in Pavillion requires an assumption that the air ppb = approximacely 0.4 pg/m°) is subscancially above samples ure represen�acive of ambien� air conditions that cypical levels of benzene in remote or rural areas (less generxlly prevail a� d�e location over long periods of cime. �han 0.001 ppb) . ' ' i „ILc �ollowin� dalh' nirdian bcnienr u� concan��a[iuns wcrc nponed In ihc Anla�ilc (1��y�ic Compou�iJ A'a�ional Ambicnt [)staba�c I19'5_I `)857: �rmo�c (0. 16 ppb7. ru�21 i0.4T pphl. suburbxn II .N ppb). urhan ( Lfi ppb). Induo� air ( ! .4 pph), nnd wurkplaee air (2. 1 ppb). '16e uu[duur air dae� reprarn[ 300 eitiex In 42 smtes while dte indoor �air duia reprcsent 30 ci�ies in IG sm�e< ($hah anJ Singh 19RR)` U.S. Agenq- forTosic Substances anJ Discuc Ri�,is�ry. (August 2007) "li�ximlogical Info�maeion Prohle thr Henzene"ASZ'DR (2007) op.ci�. '� "A mean maphehalene mncenaution of 0. 129 ng/m3 was detectcA in ambient air m the Mississippi Sanelhill Cr'vne Naiional Wildlife Reh�ge, �ackson Coun�v from May m $ep�ember 1991 (Whim and HarJc 1994):' U.S. Agenry Fo� lbxic Subxances anJ Diseast Registry, (Augua'i 200>) "l'oxicologieal Information ProfilcYurNaph�halene � ehd,�.��i � i ��,r,':, r,�= --/--Il' 36 WHEN THE WIND BLOWS T A 8 L E 5 Levels of 10 VOCs in Summa Canisters and Sorbent Tubes, Compared to ESLs VOC levels detected in sorbent tubes (in ppb) . - . . • • . - . . . . . . � , -. • acetone BDL 12.32 52.6 26000 none 1300 1300 none none none none 2-butanone 0.02 0.49 2.45 none 4500 none none 1695 none none none hexane 0.02 1.19 6]4 none none 600 none 200 2000 none none ethylacetate BDL 0.97 621 none none none none 250 none none none benrene BDL 0.47 1.12 9.00 8.00 3.00 6.00 9.40 1 .00 0.04 0.10 cyclohexane � 0.02 0.84 6.27 �. none none none none 1715 none none none � toluene � � BDL 1.44 3J3 2000 9800 1000 none 1325 70 none none ethylbenzene BDL 0.18 0. 54 5000 none 60 2000 600 400 none none xylenes BDL 0.84 275 2000 5000 50 600 23 200 none 0.92 naphthalene 0.01 0.08 0.36 none none 0.7 none 200 2.0 none I, 0.056 VOC levels detected in summa canisters (in ppb) .. _ . _. _ . __ _I . . .. . . _ .__ . . .. . . . . . _ . .. . . . � . � . . • . . - . . . . , . . . . acetone BDL BDL BDL 26000 none 1300 1300 none none none none 2-butanone BDL BDL BDL none 4500 none none 1695 none none none hexane 0.61 3303 11000 none none 600 none 200 2000 none . none ethylacetate BDL BDL BDL none none none none 250 none none � none benzene 9.00 8.00 3.00 6.00 9.40 1 .00 0.04 0.10 cydohexane � 0.66 i 3643 12000 '� none none none none � 1715 none nonel none toluene 03 1179 � 2000 _ 9800 _ 1000 none _ 1325 70 nonel none ethylbenzene BD� 5300 1300 5000 none 60 2000 600 400 none none xylenes _ 0_4 �r 2000 _ 5000 _ 50 600 _ 23 _ 200 _ none _ 092 naphthalene BDL 147.5 210 none none 0.7 none 200 2.0 none 0.056 � RED = VOC levels that exceed a short-term ESL. YELLOW = VOC levels that exceed a long-term ESL. � ORANGE = VOC levels that exceed a level exposure which is estimated to increase a person's risk of cancer by more than 1 in 1 million. iRACKW6 �_i � ��. Ci II ��II[F,LS IM �, � � � !� LDS 4ND IMPa+� � � C COF1MUNITIE5 I 37 APPENDIX 3 VOCS AND METABOLITES IN THE URINE OF RESIDENTS OF PAVILLION Table 6 below decails che aggregace daca of VOCs and chemical in �he urine of the general popida�ion. The �heir mecabolices in che urine of Pavillion residencs smdied maximum level of hippuric acid in the urine of residencs and contains composire informacion abou� �hese levels of Pavillion is more �han 2 �imes higher �han che level (media� and max) ; it also concains informacion abouc of diis cheinical in �he urine of t6e general populacion. levels of VOCs and VOC mecabolites in the urine of the PMA (N-Aceryl-S-(phenyl)-L-cysreine) another marker �eneral popula[ion. Values are from [he CDC NHANES of benzene exposure—in [he urine of residents of Pavillion dataset with the exceptioo of values for hippu�ic acid is many times lower than levels of �hese same chemiails (a marker of toluene exposure) .Je 'ihe CDC HANES in che urine of the ge�e�al populacion. 7he highest level did noc �es� urine for che chemical paren�. ot PMA in �he urine of residencs of Pavillion is 70% lower than rhe 95rh percenrile of PMA in the urine of [he gem 7he levels of hippuric acid (a marker of coluene exposure) eral populacion. However, there is no consensus in the and trans,transmuconic acid (a marker of benzene expo- sciencihc communiry abouc che validiry of PMA as a sure) in the urine of residents of Pavillion are significandy reliable biomarker for benzene exposure. higher than levels of �hese same chemicals in che u�ine of the general popula�ion. Levels of che followin�, subscaoces in the urine of residents of Pavillion showed noticeable but inconsisrent variacions For example, the median level of trans,cransmuconic acid with levels of rhese substances in the urine oE the general (c�MA) in che urine of residencs oFPavillion is 10 rimes populaiion: MHBMA (N-Aceryl-S-(2-hydroxy-3-bucenyl) higher than che median level of ttMA in the urine of ehe -I-cysteine) , HEMA (N-Acetyl-S-(2-hydro�ryechyl)-l- general populacion. In addition, [he median level of ttMA cysreine), CNEMA/CYMA (N-Acetyl-S-(2-cyanoethyl)- in �he urine ot residents of Pavillion is higher than the L-cysreine) , 3-HPMA (N-AceryI-S-(3-hvdroxypropyl)-I- median level of m'VtA in refinery workers in Brazil (posr- cysreine), 2-HPMA (N-AcetyI-S-(2-hydroxypropyl)-I- shih) .