NRDC Issue BRIEF december 2014 ip:14-10-a Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Just off Interstate Highway 25, Drill Rig in front of homes in the town of Frederick in Weld County, Colorado. Pipes, vehicles and storage tanks also stand in front of homes as hazy, snow capped Rocky Mountains stand in the background. Tanja Srebotnjak Miriam Rotkin-Ellman Natural Resources Defense Council Introduction H ydraulic fracturing (‘fracking’) and other well stimulation methods have led to a rapid expansion of oil and gas development in the United States.1 This expansion has brought oil and gas development closer to backyards and communities and increased the potential for human exposure to new contaminants and threats. At the same time, a growing body of new research points to health threats from unconventional oil and gas development and fracking in particular. Although health discussions, particularly in eastern states, have focused on drinking water contamination, there is mounting evidence for a range of health threats from air pollution as well. For example, research has linked pollution from fracking to unhealthy levels of smog and of toxic air contaminants. Exposure to this pollution can cause eye, nose, and throat irritation, respiratory illnesses, central nervous system damage, birth defects, cancer, or premature death.2 At the same time, the oil and gas industry has been exempted from many regulations that limit air pollution from industrial activity.3 At the federal level, the Environmental Protection Agency (EPA) recently issued new standards to limit harmful air pollution from the oil and gas industry—but these still contain major gaps.4 Health protective regulations are also hampered by lack of scientific data on the potential cumulative risks posed by the combined emissions from a dense network of wells and associated infrastructure such as pipelines, compressor stations, and roads. State regulations are patchy and enforcement often cannot keep up with the industry’s rapid expansion, resulting in insufficient protection from air pollutants. Health studies find impacts from fracking-related air pollution Conventional oil and gas production has been known for some time to create harmful air emissions.5 With the increase in fracking activity, more and more studies now document emissions of airborne pollutants at and near fracking sites that are known to cause cancer and harm the nervous, respiratory, and immune systems (see Figure 1). At the same time, people and communities in areas with many hydraulically fractured wells report health problems consistent with these types of exposures.6,7,8,9,10 While it is difficult to measure actual exposures to pollutants from nearby fracking operations and establish clear links to adverse health outcomes, some studies found associations between air pollutants that are present at oil and gas production sites and health impacts observed in nearby communities.11,12 In Colorado, for example, an evaluation of birth defects in areas with high concentrations of oil and gas activity found that mothers who lived near many oil and gas wells were 30 percent more likely to have babies with heart defects.13 Similarly, preliminary results from a study in Pennsylvania show impacts among newborns that could be linked to air pollution such as increases in low birth weight.14 In many rural areas, the boom in oil and gas activity has been linked to unhealthy spikes in ozone concentrations.15 In 2008 and 2011, increased ozone concentrations in Wyoming’s Sublette County were associated with subsequent increases in outpatient clinic visits for respiratory problems.16 Researchers who looked at air pollution levels near fracking sites in Colorado also found an increased risk of chronic and sub-chronic effects mainly stemming from oil and gas related pollutants, which can harm the respiratory and neurological systems and lead to symptoms like shortness of breath, nosebleeds, headaches, dizziness, and chest tightness.17 Thus, while research into the health effects of air pollution from unconventional oil and gas development is ongoing, there is mounting evidence that it causes pollution, which can affect the health of workers and communities. PAGE 2 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Figure 1: Summary of major health effects associated with the release of airborne pollutants from fracking HEALTH THREATS FROM FRACKING-RELATED AIR POLLUTION GLOBAL EFFECTS Emissions of carbon dioxide and methane contribute to climate change. Methane warms the climate at least 80 times more than an equal amount of carbon dioxide over a 20-year period. ------------------------------- REGIONAL EFFECTS Nitrogen oxides and volatile organic compounds form ground-level ozone in the presence of sunlight, which can cause: Respiratory problems, including coughs, shortness of breath, airway and lung inflammation, decreased lung function, worsening of asthma and other respiratory diseases, increased hospital admissions, and premature mortality Cardiovascular effects, including cardiac arrhythmia, increased risk of heart disease, heart attacks, and stroke ------------------------------- LOCAL EFFECTS Exposure to diesel particulate matter, hydrogen sulfide, toxics, including benzene, toluene, ethylbenzene, and xylene, and other volatile hydrocarbons can lead to: Eye, nose, and throat irritation Respiratory problems, including cough, difficulty breathing, and worsening of asthma and other respiratory diseases Cardiovascular problems, including high blood pressure, heart attacks, and worsening of cardiac diseases Brain and nervous