�� The mruc level «MA in �he urine of residents of cysteine) , AAMA ( N-Aceryl-S-(2-carbamoyle�hyl)-1- Pavillion is 4-5 cimes higher than die 95'�' percentile level eysreine) , and HPMMA (N-Acetyl-S-(3-hydroxypropyl- of ttMA in the urine of �he general population and even 1 -methyl)-Irysteine) (che last 7 rows of Table 6) . However, higher than che Biological Exposure Index (BBT) for ttMA the differe��ces becween Pavillion levels and levels in d�e establisheci by �he Ainerican Conference of Governmental general popula�ion seem random, and chese subs[ances Industrial Hygienis[s (ACGIH) of 500 pglg creatinine.Je are not markers for esposure to VOCs rypically emi[[ed by namral gas produc�ion wells (e.g. many of �hese substances Simila�ly, the median level of hippuric acid in the urine of are biomarkers for exposure ro �obacco smoke, wood residents of Pavillion is 80°/u higher than die level ot this smoke, for diesel emissions) . � 7G CDC (10151 �fth report Feb. 2015 upda�c .-. .. . . i ��..,, .. d, .,ri � ; , i -„�: . l , , ,./„[/. Por 6ippu�ic add� tiiqueira. M H P, & 1'xivo. M J N Q00?). Hippuric ucid in urine: rete�ence values, Revisra de 3aude PubGca, 36(G), 723-727 76 Martins, 1. & Siquei�a. M E P B D (2004). Trans tans-mucunic vcid in urine mmples mlle¢cd in rh�ee periods fmm benzene handling woeke� in a B�azilian mhnery Re�iaa B�asileira de Ciencias harmac@ueicaz 40(2), 197-201 . 77 Secl,r; i . rJ�,q5„ hG./ruoi/uunmrn i�/vrn,�� _,l,pr- .q,�,l,_pol_� 38 i WHEN THE WIND BLOWS TABLE 6 VOCs and Metabolites in Urine Samples of Pavillion Study Participants, Compared to the General Population Level of chemical in urine samples of residents of Pavillion, Wyoming Level of chemical in (August 2014), micrograms per gram of creatinine general population'" , . : . . . . Benzene Benzene 0,022 0.385 No data No data Ethylbenzene Ethylbenzene 0.012 0271 No data No data m/p-Xylene m/p-Xylene BDL 0.118 No data No data Styrene Sryrene 0.089 0.531 No data No data O-xylene O-xylene BDL O.D4 No data No data Toluene Toluene 0256 2.917 No data No data 4-Heptanone 4-Heptanone 19.869 214.953 No data No data 2-Heptanone 2- Heptanone 2216 10.358 I No data No data Naphthalene Naphthalene 0.210 1 .078 No da[a No data Hippuric acid Toluene, 322,958.63 1 ,197,549.00 180,000.00 360,000.00 cinnamaldehyde 2-hydroxy-N-methylsuccinimide N-Methyl-2- 64,852J1 218,422.00 No data No data pyrrolidone ( NMP) 2-pyrrolidone N-Methyl-2- 309.165 1638.980 �� No data No data pyrrolidone (NMP) - . _. .. . . . _ . . . Mandelic acid Ethylbenzene, Z�q.608 2466240 158.00 513 Styrene 4-Methylhippuric acid Xylene 92.119 1394593 212.000 1540 2-Methylhippuric acid Xylene 80.975 630.937 35.200 248.000 3-Methylhippuric acid Xylene 99.033 643.311 212.000 1540 a-naphthylgiucuronide � Naphthalene 924.94 6809J6 No data No data b-naphthylsulphate Naphthalene 8.65 2865.919 No data No data � 1-naphthol (1-naphthalenop Naphthalene BDL 255J29 � No data � No data Phenylglyoxylic acid Ethylbenzene, 53.384 411.338 206.000 518 styrene trans, transmuconic acid � � Benzene 369350 2045.534 76. 9 473 PMA (N-Aceryl-5-(phenyl)-L- genzene BDL 0.977 BDL 3.030 cysteine) MHBMA (N-Acetyl-S- � ,3-butadiane BDL 0.840 ' BDL 3J00 (2-hydroxy-3-butenyp-I-cysteine) HEMA (N-Acetyl-S-(2-� Acrylonitrile, Vinyl � �,320 3.615 0.941 4J50 hydroxyethyD-I-cysteine) chloride CNEMA/CYMA (N-Acetyl-S- qcrylonitrile 1.295 31922 1.830 256.000 (2-cyanoethyl)-L-cysteine) 3-HPMA (N-Acetyl-S- qcrolein 388.475 7057.75 276.000 2190.000 (3-hydroxypropyq-I-cysteine) 2-HPMA ( N-Acetyl-S- Propylene oxide 35.046 162.473 50.800 284.000 (2-hydroxypropyp-Lcysteine) AAMA (N-Acetyl-S- qcrylamde 99.091 199.188 49.500 199.000 <2-carbamoylethyl)-I-cysteine) HPMMA (N-Acetyl-5-(3-hydroxy- Crotonaldehyde 235.118 630.465 398.000 3970.000 propyl-l-methyl)-Icysteine) 78 Uaca is all from CDC f?01 �) op.cic, excepc for Hippu�ic vcid which is Siyuicra e�aL (1002), op.cit. J< I �-.; � � .-. .- :6 i �: _ . . ' i � iM �-.� i . . S �� • , � ' ll 'ILti � 39 APPENDIX 4 GREENSCREEN ASSESSMENTS OF CHEMICALS FOUND IN URINE OF STUDY PARTICIPANTS , PAVILLION Note thatthe full GreenScreen reports are available at � � . ; �!� :� � ' _ � > >� r � �� s; � . �. � ' � � reporr GreenScreen Benchmark Score and Hazard Summary Tables Abbreviations in all of these tables are as follows: C Carcinogenicity SnR Respiratory sensitization Sn5 Skin sensitization vH Very High M Mutagenicity IrS Skin irritation CA Chronic aquatic toxicity H High R Reproductive Toxicity IrE Eye irritation P Persistence M Moderate D Developmental Toxicity AA Awte aquatic toxicity B Bioaccumulation L Low E Endocrine activity ST Systemic toxicity Rx Reactivity vL Very Low AT Acute mammalian toxicity N Neurotoxicity F Flammability DG Data Gap Hazard levels in italics reflect estimated (modeled) values, authoritative B lists, screening lists, weak anaiogues, and lower mnfidence. Hazard levels in BOLD font are used with good quallty data, authoritative A lists, or strong analogues. The following color scheme also denotes the hazard dassification for each hazard endpoint: ■ vL deep green M yellow ■ vH deep red L light green ■ H red DG white Benzene was assigned a Benchmark Score of 1 ("Avoid—Chemical of High Concern") as it has High Group 1 Human Toxicity <High carcinogenicity (C), mutagenicity ( M), reproductive toxicity ( R), and developmental toxicity (D)). This corresponds to GreenScreen ' benchmark classification le in CPA 2011 . There are no data gaps. . . . . . . . � C I M R i D E AT ST N � SnS' '. SnR' Ir5 IrE AA I CA P B Rx F � �' SINGIE REPEAiED'� SINGI.E RE�EAiEO' � , I . � M _ . . . M , � - � _ _ _. Toluene was assiqned a Benchmark Score of 1 based on failure of Benchmark Rule le, due to High reproductive and developmental toxicity. . . . . . . . � � C M R D E AT 5T N � SnS' �� SnR' Ir5 IrE AA CA P B Rx F . . . . . . SMG: fi kE�lAiED' SW4lE RWEAiE�' . �. . . . . . - ._ _ . . � . . . DG L �� M L M M M �. DG 40 I WHEN THE WIND BLOWS o-Xylene was assigned a Benchmark Score of 1 based on a High Group I human health endpoints ( Developmental toxicity (D). A data gap (DG) exist for respiratory sensitization (SnR), o-Xylene meets requirements for a Green- Screen�`� Benchmark Score of 1 despite the hazard data gaps. In a worst-case scenario, if ethylene oxide were assigned a High score for respiratory sensitization, it would still be categorized as a Benchmark 1 Chemical. • • • • ` • ��fiii�� C M R D E AT ST N Sn5' � SnR' Ir5 IrE AA �! CA P B � Rx F SiNGLE REPEAiED' SWGtE REPEAiEO' � L L M - M M M M M � DG - M � M _ L . M Ethylbenzene was assigned a Benchmark Score of 2 ("Use but Search for Safer Substitutes") based on Moderate Group I human health endpoints (carcinogenicity (C), developmental toxicity (D), and endocrine activity <E)); High Rammability (F); and a score of very high single dose neurotoxiciry (N). A data gap (DG) exist for respiratory sensitization (SnR). Ethylbenzene meets requirements for a Green5creen ` Benchmark Score of 2 despite the hazard data gaps. In a worst-case scenario, if ethylbenzene were assigned a High score for respiratory sensitization it would stillbe categorized as a Benchmark 2 Chemical. . . . . . . . C M R D E AT 5T N Sn5' SnR' IrS IrE AA I CA P B Rx F bINGLE REPEAiED' SINGLE REPEPiED' M I ,�Cu•.'�� M M M M M _ M _ _ DG r M Naphthalene was assigned a Benchmark Score of 1 based on criteria le (high concem for Group � Human health endpoint: cancer and possibly endocrine activity). This Benchmark score meets the Data Gap analysis. Note this chemical is also flagged on a number of PBT lists, however no data was found to support a concem for bioaccumulation. . . . . . . . �� C M R D E AT 5T N Sn5' SnR' Ir5 trE AA ��, CA P B Rx F SINGtE RE�E4TED' SINGLF REPEATED' , - M . DG � L M M — M DG M DG M L � M L �'(,,., M Propytene oxide was assigned a Benchmark Score of 1 based on High Group I human health endpoints (carcino- genicity (C), mutagenicity (M), and reproductive toxicity (R)). A data gap ( DG) exist for respiratory sensitization (SnR) and chronic aquatic toxicity (CA). Propylene oxide meets requirements for a GreenScreen ' Benchmark Score of 1 despite the hazard data gaps. In a worst-case scenario, if ethylene oxide were assigned a High score for respiratory sensitization or chronic aquatic toxicity it would still be categorized as a Benchmark 1 Chemical. . . . . . . . �� C ! M R D E AT ST N � Sn5' � SnR' Ir5 IrE AA CA P B Rx F SiNGLE REPEAIEO' SINGIf HEPEAiE�' � M M M M M M M M �, DG �_ M ��I DG — M - TRACKING TOXIC CHEMICALS IN GAS FIELDS AND IMPACTED COhIMUNITIES I 41 1,3 Butadiene was assigned a Benchmark Score of 1 based on high Group 1 human health endpoints (carcino- genicity, mutagenicity, reproductive toxicity). Data gaps ( DG) exist for skin sensitization (SnS), respiratory sensitization (SnR), skin irritation ( Ir5) and chronic aquatic toxicity (CA). 1,3 Butadiene meets requirements for a Green5creen ' Benchmark Score of 1 despite the hazard data gaps. In a worst case scenario even if 1 ,3 Butadiene were assigned a High score for the data gaps it would still be categorized as a Benchmark 7 Chemical. . . . . . . . C M R D E AT 5T N � Sn5' SnR' 15 IrE AA CA P B Rx F sw��E aEVEarEo• si�vc�E aECEarFo� . � M M � _ ;. " i M M M DG DG DG M DG . M - M _.. - _;., .: Acrylonitrile was assigned a Benchmark Score of 7 based on High Group I human health endpoints (carcino- geniciry (C), mutageniciry (M), and reproductive toxicity (R)). A data gap ( DG) exist for respiratory sensitization (SnR). Acrylonitrile meets requirements for a GreenScreen ' Benchmark Score of 1 despite the hazard data gaps. In a worst-case scenario, if acrylonitrile were assigned a High score for respiratory sensitization it would still be categorized as a Benchmark 1 Chemical. . . . . . . . � C � M R . D E AT ST N � Sn5' �, SnR' I�S IrE AA CA � P B Rx I F SINGLE REPEAiED' SINtiIE REPEAiED' � M M . M _ M � DG �- M_ _ M . Acrolein was assigned a Benchmark Score of 2 based on Moderate Group I human health endpoints (carcino- gencity (C), mutagenicity (M), and developmental toxicity ( D)); very high Group II human health endpoints (acute mammalian toxicity (AT), single exposure systemic toxiciry (ST), skin irritation ( IrS), eye irritation (IrEp; high Group II " human health endpoints ( repeat exposure systemic toxicity (ST)); very high ecotoxicity <acute and chronic aquatic toxicity (AA and CA)) and high flammability (F)). Data gaps ( DG) exist for endocrine activity (E) and respiratory sensitization (SnR). Acrolein meets requirements for a Green5creen ` Benchmark Score of 2 despite the hazard data gaps. In a worst-case scenario, if acrolein were assigned a High score for endocrine activity it would be categorized as a Benchmark 1 Chemical. . . . . . . . � C M R D E AT ST N � Sn5' SnR' Ir5 IrE AA ' CA � P B Rx F SINGIE REPE4TED' SINGLE REPEAiEO' � � � M , M � M DG M DG Vinyl chloride was assigned a Benchmark Score of 1 based on high Group 1 human health endpoints (carcino- geniciry and mutagenicity) and very high persistence along with high Group II ' human health endpoints. Data gaps <DG) exist for skin sensitization (Sn5), respiratory sensitization (SnR), skin irritation (IrS) and chronic aquatic toxicity <CA). Vinyl chloride meets requirements for a GreenScreen ' Benchmark Score of 1 despite the hazard data gaps. In a worst-case scenario, if vinyl chloride were assigned a High score for the data gaps it would still be categorized as a Benchmark 1 Chemical. . . . . . . C M R D E AT ST N Sn5' SnR' Ir5 trE AA CA P B Rx F � SiM3:_F ��EGE4iE0' SINGLE REPEATED' _ M M M L L � M _ DG DG DG M L � DG — M - 42 I WHEN THE WIND BLOWS Styrene was assigned a Benchmark Score of 1 based on a high Group 1 human health endpoint (carcinogenicity). No data gaps exist for styrene. . . . . . . . �� C M R D E AT ST N Sn5' SnR' Ir5 IrE AA CA P 8 Rx F 51NGLE FEVE4tEfJ' SMGLE FEGcqiEp' � . M L M M M M M � M M �� M M - M M 4-Heptanone was assigned a Benchmark Score of U (" Unspecified Due to Insufficient Data") based on not meeting the data requirements for a benchmark 2 or higher score. Specifically, data do not exist for carcinogenicity and exists only for 2 of the 3 Group 1 Human Health endpoints. In a worst case scenario, if 4-heptanone were assigned a High score for the Group 1 Human Health data gaps it would be categorized as