system problems, including headaches, lightheadedness, and disorientation Damage to the blood and bone marrow leading to anemia and immunological problems Reproductive system effects Effects on fetal and child development Cancer and premature mortality Sources: ATSDR factsheets on nitrogen oxides, benzene, toluene, ethylbenzene, and xylene. www.atsdr.cdc.gov/toxfaqs/Index.asp OEHHA factsheet on health effects of diesel particulate matter. oehha.ca.gov/public_info/facts/dieselfacts.html NIOSH pocket guide to chemical hazards: hydrogen sulfide. www.cdc.gov/niosh/npg/npgd0337.html US EPA on volatile organic compounds and ozone. www.epa.gov/groundlevelozone/basic.html PAGE 3 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Air Pollution from Fracking A comprehensive literature review identified 15 different oil and gas development processes and sources—including the drilling process, wastewater, and condensate tanks—that can release air contaminants (see Figure 2 in the Appendix).18 The authors conclude that “there is legitimate concern that local air pollution may produce adverse effects in individuals who live near the high emitting site or processes.” The rapid expansion of fracking, both in areas with existing oil and gas operations and previously undrilled areas, can lead to an increase in the type of pollution generally found at conventional oil and gas development and to other pollutants specific to fracking, such as silica sand, fracking chemicals, and flowback wastewater. Local Impacts Diesel Emissions Diesel emissions originate from the combustion engines of heavy trucks and machinery used during well site preparation, drilling, and production. Exhaust from diesel engines contains hundreds of toxic chemicals. Of greatest concern is the fine diesel soot particles, which can lodge deep within the lungs, increasing health risks including: emergency room visits, hospital admissions, asthma attacks, cardiopulmonary disease (including heart attack and stroke), respiratory disease, adverse birth outcomes, and premature death (from pneumonia, heart attack, stroke and lung cancer).19,20 Researchers are concerned about local residents’ increased risk of exposure to diesel exhaust.21 A study of regional air quality impacts from natural gas extraction in Pennsylvania’s Marcellus Shale included diesel emissions from truck traffic, well drilling and hydraulic fracturing, gas production, on-site combustion, and compressor stations in the monetary damage calculations.22 The National Institute for Occupational Safety and Health (NIOSH) expressed concern about the levels of diesel particulate matter measured at 11 oil and gas sites in Colorado, Arkansas, Pennsylvania, Texas, and North Dakota.23 Toxics Toxic air pollutants originate from direct and fugitive emissions of hydrocarbons at the well and from associated infrastructure such as condensate tanks, dehydrators, wastewater impoundment pits, and pipelines. The fracking process involves dozens of chemicals and the process returns oil, gas, fracking chemicals, formation brines, and mobilized compounds, including heavy metals and naturally occurring radioactive materials (NORM) to the surface. Hydrogen sulfide (H2S) is a toxic and explosive gas that may be present in oil and gas formations and is produced along with the hydrocarbons. It is damaging to the central nervous system and can be lethal at higher concentrations (~1000 ppm).24 While oil and gas workers may be required to wear protective respirators,25 no such protections are considered for surrounding communities. Benzene, toluene, ethylbenzene, and xylene (BTEX) and other toxic hydrocarbons, such as formaldehyde, released from oil and gas operations and equipment can lead to health impacts ranging from irritation of eyes, nose, mouth, and throat to aggravated asthma and other respiratory conditions, blood disorders, harm to the developing fetus, immune system-related diseases, and cancer (e.g., leukemia, nonHodgkins lymphoma). A study commissioned by the West Virginia Department of Environmental Protection found that, at many sites, a 625-feet distance from oil and gas activity—above the distances set by many states—still resulted in benzene concentrations above levels the Center for Disease Control and Prevention (CDC) considers “the minimum risk level for no health effects.”26 At least one of the BTEX compounds was found at all of the seven drilling sites examined. A health risk assessment in Colorado’s heavily drilled Garfield County identified many hydrocarbon pollutants (including trimethylbenzenes, aliphatic hydrocarbons, and xylenes) associated with adverse respiratory and neurological effects.27 It further found that concentrations of benzene, toluene, ethylbenzene, and xylene increased with proximity to the well site and were up to nine times higher during well completion than during well production. In tight gas fields in rural northeastern Utah, researchers estimated the total annual mass flux of volatile organic compounds (VOCs) from the surveyed gas fields to be equivalent to the emissions from 100 million cars.28 The benzene levels measured in this study also exceeded health standards set by the Agency for Toxic Substances Disease Registry (ATSDR) and the California Environmental Protection Agency (CalEPA) to protect against harm to the developing fetus, immune system and blood. Silica Silica—the main component of ‘frac sand’—is used widely and in large quantities to hold open the fractures created during the fracking process.29 Inhalation of respirable silica can cause silicosis, an irreversible lung disease,30 as well as lung