a Benchmark 1 Chemical. . . . . . . . C M R D E AT 5T N Sn5' SnR' Ir5 IrE AA CA P B Rx F SIH6LE RE�EAiED' SIN6LE REPE4TED' DG DG _ DG . M � 1 � _ _L M �, �� _� M �. . M _. � M � M �I ._ . �. _� M 2-Heptanone was assigned a Benchmark Score of U based on not meeting the data requirements for a benchmark 2 or higher score. Specifically, data does not exist for carcinogenicity and exists for only 2 of the 3 Group 1 Human Health endpoints. In a worst case scenario, if 2-heptanone were assigned a High score for the Group 1 Human Health data gaps, it would be categorized as a Benchmark 1 Chemical. . . . _ . . . . . . . . . : . . . . - � C I M R � D E AT S? N SnS ' SnR' Ir5 hE AA , CA . P B Rx F . . . - � an � �- �u-� �i_ o� swc,a� .:. � ,ac� . . - . . DG �� DG DG M L L M L L DG M M M M _ M . M Ethylene oxide was assigned a Benchmark Score of 1 based on High Group I human health endpoints (carcino- genicity (C), mutagenicity (M ), reproductive toxiciry (R), and developmental toxicity ( D)). The Benchmark 1 score is also based on very high persistence (P) along with very high Group II human health endpoiM (single dose neuro- toxicity (N)) or very high P along with high Group II ' human health endpoints (repeat dose neurotoxicity ( N)). A data gap (DG) exist for respiratory sensitization (SnR) and chronic aquatic toxicity (CA). Ethylene oxide meets requirements for a GreenScreen ' Benchmark Score of 1 despite the hazard data gaps. In a worst-case scenario, if ethylene oxide were assigned a High score for respiratory sensitization or chronic aquatic toxicity it would still be categorized as a Benchmark 1 Chemicai. . . . . . . . . . �� C M R D E AT ST N SnS' SnR' Ir5 trE AA CA P B Rx F SINGd e[�EAiED' SINGLE RE�EAiED' � M . M M _ M DG � M DG � � :� - IUf-i�_ _ . . I -=: LS IF. � _ � ! LL' - - ll� IMF- i _C � �- �._G "-il_INITIES � 43 • • • . WHEN THE WIND BLOWS TRACKING TOXIC CHEMICALS IN GAS FIELDS AND IMP/� CTFD COMMU ��IITIES In 2014 a team of residents from the area of Pavillion , Wyoming, science and health experts, and environmental health groups, collaborated on a project to test the air and residents' bodies for chemicals known to be linked to oil and gas production. This is the first study which combines environmental sampling with the monitoring of body tissues or fluids (biomonitoring) of community members in very close proximity to gas production equipment and activities. Through this research project, we designed and tested methods for environ- mental monitoring and exposure assessment in people living near oil and gas fields. We did this by using a variety of air monitoring tools with the capacity to test for VOCs, which are a large group of carbon- based chemicals that easily evaporate at room temperature. VOCs can be both naturally occurring and man-made. Pavillion area community members hope to use the monitoring results to encourage legislators and regulatory agencies to protect residents' health and to help other communities facing existing or new oil and gas development avoid the health challenges that Pavillion area residents are facing . A precau- tionary approach to decision making is critical if we are to truly protect public health and the environment. For communities impacted by existing oil and gas development this needs to happen now and it is not too late to prevent future damage in communities which are threatened with new development. The report is available online at http://comingcleaninc.org. For more information related to this report, contact Coming Clean, (802) 251-0203 or 28 Vemon Street, Suite 434, Brattleboro, VT 05301 Drilling Bella Romero: Children a[ Risk in Greeley, Colorado lile:///Users/Anne/Desktop/Drilling Bella Romero_ Children a[ Risk ... O FRACTRACKER '� A l l. I A ?J � �. EXHIBIT � � B �Og - �BISffiBA�� Home / States / Cobrado / Drilling Bella Romero: Children at Risk in Greeley, Colorado � - 'y � � � '"' � . .�i�'�.�1�� ' � ��1l�� '[ �21 s �� . / � A M Y L X � ...�.� ' � 0n!6 �. � . . _ .R P y� 4 � � � � � ,.0� .. � � � � � � � �� *r � � . a8 . t : i � - ; . � � k� �. �r� •„_ _ f k�.: t . /I j l.�L:�Ye • i : . ... . ' r�` � �4 N �[ T �: - � !' . )f . • 1 ♦ SJ� ry.� ! � ` ' . � .1'[ � � �f�`i :� . � ^ u�iR � a� � .jeyT- � " ��1II� ,.��,s�i��,��: , � �4, 4 i ,4� , � u �. • � • _` .:e tljyl � � IqYY� ii'.��' . � f.� ' E � 1� � � I�}I . e V11�� 4 � � � � � . e • � f�l�� 1� � ,� �� Ty � �� ua _ �. ��r�l ��6 � '�\ ` �� w i�.i��a�Y^Ai' ._ . � ... . � T 1 � u Drilling Bella Romero : Children at Risk in Greeley, Colorado June 21 , 2016 / 2 Comments / in Artides, Colorado, Environmental Justice, Permits / by Kirk Jalbert, PhD, M FA ey KirkJalbert, Manage� ofCommuniry eased Research & Engagement Kyle Ferrar, Western P�ogram Coordinator 1 of 1 + 6/29/ 168:�0AM Drilling Bella Romcro: Children at Risk in Greeley, Colorado file:/pUscrs/Anne/Desktop/Drilling Bella Romero_ Children a[ Risk ... Weld County, Colorado, is one of the top producing shale oil and gas regions in the United States, boasting more than 12,000 active horizontal or directional wells, which account for 50% of all horizontal or directional wells in the state. To put this into perspective, the entire state of Pennsylvania has ten times the land area with "only' 9,663 horizontal or directional wells. At the center of Weld Counry is the ciry of Greeley, population 92,889. Greeley has experienced dramatic changes in the past decade as extraction companies compete to acquire oil and gas mineral rights. Extensive housing developments on the outskirts of the city are being built to accommodate future well pads on neighboring lots. Meanwhile, a number of massive well pads are proposed within or on the border of city limits. FracTracker visited Colorado back in November 2015 and met with regional advocacy organizations including Coloradans Against Fracking fhttp://coloradansa�ainstFrackinQ.us/1 , Protect our Loveland fhttps://www.facebook.com/ProtectOurLoveland/1 , Weld Air and Water fhttps://weldairandwater.org/1 , and Our Longmont fhttp://ourlongmont.orgQ to determine how we could assist with data analysis, mapping, and digital storytelling. FracTracker returned in June 2016 to explore conditions unique to Weld County's oil and gas fields. During our visit we interviewed residents of Greeley and found that one of their greatest concerns was the dangers of siting oil and gas wells near schools. While there is much more we wili be pubiishing in coming weeks about our visit, this article focuses on one troubling project that would bring gas drilling to within 1 ,300ft of a public school. The proposal goes before the Weld Counry Commissioners on Wednesday, June 29th for final approval . As such, we will be brief in pointing out what is at stake in siting industrial oil and gas facilities near schools in Colorado and why residents of Greeley have cause for concern. Drilling Bella Romero On June 7th, the Weid County Planning Commission unanimously approved a proposal from Denver-based Extraction Oil & Gas to develop "Vetting 15H"—a 2of 13 6/29/ 16R:�0AM Drilling Bcllx Romcro: ('hildren at Risk in Grecle}�. Colorado �ilc:///Users/AnnelDesktoplDrilling Bella k�imcru_ ('hildren al Risk ... 24-head directional well pad in close proximity to Bella Romero Academy, a middle school just outside Greeley city limits. In addition to the 24-head well pad would be a battery of wastewater tanks, separators, and vapor recovery units on an adjacent lot. The permit submitted to the Colorado Oil & Gas Conservation Commission (COGCC) aiso states that six more wells may be drilled on the site in the future. f https://www.fractra c ker.o rg/a5ej 20sjfwe/wp-co nte nt/up I oa d s/2016/06 /bella romero school. ioel As was detailed in a recent FracTracker article fhttps://www.fractracker.org/2016/04 /colorado-setbacks-one-step-forwardll , Colorado regulations require a minimum setback distance of 500ft from buildings and an additional 350ft from outdoor recreational areas. In more populated areas, or where a well pad would be within 1 ,000ft of high occupancy buildings, schools, and hospitals, drilling companies must apply for special variances to minimize community impacts. Setbacks are measured from the well head to the nearest wall of the building. For well pads with mu�tipie heads, each well must comply with the respective setback requirements. ,� �a;�.. � i : : ; - . .� r .'... t _ .- , �, .• -, : . . � � . .L �,y� ' �� i �. �y, . � ,;. � � �� :. � � , , �'T"r ��'` f . x.'+�;_.�> � � . . ,. .ri�l,,.+-��-- .�.. .fb • ' � �� i � . �. � � � ' ,' , . . .. . ' . . . i $ ��' � i ' � � , . �� . 1. ) . �. i i � , i, � �_ �...' . . -... . � - - - . Y/ T�'/ . . . . � �_i"��. R. _.�- _. ' �i . � . . . y` �}� y�. lY • \ N�1 .. ; n '��6 �'.WMak'\��.! y '}.v� ^�' � . . _ . . ... '. . .. .. . �s . 0 _ �.afV[k111H'i^��w'3�li31a1$ti�apMiw') . . � . .. .. )Y•-• 51! _ � .jwv . [https://www. fracfracke�.o�e/a5ei20si(we/wp-mnfenVuUloads/2016/06/bella romero olavzroundipel Bella Romero's playyround with Vettiny igN:c pro�sed si[e jvst beyond thefence. Vetting 15H would prove to be one of the larger well pads in the county. And while its well heads remain just beyond the 1 ,000ft setback requirement from Bella Romero buildings, a significant portion of the school's bailfields are within 1 ,000ft of ihe proposed site. When setbacks for the well pad and the processing facility are taken together—something not explicitly demonstrated in the permit—almost the entirety 3 0l' I �3 6/29/ 16 R:50 AM Driiling Bel la Romero: Children at Risk in Greeley, Colorado filc:///Uscrs/Anne/Desktop/Drill ine Bel la Romero_ Children at Risk ... of school rounds are within 1 ,000ft and the school itself lies onl 1 ,300ft from the g Y ad. The below fi ures show the ima es su lied b Extraction Oil in p g g pp y & Gas their permit as well as a more detailed graphic generated by FracTracker. _ .._ �,.� ,, , , "�N ° . r;�. . �� ? r�y�i. 6 � �� .w 'iM'`�n �'�, �i.��.. �. • ` �� . � �i �' � � . � J' S r.Q� �" ^ $ , � �.', �. . -� , , . � �ii � 'v'z@9ti�. ✓��p '� � . �� '�� 4 � " �' « ' � ' � . .. .,.��.. .. .t _ ' �� T� � •�J� rt � � � _ r � �� 'St,i '�4 � . � ' ' _.__ .: ' _ . .._- t tl � . . ��<. . . . . � . , ! ._ ,� . ., .. � fhttps�//www fractracker orgfhttps//www fractracker orgfhttps//www fractracker org /a5ei20sifwe/wp-content /a5ej20sjfwe/wp-content /a5ej20sifwe/wp-content /uploads/2016/06 /uploads/2016/06 /uploads/2016/06 /bella romero wellpad_ /bella romero facility setbadt�lla romero Setbacks- setbacks-788x1030. onal 790x1030. n�l FT-1030x79�i,jo 1 Youth : A High Risk Population The difference between 1 ,000ft and 1 ,300ft may be negligible when considering the risks of lo a ing industrial scale oil and gas facilities near po�� lated areas fhttp://ehp. niehs. nih .Qov/1 5- 1 0 547/1 . The COGCC has issued 1 ,262 regulatory violations to drilling companies since 2010 ( Extraction Oil & Gas ranks 515t of 305 operators in the state for number of violations). Some of ihese violations are for minor infractions such as failing to file proper paperwork. Others are for major incidents; these issues most often occur during the construction phases of drilling, where a number have resulted in explosions and emer�encv evacuations Ihttp://www.denverpost.com/2014/03/04/oil-and-sas-explosion-north-of-ereelek results-in-two-minor-injuries/1 . Toxic releases of air fhttp://www.greeleytribune.com Laews/b �siness/11343354- 113/gas-methane-oil-emiscionci and water �ollution [http://kfor.com/2016/03/08/more-than-700000-ea Ilons-of-oi I-waste-wate r-soi I I ed- 4of 14 6/29/ I68:S0AM Drilling Bella Romero: Children at Risk in Greeley, Colorado file:/UUsers/Anne/Desktop/Drilling Bella Romero_ Children at Risk ... in-grant-countvl are not uncommon at these sites. In fact, ihe permit shows drainage and potential spills from the site would flow directly towards Bella Romero school grounds as is shown in the figure below. ' I : . � i , V N = _ ' . S�_' ' _T.y+i<�.a..c:" _ _ _ ___ ___ _ " _ :' . � > � = �' = S z r �' , _ � � � � �'�._ ��'� � � " �� r , > � ' t � � � / ,.., . ,. . .. .