cancer in miners, sandblasters, and foundry workers.31 Silica inhalation is now also recognized as an occupational health hazard among oil and gas workers. NIOSH researchers collected 111 personal breathing zone (PBZ) samples at 11 sites in 5 states. At each one, they found that full-shift samples exceeded occupational health criteria,32 in some cases by 10 times or more. This means that even if workers are properly using half-mask air-purifying respirators, they would not be sufficiently protected, because the measured concentrations exceed the masks’ maximum use concentration.33 PAGE 4 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Regional Pollution Ozone smog Fracking-related processes and other stages of the oil and gas production process release nitrogen oxides and VOCs, which react in the presence of sunlight to form ozone (‘smog’). Exposure to ozone is associated with a variety of respiratory and cardiovascular effects, including shortness of breath, reduced lung function, aggravated asthma and chronic respiratory disease symptoms, inflammatory processes, and premature death.34 A growing number of studies have attributed emissions of ozone precursors from rapidly growing oil and gas development35 to significantly elevated ozone concentrations in Wyoming,36 Colorado,37 Utah,38,39,40 Pennsylvania,41,42 Texas,43,44 and Oklahoma.45 In the study on Wyoming’s Sublette County, tight gas production activities caused winter ozone levels46 to spike above the EPA’s 8-hour ozone standard of 75 parts per billion 13 times between February 14 and March 15, 2011.47 In Utah’s Uintah Basin ambient 1-hour ozone levels exceeded 150 ppb—twice the federal standard.48 Workers Not Protected In addition to the community health concerns from fracking, worker safety at oil and gas production sites is also coming under increased scrutiny, in part because the oil and gas industry is one of the most dangerous occupational sectors in the country. According to statistics released by the Bureau of Labor Statistics there were 545 fatalities at U.S. oil fields between 2008 and 2012, of which 216 occurred in Texas.49 At this level, the industry’s fatality rate is 2.5 times higher than the accident-prone construction sector and more than 8 times higher than the industrial sector as a whole.50 A major contributing factor to the industry’s high fatality rate are traffic accidents, which also impact neighboring communities. On-site toxic exposures present another health hazard to oil and gas workers. In 2010, at least four worker deaths may be linked to chemical and petroleum vapor exposure at or near flowback tanks at oil well sites in North Dakota and Montana.51 Air samples collected by NIOSH in the personal breathing zone of workers at six flowback sites in Colorado and Wyoming identified benzene as the primary VOC of concern, especially near the hatches of the flowback tanks. Of the 17 samples, 15 met or exceeded the NIOSH Recommended Exposure Limit (REL) of 0.1 ppm.52 The unprotected inhalation of silica dust and diesel fumes also threatens worker health and may lead to cancers and other illnesses many years after exposure.53 Workers may even bring contaminated clothes and boots home, putting their families at risk. Current Policies and Regulations Provide Inadequate Health Protections The oil and gas industry enjoys numerous exemptions from parts of key environmental and health protection laws, including the Clean Air Act, the Clean Water Act, and Hazardous Waste Laws.54 These exemptions lead to weak regulations and inadequate monitoring for air pollutants and toxins from oil and gas facilities. As fracking and other extreme stimulation techniques move closer to towns and cities, this creates an information, legal, and regulatory vacuum that hampers communities’ knowledge of and ability to protect themselves from harmful oil- and gas-related emissions and associated health impacts. Faulty Inventories Underestimate Air Pollution State and federal inventories provide important information for tracking and regulating air emissions of greenhouse gases, VOCs, and other hazardous air pollutants. Recent research indicates that these inventories may significantly underestimate air pollution from the oil and gas sector for a variety of reasons, including data gaps, uncertainty in the efficiency of emissions control equipment, use of obsolete or unrealistic emissions factors, incomplete reporting by operators, and changes in industry practices. One investigation led by the National Oceanic and Atmospheric Administration (NOAA) in Colorado’s heavily drilled DenverJulesburg Basin concludes that the state inventory for total VOCs emitted by oil and gas activities—which contribute to ozone formation and cause local toxicity—may be too low by a factor of at least two and that benzene emissions are seven-fold higher than reported in the state inventory.55 An earlier systematic review of eleven “top-down” (starting with levels of pollutants in the atmosphere and attributing those emissions to sources) and a number of “bottom-up” (starting with measurement of a set of sources’ emissions and extrapolating to aggregate emissions) studies looking at methane emissions from the sector estimates that total U.S. methane emissions from all sources were 25 percent to 75 percent higher than the U.S. Greenhouse Gas Inventory estimates for 2011, and finds that oil and gas are important contributors to these unreported emissions.56 This review also concludes that a small number of “superemitters” could be responsible for a large fraction of the industry’s methane leakage that had not been accounted