� � � � 4.. �. .�. . .. . . . y— ��r� � ��.' � i I . . . e�vx.p a '. ' • l t r �, ,w � . � � ,�'f �� ..w "°a �� .�E �� r �ue.�i+ci �m.w � cvruc a} , . � _• LEGENO }� �� O ' , � B I Rinl � _ _ - :,�.�x.w�� @ ,Q , �� ..w.rew.o�. .. I b 36j� . . . -a�C(49EOWXACQ�M 'i I � V[� a•�. � � ��•. • .> . . aYUYO1�fI1fYRpP � � a ♦ f : Ji �M eY] ��[1sqWplGplfqq a �—I {4�_ � 6N 'OJ, ] ]) _• ..r:5rMGWL'�IWfOIf � . vM Vcttiny �gH post-development drainaye mup. A host of recent research suggests that people in close proximiry to oil and gas wells experience disproportionate heaith impacts. Emissions from diesel engine exhaust contribute to excessive Ievels of particular matter, and fumes from separators generate high levels of volatile organic compounds. These pollutants decrease lung capacity and increase the likelihood of asthma attacks, cardiovascular disease, and cancer (read more on that issue here fhttps://www1 .villanova.edu/content /dam/villanova/sustainabilitv/McD-LFrackingEnvironmentHealth. pdfl ). Exposure to oil and gas facilities is also linked to skin rashes and nose bleeds fhttp://www. usnews.com/news/articles/2014/09/10/respiratory-ski n-problems- s o a r-n e a r-ga s-we I I s-st�dy-�. As we've mentioned in our analysis of oil and gas drilling near schools in California Sof 1 -1 6/29/ 168:S0AM Dril�ing Bella Romero: Children at Risk in Greeley, Colorado file:///llsers/Anne/Desktop/Drilling Rella Romero_ Children a[ Risk ... fhttps://www.fractracker.org/2014/11 /caschooldemos stimswells ejl . children are more vulnerabie to these pollutants. The same amount of contaminants entering a child's body, as opposed to an adult body, can be far more toxic due to differences in body size and respiratory rates. A child's developing endocrine system and neural pathways are also more susceptible to chemical interactions. These risks are increased by children's lifestyles, as they tend to spend more hours playing outdoors than adults and, when at school, the rest of their day is spent at a central location. At the June 7th public hearing Extraction Oil & Gas noted that they intend to use pipelines instead of trucks to transport water and gas to and from Vetting 15H to reduce possible exposures. But, as residents of Greeley noted of other projects where similar promises were made and later rescinded, this is dependent on additional approvals for pipelines. Extraction Oil & Gas also said they would use electric drilling techniques rather than diesel engines, but this would not eliminate the need for an estimated 22,000 trucking runs over 520 days of construction . Below is a tabie from the Vetting 15H permit that shows daily anticipated truck traffic associated with each phase of drilling. The estimated duration and operational hours of each activity are based on only 12 wells since construction is planned in two phases of 12 wells at a time. These numbers do not account for the trucking of water for completions activities, however. The figures could be much higher if pipelines are not approved, as well as if long-term trucking activities needed to maintain the site are included in the estimates. _ -- --- - — - ,, i Daily Vehicle ActNfty Trlps Construction 8 ' _ I Drilling Compledons Flowback � Production - *- - -- --- �— Approximate Duratlon l 150 days ;. 50 day_s _ 60 da s On 'n Operating Hours _ _ _ 24 hours _ 24 hours _ � 24 hours _ 24 hours _� Trucka 20 100 50 15 Supervisors 15 4 20 3 ConVact Employeea ' 20 ; 4 20 5 Vetting �SH daily uehicleesfimatesfrom permit 6 of 14 6/29/16 5:50 AM Drilling Bclla Romero: Children at Risk in Greeley, Colorado file:///Users/Anne/Desktop/Drilling Bella Romero_ Children at Risk ... At the Top of the Most Vulnerable List Bella Romero Academy has the unfortunate distinction of being one of the few schools in Colorado in close proximiry to a horizontal or directional well amongst 1 ,750 public and 90 private schools in the state. Based on our analysis, there are six public schools within 1 ,OOOft of a horizontal or directional well . At 2,500ft we found 39 public schoois and five private schools. Bella Romero is presently at the top of the list of all schools when ranked by number of well heads located within a 1 ,OOOft buffer. An 8-head well pad is only 800ft across the street from its front door. If the Vetting 15H 24-head well pad was to be constructed, Bella Romero would be far and above the most vulnerable school within 1 ,OOOft of a well. It would also rank 3rd in the state for weil heads located within 2,SOOft of a schooi. The tables below summarize our findings of this proximity analysis. sa� ora� cn.w .�o wr. BellaXomemElementa Xhool Grreley6 Presc�oel � SMGaEe N CUETTEl3040d6 & 65N65W1O5W5W 8 CwINqeMidEleXtrool StVrainValle NeL 6tM1Grade � Bt� Gnde N WRNDEll2N6JW/JSWNW J PnirieNid Ekmenb Schod StVninValleyReL PresclwoL5MGotle N WRNOEL463N6]W ]SWNE 2 AlverCrcek Elementary Adams ll Fve Sur Xhooli I(inCer artm - SN GnEe N NORTH COIORAD0�61S68W 13NENW 1 ImaineCharter 5[ VolnValle MeL Presc�ool � BMGraEe Y BORGMANNII-62N6BWISE5 1 leatyElementary5cM1ool SlVrainValleypeL Prescho01 � 5MGptle N GNANTBROTHENS�63N68W265ENE 1 (httos.Y/www.fractrackecore/a5ei20si(we/wo-contenUuoloads/2076/06/CO oublic 1000h.ioel Colorada pubfic schoo(s within �,000f[ of a horuon[al or direc[ional wefl faea o�o+n .�o WinJswC�anerKatr WiWmrPea [inCr�Rene^ P:nGeaM Y Greel O✓ea�o'�:� & 39} VfMiURf5V.�OCN�ll 66 GevqVai Far C�iIE1ao� CenhrBN � Ylwoi Gar'e�Clu ReuM1m� - Tn �raOe Y 06V >4� S� GrEinllCommumry CNr1aX�ad WeIECou+ryAe31 XinJr. rten gmG�aOe Y YnneOe. r] n>Ol� ]09XN6Mum ka(e36RVM6 MI CWIR MIWkkMd Av�amVtlie NeL 6hGraEe BnGnEe N WanGei� >r..916: 6WANC[LllN6]V//JSWMW IS PmrcerR eflemema YAopl 1m+s:v.vnM.A�kenPeL R�.