for in the Inventory. In sum, the studies strongly suggest that oil and gas development is making a larger contribution to climate change than previously thought and that inventories may underestimate other pollutants. PAGE 5 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Gaps in Federal Air Quality Regulations In 2012, EPA issued two urgently needed standards aimed at limiting dangerous air pollution from oil and gas operations, including gas wells that are hydraulically fractured.57 Although the rules are an improvement over the status quo, they fall short of the full level of health protection needed. The new rules, which are scheduled to take effect in 2015, will reduce well-site VOC emissions by 95 percent, but EPA monitoring will rely heavily on self-reported emissions data and the rules only apply to new gas wells and existing well sites will not be required to reduce pollution. In addition, the EPA still allows up to one ton of BTEX emissions from single glycol dehydrators per year.58 And EPA relied relied on an analysis of health risks that was based on inadequate, inaccurate and incomplete emission inventories, ommitted pollutants with adverse health effects, excluded several sources of pollution, and failed to protect the most vulnerable populations.59 The rules also fail to consider existing best practices that are already being deployed by many facilities to control pollution and prevent health impacts to surrounding communities. These technologies—such as improved efficiency, leak prevention systems, and emission controls— are readily available, feasible, and can even save the industry money.60 Lacking Enforcement Federal and state agencies in charge of monitoring and enforcing oil and gas regulations have been overwhelmed by the industry’s rapid growth. The Bureau of Land Management (BLM), charged with inspecting wells on federal lands and designating ‘high priority wells’ in need of greater environmental and groundwater protection, inspected only 40 percent of the 3,486 high priority wells between 2009 and 2012.61 State oil and gas regulators, environmental protection departments, and public health agencies are left to fill in the gaps created by inadequate and constrained federal regulatory oversight. The result is a patchwork of state regulations and a distribution of responsibilities that leaves many loopholes and is plagued by a lack of resources for adequate inspections and enforcement. The Pennsylvania Department of Environmental Protection (DEP), for example, inspected fewer than 14 percent of active wells62 and only 20 percent of producing wells in 2011.63 A report for Texas found that enforcement actions were brought on only 2 percent of 55,000 logged violations.64 There are no comprehensive national figures on enforcement in the oil and gas sector and state records are inconsistent in detail and accessibility.65 Companies are not mandated by federal regulations to disclose the identities or quantities of chemicals used during hydraulic fracturing operations on private or public lands. These chemicals can volatilize into the air from tanks and wastewater impoundments and contribute to air pollution. Some states have begun to set their own rules for chemical disclosure. Unfortunately, these laws often have shortcomings, including the non-disclosure of the composition of proprietary or “trade secret” fracking fluid products, insufficient penalties for reporting inaccurate or incomplete information, and allowances for afterthe-fact reporting.66 The industry-funded fracking fluid disclosure website FracFocus.org has been criticized in a review by researchers at Harvard Law School for inadequate transparency, accuracy, and user-friendliness.67 The researchers concluded that “FracFocus is not an acceptable regulatory compliance method for chemical disclosures,” but it is the official reporting site used by at least 11 states.68 These limitations leave lawmakers, regulators, public safety officers, and the public uninformed and ill-prepared to anticipate and respond to possible environmental and health hazards and emergencies associated with hydraulic fracturing fluids. Conclusions There is mounting evidence that air pollution from oil and gas operations threaten the health of nearby communities and immediate protections are needed. They should have the right to protect themselves by restricting or prohibiting these techniques within their jurisdictions. Where possible, ongoing unconventional oil and gas development should be put on hold to conduct comprehensive health assessments before determining whether or how these technologies should be allowed to proceed. In areas already bearing the brunt of fracking-related pollution and with no moratoria, strong safeguards are needed to control emissions and limit pollution. Recommendations The following is needed to ensure comprehensive health protections from air pollution: n P rotective standards at the federal and state level for communities and workers that ensure pollution controls including but not limited to: n R educed Emission Completions (REC), also known as “green completion,” to reduce methane and other VOC leaks for all wells, not only gas wells69 n Leak n A dvanced n R eduction n L imitations detection and repair (LDAR) programs technologies to control fugitive emissions of diesel particulate matter through the use of cleaner combustion engines and alternative fuel types on venting and flaring gas associated with oil production and ensuring that all gas is captured and sold or used on-site PAGE 6 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities n C omprehensive characterization of all pollution sources in unconventional oil and gas development and quantitative assessment of pollutants and emission rates through research and updated federal and state inventories n C losure n I mproved n R igorous air quality monitoring before, during, and after well development and around all sources n E xpansion of the federal and state ozone monitoring network to better characterize air quality in rural areas highly impacted by pollution from oil and gas development of regulatory loopholes in federal environmental programs to fill data gaps, increase transparency and oversight of the oil and gas industry and ensure public health protections scientific studies in regions with intensive oil and gas development examining the effects of air pollution on the health of the local population, including comprehensive health impact assessments prior to new site development and followed by ongoing evaluations.71 n I dentification and implementation of adequate and protective setback requirements to reduce the exposure of residents to intermittent and chronic levels of air pollutants and toxins70 What residents can do Residents can take the following actions to reduce their potential exposure to dangerous air pollutants: Get informed n L earn about possible pollution in your area: n V isit the U.S. EPA website for information on ozone and particulate levels n C ontact n V isit n F or your state environmental agency or health department for information on local monitoring for other air pollutants NRDC’s Don’t Get Fracked! Information Center to learn how to protect yourself and your family from pollution linked to hydraulic fracturing more information on specific oil and gas-related pollutants visit: n Benzene n Hydrogen sulfide (H2S) n Diesel n Other toxics n I f you are worried about health symptoms or impacts, make sure to see your doctor and consult healthcare providers knowledgeable about the health impacts of air pollution. More resources are available through the following organizations: n T he Pediatric Environmental Health Speciality Units (PEHSU) n A ssociation of Environmental Medicine Clinics Protect the most vulnerable n Y oung children, the elderly, and individuals with respiratory conditions (e.g., asthma) can be sensitive to lower levels of pollution and should avoid exercise or extended outdoor activity when odors are present or agency websites (EPA or state) indicate poor air quality. Take Action n I mprove n R eport spills and other environmental problems in your community n C onnect n S peak air quality monitoring in your community with your neighbors and set up a Citizen Science group up and organize your community’s defense n D emand stronger protections PAGE 7 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Appendix Figure 2: Major air pollutants and air toxics released during the different fracking process stages and sources of equipment LOCAL POLLUTION WELL SITE PREPARATION AND ROAD CONSTRUCTION TRUCKS AND HEAVY MACHINERY: diesel PM, NO x, CO 2, CO, BTEX, PAH, dust 2 REGIONAL POLLUTION GLOBAL POLLUTION WELL DRILLING, HYDRAULIC FRACTURING & WELL COMPLETION DRILLING: diesel PM, NO x, CO 2, CO, BTEX, PAH, CH 4 , volatile drilling mud fluids, and volatile hydrocarbons from drill cuttings HYDRAULIC FRACTURING: silica dust, volatile fracturing chemicals, BTEX, and other volatile hydrocarbons, PM, NO x, CO 2, CO FLOWBACK AND PRODUCED WATER: volatile fracturing fluids, BTEX, and other volatile hydrocarbons, H 2S 3 4 PRODUCTION PROCESSING & STORAGE PRODUCED WATER: BTEX, and other volatile hydrocarbons, H 2S GAS VENTING: CH 4, H 2S, BTEX, and other volatile hydrocarbons GAS FLARING/VENTING: CH 4, NO x, CO 2, CO, PM, H 2S, BTEX, and other volatile hydrocarbons SEPARATORS AND CONDENSATE TANKS: CH 4, BTEX, and other volatile hydrocarbons WORK-OVER AND MAINTENANCE: diesel PM, NO x, CO 2, CO, CH 4, BTEX, PAH, and other volatile hydrocarbons 5 TRANSMISSION COMPRESSORS: diesel PM, NO x, CO 2, CO, BTEX, PAH, and other volatile hydrocarbons 6 WELL ABANDONMENT & SITE REHABILITATION PIPELINES: CH 4, BTEX, and other volatile hydrocarbons TRUCKS AND HEAVY MACHINERY: diesel PM, NO x, CO 2, CO, BTEX, and PAH COMPRESSOR STATIONS: diesel PM, NO x, CO 2, CO, BTEX, PAH, and other volatile hydrocarbons ABANDONED / ORPHANED WELLS: CH 4 GAS VENTING: CH 4, H 2S, BTEX, and other volatile hydrocarbons Learn more at: nrdc.org/energy/gasdrilling BTEX: benzene, toluene, ethylbenzene, and xylene; CH4: methane; CO: carbon monoxide; CO2: carbon dioxide; H2S: hydrogen sulfide; NOx: nitrogen oxides; PAH: polycyclic aromatic hydrocarbons; PM: particulate matter PAGE 8 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Table 1: Characterization of the main sources of air pollution from oil and gas development according to well process stage Local Regional Greenhouse Gases Volatile Organic Compounds (VOCs) Particulate Matter (PM) Diesel PM PM10 BTEX PAH (incl. Naphthalene, Chlorobenzene, Phenol) Well site preparation (landscape clearing, soil movement, pipelines and other infrastructure) • • • • Well drilling, hydraulic fracturing and well completion (drill rig, drilling muds and cuttings, fracturing fluid mixing, water trucks, pumps, generators, flowback • • • • • • Well production (produced water, gas flaring/ venting, well maintenance work) • • • • • Processing and storage (gas venting, glycol dehydrators, separators, condensate tanks, compressors) • • • • • Transmission (compressors, gas venting, pipelines, tanker trucks • • • • • Well abandonment & site rehabilitation • • • • Emissions Source Other (incl. Formaldehyde, Ethylene glycol, Methanol) Global H2S Respirable silica VOCs NOx CH4 CO2 • • • • • • • • • • • • • • • • • • • • • • • • Sources: Adgate, J., Goldstein, B., and McKenzie, L. 2014. “Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development.” Environmental Science & Technology, doi: 10.1021/es404621d. Moore, Christopher W. et al. 2014. “Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical Review.” Environmental Science & Technology, 11. doi:dx.doi.org/10.1021/es4053472. Key: BTEX: benzene, toluene, ethylbenzene, xylene; CH4: methane; CO2: carbon dioxide; diesel PM: diesel particulate matter; H2S: hydrogen sulfide; NOx: nitrogen oxides; O3: ozone; PAH: polycyclic aromatic hydrocarbons; PM10: particulate matter of 10 micrometers or smaller in diameter. PAGE 9 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Table 2: Health impacts of the main air pollutants by target organ and system Pollutant Target organ/system Carcinogen Particulate Matter (PM) Diesel PM Respiratory system; Cardiovascular system PM10 and smaller Respiratory system; Cardiovascular system • Volatile Organic Compounds (VOCs) Benzene Immune system; Blood; Fetal development, Nervous System Toluene Brain and nervous system; Respiratory system; Fetal and child development; Reproductive system Ethylbenzene Fetal and child development; Liver; Kidney; Endocrine system; Auditory system Xylene Brain and nervous system; Fetal and child development Other VOCs (incl. Formaldehyde, Methanol) Immune system; Respiratory system; Brain and nervous system; Fetal and child development; Liver; Kidney; Endocrine system • • • Other Hydrogen sulfide (H2S) Respiratory system; Brain and nervous system; Gastrointestinal system NOx Respiratory system Ozone (O3) Respiratory system; Cardiovascular system Respirable Silica Respiratory system; Kidneys; Immune system PAHs (incl. Naphthalene) Immune system*, Reproductive system*; Brain and nervous system*; Developmental effects* • •** * in animal studies ** probable carcinogens are among the PAHs emitted at unconventional oil & gas sites Sources: Factsheet on the Health Effects of Diesel Exhaust. Available at http://oehha.ca.gov/public_info/facts/dieselfacts.html. U.S. EPA (1997). Health Effects of Particulate Matter. OAQPS Fact Sheet, July 17, 1997. Available at www.epa.gov/region7/air/quality/pmhealth.htm. OSHA (2014). Crystalline Silica, www.osha. gov/dsg/topics/silicacrystalline/health_effects_silica.html. ATSDR (2004). Interaction Profile For: Benzene, Toluene, Ethylbenzene, and Xylenes (BTEX). ATSDR (2007). Public Health Statement for Benzene. Available at www.atsdr.cdc.gov/phs/phs.asp?id=37&tid=14. ATSDR (2000). Public Health Statement for Toluene. Available at http://www.atsdr.cdc.gov/phs/phs.asp?id=159&tid=29. ATSDR (2010). Public Health Statement for Ethylbenzene. Available at www.atsdr.cdc.gov/ phs/phs.asp?id=381&tid=66. ATSDR (2007). Public Health Statement for Xylene. Available at www.atsdr.cdc.gov/phs/phs.asp?id=293&tid=53. Department of Health and Human Services, Centers for Disease Control, National Institute for Occupational Safety and Health. 2005. NIOSH Pocket Guide to Chemical Hazards: Benzene. 2005-149. National Institute for Occupational Safety and Health (NIOSH). www.cdc.gov/niosh/npg/npgd0049.html. Department of Health and Human Services, Centers for Disease Control, National Institute for Occupational Safety and Health. 2005. U.S. EPA. An Introduction to Indoor Air Quality. Volatile Organic Compounds. Available at www.epa.gov/iaq/voc.html. ATSDR (1995). Public Health Statement for Polycyclic Aromatic Hydrocarbons (PAHs). Available at www. atsdr.cdc.gov/phs/phs.asp?id=120&tid=25. U.S. EPA. NIOSH Pocket Guide to Chemical Hazards: Hydrogen Sulfide. 2005-149. National Institute for Occupational Safety and Health (NIOSH). www.cdc.gov/niosh/npg/npgd0337.html. ATSDR (2002). Factsheet on Nitrogen Oxides. California EPA, Office of Environmental Health Hazard Assessment (OEHHA). Health Effects of Ozone in the General Population. Available at www.epa.gov/apti/ozonehealth/population.html. Key: BTEX: benzene, toluene, ethylbenzene, xylene; CH4: methane; diesel PM: diesel particulate matter; H2S: hydrogen sulfide; NOx: nitrogen oxides; O3: ozone; PAH: polycyclic aromatic hydrocarbons; PM10: particulate matter of 10 micrometers or smaller in diameter. PAGE 10 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities Endnotes 1 U.S. Energy Information Administration, “Today in Energy. North America leads the World in Shale Gas Production,” www.eia.gov/todayinenergy/detail.cfm?id=13491 (accessed June 6, 2014). 20 John L. Adgate et al. “Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development," Environmental Science and Technology”, 2014 doi:10.1021/es404621d. 2 John L. Adgate et al. “Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development,” Environmental Science and Technology", 2014 doi:10.1021/es404621d). 21 Allen Robinson, “Air Pollutant Emissions from Shale Gas Development and Production,” Workshop presentation on the Health Impact Assessment of New Energy Sources: Shale, Institute of Medicine, April 30-May 1, 2012. 3 U.S. Government Accountability Office (GAO), “Unconventional Oil and Gas Development. Key Environmental and Public Health Requirements,” GAO-12-874. 22 Aviva Litovitz et al., “Estimation of Regional Air-Quality Damages from Marcellus Shale Natural Gas Extraction in Pennsylvania,” Environmental Research Letters, 8 (2013), doi:10.1088/1748-9326/8/1/014017. 