+4e� artm � 5mLMe H FyvnE�Marps�'�pMuinWellcap 15 8lI1i110mlNEIlmin YIIMI Grte4Y6 Grex�W! . SI�GpOe X 4UfRFll� i�d56h5N65WIG$WSW ! FronlYrCNnM Gr¢Ykv6 xmyr r[en � 12MGraEe v yGL6SN61W }�SENW ! MeM MMUk NMwI L Mea] Flememary XM1aal SNr�m Vaiie Ne ll 6�� GuOe � Bro GraG N 5(a:e 5EN� 1U 16N I fiB >M > PraneRM Llemmfa X�od SlVtynValleYPeL >reu�cai . 50G�We X W4N�P.L )46JW�)N(Y! 1 VmeMmcPEamem� 6NaTWlb MIEEI¢5�woi WeW (eunt Pe-1 P�e¢nmi . 5MGnJe N I�SaIrtP�rnona. o�mr¢ i 6 LWS� IMnM�EEieXnwi Wr41E16 b�euoh 9vnGaEe N iiopiryLeR%W3aNWNW 5 [https://www.fractracker.or2/a5ei20sihve/wp-mntenduploads/1076/06/CO_public_2500Ripz1 Colorudo puhlic schools wi[hin z,5ooJi of a horizontnl or directiona/ well with 5 or more well heads. There are 39 schools in mta( xhool oiserke v�o w.as Plaza Del Mila ro Greele Kinder arten Greele Directional 52 Childreds House Of Weld Cty St Vrain Valley RE L Elementary lillson-Eas[ Rinn 22H-M268 SO Faith Preschool Eaton REQ Kindergarten Alm 33V-HZ NORTH & SOUTH 8 Triniry Wtheran School Greele 6 Elemenca SEGL-65N66W 245ENW 4 Montessori Academy Boulder ValleV R62 Kindergarten YOUNG MC 26-OSD 1 7of I -1 6/29/ 168:S0AM Drilling Bella Romero: Children at Risk in Greeley, Colorado file:///Users/Anne/Desktop/Drilling Bella Romero_ Children at Risk ... 1 rinity Lutheran School Greeley b Elementary SELL-55NbbW Z4SENW 4 Montessori Academy Boulder Valley RE -2 Kindergarten YOUNG MC 26-05D 1 /https://www.fractracker.org/a5e/20s/fwe/wp-content/uploads/2016/06/CO private 2500f ./pgj Colorado private schools within 2,5ooft of a horizontal or directional well The following interactive map shows which schools in Colorado are within a range of 2,500ft from a directional and horizontal well. Additional buffer rings show 1,000ft and 500ft buffers for comparison. 1,000ft was selected as this is the minimum distance required by Colorado regulations from densely populated areas and schools without requiring special variances. Environmental advocacy groups http://coloradansagainstfracking.usi are presently working to change this number to 2,500ft. The map is zoomed in to show the area around Bella Romero. Zoom out see additional schools and click on features to see more details. [NOTE: The Colorado school dataset lists Bella Romero Academy as an elementary/middle school. Bella Romero was recently split, with the elementary school moving a few blocks west] Map of schools and setbacks in Colorado 8 of 14 6/29/16 8:50 AM Drillim_ Hclla Komera Children a[ Risk in Greeley, Colorado fileJ//Users/Annc/Desktop/Drilling Rclla Romero_ Children at Risk ... � a -' ' 1a . vc ...c ` . 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'V�� . . _ ._ ��s�aY.+3�4 � � . . ' 3 . r � _� _ View map full screen /http://maps. fractracker. or�/latest /?ap,oid=09c5d6962f214ddd81a47f3b84a8cZacl / How FracTracker maps work �https://www. fractracker. o�g/resources/how-fractracker-works/7 Environmental Injustice Drilling near Bella Romero is also arguably an environmental justice issue, as its student population has some of the highest minoriry rates in the county and are 9of I -1 6/29/ 16R:SOAM Drilling Bella Romero: Children at Risk in Greeley, Colorado file:///Users/Anne/Desktop/Drilling Bella Romero_ Children al Risk ... amongst the poorest. According to coloradoschoolgrades.com, fhttp://www.coloradoschoolgrades.com/SchoolReportCard.aspx?sid=0054M1 Bella Romero is 89% Hispanic or Latino and 3% African American whereas, according to the U .5. Census Bureau �http://www.census.gov/quickfacts/table/PST045215 /0832155/accessiblel . Greeley as a whole is 59% White and 36% Hispanic or Latino . 92% of Bella Romero's students are also from low income families. Furthermore, according to the EPA's Environmental Justice Screening Tool fhttos://www.eoa.eov /eiscreenl , which is used by the agency to assess high risk pop� lations and environments, the community surrounding Belia Romero is within the 90-95% percentile range nationafly for linguistically isolated communities. . ,- � . , y , �� . . � �, ,` , �� s: , „ �, — � - _ — � . , `�r. - r � '�`�?� ... r � ""m • ' " � .� e . � � �. . . i , �� l , � . , ' .< �.. ,� . .. '.--• � � ---_ _ - -` . . , .. .: �. ' ' =tz. a. _ � °! . . ;r �' ¢" . 4�, � '. —, �-- �� V��y� i.. � � ,' • � � �. t^/f"S n y _ ., I �1 ."� � � ` .:> �°ts 1�1, � Y�� . . � � . � , ' . .. + � � � ' � . f` �. � �rr �:_.�1 5 , ,'�: � :. ;-.. 1 f. : ' > , ��A,. . -, j� •y�'� �x � ,: �. ' �� ' f ¢ �� lvJ� �� Y � i . , ` — � �� rY � f 1 '�'�� _; - • ? r e �y . '�£� ` ''' I� .` �♦ '.i Y� 2 �� l'� f � � i � � � � � � �� l i . l f � � + � . �"r s� j� t, i kr . . . . � ,�- � , ni t''. . � . . �'.�� LC�s://www.f�acfrackecore/a5ej20si(we/wp-contenf/u�loads2076/06/bella romero Craileroarkipel Many of Bellu Romero's shidents come from (ow-incrome communi[ies surrounding Greeley. Implications These statistics are significant for a number of reasons. Firstly, oil and gas permitting in Colorado only requires operators to notify residents immediately surrounding proposed well pads. This rule does not include residents who may live further from the site but send their students to schools like Bella Romero. Parents who might comment on the project would need to hear about it from local papers or neighbors, but language barriers can prevent this from occurring. Another factor we witnessed 10 of 14 6/29/16 5:50 AM Drilling Rella Romero: Children at liisk in Grecley, Coloradu filc:/UUsers/Anne/DesktopNrilling Bclla Romero_ Children at Risk ... in our June visit to Latino communities in Weld Counry is that many students have undocumented family members who are hesitant to speak out in public, leaving them with no voice to question risks to their children . ,. - .,,, . , - r.-:,:- � .. � ; ;, � ;:; , : . ,, d ,�� , { Y � �N� • � .��ti � . . � ._.... - ..�... ��.