4 The new rules still allow existing facilities to release up to 1 ton per year of the carcinogen benzene from large glycol dehydrators despite analysis showing that this could increase the cancer risk for neighboring communities. Existing facilities are also not required to upgrade their equipment to reduce emissions and protect public health. 23 Eric J. Esswein, Michael Breitenstein, John Snawder, “NIOSH Field Effort to Assess Chemical Exposures in Oil and Gas Workers: Health Hazards in Hydraulic Fracturing,” Workshop presentation on the Health Impact Assessment of New Energy Sources: Shale, Institute of Medicine, April 30-May 1, 2012. 5 U.S. Environmental Protection Agency, “Improving Air Quality in Your Community,” www.epa.gov/oaqps001/community/details/oil-gas_addl_ info.html (accessed September 3, 2014). 24 Ibid. [14]. 6 Elizabeth Ridlington, John Rumpler, “Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level”, Environment America Research & Policy Center and the Frontier Group, 2013. 7 Charles W. Schmidt, “Estimating Wastewater Impacts from Fracking,” Environmental Health Perspectives 121 (4) (2013): A117. doi:10.1289/ehp.121-a117. 8 Roxana Z. Witter et al., Potential Exposure-Related Human Health Effects of Oil and Gas Development: A Literature Review (20032008), White Paper, Denver, CO, 2008, docs.nrdc.org/health/files/ hea_08091702b.pdf (accessed August 21, 2014). 9 Roxana Z.Witter et al., Health Impact Assessment for Battlement Mesa, Garfield County Colorado, Aurora, CO, 2010, www.garfield-county. com/public-health/documents/1%20%20%20Complete%20HIA%20without%20Appendix%20D.pdf (accessed August 21, 2014). 10 Peter M. Rabinowitz et al. “Proximity to Natural Gas Wells and Reported Health Status: Results of a Household Survey in Washington County, Pennsylvania,” Environmental Health Perspectives, 2014, doi:http://dx.doi.org/10.1289/ehp.1307732. 25 Occupational Safety and Health Administration (OSHA), “Standards for Hydrogen Sulfide”, www.osha.gov/SLTC/hydrogensulfide/standards. html (accessed June 6, 2014). 26 West Virginia Department of Environmental Protection, Division of Air Quality, “Air, Noise, and Light Monitoring Results For Assessing Environmental Impacts of Horizontal Gas Well Drilling Operations (ETD‐10 Project),” Charleston, WV. 27 Ibid. [11]. 28 Ibid. [15]. 29 According to industry representatives, hydraulic fracturing companies use up to 10,000 tons of silica sand to hydraulically fracture a single well. See Kanika Sikka, Sneha Banerjee, “U.S. Silica Sees Sand Demand Piling up as Fracking Goes Super-Sized,” Reuters, September 19, 2014. www.reuters.com/article/2014/09/19/us-ussilica-demand-idUSKBN0HE12P20140919. 30 Long-term exposure can lead to chronic silicosis, while short-term exposure to very large amounts of silica can cause acute silicosis. 31 OSHA, “Silica, Crystalline,” www.osha.gov/dsg/topics/silicacrystalline/ (accessed September 4, 2014). 11 Lisa M. McKenzie et al., “Human Health Risk Assessment of Air Emissions from Development of Unconventional Natural Gas Resources,” Science of the Total Environment 424 (2012): 79–87, doi:10.1016/j.scitotenv.2012.02.018. 32 The criteria used in the study are the Occupational Safety and Health Administration calculated permissible exposure limit (PEL), the NIOSH recommended exposure limit (REL), or the threshold limit value (TLV) set by the American Conference of Industrial Hygienists (ACGIH). 12 Lisa M. McKenzie et al., “Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado,” Environmental Health Perspectives, (2014), doi:http://dx.doi.org/10.1289/ehp.1306722. 33 Eric J. Esswein et al., “Occupational Exposures to Respirable Crystalline Silica during Hydraulic Fracturing.” Journal of Occupational and Environmental Hygiene 10 (7) (2013): 347–56, doi:10.1080/15459624.201 3.788352. 13 Ibid. [12]. 14 John L. Adgate et al., “Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development,” Environmental Science & Technology, (2014), doi:10.1021/es404621d. 15 Detlev Helmig et al., “Highly Elevated Atmospheric Levels of Volatile Organic Compounds in the Uintah Basin, Utah.” Environmental Science & Technology, March 27, 2014. doi:10.1021/es405046r. 16 State of Wyoming Department of Health, “Associations of ShortTerm Exposure to Ozone and Respiratory Outpatient Clinic Visits — Sublette County, Wyoming, 2008–2011,” 2013, Cheyenne, WY. 34 US EPA, “Health Effects of Ozone in the General Population,” www. epa.gov/apti/ozonehealth/population.html (accessed June 13, 2014). 35 Christopher W. Moore et al., “Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical Review,” Environmental Science & Technology, 11 (2014), doi:dx.doi.org/10.1021/es4053472. 36 Wyoming Department of Environmental Quality. “WDEQ Winter Ozone Update,” Public Meeting, Pinedale, WY, March 22, 2011. 17 Ibid. [11]. 37 Gabrielle Pétron et al., “A New Look at Methane and Non-Methane Hydrocarbon Emissions from Oil and Natural Gas Operations in the Colorado Denver-Julesburg Basin,” Journal of Geophysical Research: Atmospheres (2014), doi: 10.1002/2013JD021272. 18 Ibid. [14]. 38 Ibid. [15]. 19 Seth B. Shonkoff et al. Environmental Public Health Dimensions of Shale and Tight Gas Development. Environmental Health Perspectives. (2014). 39 Seth Lyman, Howard Shorthill, “Final Report: 2013 Uintah Basin Winter Ozone & Air Quality Study,” CRD/9.273A, Vernal, UT: Utah State University, 2013. PAGE 11 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities 42 Anirban A. Roy et al., “Air Pollutant Emissions from the Development, Production, and Processing of Marcellus Shale Natural Gas,” Journal of the Air & Waste Management Association 64 (1) (2014): 19–37, doi:10.1080/10962247.2013.826151. 