� ' � � � �. e ' � . / . i.. � � , .. /httas://www.fiacrracker.ore/a5eiZOsi(we/wp-mnten�vt�/oads/7076/06/bella romero hearinz.ipz7 Residerus ofGree(ey speakoutat theJune7th Plunniny Cammission mee[iny Nevertheless, at the June 7th Planning Commission hearing, Weld County administrators insisted that their decisions would not take race and poverty into consideration, which is a blatant disregard for EPA guidelines fhttps://www.e�a.gov /environmentaliusticel in siting industrial development in poor minoriry communities. Weld Counrys Planning Commission claimed that their ruling on the site would be the same regardless of the school's demographics. By comparison, another proposed Extraction Oil & Gas site [http://www.Qreelevtribune.com/news/20220469- 113/oil-company-appeals-greelev- plannina-commissions-denial-ofl that would have brought a 22-head well pad to within 1 ,000ft of homes in a more well off part of town was denied on a 0-6 vote by I I of Id 6/29/168:S0AM Drilling Rclla Romaro: Children ��t Kisk in Greele��, Coloradu filrl//Uscrs/AnnelDesktop/llrilling I3clla Romero_ Children at Rick _. the City of Greeleys Pianning Commission earlier this year after nearby residents voiced concerns about the potential impacts. Extraction Oil & Gas appealed the ruling and Greeley City Council passed the proposal in a 5-2 vote pending additional urban mitigation area permit approval . While the Greeley Planning Commission and the Weld County Planning Commission are distinct entities, the contrast of ihese two decisions should emphasize concerns about fair treatment. Conclusion There are very real health concerns associated with siting oil and gas wells near schools. When evaluating this project, county administrators should assess not only the immediate impacts of constructing the well pad but also the long-term effects of allowing an industrial facility to operate so close to a sensitive youth population . There are obvious environmental justice issues at stake, as well . Public institutions have a responsibiliry to proted marginalized communities such as those who send their children to Bella Romero. Finally, approving the Vetting 15H project would place Bella Romero far at the top of the list for schools in Colorado within 1 ,000ft of oil and gas wells. School board administrators should be concerned about this activiry, as it will undoubtedly put their students' health and academic performance at risk. We hope that, when the County Commissions review the proposal, these concerns wili be taken into account. Tags: S.Q, Colorado• environmental justice, p�p1j�, ro� ximit_v. r�ulation• �, schools Snare this entry ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ 12 0( 14 6/29/ 16 S:S0 AM Comments in Opposition to the Vetting Facility East of Cherry Avenue and North of East 24th Street. 0S/20/2016 '�, EXTRACTION OIL 8 GAS ; qtyssa �I (720) 481 - � �N 0 6/1 012 0 1 I, New �e� � 6 SENW 15 SN 65 06/10/2016 �'�.. LLC �I qndrews p37g '� PROCESS 6 ' Location Fa� Acres � W . 10459 I 1401051216 I i ; � .. 1. Traffic: Those of us who live close to this site are concerned about the amount of large truck traffic that will be created on Cherry Avenue. This is a main access road to the school and there are often �hildren walking to school during the school year, families walking with children in the evenings and days when school is not in session, parents driving children to school, school buses, horses being ridden and driven in training, people walking their dogs, etc. This is part of what makes this a nice neighborhood area and people feel safe, even , though Cherry has no sidewalks, as it is just outside the city limits. 2 . Noise, Air Quality/Odor, Dust, Pollution, and Lighting : We are also concerned about our property values going down with so many wells so close to our homes. For 2 years there will be a great deal of noise, odor (we have just learned that they will be using oil base drilling fluid ), and pollution . This pollution will be a danger to young, developing lungs and to those of us who must live with it 24/7. The high power lights are on all night and will make it difficult for those of us near this facility to sleep at night. 3 . Size: The size of this project is ridiculous in this area, 24 wells, 18 oil tanks, 2 water tanks, 24 separators, 2 meter houses, 4 vapor recovery units, 8 emission control devices and 2 vapor recovery towers on 6 acres in an R- 1 zones residential neighborhood . 4. Notification : The notification they sent of a neighborhood meeting was only sent to those who lived within 500' of the wells, and the school was not notified until school was out for the summer, so NO parents of Bella Romero students received notification of this monstrous project. In my experience Extraction Oil and Gas has not been honest with us. They stated it was too expensive to apply for a driveway exit onto Highway 34 Business (east iSth Street) but that they were waiting to hear back from CDOT if they could use that exit point. When I spoke to Gloria at CDOT she said they had communicated with her by email but had not yet submitted an application for a drive exit onto 34 Business, the cost of which is $ 100. They also stated that they had shareholders in the ditch that were willing to lease them water and that they have CBT (Colorado Big Thompson ) water they could run in the ditch so that they would not need to truck in water. After consulting with one of our more experienced Directors on the Greeley Irrigation Company ditch board, of which I am also a Director, he said "GIC shareholders cannot lease them their GIC shares, not legally decreed for that use. Nobody can deliver foreign waters wch as CBT in the ditch either without an agreement , from the GIC Board either" . So far, they have not presented any requests to the Board . It is my impression that the Extraction representatives are not to be trusted and anything they say should be taken with a grain of salt. Barbara Flores 2045 Cherry Avenue Greeley, CO 80631-6122 �(/��Q� (970)302-0766 � , _ �_ Hello