60 Susan Harvey, Vignesh Gowrishankar, Thomas Singer, “Leaking Profits: The U.S. Oil and Gas Industry Can Reduce Pollution, Conserve Resources, and Make Money by Preventing Methane Waste,” Natural Resources Defense Council, 2012, www.nrdc.org/energy/files/LeakingProfits-Report.pdf. ICF International, “Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries,” report prepared for Environmental Defense Fund, March 2014, www.edf.org/icf-methane-cost-curve-report (accessed September 4, 2014). US Government Accountability Office (GAO), “Opportunities Exist to Capture Vented and Flared Natural Gas, Which Would Increase Royalty Payments and Reduce Greenhouse Gases,” Washington D.C., 2010. 43 Susan Kemball-Cook et al., “Ozone Impacts of Natural Gas Development in the Haynesville Shale,” Environmental Science & Technology 44 (24) (2010): 9357–63, doi:10.1021/es1021137. 61 Associated Press, “4 in 10 higher risk wells aren’t inspected by feds,” 2014, bigstory.ap.org/article/4-10-higher-risk-wells-arent-inspected-feds-0 (accessed September 4, 2014). 44 Eduardo Olaguer “The Potential near-Source Ozone Impacts of Upstream Oil and Gas Industry Emissions,” Journal of the Air & Waste Management Association 62 (8) (2012): 966–77, doi:http://dx.doi.org/10.10 80/10962247.2012.688923. 62 An active well may not be producing continuously. 40 P.M. Edwards et al., “Ozone Photochemistry in an Oil and Natural Gas Extraction Region during Winter: Simulations of a Snow-Free Season in the Uintah Basin, Utah,” Amospheric Chemistry and Physics 13 (2013): 8955–71, doi:10.5194/acp-13-8955-2013. 41 Charles W. Schmidt “Blind Rush? Shale Gas Boom Proceeds amid Human Health Questions,” Environmental Health Perspectives, Spheres of Influence, 119 (8) (2011): A348–53. 45 A.S. Katzenstein et al., “Extensive Regional Atmospheric Hydrocarbon Pollution in the Southwestern United States.” Proceedings of the National Academy of Sciences 100 (21) (2003): 11975–79. 46 Winter time conditions such as snow cover and temperature inversions enhance the photochemical reaction of NOx and VOCs to ozone. 47 State of Wyoming Department of Health (2013), Associations of Short-Term Exposure to Ozone and Respiratory Outpatient Clinic Visits — Sublette County, Wyoming, 2008–2011. 48 Ibid. [15]. 49 Bureau of Labor Statistics, “Census of Fatal Occupational Injuries”, www.bls.gov/iif/oshcfoi1.htm (accessed June 6, 2014). 50 Ibid. [14]. 51 NIOSH, “Reports of Worker Fatalities during Flowback Operations,” blogpost, blogs.cdc.gov/niosh-science-blog/2014/05/19/flowback/ (accessed August 21, 2014). 52 Calculated as a full-shift Time Weighted Average (TWA). 53 Ibid. [33]. 54 Ibid. [3]. 55 Ibid. [37] 56 A.R. Brandt et al., “Methane Leaks from North American Natural Gas Systems,” Science 343 (6172) (2014): 733–35, doi:10.1126/science.1247045. 57 EPA, Regulatory Actions, “EPA Issues Final Air Rules for the Oil and Natural Gas Industry,” www.epa.gov/airquality/oilandgas/actions.html (accessed September 12, 2014). 58 Christopher Moore et al. “Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical Review,” Environmental Science & Technology, 11 (2014), doi:dx.doi.org/10.1021/es4053472. 59 Earthjustice, “Petition for Reconsideration of Oil and Natural Gas Sector: National Emission Standards for Hazardous Air Pollutants Reviews,” Final Rule, 77 Fed. Reg. 49,490 (Aug. 16, 2012), 40 C.F.R. Part 63, Subparts HH and HHH, Dkt. ID No. EPA-HQ-OAR-2010-0505, www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2010-0505-4591 (accessed August 8, 2014). 63 Earthworks, “Oil and Gas Enforcement: Inspections,” www.earthworksaction.org/issues/detail/pennsylvania_oil_gas_enforcement_inspections#.U5IlKChW6_Y (accessed June 6, 2014). 64 Ibid. [59]. 65 EnergyWire, “Overflow: Blowouts, Leaks and Spills from the Drilling Boom,” www.eenews.net/special_reports/overflow (accessed August 21, 2014). 66 Alexis L. Maule et al., “Disclosure of Hydraulic Fracturing Fluid Chemical Additives: Analysis of Regulations,” New Solutions: A Journal of Environmental and Occupational Health Policy: 23 (1) (2013): 167–87, doi:10.2190/NS.23.1.j. 67 Kate Konschnik, Margaret Holden, Alexa Shasteen, “Legal Fractures in Chemical Disclosure Laws: Why the Voluntary Chemical Disclosure Registry FracFocus Fails as a Regulatory Compliance Tool,” Harvard University, Harvard Law School, Environmental Law Program, blogs.law. harvard.edu/environmentallawprogram/files/2013/04/4-23-2013-LEGALFRACTURES.pdf (accessed August 21, 2014). 68 Ibid. [63]. 69 RECs and green completions refer to technologies that capture methane and other gases at the well head during and after well completion and avoid their release into the atmosphere. The NSPS of April 2014 state that owners and/or operators may use RECs or completion combustion devices, such as flaring, until January 1, 2015; as of January 1, 2015, owners and/or operators must use RECs and a completion combustion device. For more information on RECs, see EPA, “Reduced Emissions Completions for Hydraulically Fractured Natural Gas Wells,” a Lessons Learned from Natural Gas STAR Partners factsheet, 2011. 70 Such research could draw on findings from analyzing the dispersion of air pollution as a function of the distance from road traffic and consider data from the effects of new or existing setback rules in states with unconventional oil and gas development. 71 See, for example, the study being conducted by the Geisinger Health System in Pennsylvania: Geisinger Research, “Geisinger Leads Marcellus Shale Initiative Coalition Explores the Potential Health Effects of Natural Gas Mining in the Region,” Geisinger Research Connections Winter: 1–3, 2013. PAGE 12 Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities