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HomeMy WebLinkAboutMemo - Mail Packet - 5/5/2015 - Memorandum From Lucinda Smith Re: Oil And Gas Update1 Attachment 1. Summary of Legal Proceedings Related to Fort Collins Ballot Measure 2A December 2013– Colorado Oil and Gas Association (COGA) filed a civil suit against the City of Fort Collins in Larimer County District Court. COGA challenged the moratorium on the ground that that it is preempted by the state’s Oil and Gas Conservation Act (Act) and the regulations promulgated under the Act by the Colorado Oil and Gas Conservation Commission (Commission) and, therefore, the City does not have the legal authority to enforce the moratorium. February 2014 – The City filed a motion for summary judgment arguing that the moratorium is not preempted by the Act or the Commission’s regulations. Instead, it is a legitimate exercise of the City’ home rule land use powers, not a permanent ban, but a temporary moratorium reasonably necessary to allow time for the City to adequately study the impacts of fracking on human health and property values and to then adopt any needed regulations to address those impacts. COGA also filed a motion for summary judgment arguing that the moratorium is preempted by state law. August 7, 2014 – District Court Judge Gregory M. Lammons issued his order granting COGA’s motion for a summary judgment and denying the City’s motion for summary judgment. The Court declared that the five-year moratorium was impliedly preempted by and in operational conflict with the Act and the Commissions regulations promulgated under the Act.As a result of Judge Lammons’ order, the moratorium became unenforceable. October 2014 – The City asked Judge Lammons to stay the effect of his order pending the City’s appeal of his decision to the Colorado Court of Appeals. Judge denied the City’s request for a stay. The City then filed its appeal with the Court of Appeals. The City also asked the Court of Appeals to stay Judge Lammons’ decision pending the appeal, but the Court of Appeals denied this request too. In its appeal, the City asks the Court of Appeals to reverse the District Court’s decision on the primary grounds that the District Court erred in rulingthat the City’s moratorium is: (1) impliedly preempted by the Act and the Commission’s regulations, ; and (2) in operational conflict with the Act and the Commission’s regulations. February 2015 – The City filed its Opening Brief with the Court of Appeals. Amicus curiae briefs ("friend of the court" briefs) have also been filed with the Court in support of the City by the Colorado Municipal League, City of Boulder, Conservation Colorado, Citizens for a Healthy Fort Collins, Northwest Colorado Council of Governments (NWCCOG), Congressman Jared Polis and Boulder County. The Court of Appeals has approved the filing of these amicus curiae briefs. March 2015- COGA filed its Answer Brief with the Court of Appeals. Amicus curiae briefs were filed with the Court on behalf of COGA by the National Association of Royalty Owners, the American Petroleum Institute, Colorado Concern, Colorado Competitive Council, Denver Metro Chamber of Commerce, Colorado Motor Carriers Association, and the Colorado Farm Bureau. The Court has approved the filing of these amicus curiae briefs. 2 April 2015 – City filed its Reply Brief with the Court of Appeals. The City has also filed a request with the Court of Appeals asking it to hear oral argument in this appeal. The has not yet responded to the City’s request for oral argument. Future – Now that all the briefs have been filed, the Court of Appeals will decide whether to set this case for oral argument or to render its decision just on the parties’ briefs. The Court has no deadline by which it must issue its decision. The Court is, however, likely to issue its decision in the next four to nine months. FORT COLLINS MEMORANDUM 2A TECHNICAL SUPPORT DOCUMENT CITY OF FORT COLLINS PREPARED FOR: CITY OF FORT COLLINS, COLORADO PREPARED BY: TERRA MENTIS ENVIRONMENTAL CONSULTING, BOULDER, COLORADO FEBRUARY 2015 TERRA MENTIS FORT COLLINS MEMORANDUM 2A TECHNICAL SUPPORT DOCUMENT CITY OF FORT COLLINS TABLE OF CONTENTS 1. INTRODUCTION ................................................................................................................................ 1 2. RISK ASSESSMENT: A BASIS FOR DECISION MAKING ......................................................... 4 2.1 HAZARD IDENTIFICATION .................................................................................................................... 7 2.2 EXPOSURE ASSESSMENT ...................................................................................................................... 7 2.3 TOXICITY ASSESSMENT ......................................................................................................................15 2.4 RISK CHARACTERIZATION ..................................................................................................................16 2.5 UNCERTAINTY ....................................................................................................................................18 3. MECHANICAL ELEMENTS OF OIL AND GAS EXTRACTION ...............................................19 3.1 MECHANICAL EQUIPMENT ..................................................................................................................19 3.2 SEDENTARY EQUIPMENT ....................................................................................................................20 3.3 TIMELINE IN THE LIFE OF A WELL ........................................................................................................21 3.3.1 Road and Drill Pad Development ...........................................................................................21 3.3.2 Drilling and Casing .................................................................................................................22 3.3.3 Well Stimulation and Completion ............................................................................................22 3.3.4 Storage and Distribution .........................................................................................................23 3.3.5 Production, Abandonment and Reclamation ...........................................................................24 4. MEDIA SPECIFIC ANALYSIS FOR CURRENT CONDITIONS ................................................25 4.1 FORT COLLINS WATER SYSTEMS ........................................................................................................26 4.1.1 Drinking Water ........................................................................................................................26 4.1.2 Future Water Usage from Fort Collins ...................................................................................28 4.1.3 Surface Water ..........................................................................................................................28 4.1.4 Groundwater: Shallow Versus Deep .......................................................................................28 4.1.5 Active Groundwater Wells ......................................................................................................29 4.1.6 Fort Collins Water Use by Oil and Gas ..................................................................................30 4.2 HUMAN EXPOSURE TO COPCS: IMPACTED MEDIA .............................................................................30 4.2.1 Potential Surface Water Contamination [Fort Collins, Current Conditions] .........................30 4.2.2 Surface Water Contamination [Fort Collins, Future Potential] .............................................31 i TERRA MENTIS 4.2.3 Potential Groundwater Contamination [Fort Collins, Current Conditions] ..........................31 4.2.4 Groundwater Contamination [Fort Collins, Future Potential] ..............................................32 4.2.5 Potential Soil Contamination [Fort Collins, Current Conditions] .........................................32 4.2.6 Soil Contamination [Fort Collins, Future Potential] ..............................................................32 4.2.7 Air Contamination [Fort Collins, Current Conditions] ..........................................................32 4.2.8 Air Contamination [Fort Collins, Future Potential] ...............................................................33 4.3 HUMAN EXPOSURE TO COPCS: COMPLETE EXPOSURE PATHWAYS ...................................................33 4.3.1 Potential COPC Releases to Water .........................................................................................33 4.3.2 Potential Risks of COPCs to Air .............................................................................................39 4.3.3 Potential COPC Releases to Soil ............................................................................................39 4.4 RELEVANCE OF EXPOSURE PATHWAYS TO RISK ASSESSMENT ...........................................................40 4.5 SPECIFIC HEALTH EFFECTS OF COPCS ...............................................................................................42 4.5.1 Benzene Air Concentrations Near Gas Hydraulic Fracturing Wells ......................................44 4.5.2 Benzene Childhood Cancers and Birth Defects ......................................................................47 4.5.3 Other Petroleum Hydrocarbons ..............................................................................................50 4.5.4 Hydrogen Sulfide (H2S) (7783-06-4) .......................................................................................51 4.5.6 Particulate Matter (PM) ..........................................................................................................51 4.5.7 Ozone (O3) (10028-15-6) ........................................................................................................52 4.5.8 Nitrogen Oxides (NOx) ............................................................................................................52 4.6 SUMMARY OF MAJOR SOURCES OF AIR POLLUTION ...........................................................................53 5. AIR, SOIL AND WATER ANALYSES FOR FUTURE POTENTIAL CONDITIONS ...............54 5.1 RELEASES TO AIR FROM GAS EXTRACTION ........................................................................................54 5.2 RELEASES TO WATER FROM GAS EXTRACTION ..................................................................................55 5.3 RELEASES TO SOIL FROM GAS EXACTION ...........................................................................................55 6. FURTHER CONCERNS ....................................................................................................................56 6.1 TRUCK TRAFFIC ..................................................................................................................................56 6.2 SOCIAL DIMENSIONS ..........................................................................................................................56 6.3 AESTHETIC ASPECTS ..........................................................................................................................57 6.4 INDUCED SEISMICITY ..........................................................................................................................57 6.5 DROUGHT CONDITIONS ......................................................................................................................58 7. ENVIRONMENTAL CONSIDERATIONS ......................................................................................59 8. ONGOING RESEARCH ....................................................................................................................61 8.1 NATIONAL AERONAUTICS AND SPACE ADMINISTRATION, COLORADO FRONT RANGE .......................61 8.2 NORTH FRONT RANGE EMISSIONS AND DISPERSION STUDY, COLORADO FRONT RANGE ...................62 ii TERRA MENTIS 8.3 NATIONAL SCIENCE FOUNDATION, ROCKY MOUNTAIN FRONT RANGE, COLORADO AND WYOMING 62 8.4 ENVIRONMENTAL DEFENSE FUND, COLORADO AND NATIONAL METHANE STUDY ............................62 8.5 ENVIRONMENTAL PROTECTION AGENCY, NATIONAL DRINKING WATER STUDY ...............................63 8.6 HYDRAULIC FRACTURING AND ENDOCRINE DISRUPTERS IN GARFIELD COUNTY, COLORADO ...........63 8.7 FLOWER MOUND’S CANCER CLUSTER, TEXAS HEALTH STUDY .........................................................64 8.8 HOUSEHOLD SURVEY IN WASHINGTON COUNTY, PENNSYLVANIA HEALTH STUDY ...........................64 8.9 HOW THESE STUDIES MIGHT AFFECT FORT COLLINS.........................................................................65 9. FINDINGS AND CONCLUSION ......................................................................................................68 9.1 FRAMEWORK FOR THE PROCESS AND FINDINGS ..................................................................................68 9.1.1 Site Characterization and the Hydraulic Fracturing Process .................................................68 9.1.2 Exposure Pathways and Chemicals of Concern ......................................................................69 9.1.3 Dose-response of Chemicals of Concern ................................................................................70 9.1.4 Cancer Risks and Non-cancer Hazards ..................................................................................71 9.1.5 General Risk Factors ..............................................................................................................72 9.2 CONCLUSIONS AND ENVIRONMENTAL STUDIES ..................................................................................73 9.2.1 Characterizing the Environmental Setting ..............................................................................74 9.2.2 Environmental Exposure Pathways .........................................................................................76 9.2.3 Production and Decommissioning Related Pathways .............................................................76 9.2.4 Toxicology and Health Studies ................................................................................................77 9.3 OTHER OIL AND GAS QUESTIONS .......................................................................................................78 10. REFERENCES ..................................................................................................................................79 APPENDICES .............................................................................................................................................84 APPENDIX A: FORT COLLINS OIL AND NORTHERN COLORADO GEOLOGIC FORMATIONS ........................................................................................................................................85 A. FORT COLLINS OIL AND NORTHERN COLORADO GEOLOGIC FORMATIONS ...........86 A.1 OIL AND GAS INFRASTRUCTURE .........................................................................................................87 A.1.1 Current City Well Locations ...................................................................................................93 A.1.2 Neighboring Extraction Fields ...............................................................................................93 A.1.3 Future Exploration .................................................................................................................93 APPENDIX B: HYDRAULIC FRACTURING CHEMICALS AND THEIR USES .......................96 APPENDIX B-1 FRACTURING FLUID CHEMICALS AND THEIR USES........................................................97 iii TERRA MENTIS APPENDIX B-2 CHEMICALS USED IN FRACKING HYDRAULIC FRACTURING: US HOUSE OF REPRESENTATIVES, COMMITTEE ON ENERGY AND COMMERCE.................................................................99 TABLE OF FIGURES FIGURE 2-1 THE FOUR-STEP RISK ASSESSMENT PROCESS ......................................................... 5 FIGURE 2-2 SIMPLE CONCEPTUAL SITE MODEL .......................................................................... 6 FIGURE 2-3 MODEL OF POTENTIAL EXPOSURES FROM OIL AND GAS EXTRACTION .................. 9 FIGURE 2-4 CONCEPTUAL SITE MODEL FOR RELEASES TO AIR ................................................ 10 FIGURE 2-5 GENERIC CONCEPTUAL SITE MODEL FOR OIL EXTRACTION ................................. 11 FIGURE 2-6 GRAPH REPRESENTING VOLATILE ORGANIC CHEMICAL RELEASES DURING HYDRAULIC FRACTURING VERSUS PRODUCTION ................................................................. 12 FIGURE 2-7 DOSE-RESPONSE CURVES FOR TWO TYPES OF HEALTH EFFECT ........................... 17 FIGURE 3-1 EXAMPLE OIL WELL: A COMMON DESIGN ............................................................ 20 FIGURE 4-1 CONCEPTUAL SITE MODEL FOR THE OIL EXTRACTION PROCESS (FT COLLINS)... 27 FIGURE 4-2 GROUNDWATER WELLS WITHIN 1-MILE RADIUS AROUND FORT COLLINS WELLS 29 FIGURE 4-3 CONCEPTUAL SITE MODEL FOR VOC RELEASES TO AIR ....................................... 41 FIGURE A-1 DIAGRAM OF DRILLING TO VARIOUS DEPTHS WITHIN NIOBRARA FORMATION .. 86 FIGURE A-2 THE NIOBRARA SHALE FORMATION IN COLORADO ............................................. 88 FIGURE A-3 FORT COLLINS OIL EXTRACTION FIELDS AND NEIGHBORHOODS ........................ 89 FIGURE A-4 FORT COLLINS OIL EXTRACTION FIELDS AND RESIDENTIAL SUBDIVISIONS ....... 90 FIGURE A-5 FORT COLLINS UDA NEIGHBORHOOD & ZONING MAP ....................................... 91 iv TERRA MENTIS FIGURE A-6 DENVER-JULESBURG SHALE LAYERS ................................................................... 92 FIGURE A-7 MODERATE AND HIGH POTENTIAL OF OIL AND GAS DEVELOPMENT OF ALL FORMATIONS ......................................................................................................................... 95 TABLE OF TABLES Table 4-1 EPA Residential Inhalation Screening Levels1 for Petroleum Related Chemicals ............................................................................................................................. 44 TABLE 4-2 TYPICAL ENVIRONMENTAL BENZENE CONCENTRATIONS ...................................... 49 TABLE 8-1 TIMELINE FOR ONGOING STUDIES RELATED TO OIL AND GAS DEVELOPMENT ..... 66 TABLE 8-1 (CONTINUED) TIMELINE FOR ONGOING STUDIES RELATED TO OIL AND GAS DEVELOPMENT ........................................................................................................... 67 TABLE B-1 FRACKING FLUID CHEMICALS AND THEIR USES .................................................... 97 v TERRA MENTIS 1. INTRODUCTION On February 5, 2013, the citizens of Fort Collins voted to approve a moratorium on hydraulic fracturing and associated waste storage for the next five years. The goals of this report are to provide an aid to the City of Fort Collins for future decision- making regarding hydraulic fracturing (also called “fracking”) and the implications for the future of hydraulic fracturing in the City of Fort Collins in light of Moratorium 2A, and the August 2014 ruling. More specifically, this report describes: • The Human Health Risk Assessment process. This process is used by the United States Environmental Protection Agency (EPA) as the core systematic process for evaluating the potential impacts to human health from environmental chemicals. Within this framework, this report describes the potential risk pathways from hydraulic fracturing within the Fort Collin City limits. • The geology in the vicinity of Fort Collins that makes oil and gas extraction possible. • A summary of the oil and gas extraction process, with a specific definition of, and an emphasis on hydraulic fracturing. • The nature of the chemicals used or extracted and a summary of the potential health effects of these chemicals Oil and gas extraction is a complex process with its own specific terminology, and, hydraulic fracturing is only a particular small part. To limit the extent of this report and to stay focused on the moratorium its focus is primarily hydraulic fracturing, and the storage of its wastes. For purposes of this report, the definition of hydraulic fracturing is provided below, and is taken from the citizen-initiated ordinance proposed in Ballot Measure 2A that was adopted by the City’s voters on November 5, 2013. It reads: (Fort Collins, 2013): “The well stimulation process known as hydraulic fracturing is used to extract deposits of oil, gas, and other hydrocarbons through the underground injection of large quantities of water, gels, acids or gases; sands or other proppants, and chemical additives, many of which are known to be toxic.” 1 TERRA MENTIS Based on this definition, this report focuses on the “direct” impacts associated with this limited phase of well stimulation known as hydraulic fracturing that occurs during a short period of time (a few days to a few weeks) early in the lifecycle of a well, and perhaps again later in the life of the well. These direct impacts may be incurred by a single application of hydraulic fracturing or from the additive impacts of many applications. Direct impacts include, for example, the addition of the chemicals in the fracturing fluid or volatilization of chemicals from flowback water. Because hydraulic fracturing can increase the production in new or existing oil and gas fields it can have “indirect” impacts associated with building, supplying, operating, and managing well operations such as land clearing, new construction, and increased waste management. These indirect impacts are only briefly addressed in this report. In order to educate and provide a baseline framework to evaluate potential harm, Section 2 of this report provides a brief overview of the human health risk assessment process to show how a source may release chemicals of potential concern (COPCs) that could be transported to a resident, and so have a potential risk of harm to that resident. Section 3 provides an overview of the oil and gas extraction process, and associated mechanical elements by describing the phases of drilling, extraction, production, and storage; although distribution is not the focus of this report. The term hydraulic fracturing is often inappropriately used to describe the entire process from drilling to storage, but using the definition above, hydraulic fracturing is only the process by which the oil and gas bearing layer of a geologic formation are opened to release more oil and/or gas, which occurs between drilling and the production phase of the well. Oil and gas production requires the appropriate geologic formations, and a discussion of the geology beneath Fort Collins is provided in Appendix A rather than in the body of this report. The geographic framework of Fort Collins and the surrounding areas (Appendix A), including the geological formations’ depth to groundwater, shale and oil depths, and surface gradients, is important in the context of this report. Major geographic identifiers such as residential locations, oil well locations, and groundwater well locations are outlined in this appendix. 2 TERRA MENTIS Oil and gas production is undertaken within a multilevel regulatory framework, which is complex and is not reviewed in this technical support document. Section 4 outlines potential interaction between the public and the oil and gas COPCs used or produced during oil and gas production, and the human health effects resulting from human exposure. Oil and gas production uses a wide range of chemicals to lubricate drills in the exploration and drilling phase and to assist in fracturing the geologic formation that is the source of the oil or gas; the hydrocarbons being extracted are chemicals that have human health and environmental effects. Hydraulic fracturing produces wastewater that may also contain COPCs. This report will outline the possible sources of contamination, the associated COPCs and their potential health effects. The COPCs that are introduced into the environment can potentially impact surface water, groundwater, air, or soil either chemically through ongoing releases or through accidental releases. Section 5 discusses some future potential scenarios for oil and gas development in relation to the moratorium. While other concerns of hydraulic fracturing, such as increased truck traffic, social cohesion, aesthetic degradation, induced seismicity, and heavy water use during periods of drought conditions are only briefly described in Section 6. The carbon footprint and greenhouse gas releases due to oil and gas production are also of concern to both the citizens and the government of Fort Collins because of their goal of future carbon neutrality. Section 7 briefly discusses greenhouse gases and methane released to the atmosphere in Colorado’s Front Range. Section 8 outlines the current state of research on the quantity of greenhouse gases released from oil and gas production; and where known, the current health studies related to oil and gas development in Colorado, or elsewhere. This report will not go into detail on the probability of oil and natural gas production, the possible advancements in technology that may lead to future drilling, or the governmental regulations that are in place. Instead, this report will examine where possible contamination may add risks for Fort Collins residents, which may require investigation. A summary of findings and conclusions is presented in Section 9, with cost ranges for monitoring or research programs that could be undertaken. These are not recommendations for future work, but are provided for comparative purposes. 3 TERRA MENTIS 2. RISK ASSESSMENT: A BASIS FOR DECISION MAKING The section of the report provides a general overview of the risk assessment process, a description of why it was selected as the framework for the discussion and a brief description of each component in the process. Risk assessment is a tool used in risk management because it is a systematic way of laying out how an individual might be exposure to chemicals in the environment, and the potential health problems they might cause. Risk assessment is the process that scientists and government officials use to estimate the increased risk of health problems in people who are exposed to different amounts of toxic substances. Figure 2-1 was excerpted from the EPA’s 1991 web site on air toxics (EPA, 1991) and it shows the four steps of the risk assessment process. The process systematically breaks down each step to identify the sources of chemicals, the media they impact, transport mechanisms that allow chemicals to migrate to an individual, called a receptor, and allows for the ranking or the calculation of potential risks and hazards. For each site or facility being assessed, this information is pictured in a Conceptual Site Model (CSM). A simple example of a CSM is shown in Figure 2-2. Two types of “health risks” are typically calculated, 1) cancer risk, which is defined as the increased potential of developing cancer over a lifetime of exposure, and 2) non-cancer hazard, which is the probability of other health effects. The hazard is the increased potential of developing non-cancer health effects (such as asthma, liver or kidney problems) over the exposure period. In this example, exposure is compared to an acceptable level of exposure and a ratio is calculated to give a measurement that is called a Hazard Index (often abbreviated to HI). 4 TERRA MENTIS FIGURE 2-1 THE FOUR-STEP RISK ASSESSMENT PROCESS HAZARD IDENTIFICATION What Pollutants are present? What health problems does the pollutant cause? EXPOSURE ASSESSMENT How much pollutant do people inhale during a specific period? DOSE-RESPONSE ASSESSMENT What are the health problems at different exposures? RISK CHARACTERIZATION What is the extra risk in the exposed population? 5 TERRA MENTIS FIGURE 2-2 SIMPLE CONCEPTUAL SITE MODEL Chemical Source Hydrocarbons (Benzene, toluene, xylene, methane, etc.) Spill release to soil or groundwater Residence Well water Ozone (Generated) Inhalation Air Residence Air Inhalation Ingestion Dermal Migration in groundwater Primary Transport Source Exposure Point Route of Entry Risk Endpoint Increased cancer risk Potential non-cancer health effects Increased cancer risk Potential non-cancer health effects 6 TERRA MENTIS 2.1 HAZARD IDENTIFICATION Identifying risks and hazards starts with understanding the process by which chemicals are used, generated, or released into the environment. For the hydraulic fracturing process, fracturing fluids, water and proppants are used to liberate oil, volatile petroleum compounds, and gas, which are then extracted. Fracturing fluids are a mixture of multiple individual chemical compounds with different physical properties, and human health effects. A list of chemicals used in fracturing fluids is shown in Appendix B. Some fracturing fluids and their uses are shown in Appendix B-1. The chemicals used in hydraulic fracturing identified by the US House of Representatives Committee on Energy (US House, 2011) are shown in Appendix B-2. Initially in the risk assessment process, all of the chemicals in the mixture are considered; petroleum is a mixture of aromatic and aliphatic hydrocarbons. Some of the chemicals in the mixture have more severe adverse health effects, than others, and are of greater interest. The chemical with the highest risk is called the “risk driver,” in the case of oil petroleum the driver is usually benzene. 2.2 EXPOSURE ASSESSMENT An exposure assessment first determines if a person is exposed, and whether that exposure occurs by contacting air, water or soil. Four elements must be in place for exposure to be complete: • A source of pollutant • A transport mechanism to get the pollutant to the individual • A point of exposure • A route of exposure into the body If any one of these elements is missing, there is no exposure, and therefore no risk. This is important because if one does not contact fracturing fluids there is no risk from fracturing fluids. 7 TERRA MENTIS Figure 2-2 is a simple Conceptual Site Model (CSM) that allows for a systematic determination of chemical concentrations at important points in the process. This model is expanded as a picture of the multiple exposure pathways is developed. By understanding the location of chemical release points, and the media the chemicals are released into, it is possible to answers questions about which media should be monitored, at which exposure point, and what media action levels form the basis for regulatory enforcement and potentially legal actions. Figure 2-3 shows a typical diagram of how the EPA pictures potential exposures. Specific exposure pathways are discussed in Section 4. Because exposure depends on the properties of the chemical released (oil or gas), the medium they are released into (water or air) and their persistence in the environment (i.e., gas will quickly disperse, whereas radioactive material may be present for many years), a more detailed analysis is needed. If an exposure pathway is complete, quantification of exposure is often measured at the point of exposure. For example, measuring benzene in air at a residence or in groundwater at a residential well provides data that can be utilized to quantify the exposure to a receptor. Figure 2-4 shows how the exposure diagram would translate into the Conceptual Site Model for air and Figure 2-5 shows a diagram of typical ways for a receptor to be exposed to all media (e.g., inhalation of contaminated air and ingestion of and dermal contact with contaminated groundwater). 8 TERRA MENTIS FIGURE 2-3 MODEL OF POTENTIAL EXPOSURES FROM OIL AND GAS EXTRACTION 9 TERRA MENTIS FIGURE 2-4 CONCEPTUAL SITE MODEL FOR RELEASES TO AIR VOCs at the Source Volatile Hydrocarbons Benzene, toluene, xylene, methane, etc. Spill release to soil or groundwater Residence Ozone (Generated) Inhalation Child – Adult Leukemia, blood problems Air (Benzene) Residence Inhalation A B C D Migration in groundwater Primary Transport Source Exposure Point Route of Entry Risk Endpoint Child – Adult Leukemia, blood problems 10 TERRA MENTIS FIGURE 2-5 GENERIC CONCEPTUAL SITE MODEL FOR OIL EXTRACTION 11 TERRA MENTIS Illustrative VOC Concentration FIGURE 2-6 GRAPH REPRESENTING VOLATILE ORGANIC CHEMICAL RELEASES DURING HYDRAULIC FRACTURING VERSUS PRODUCTION The risk assessment process might cover different exposure timeframes, such as a few days, or a lifetime. When collecting environmental data, the time period should be representative of the length of exposure, where possible. For long term, or chronic, exposures long-term average exposure concentrations are important, but the environmental data are often not available and health protective assumptions have to be made. For example, when considering hydraulic fracturing, current air benzene concentrations can be used to predict future potential concentrations by assuming that future concentrations will be the same as current concentrations. Or they might be assumed to increase if the number of wells increases, and vice versa. However, air COPC concentrations vary with activity at the well. Figure 2-6 is a diagram that represents hypothetical benzene concentrations over time, based on activity, and it shows that benzene concentrations are highest during the hydraulic fracturing phase, and that concentrations will decrease after the production phase is over. Risk assessments are driven by environmental and toxicological data. The concentration of a chemical in an environmental medium can be measured at any point in the transport pathway Time Hydraulic Fracturing Phase Production Phase 12 TERRA MENTIS from the source (in the case of oil and gas, the well), to the target organ of the exposed individual. However, there are a number of important factors that must be considered including: • Access to the medium where concentrations should be measured • The cost of sample collection, analysis, data validation, reporting and storage • The number of samples needed to provide a valid and statistically significant representation of exposure to the medium of interest • An understanding of how environmental concentrations change with fluctuations at the source, time, geological and meteorological conditions, and the location of the exposure point • An understanding of chemical mobility, persistence and bioaccumulation • Absorption into the body • Biological markers for exposure and the relationship between these markers and the toxicological effect It is impracticable to measure chemical concentrations in all media at all times. It would be prohibitively expensive. To reduce the need for actual physical data, mathematical models are used to estimate environmental chemical concentrations that represent exposure point concentrations. Modeling is cheaper, but still expensive. To complicate these points, not all data are equal. The method of collection, chain-of- custody, sample holding times, analytical detection limit, and analytical problems (interferences, cross contamination, equipment failures) can render the data of poor quality or unusable. Before data are collected, data quality objective (DQO) should be established (EPA, 1994), and after collection a data quality assessment is employed to verify data quality (EPA, 2006). The EPA provides a ranking system to indicate data quality, and for litigation, or enforcement it is advisable to have data of high quality. High quality data is often the most expensive to collect. All data may serve a purpose, but the purpose should be established prior to data collection. For oil and gas issues related to hydraulic fracturing, air data are the most relevant and important because VOC releases to air are more routine, and this pathway might represent 13 TERRA MENTIS common exposure to a resident. Whereas releases of fracturing fluids and petroleum hydrocarbons to soil, groundwater and surface water require leaks from piping and equipment, and spills, which may also occur, but may be harder to detect if they are below the ground. Volatile chemical releases to air stem from both routine and fracturing specific activities, and they represent actual chemical concentrations being inhaled by a resident. However, air chemical concentrations will change with time of day, distance from the source, meteorological conditions such as wind speed and direction, and sample collection duration and location. Serious consideration should be given to data collection efforts because these complicating factors can compromise data quality and usefulness. Using Figure 2-4 as an example for an oil well, to prove an individual is exposed to chemicals from hydraulic fracturing at a well, it must be shown that the chemicals at the source are transported through air in the direction of the resident for a sufficient duration to exceed either average or specific regulatory concentrations, or at levels sufficient to cause harm. For example, in Figure 2-4, Box A answers the question - What is the concentration of a chemical at its source? Box B describes the transport media that might be affected. In this example, soil and/or groundwater become contaminated, and there is the potential for benzene to migrate into ambient or indoor air. The distance from various receptors to the source may vary and the chemical concentration in air would typically decrease with increased distance to the point of exposure for a resident (represented in Figure 2-4 in Box C). Box D represents the air concentration at the route of entry into a resident’s body. Simply measuring chemical concentrations at the point of exposure might show the resident was exposed but does not show the well is the source; exposure might be due to background sources such as a gas station, or car in a garage. If a site were regulated under a hazardous waste program, such as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or a voluntary remediation program, data would be collected under EPA data collection protocols, and environmental characterization would establish DQOs for each medium. At this point in time, there are few or no air data characterizing potential exposures to releases from Fort Collins oil wells over time. Residential exposure from a well 14 TERRA MENTIS might be suspected, due to the presence of hydrogen sulfide in the air at a residence next to a well, but to adequately prove exposure from the well all four elements must be shown, and the exposure must be quantified. When environmental data are available they could be used in the risk assessment process. For example, when calculating the risks to a resident from a chemical like benzene the time span of data collection should be sufficient to be representative of a lifetime of exposure. A year of data would show seasonal variability within a year, but not year-to-year variability. Five years of data could provide year-to-year variability, and it would allow an estimation of exposure over the 30-year lifetime assumed by EPA. Chemical concentration data may vary with wind direction, distance from the source, etc., and each variable might require the collection of additional data. With each location, it may be necessary to collect background measurement with the goal of separating well-related benzene concentrations from benzene derived from other sources. The quality of the data for each variable should also be considered; the cost of collecting and analyzing data for each variable will be impacted by data quality requirements. 2.3 TOXICITY ASSESSMENT A toxicity assessment provides information on the potential adverse health effects of the chemicals involved with hydraulic fracturing or the resulting petroleum hydrocarbons. In general human health dose-response data are unavailable except from epidemiological studies. In the absence of human data, toxicologists rely on animal studies. Cancer development in humans is a complex process; cancer may take many years to develop after initial exposures, or may take multiple exposures for certain cancers to develop. In rare cases, with benzene for example, there is evidence that exposing the pregnant mother may result in childhood cancer after the infant is born. Because cancer development is a complex process, some simple assumptions are made in the interest of being health protective. In this case EPA assumes that any exposure will increase the risk of developing cancer. This is called a zero risk, non-threshold assumption. 15 TERRA MENTIS Evaluating non-cancer effects in humans is also a complex process because each chemical may have different effects. Also, a chemical may have different effects based on the length of exposure or the exposure concentration. For hydraulic fracturing and oil and gas these are also discussed in Section 4. Figure 2-7 shows how these dose-response curves appear on a graph. The EPA dose-response process adds safety factors to the actual response found in animal experiments to account for uncertainties when extrapolating from animal studies to human responses. These uncertainty factors are conservative, meaning they lower the acceptable concentrations, but they are protective of sensitive sub-populations, like children or health-compromised individuals. Health Effects: For petroleum compounds many of the adverse health effects are known. For some compounds, such as fracturing fluids, toxicological information is unavailable. This leads to uncertainty in the risk assessment process. 2.4 RISK CHARACTERIZATION The EPA’s risk assessment process considers both cancer and non-cancer effects. For cancer effects, because of the zero risk approach, a chemical that can cause cancer is considered to have risk, and the US National Contingency Plan provides an acceptable risk range against which risks are assessed. Cancer risks are expressed as a probability, and the acceptable excess cancer risk range is one in ten thousand (1 in 10,000 or 10 -4 ) to one in one million (1 in 1,000,000 or 10 -6 ). Risks are calculated as the product of the exposure multiplied by the dose-response factor. 16 TERRA MENTIS FIGURE 2-7 DOSE-RESPONSE CURVES FOR TWO TYPES OF HEALTH EFFECT Curve A represents potential cancer effects and has no threshold (i.e., any exposure has a risk), and curve B represents non-cancer effects and has a threshold for its effect (i.e., there is a level of exposure that will not cause harm). Chemicals with non-cancer effects are assumed to have a safe threshold (see Figure 2-7) meaning there is an exposure level that has no risk. The threshold may be different for each chemical. Once the threshold is exceeded there is the potential for an increased hazard. Hazards can be determined for short-term (hours to a few days of exposure), intermediate- term exposure (a few days to few months of exposure) or long-term exposures (greater than a few months). Non-cancer hazards are determined by comparing (dividing) the dose for the exposure period to the acceptable dose for the same period. The resulting ratio is called a Hazard Quotient and it is used to quantify the non-cancer exposure to a receptor. The value of the Hazard Quotient that is equal to or below one (1) is considered acceptable in the Superfund Program (EPA 1989). The sum of Quotients is called the Hazard Index, and for chemical mixtures, a Hazard Index summing the actions of chemical mixtures affecting the same target organ that is equal to or below one (1) is considered acceptable. 17 TERRA MENTIS The risk assessment process calculates risks and hazards for each chemical individually, and then sums those for an estimate of total risk. Oil and gas chemicals are usually present as mixtures and not singly or individually; therefore, the risks and hazards from each chemical are added together to provide a cumulative total risk estimate. 2.5 UNCERTAINTY All risk assessments have uncertainty. Often the uncertainty can be factors of 100 or 1000, depending on the medium sampled or the type of risks being calculated. In most, if not all, cases the uncertainty cannot be estimated because the actual risk cannot be known. The two main sources of uncertainty are environmental data and dose-response information. Data Uncertainty When dealing with environmental data there is uncertainty because all data represent a “snap shot,” or data collected from a short timeframe that is used to represent a longer time period. This is particularly true for air data because atmospheric conditions will act to disperse, and move contamination either towards or away from a fixed receptor. When the chemicals under consideration are common, background concentrations should be established, and for benzene the background range may have a measureable and significant risk. Toxicological Uncertainty Toxicological dose-response factors are highly uncertain and because they are often based on high dose animal toxicology or epidemiologic studies and extrapolated to effects in humans exposed at low doses, the extrapolations include health protective assumptions. Extrapolating from high doses (often in animals), where effects are clear, to low levels where responses may be different due to the lack of data, leads to high uncertainty in cancer dose-response factors. Similarly, uncertainty factors for non-cancer effects can range from ten to 3000 depending on the chemical and the study used as the basis for the dose-response factor. Risk Uncertainty When calculations are performed by combining data uncertainty with dose-response uncertainty the overall uncertainty in the risk estimates is increased. 18 TERRA MENTIS 3. MECHANICAL ELEMENTS OF OIL AND GAS EXTRACTION This section provides a brief overview of the mechanical and engineering aspects of the unconventional oil and natural gas development process, the type of mechanical equipment used and the components where hydrocarbons might be released. 3.1 MECHANICAL EQUIPMENT Mechanical elements associated with oil and gas development produce pollutants as a by- product of their function. This includes diesel emissions, particulate matter, and/or volatile organic chemicals (VOCs) either through engine emissions, the evaporation of lubricants, solvents, etc., and the release of product. Mechanical elements are also susceptible to leakage from pipes, flanges, valves and malfunction of moving parts that can result in larger scale spills. Diesel trucks provide transport for all elements used on the well site; this includes but is not limited to concrete for pad construction, hauling water, heavy machinery, storage tanks, and pipelines. Drilling rigs are used during the drill process to drill the borehole to the hydrocarbon-containing deposits. Power generators may be used throughout the well’s life to provide electricity to power the oil and gas pumps and to run compressors and other on-site machinery. Phase separators are used throughout the production of the well to separate the hydrocarbons produced from a well. Dehydrators are used to remove water from the produced hydrocarbons, and compressors are used to create liquid natural gas from the gas produced in the well. This is an easier way to store methane and transport it to offsite facilities. Well equipment and a sample oil well site are shown in Figure 3-1. 19 TERRA MENTIS FIGURE 3-1 EXAMPLE OIL WELL: A COMMON DESIGN 3.2 SEDENTARY EQUIPMENT Some mechanical elements have few to no moving parts and are therefore unable to malfunction as such. However, this equipment is still able to leak or rupture causing spills. Well casing and the cement that surrounds it are used to separate the chemicals going in and out of the well from the environment around it. As shown in Figure 3-1, sealed casing is SOURCE: Energy BC, Canada: www.energybc.ca/profiles /oil.html 20 TERRA MENTIS particularly important to separate groundwater aquifers from the well. The wellhead is the cap and access point at the surface of the well for ongoing production and future re-fracturing (Figure 3-1). Storage tanks and condensate tanks are used on site to store fracturing fluid, produced water, and produced hydrocarbons (oil, volatile gas condensate, or liquid gas). Venting is a protocol used in situations where “low VOC emission completion” is not used. Tank vents are currently a significant source of VOCs in the Denver-Julesberg Basin. Pipeline is used in some cases to transport produced hydrocarbons and other materials off- site when the use of trucks is less economically viable. Green completion practices are required on most oil and gas wells in Colorado except where the wells are not sufficiently proximate to sales lines, or where green completion practices are otherwise not technically and economically feasible. Prior practices relied on flowback ponds, or lined open pits, used to evaporate volatile chemicals and contain the liquid until it can be reused or removed. Flowback ponds have largely been replaced by low VOC emission completion technology that uses tanks to collect all flowback water, not allowing as much evaporation as before. 3.3 TIMELINE IN THE LIFE OF A WELL Well activity can last as long as a few months from pad development to the steady production of hydrocarbons over several years or decades. Once a well is drilled, it can be fractured multiple times to maintain hydrocarbon production for several decades. See Figure 2-6 for a representation of this process. 3.3.1 Road and Drill Pad Development Once the location of a well has been selected, a concrete well pad is constructed. The well pad consists of several acres of land where all the future staging, drilling, and storage will take place. The size of well pads depends on the depth and number of wells drilled (ANL, 2013). To prepare the well pad, the ground must be leveled and cleared of vegetation using chemicals and heavy machinery. Cement well bases are then poured to provide stable drill pads. Access roads will also be constructed where necessary to allow for the truck traffic required to transport materials to and from the well site to public roads. 21 TERRA MENTIS 3.3.2 Drilling and Casing The well is drilled down to near the level of the hydrocarbon containing formation (roughly 900 feet before the level of the formation) (ANL, 2013) and the borehole is then gradually curved at a 90-degree angle to allow for horizontal access into the formation layer. As drilling advances, casing is inserted to protect the well from the aquifers and leakage of other materials into the well. Cement is pumped into the annulus (the space between the ground and the well casing) to further protect the well (Figure 3-1). The horizontal portion of the well and the casing is perforated with small explosives to allow the future flow of fracturing fluid out and oil or gas to flow into the well for collection. The horizontal portion of the wellbore can extend for more than 5,000 feet below ground surface (ft. bgs) (ANL, 2013). In Fort Collins the oil wells are between 5,000 and 7,500 feet bgs (FracFocus, 2014). Typical shale depths in Larimer and Weld Counties are discussed in Appendix A. 3.3.3 Well Stimulation and Completion Hydraulic fracturing “describes the process of fracturing low permeability rocks using water mixed with sand and proprietary chemicals pumped into the borehole under high pressure.” (Moore et al., 2014) Only a limited length of a horizontal well can be fractured at any one time, resulting in the need for fracturing in multiple “stages” by separating the well with cement plugs and then removing these plugs after fracturing a stage is complete. The overall process might vary for oil versus gas production, or for new wells versus enhancing production in older well, and the process can last a few days to a several weeks depending on the number of stages being fractured and the number of wells on a single well pad (Moore et al., 2014). During the fracturing process, fracturing fluid is pumped into the well at high pressure (e.g., greater than 3,500 psi) to break up the shale (or other geologic strata) pockets that trap the oil and gas. Fracturing fluid is composed predominantly of water (approximately 90 percent) with added proppant (~8-9 percent) to hold the formation open after the fluid has left. Proppant usually consists of fine sand (silica), meta basalt, or synthetic chemicals) (Vengosh et al., 2014). The remaining elements in the fracking fluid are chemicals (~0.5 to 2 percent), usually proprietary, with a range of functions including acids, lubricants, biocides, corrosion 22 TERRA MENTIS inhibitor, pH adjusting agents, and scale inhibitors (See Appendix B for a list of chemicals in hydraulic fracturing fluids). After pressure is removed from the well, the fracturing fluid and natural fluids previously trapped in the formation return to the surface. The water that returns to the surface of the well immediately following hydraulic fracturing is referred to as flowback water which consists of the dozens of chemical constituents present in hydraulic fracturing fluids, but it is also mixed with the fluids that were originally present with the hydrocarbons in the formation (referred to as produced water). The produced water may also contain hydrocarbons, dissolved minerals (total dissolved solids, TDS), trace elements, and naturally occurring radioactive materials (NORMs). The volumes of flowback water are extremely small relative to the volumes of produced water. Flowback water is directly attributed to hydraulic fracturing, whereas produced water is an indirect effect of hydraulic fracturing enabled production. After a hydraulic fracturing event, the fluid that comes out of the well changes from flowback water to produced water, but there is no formal distinction between the two fluids. The injected fracturing fluid continues to return in small quantities throughout well production with between 10 and 40 percent of injected fracturing fluids returning to the surface (Vengosh et al., 2014). Produced water can be reused for further hydraulic fracturing, disposed of in Class II deep injection wells, or treated using either municipal or industrial wastewater treatment facilities (Vengosh et al., 2014; COGCC, 2014). 3.3.4 Storage and Distribution Well pads include storage tanks that perform a number of holding functions including storage of fracturing fluid, produced water, and produced hydrocarbons. Storage of hydrocarbons is required on-site for as long as it takes to remove water and separate crude oil from natural gas. Once this occurs, the crude oil or liquid gas is either stored on-site until retrieved by a transport truck, or is sent off-site via a pipeline. According to data provided by the current operator within the City, reviewed by City staff and provided to the authors, the existing wells in Fort Collins currently pass over 98% of gas through a thermal oxidizer; however, in some cases gas is simply vented. 23 TERRA MENTIS 3.3.5 Production, Abandonment and Reclamation The life of an oil or gas well can be approximately 20-30 years (Adgate et al., 2014; Moore et al., 2014). As production decreases below profitability, hydraulic fracturing can be performed again to re-stimulate the well. Wells that have unconventional production methods (horizontal drilling and hydraulic fracturing) decline much more rapidly than conventional wells (Adgate et al., 2014). After a well has stopped producing at a profitable rate, the well can be capped, and the land can be returned to non-oil usage, depending on local regulations. Colorado allows for the return to regular usage by the landowner, with the responsibility of re-vegetating the well pad resting with the well operator. 24 TERRA MENTIS 4. MEDIA SPECIFIC ANALYSIS FOR CURRENT CONDITIONS This section builds on the information provided in Section 2 to address the potential human health risks and hazards associated with the chemicals released during oil extraction and storage at well sites in Fort Collins. The more general risks and hazards potentially associated with the chemicals released during the process of hydraulic fracturing and the extraction of oil and gas that might occur in the future are also briefly discussed. In risk assessment practice two aspects are typically considered: 1) the probability that an event will occur, and 2) the potential adverse outcomes should that event occur. A good example might be the storage of oil at a well site. There is typically a low probability that a storage tank will rupture due to failures in engineered systems, but there is always the possibility of a “force majeure,” or a major catastrophic destructive force that might rupture the tank or wash it away. Should this occur, there would be potential impacts to human health and the environment. The risk assessment process described in Section 2 addresses the risk of possible adverse outcomes should a rupture event occur. To evaluate the potential risk to human health and the environment, the EPA’s Superfund program has developed a systematic evaluation process described in a number of guidance documents, starting with the Risk Assessment Guidance for Superfund (EPA, 1989). The starting framework for this process is a Conceptual Site Model Site (CSM) that identifies sources of contamination, the transport mechanisms by which these COPCs can migrate to exposure points where individuals may come in contact with them, and routes of entry into the body. Figure 4-1 shows a CSM for a hypothetical oil well in Fort Collins; the area with the red background indicates the production areas. At first glance this diagram appears complicated, but when broken down into media it shows where a source might impact water, soil, and air, and where humans might be impacted. Hydraulic fracturing pumps fluids, proppants and water in to the well. The chemicals that return from the well are fracturing fluids, produced water and any additional chemicals dissolved in the water (e.g., naturally occurring radioactive material or NORMS), oil and gas. 25 TERRA MENTIS Potential releases of these chemicals to water (surface water and shallow groundwater) are diagramed in Figure 4-1 with a blue background. This diagram indicates that deep groundwater (5000 feet bgs) is not accessed for drinking water. Releases from a well or well casing might impact shallow groundwater, which could act as a carrier to a residence. Releases to surface water might impact surface water bodies. Potential releases to soil are shown in Figure 4-1 with a brown background, and this exposure mechanism would require a spill and access to the site. Potential releases to air are shown in Figure 4-1 with a green background. This is the most common exposure pathway, and releases are both routine and would occur if there was a spill. For the purposes of this analysis, current exposures in Fort Collins are for oil wells only, and are discussed in this section (Section 4). 4.1 FORT COLLINS WATER SYSTEMS Drinking water is one of the most valued resources in Colorado, and the drinking water systems in Fort Collins are no exception. Drinking water is not used, nor is it impacted by oil extraction in Fort Collins; however, an upset condition could contaminate surface and ground water locally. 4.1.1 Drinking Water The drinking water in Fort Collins comes from the Cache la Poudre River watershed and the Colorado-Big Thompson watershed via Horsetooth Reservoir to the west. Drinking water is currently uncontaminated by oil extraction, as the wells are located east and north of Fort Collins. Well development is also unlikely to occur on the west side of Fort Collins, as the oil and shale plays do not continue into the foothills and are not beneath the watersheds. The facilities that treat the water for Fort Collins consumption are the Fort Collins Utilities’ Water Treatment Facility and the Soldier Canyon Filter Plant. These facilities do not provide water for oil and gas production or hydraulic fracturing at the current time. The drinking water in Fort Collins is also treated and monitored due to recent fires and floods that increased particulate matter and chemical contamination. 26 TERRA MENTIS FIGURE 4-1 CONCEPTUAL SITE MODEL FOR THE OIL EXTRACTION PROCESS (FT COLLINS) Primary Transport Source Exposure Point Route of Entry RESIDENTIAL RECEPTOR All receptors Requires Contact with Soil Explosion Hazard Fracturing Fluid Produced Water NORMs Oil and Gas Residues TDS (Salts and Metals) Antibacterial agents Hydrogen sulfide Inhalation Regional Air Quality SHALE Oil Bearing Shale (5000 feet) Deep Groundwater Requires Private Well EXTRACTION Fracturing Fluids Water / Sand PRODUCED OIL/WATER PRODUCT Oil Surface Water Shallow Groundwater Deep Groundwater Accidental Soil Release Release from Casing Ingestion Dermal Inhalation Soil Gas Basement Gas Accidental Release Release Mechanism Ongoing /routine VOC releases, PM10, PM2.5, air toxics, etc., Ingestion Dermal Inhalation TERRA MENTIS Current reports show that the City’s drinking water has recovered from recent natural disasters and is free of associated contaminants. The Prospect and Mulberry Water Reclamation Facilities are the Fort Collins two-wastewater processing facilities. Currently, these facilities do not treat wastewater from hydraulic fracturing or provide water for use in the Oil and Gas Industry. 4.1.2 Future Water Usage from Fort Collins As Fort Collins develops the need for water for residential uses will also increase. And, if further oil well development occurs or if natural gas exploration and production occurs, the demand for water will rise. This requires consideration by the City of Fort Collins especially as Colorado frequently has drought conditions. The distribution of water should be managed by the City and allocated as needed. 4.1.3 Surface Water Uses for surface water in the City of Ft Collins include recreation, fishing, irrigation, and drinking water. Human contact with surface water is moderate to high depending on the location and season. Horsetooth Reservoir in particular is of critical importance as it is a source of drinking water for the City of Fort Collins and a popular recreation area; however, the reservoir is under a low chance of influence from hydraulic fracturing. The accessible shale and sandstone plays in the region are to the east of the reservoir and water runs west to east. If development occurs west of Fort Collins, there would be need for concern regarding two water basins in the foothills to the west, and the surface water of Horsetooth Reservoir to the west. The likelihood of the development to the west of the City is low due to the geographic formation and the location of the hydrocarbon bearing formations and oil plays. 4.1.4 Groundwater: Shallow Versus Deep Shallow groundwater is a term used to describe the groundwater aquifers that are located immediately below the earth’s surface. Groundwater in Fort Collins begins at ground level and goes as deep as 160 ft. bgs (USGS). Deep groundwater is a term used to describe the groundwater at the depth of shale (from 5,000 to 8,000 ft. bgs), which is where untreated wastewater from previously exploited wells is injected via Class II injection wells. This is contaminated water and is not fit for human or animal consumption. The goal of deep well 28 TERRA MENTIS injection is to remove the wastewater from the water system completely and prevent the impacts caused by contaminants. Further hazards of deep well injection are discussed in Section 5. 4.1.5 Active Groundwater Wells There are currently 15 active groundwater wells within one mile of the current oil well sites in Fort Collins (Figure 4-2). The depths of these wells range from 20 to 350 feet (as permitted) and are located in the shallow unconfined aquifer of the groundwater system. The uses of these wells include domestic, irrigation and livestock, and monitoring wells. There is a plethora of other groundwater wells located around Fort Collins including in areas outlined previously as possible locations for further oil development. These wells should be considered when planning all future development within and around the city. FIGURE 4-2 GROUNDWATER WELLS WITHIN 1-MILE RADIUS AROUND FORT COLLINS WELLS 29 TERRA MENTIS 4.1.6 Fort Collins Water Use by Oil and Gas Currently, Fort Collins does not supply water to the oil and gas industry for hydraulic fracturing. The source of water for hydraulic fracturing by the current local operator is not known, nor is it known how the water used in fracking is supplemented. The operator does recycle it’s produced water following onsite treatment, and reuses it as fracking fluid. The future use of Fort Collins water by the oil and gas industry also requires further consideration. 4.2 HUMAN EXPOSURE TO COPCS: IMPACTED MEDIA In general, Fort Collins’ resident exposure to the hazardous components from oil production in water and soil is very limited, or non-existent. Direct contact is possible should chemicals be released during an upset such as a spill, accident, catastrophic incident or well failure. Exposure to the chemicals released to air is much more likely. Methane, hazardous air pollutants (HAPs), hydrogen sulfide (H2S), volatile organic compounds (VOCs) and other chemical releases to air are routine and on-going at most wells; both oil and gas. However, the amount of methane gas released is higher for gas wells. This section first describes the nature of potential releases from oil wells, followed by a discussion of the potential health effects. 4.2.1 Potential Surface Water Contamination [Fort Collins, Current Conditions] Surface water bodies within Fort Collins’ city limits have a low probability of being contaminated as current streams, lakes, and reservoirs are not located near active wells. Contamination of surface water would require a catastrophic release or malfunction in combination with environmental circumstances, such as heavy rainfall, to transport an aqueous spill from the well site to public surface water. Currently three reservoirs are located down gradient from and within meters of active wells. Surface water is not used for human consumption; however, spills that affect surface water will migrate to groundwater. A surface water impact would potentially affect ecological receptors, but this report only covers human health impacts, not impacts to environmental receptors. Spilled liquids would contaminate soil and could migrate to groundwater if not properly remediated. 30 TERRA MENTIS 4.2.2 Surface Water Contamination [Fort Collins, Future Potential] The potential for surface water to be contaminated due to future oil production in Fort Collins would depend on the location of a well relative to surface water bodies. The closer the well the higher the likelihood surface water might be impacted in the event of a release. Berms and engineering controls would decrease the possibility of contaminant migration in the event of a release. 4.2.3 Potential Groundwater Contamination [Fort Collins, Current Conditions] Groundwater could be contaminated in multiple ways. The mechanics of oil extraction are designed to avoid the interactions of produced fluids with aquifers; therefore, groundwater contamination will only occur in the case of a malfunction or spill. First and more likely, if a drill casing bursts within the 160 feet bgs (USGS), it would cause direct contact between fracturing fluid, produced water, and produced oil and the shallow groundwater aquifer. This could contaminate drinking water for those water wells in the proximity of a burst casing. The second potential human health impact, which is less likely for this pathway, is contaminant migration to groundwater from a fracture. Hydraulic fracturing is known to cause fissures up to 600 feet (183 meters) from the point of fracture, making groundwater contamination from fracturing in Fort Collins unlikely due to the distance between the fractures and shallow groundwater. However, when a fracture occurs near a previously existing fault line or previous well boring, fracturing fluid or trapped methane can flow freely to a much greater distance, even returning to the surface (ANL, 2013). Given the depth of the sandstone layer being extracted this too is unlikely. The final potential human health impact is from surface to groundwater migration. If there is a surface spill that is unnoticed or improperly mitigated, whether the spill is fracking fluid, produced water or crude oil, the fluids could migrate down into the shallow groundwater table. Fort Collins well sites are currently required to berm around storage tanks and to line the ground under areas of potential concern; however, unless sites are monitored consistently, spills and leaks could go unnoticed and cleanup operations may not happen within an effective time period to prevent migration to groundwater. 31 TERRA MENTIS 4.2.4 Groundwater Contamination [Fort Collins, Future Potential] The potential for groundwater to be contaminated due to future oil production in Fort Collins would be similar to that for current groundwater and is dependent on accidents, spills or releases. Berms and engineering controls to decrease the possibility of contaminant migration in the event of a release would reduce risk. 4.2.5 Potential Soil Contamination [Fort Collins, Current Conditions] Potential releases to soil can occur, but would be localized and the potential for human health risk is proportional to contact with contaminated soil, which would require entering a well site, or migration of COPCs off site. Therefore, fencing and labeling of potential health dangers could mitigate any contact with site soils. Mishandling of wastes, especially sludges containing NORMS and oily residues represents a potential health risk. An awareness of residual contamination and remediation would prevent future potential risks. Contact with un-remediated wastes would represent a higher risk after the removal of fences and other barriers to direct contact. 4.2.6 Soil Contamination [Fort Collins, Future Potential] The future potential for risks from contamination of soil at oil sites is the same as described above. Assuming current fencing regulations remain, contact with contaminated soil would require entering a well site, or migration of COPCs off site. Therefore, fencing and labeling of potential health dangers could mitigate any direct contact with site soils. 4.2.7 Air Contamination [Fort Collins, Current Conditions] The existing Fort Collins oil wells have the potential to release methane, H2S and VOCs to air from continuous, routine operations such as ongoing production and processing, product storage, and loading and unloading activities. Emissions may also be released from short- term operations such as repairs, work-overs and well stimulation. According to data provided by the site operator to the State of Colorado, the amount of gas produced by the Fort Collins wells is approximately 475 Mcf (457,000 cubic feet) per year. The gas emitted from processing operations, storage tanks, and truck loading operations at the Fort Collins tank battery is captured and routed through a thermal oxidizer control system. Residents could potentially be affected by chronic exposure to emissions from routine operations or by chronic and acute exposure to short-term emissions. The exposure is likely to be low due to 32 TERRA MENTIS the control efficiency of air pollution equipment and the short duration of non-routine operations. However, there are currently no publically available data quantifying VOC concentrations in the vicinity of nearby residences. The operator has conducted air monitoring for hydrogen sulfide. The potential health risks associated to exposed residents are dose-dependent, meaning they would increase with increasing exposure, or decrease with or decreasing exposure. 4.2.8 Air Contamination [Fort Collins, Future Potential] It is assumed that future potential oil development in and around Fort Collins would be similar to current oil extraction and gas extraction would be less prevalent because the primary deposit beneath Fort Collins is the oil bearing Muddy J. Gas exploration might occur on the southern and eastern boundaries of the city. The releases described above for oil development would be the same. An increase in the number of wells will potentially increase releases of volatile hydrocarbons, such as benzene, toluene, ethylbenzene and xylenes (also called BTEX), trimethylbenzenes and a host of aliphatic (straight chain) hydrocarbons. 4.3 HUMAN EXPOSURE TO COPCS: COMPLETE EXPOSURE PATHWAYS As noted earlier, for a risk to be present the exposure pathway from the source to the receptor must be complete. Figure 4-1 shows the potentially complete exposure pathways. The following sub-sections discuss the types of COPCs in the hydraulic fracturing process, and oil well products. These are sub-divided by receiving medium. 4.3.1 Potential COPC Releases to Water Under normal oil extraction procedures COPC releases to groundwater are less likely, and would require the failure of a well casing, or the rupture of a well or tank that discharges to ground- or surface water. This section discusses each of the COPCs that might be released to water in the event of an accident. 33 TERRA MENTIS 4.3.1.1 Fracturing Fluid Fracturing fluid consists predominantly of water and proppants (such as fine sand), which are not significant sources of concern. Fracturing fluids contain chemicals (Appendix B) that are typically propriety formulations with confidential compositions, although in accordance with an agreement with the Fort Collins, the operator has released their fluid compositions. The typical types of chemicals found in fracturing fluid and their potential health effects are discussed below. 4.3.1.2 Flowback and Produced Water After a well has been drilled and the oil or gas bearing formation has been opened using the hydraulic fracturing process, the pressure of the liquid in the shale forces the oil or gas to flow back up the well to the well head. The chemicals in this “flowback” liquid is a mix of dissolved fracturing fluid, proppants, and the produced water from the deep aquifer that contains chemicals previously trapped in the geologic formation. This water will potentially also contain increased total dissolved solids (TDS, brine, or salt water), naturally occurring radioactive materials (NORMs), and hydrocarbons (oil and gas). Historically, flowback water was flushed from a well into a holding pond or pit, which may or may not be lined where gases and VOCs were allowed to freely vent to the atmosphere. In Colorado, this practice is permitted under COGCC Rule 907. Generally, operators are not placing pits near residences, and low VOC emission completion technology is currently available to process flowback water (COGCC, 2014). After hydraulic fracturing, and the initial flowback period, the oil wells enter the production period. During this phase, volatile organic compounds may be vented to the atmosphere or captured and thermally oxidized (i.e., burned). Produced water is reused in fracturing other wells and/or re-injected back into Class II deep groundwater wells for disposal. Produced water can contain sulphide-producing bacteria that generate hydrogen sulphide (H2S) sometimes called “sour gas,” which is a toxic gas with an offensive odor. It can be a nuisance to residents near oil and gas operations. In the event of an accidental release, flowback or produced water would come into contact with soil at the drill site, surface water, and potentially shallow groundwater. These media are likely to be remediated. Groundwater remediation would be mandated under groundwater 34 TERRA MENTIS regulations for benzene and other toxic volatile compounds. However, there are no regulations or cleanup standards for fracturing fluids, and the toxicity of some fracturing fluid components are unknown. The volatile constituents in flowback or produced water can migrate from holding lagoons and tanks to the atmosphere. These VOCs include methane, volatile aromatic hydrocarbons, such as benzene, toluene, ethyl benzene, and xylenes (BTEX), trimethylbenzenes (TMBs) and aliphatic (straight chain) hydrocarbons. Fort Collins oil does not contain sour gas, which is more commonly associated with natural gas than crude petroleum, but it may be generated from the presence of sulfate-reducing bacteria. If these chemicals are released to the atmosphere they will disperse in air. Chemical concentrations at a residence will depend on the initial amount and concentration of the chemical released and atmospheric conditions such as wind speed and direction, temperature, humidity, atmosphere stability, and distance from the source. Releases to air are discussed below. Petroleum hydrocarbons are familiar because we use them every day to fuel engines. As such, we often forget they can have a wide range of adverse human health effects when inhaled, ingested or when they contact skin. In short, petroleum hydrocarbons can cause leukemia, cancers of the liver and kidney, and non-cancer health effects of the blood, liver, kidney, skin and neurological system. Summaries of the adverse health effects of petroleum hydrocarbons are available from regulatory and governmental agencies such as the Agency for Toxic Substances and Disease Registry (ATSDR, 2014), the International Agency for Cancer Research (IARC, 2014), the US Environmental Protection Agency’s (EPA’s) Integrated Risk Information System (EPA, 2014b), and many State agencies, such as the California’s Office of Environmental Health Hazard Assessment (OEHHA, 2104), and are not provided here. 4.3.1.3 Oil and Volatile Hydrocarbons Crude oil contains hydrocarbons with different structures, and aromatic and aliphatic carbon molecules of different length. The number of carbons in the carbon chain is typically used to evaluate oil’s physical characteristics. Crude oil also contains VOCs. In the event of an accidental release from an oil tank, the oil might contaminate soil, surface water, and 35 TERRA MENTIS potentially shallow groundwater. These media are likely to be remediated. Groundwater remediation would be mandated under groundwater regulations for benzene and other toxic volatile compounds. 4.3.1.4 Methane Releases to Water Methane is the primary target of natural gas production. Relative to Fort Collins oil production, gas is a by-product that may be released to water at a number of points in the oil production and storage process, from leaking flanges, piping, cracked casing, and cement containment at the well head below the ground surface. The EPA is conducting an on-going study of the issue that is titled, “Numerical modeling of subsurface fluid migration scenarios that explore the potential for gases and fluids to move from the fractured zone to drinking water aquifers.” A progress report called, “Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources, Progress Report,” was issued in 2012 (EPA, 2012). The results of this work will provide more information on the probability of this being a complete and significant pathway. Methane is of low human health risk, but represents a risk of explosion at levels over its Lower Explosive Limit (LEL) (five percent (5 %) in air). If methane were to migrate into a confined space and reach this level there is a potential danger of explosion. No wellhead screening process is currently required by the COGCC (COGCC, 2014). Methane gas migration has been shown to impact drinking water wells and in some historical situations local oil producers have been found responsible and were required to provide clean drinking water. However, this has only occurred in cases where groundwater methane was previously established or large amounts of methane were produced. Methane can migrate and accumulate as soil gas, and has led to home explosions. The EPA has previously stepped into situations where methane proves immediately dangerous to structural safely. 4.3.1.5 Naturally Occurring Radioactive Material Releases to Water Naturally occurring radioactive materials (often called NORMs) are found in oil and gas deposits and therefore in oil and gas production. The water pumped into the well during hydraulic fracturing, and subsequently pumped from the well will bring dissolved NORMS to the surface. The EPA has a website devoted to NORMs from oil and gas production, 36 TERRA MENTIS which was the source of the text below. The EPA identifies thorium, uranium (and its daughter products including radium, radon (a gas), polonium and lead). The following excerpts are taken from the EPA’s website: (EPA, 2014a). Much of the petroleum in the earth's crust was created at the site of ancient seas by the decay of sea life. As a result, petroleum deposits often occur in aquifers containing brine (salt water). Radionuclides, along with other minerals that are dissolved in the brine, precipitate (separate and settle) out forming various wastes at the surface: • Scale (or mineral deposits, mainly the insoluble salts of barium, calcium and strontium), that precipitate out as scaly deposits inside pipes, tanks, heater treaters and gas dehydrators (that can have up to four inch think deposits). • Sludges (or scaly precipitated deposits from produced water that precipitate out barium salts with oil, often with silica). • Contaminated equipment or components (technologically enhanced naturally occurring radioactive materials (TENORM) radioactivity levels tend to be highest in water handling equipment. Average exposure levels for this equipment were between 30 and 40 micro Roentgens per hour (μR/hr), which is about 5 times background. Gas processing equipment with the highest levels include the reflux pumps, propane pumps and tanks, other pumps, and product lines. Average radiation levels for this equipment are between 30 to 70 μR/hr. Exposures from some oil production and gas processing equipment exceeded 1 mR/hr, (EPA, 2014a) (or 125 times background). • Produced waters (The radioactivity levels in produced waters are generally low, but the volumes are large. The ratio of produced water to oil is approximately 10 barrels of produced water per barrel of oil. According to the American Petroleum Institute (API), more than 18 billion barrels of waste fluids from oil and gas production are generated annually in the United States. (EPA, 2014a) However, according to the USGS (1999), Radium tends to be more abundant in the more saline and chloride-rich varieties of produced waters. The maximum concentration of dissolved 226Ra in a limited data set provided by Fisher (1998) was several thousand picocuries per liter (pCi/L), but concentrations above 10,000 pCi/L have been reported in the U.S. Produced water also contains dissolved 228Ra, which is typically one-half to twice the 37 TERRA MENTIS concentration of 226Ra. For comparison, the U.S. EPA maximum contaminant level for drinking water is 5 pCi/L for total dissolved radium). Because the extraction process concentrates the naturally occurring radionuclides and exposes them to the surface environment and human contact, these wastes are classified as technologically enhanced naturally occurring radioactive materials (or TENORMs). (EPA, 2014a) Because TENORM contaminated wastes in oil and gas production operations were not properly recognized in the past, disposal of these wastes may have resulted in environmental contamination in and around production and disposal facilities. Surface disposal of radioactive sludge/scale, and produced water (as practiced in the past) may lead to ground and surface water contamination. Those at risk include oil/radiation waste disposal workers, and nearby residents/office workers. Risks evaluated for members of the public working or residing within 100 meters (980 feet) of a disposal site are similar to those of disposal workers. They include: direct gamma radiation, inhalation of contaminated dust, inhalation of downwind radon, ingestion of contaminated well water, ingestion of food contaminated by well water, and ingestion of food contaminated by dust deposition. Risks analyzed for the general population within a 50-mile radius of the disposal site include exposures from the downwind transport of re-suspended particulates and radon, and exposures arising from ingestion of river water contaminated via the groundwater pathway and surface runoff. Downwind exposures include inhalation of re-suspended particulates, ingestion of food contaminated by deposition of re-suspended particulates, and inhalation of radon gas. Many states with oil and gas production facilities are currently creating their own NORM regulations. For example, the State of Louisiana has regulations for NORM in scales and sludges from oil and gas production that differ from the Part N model regulations, where the State of Texas has NORM regulations similar to Part N regulations (EPA, 2014a). 38 TERRA MENTIS 4.3.2 Potential Risks of COPCs to Air As noted above, the majority of releases from the oil and gas extraction process are to air. This section discusses each of the COPCs that might be released to air from normal operations, from spills and in the event of accidents. When evaluating releases from the oil and gas extraction process that uses hydraulic fracturing it is important to differentiate between how VOCs might be released. In oil production, volatile hydrocarbons are released as an uncaptured fraction of the hydrocarbon (oil) collection process. However, in gas production the EPA estimates that a gas well releases 1 to 7 percent of the hydrocarbons taken from the well as VOCs (C&EN, 2014). The predominant point source of pollution from oil production is from storage tanks used to store produced water and produced oil. VOCs and methane may evaporate or leak from piping, tanks, flanges, and other connections. The active wells in Fort Collins currently produce as much as 475 Mcf (475,000 cubic feet) of methane annually, along with the oil it produces (COGCC, 2014). The current operator processes emissions through a thermal oxidizer, but product transfer provides an opportunity for methane and VOCs to vent to the atmosphere. Current development in the City of Fort Collins produces predominantly oil. If additional oil production did occur within the City limits, it would lead to an increase in VOC emission but on a larger scale. Health concerns are based on the presence of petroleum VOCs and natural gas. Releases to air from future gas development are discussed in Section 5.0. 4.3.3 Potential COPC Releases to Soil The potential for releases to soil are discussed above. The chemicals identified for water are the same set of chemicals that might be released to soil, and because contaminants in soil are less mobile than in water, contamination is less likely to migrate except as wind-borne dust. However, soil might represent a source of contamination for groundwater. 39 TERRA MENTIS 4.4 RELEVANCE OF EXPOSURE PATHWAYS TO RISK ASSESSMENT As noted in Section 2.0, risk requires that all four elements of exposure be complete. Figure 4-3 provides an example CSM for potential petroleum VOCs being released from a wellhead or storage tank, its transport medium, in this case air, and the point of exposure at the receptor. The letters in the square callout box show potential monitoring points, as follows: A. Air monitoring at the source B. Air monitoring at some distance from the source C. Air monitor at the residence D. Personal air monitoring on the resident E. Blood, urine or tissue sample monitoring (bio-assay) The closer to the source of VOCs the higher the concentration, and using benzene as an example, the following points are important to note. The concentration of benzene at point A would be higher than at point B because of dispersion. Higher benzene concentrations are generally easier to measure and easier to obtain better detection limits. Benzene will disperse in air and concentrations would be lower at the residence. Although the benzene concentration at the residence (point C) would provide better information on the level of benzene the resident might actually be exposed to, the source of the benzene at the residence might not be the source at point “A” but another source. Monitoring point D represents a personal monitor, where the air the resident actually breathes is measured by equipment worn by the resident. Due to the low level of chemicals generally found in air, detection limits should be established prior to sampling to make sure they are adequate for the project. For a limited number of chemicals it is possible to characterize exposure by monitoring particular biomarkers in blood, and other bodily tissues or fluids (point E). For benzene, for example it is possible to measure the biomarker, such as S-phenylmercapturic acid (Weisel, et al. 1996), but exposure must be at high levels for long periods of time to accumulate biomarkers at a measurable level. These biomarkers are generated by benzene from any source, not just the source in question. 40 TERRA MENTIS FIGURE 4-3 CONCEPTUAL SITE MODEL FOR VOC RELEASES TO AIR Primary Transport Source Exposure Point Route of Entry Risk Endpoint Tank or VOC Source Volatile Hydrocarbons Benzene, toluene, xylene, etc. Spill release to soil or groundwater Residence Well water VOCs and Ozone (Generated) Inhalation Child – Adult Increase cancer risk and health effects Air Residence Inhalation Ingestion Dermal Child – Adult Increase cancer risk and health effects A B C D E Migration in groundwater 41 TERRA MENTIS A similar CSM can be drawn up for each medium, and a similar inverse relationship between the distance from the source and concentration would also apply. The concentration of COPCs will decrease with distance. The higher the concentration the greater the risk associated with exposure. In addition, petroleum is a mixture of many compounds. To fully assess the risks, all of the COPCs (or at least all of the most toxic COPCs) should be monitored and quantified. The risk from each of these COPCs would then be added together. 4.5 SPECIFIC HEALTH EFFECTS OF COPCS The COPCs at oil and gas sites are predominantly hydrocarbons. Figure 4-1 indicates that inhalation is the primary pathway by which residents would be exposed, and Figure 4-3 indicates potential monitoring points. Benzene, toluene, ethylbenzene and xylene (BTEX) are the hydrocarbons that have been shown to have adverse health effects, and are the COPC regulated by oil and gas regulating agencies. US EPA Superfund programs use Regional Screening Levels (RSLs) to evaluate these constituents in a residential setting. These RSLs are based on adverse health effects, and are noted for both non-cancer, and cancer effects if appropriate. Typically there are one or two chemicals that “drive” the risk assessment, meaning they have the highest risk, and if the risks are understood, they can be used as a surrogate, or marker for exposure and risk. RSLs are health based and are generally established to be protective for long-term exposure. They are not based on what is achievable by engineering controls, or other technologies. The EPA has established RSLs for residential and industrial receptors. For comparison purposes the EPA’s Regional Screening Levels (EPA, 2014d) for BTEX are shown in Table 4-1 at the EPA and State of Colorado’s Point of Departure acceptable risk level of one in one million (10 -6 ). At the excess risk level of 10 -5 and a Hazard Index of 1.0 the Colorado Department of Public Health and Environment (CDPHE) requires sites in hazardous waste programs to undergo remediation, that is, implement active cleanup 42 TERRA MENTIS measures. However, there are no similar regulatory limits for cleanup concerning the emissions of BTEX from oil and gas production sites. “Why are industrial goals not applicable?” A number of organizations have benzene goals or action levels, air thresholds for worker safety, including the Occupational Safety and Health Agency (OSHA), National Institute of Occupational Safety and Health (NIOSH), American Conference of Governmental and Industrial Hygienists (ACGIH). Industrial action levels are applicable to workers only and not to residents for a number of reasons. Industrial workers are educated about the chemicals to which they might be exposed, they are provided protective equipment and are paid to understand and prevent exposure, while residents are not. Workers are generally healthy and typically do not have compromised health. Some residents may have compromised health or may be more susceptible (such as children). EPA also has RSLs for soil and tap water. These are also different from industrial soil contact levels for the same reason. Therefore, industrial levels may be cited, but they are inappropriate for residents. Cleanup levels exist for water and soil, but inhalation is the primary potential chronic exposure pathway. Two types of adverse health effect are considered: cancer and non-cancer effects. For inhalation risk assessments two elements are important: • The concentration of the chemical inhaled, and • The length of the exposure. The EPA has standard exposure parameters for residential exposure, which have been recently updated, and which are used at all sites across the US. 43 TERRA MENTIS Table 4-1 EPA Residential Inhalation Screening Levels1 for Petroleum Related Chemicals Chemical Name Residential Goal (10 -6 ) (µg/m 3 ) Type of Cancer 2 Residential Goal (HI=0.1) (µg/m 3 ) Target Organ Volatile Hydrocarbons 1,3-Butadiene 0.41 Leukemia in humans 0.88 Reproductive effects Benzene 0.36 Leukemia in humans 3.1 Lymphocyte Count Toluene NC NA 520 Neurological effects Ethylbenzene 1.1 Kidney cancer 100 Developmental toxicity Xylene(s) NC NA 100 Impaired coordination Trimethylbenzene NC NA 0.73 Blood clotting time Polynuclear Aromatic Hydrocarbons (Less Volatile) Benz[a]anthracene 0.11 Stomach cancer NA -- Benzo[a]pyrene 0.011 Stomach cancer NA -- Chrysene 1.1 Lung and Liver Tumors NA -- Naphthalene 0.36 Nasal Tumors 1.3 Nasal Effects µg/m 3 Micrograms per cubic meter NA Not applicable NC Non-carcinogenic 1. EPA Regional Screening Levels, EPA, 2014d 2. EPA IRIS files (EPA, 2014b) 4.5.1 Benzene Air Concentrations Near Gas Hydraulic Fracturing Wells There are a limited number of studies in Colorado measuring the concentrations of benzene in air near Gas Hydraulic Fracturing Wells. Benzene is considered a “driver” or critical chemical for petroleum VOCs, because it has the highest ability to cause cancer of all petroleum VOCs. TERRA MENTIS In November 2014, Thompson et al., (2014) published a paper titled; “Influence of oil and gas emissions on ambient atmospheric non-methane hydrocarbons in residential areas of Northeastern Colorado,” which provides data showing that benzene is higher in Platteville (a rural area) than in Denver (an urban area). And that non-methane hydrocarbon compounds are elevated across the Northern Front Range, with the highest levels found within the Greater Wattenberg Gas Field. The authors state: “This represents a large area source for ozone precursors in the Northern Front Range.” The study does not discuss the health risks associated with elevated ozone precursors, or the cancer and non-cancer health risks, as calculated using EPA’s methods. One key study by McKenzie et al., (2012) provided BTEX (and other hydrocarbon) concentrations at gas wells in Garfield County. Two types of data were collected: 1) samples from less than or equal to one-half mile from the well and samples from greater than one-half mile from the site. Benzene air concentrations closer to the flowback ponds ranged from 1 to 69 micrograms per cubic meter (µg/m 3 ), and benzene air concentrations further from the well site (greater than one-half mile) following well completion ranged from 0.1 to 14 µg/m 3 . Other hydrocarbon concentrations are also elevated, and summary statistics were provided. A comparison of the range of concentrations and the average concentration to the benzene screening levels shown in Table 4-1 indicated that some benzene concentrations were in excess of the 10 -5 risk level (should the exposure be for 30 years), where CDPHE requires sites in hazardous waste programs to undergo remediation for potential cancer impacts. The EPA’s acceptable risk range is one in ten thousand (1x10 -4 ) to one in one million (1x10 -6 ) and is difficult to conceptualize. Most State regulatory agencies require that hazardous waste sites achieve cleanup for single chemicals at a risk level of 1x10 -6 , and chemical mixtures at a risk level of 1x10 -5 . For benzene, this gives a risk equivalent to a benzene level of 0.36 µg/m 3 , alone. Typical indoor background benzene concentrations range from 1.9 to 7.0 µg/m 3 (75 th percentile range) (EPA, 2011). Indoor air benzene concentrations are provided as examples because they may include background benzene from an attached garage that would complicate benzene interpretation. 45 TERRA MENTIS The McKenzie et al., (2012) study has been criticized for using data from before Colorado regulations changed to require contained treatment technologies to manage flowback pond emissions (COGCC, 2014), and the data do not appear to have been republished with 2010 data. However, there is also no information showing the wells studied were in compliance with the 2009 regulations. Furthermore, on-going emissions would be unaffected by the contained treatment technologies. The McKenzie study also calculated non-cancer inhalation Hazard Indices (HIs) (hazards to blood) for the two data sets, and showed chronic HIs of 1.0 and 0.4 for close in and more distant data sets, respectively. Sub-chronic HIs, or an index of the chemical’s hazards for short-term exposure were higher, and also above one. Sub-chronic exposure represents a potential adverse health reaction to short duration exposures. The data in the McKenzie study were collected in 2008 and 2010, and might represent data at a residence located at the distances indicated. These distances (>0.5 miles, 800 meters) are considerably greater than the current range of setback distances of 500 feet (0.094 miles, 152.4 meters) to 1,000 feet (0.1894 miles, 304.8 meters). Chemical concentration decreases by dispersion with distance from the well so BTEX concentrations at the setback distance are likely to be higher than those reported in McKenzie et al., (2012). On a local level the concentration of air COPCs from a well will decrease with distance from the well due to air dispersion. Airflow patterns mean that air COPC concentrations will also vary with wind speed and direction carrying COPCs to or away from a particular receptor. This does not apply to situations where a well is in the center of a residential sub-division; this is a location where a residential receptor is always down wind. In a more recent study by Macy, et al. ((2014), which used a community-based sampling program where trained volunteers collected air data at locations suggested by residents near gas wells, benzene concentrations in Wyoming air as high as 110,000 µg/m 3 and toluene as high as 240,000 µg/m 3 were found at selected locations. These samples were taken 30 to 350 yards from the well, or from farmland along the perimeter of the well pad. A significant number of compounds were analyzed and detected, and one sample contain up to 1.6 million µg/m 3 total VOCs (excluding methane) suggesting that the sampling location is very 46 TERRA MENTIS important in any monitoring program, and that community involvement may also be important when considering a sampling program. 4.5.2 Benzene Childhood Cancers and Birth Defects The US EPA’s (2009) Benzene TEACH Summary states, “Two studies have shown a significantly increased risk of childhood leukemia associated with paternal exposure to benzene (Buckley, et al., 1989; McKinney et al., 1991), while another showed no such association (Shaw, et al., 1984). A case control interview study showed that acute non- lymphocytic leukemia was significantly associated with maternal occupational exposure to benzene during pregnancy (Xiao, et al. 1988). The EPA’s toxicological update on benzene states: “The effects from exposure to benzene can be quite different among subpopulations. Children may have a higher unit body weight exposure because of their heightened activity patterns, which can increase their exposures, as well as different ventilation tidal volumes and frequencies, factors that influence uptake. This could entail a greater risk of leukemia and other toxic effects to children if they are exposed to benzene at similar levels as adults. Infants and children may be more vulnerable to leukemogenesis because their hematopoietic cell populations are differentiating and undergoing maturation. Many confounding factors may affect the susceptibility of children to leukemia (e.g., nutritional status, lifestyle, ethnicity, and place of residence) (EPA, 1998).” “Some recent research has shown, with limited consistency, that parental occupational exposure to benzene plays a role in causing childhood leukemia. Shu et al. (1988) conducted a case-control study of acute childhood leukemia in Shanghai, China, and found a significant association between acute nonlymphocytic leukemia (ANNL) and maternal occupational exposures to benzene during pregnancy (OR = 4.0). These excesses occurred among second- or later-born children rather than firstborn children. In addition, Mckinney et al., (1991) conducted a case-control study to determine whether parental occupational, chemical, and other specific exposures are risk factors for childhood leukemia. They found a significant association between childhood leukemia and reported preconceptional exposures of fathers to benzene (OR = 5.81, 95% confidence intervals 1.67 47 TERRA MENTIS to 26.44) and concluded that the results should be interpreted cautiously because of the small numbers, overlap with another study, and multiple exposures of some parents. Furthermore, Buckley et al. (1989) conducted a case-control study of occupational exposures of parents of 204 children (under 18 years of age) with ANNL. They found a significant association between ANNL and maternal exposure to pesticides, petroleum products, and solvents. Among many chemicals, benzene was identified as one of the solvents. These studies, however, have not provided data to indicate how the occupational exposures might affect offspring. Some possible mechanisms include a germ-cell mutation prior to conception, transplacental fetal exposures, exposures through breast milk, or direct exposures postnatally to benzene from the environment.” (EPA, 1998) Recent studies have found similar results linking the presence of leukemia in children to residing in close proximity to gasoline stations and roads. A 2004 Italian study (Crosignani et al., 2004) that looked at 120-childhood leukemia cases in relation to traffic exhaust found a strong correlation between estimated benzene concentration above 10 micrograms per cubic meter (µg/m 3 ) with childhood leukemia, and in particular acute non-lymphocytic leukemia. However, benzene concentrations were estimated using a model and proximity to a highway. Three benzene levels were used and there was a dose-related correlation. At 300 meters (984 feet) impact was assumed to be negligible, based on an EPA (2001) model. A 2004 French study (Steffen et al, 2004) that looked at 280 childhood leukemia cases in relation to gas stations or repair garages found a strong correlation of location with leukemia, and in particular acute non-lymphocytic leukemia. However, the dose to child is not provided, and the level of benzene linked to the childhood leukemia is unclear. These findings were supported by a 2009, 765 leukemia case-study (Brosselin, 2009). A 2006 US study (Utah, 2006) identified that children living in close proximity to roads (< 150 meters, 492 feet) appear to have an increased risk for all types of childhood leukemia and for myelogenous leukemia. Benzene levels were estimated using a model to be >5 µg/m 3 . The study did not account for confounding factors. 48 TERRA MENTIS The above findings suggest that a pregnant woman exposed to high levels of benzene during pregnancy, especially during the stage of fetal blood system development, would have higher risks of birthing a child with childhood leukemia, and children exposed to benzene (or gasoline) have a higher risk of acute non-lymphocytic leukemia. The benzene concentrations, the associated exposure duration, and the sensitive period duration during pregnancy are unclear. However, benzene exposure concentrations are within the range of those measured by McKenzie (2012). McKenzie, et al., (2013) examined the relationship between birth outcomes and maternal residential proximity to natural gas development in rural Colorado and in a large cohort, observed an association between the density and proximity of natural gas wells (in a 10 mile radius) and the teratogenic effects of congenital heart defects and possible neural tube defects. Childhood leukemia was not studied. There are limited studies measuring benzene levels near oil and gas operations, and the studies that currently exist indicate that benzene concentrations vary when containment or evaporation pits are used versus under low VOC emission completion techniques, as shown by the McKenzie study (2012). Typical benzene concentrations are shown in Table 4-2. TABLE 4-2 TYPICAL ENVIRONMENTAL BENZENE CONCENTRATIONS Type of Study and Location Benzene Concentration (µg/m 3 ) Toluene Concentration (µg/m 3 ) Service station attendant 910 ± 140 1580 ± 180 Mechanic repairing gas pump 233 ± 165 2218 ± 1736 Air within service station 4 ± 2 47.7 ± 27.4 Worker air within service station 5 ± 6 330 ± 393 Customer refueling car 1767 ± 1595 27,878 ± 28,337 Air external to service station 17 ± 3 27 ± 38 23 ± 4 Source: Edokpolo, et al., 2014 49 TERRA MENTIS 4.5.3 Other Petroleum Hydrocarbons Petroleum contains a host of organic molecules that have adverse health effects, and benzene is only one of many that are potentially carcinogenic (will cause cancer). It was evaluated in greater detail due to its more well-known and severe toxic effects. Ethylbenzene has been shown to cause kidney cancer in mice (Cal EPA, 2007), and it was listed under California’s Proposition 65 as a cancer-causing agent in 2004. The EPA considers the potential effects of two or more carcinogenic chemicals to be additive, so the cancer risks from benzene and ethylbenzene and other chemicals would give an added risk. 1,3-Butadiene has been shown in epidemiological studies to cause leukemia (EPA, 2002). The EPA considers the potential effects of two or more carcinogenic chemicals to be additive, so the cancer risks from 1,3-butadiene, benzene, ethylbenzene and other cancer causing chemicals would be added together in a risk assessment. The McKenzie study provides summed risks, which is the appropriate approach for carcinogenic chemicals under US EPA risk assessment guidance. Other less volatile petroleum chemicals that cause cancer in animals, and that are suspected of causing cancer in humans are polynuclear aromatic hydrocarbons. These chemicals are more associated with oil than gas, but could be present in all petroleum products and gases at low levels. They can often have a greater ability to cause cancer in children because the mechanism of cancer development is more active in the rapidly developing DNA of a child. All chemicals can have adverse health effects and because petroleum hydrocarbons are a mixture of many chemicals; each can be evaluated individually, or the total petroleum hydrocarbon (TPH) suite can be evaluated as a whole. A number of government agencies have issued toxicological reviews of TPH especially, the Agency for Toxic Substances and Disease Registry (ATSDR, 2011). The State of Massachusetts has developed health-based toxicity values for petroleum hydrocarbons (MassDEQ, 2003). The important fact is that all of the chemicals in petroleum hydrocarbons can act together to have potential additive adverse health effects, and for volatile hydrocarbons that can migrate 50 TERRA MENTIS in air to a resident, and the potential effects depend on the level of exposure, which is dependent on the release concentration, and the distance to the source. 4.5.4 Hydrogen Sulfide (H2S) (7783-06-4) Hydrogen sulfide is the toxic gas found in sour gas, but in Fort Collins oil well bacteria within the wells may produce it. If inhaled at high concentrations hydrogen sulfide is toxic by many mechanisms including the prevention of cellular respiration, but at low concentrations it is more of an unpleasant nuisance because it has the smell of rotten eggs. The odor threshold also known as the recognition is 0.00047 parts per millions (ppm) or 0.47 parts per billion (ppb) (Iowa, 2004). The EPA’s RSL for H2S is 0.2 µg/m 3 (0.0001 ppm) (HQ = 0.1), and the OSHA Immediately Dangerous to Life and Health level is 100 ppm. High concentrations may be encountered by oil and gas workers but generally not encountered by the general public. H2S may prove a problem to those living within close proximity to active wells. 4.5.6 Particulate Matter (PM) Particulate matter (PM) is the term used for small particles of dust, and smoke in the air, and it can prove a concern at oil and gas sites. Particles in the air can range in size, and the small particles are of more concern than large ones because they can penetrate deeper into the lung, by passing the lung’s protective mechanisms. Two types of PM are often monitored: particulate matter that has a diameter of ten micrometers (PM10), and particulate matter that has a diameter of two and a half micrometers (PM2.5). PM may be produced in the fracturing process by the diesel engines used to run drill rigs, compressors, pumps and other equipment or through the dirt kicked up by heavy truck traffic. Both of these concerns are temporary and unique to specific parts of the hydraulic fracturing process and can last for weeks in the life of a well. These are only issues for residences located in very close proximity to unpaved roads and/or the drill pad. It is more of a concern for workers, and no significant hazards are likely due to current Fort Collins operations. PM2.5 emissions from oil and gas development can be a significant concern both locally and regionally when emissions contribute to ozone formation or acid deposition or form toxic or contain carcinogenic compounds that can be inhaled. These emissions can be emitted from fuel combustion for processing equipment and 51 TERRA MENTIS vehicles as well as emitted product and wastes generated during the extraction and production process. 4.5.7 Ozone (O3) (10028-15-6) Ozone is an invisible gas made of three oxygen atoms (O3). Ozone is often referred to as smog, and is formed when two groups of gases, VOCs and nitrogen oxides, undergo a chemical reaction in the air in the presence of sunlight. Ozone reacts chemically ("oxidizes") with internal body tissues, such as those in the lung, where it irritates and inflames the respiratory system at levels frequently found across the nation during the summer months. Breathing ozone may lead to: • Shortness of breath, chest pain • Inflammation of the lung lining, wheezing and coughing • Increased risk of asthma attacks • Make lungs more susceptible to infection People with lung diseases, such as asthma or chronic obstructive pulmonary disease (COPD), often need medical treatment or hospitalization. These diseases can lead to premature death. The EPA has a good body of information on the adverse health effects of ozone (EPA, 2014c). 4.5.8 Nitrogen Oxides (NOx) Oxides of nitrogen are nitrous oxide (NO), nitrogen dioxide (NO2) and nitrogen trioxide (NO3). They are all gases. When they contact water, either in the environment or in the lung, they can form acids and can irritate or burn lung tissue causing irritation, asthma, and other lung problems. 52 TERRA MENTIS 4.6 SUMMARY OF MAJOR SOURCES OF AIR POLLUTION In summary, barring spills, the major exposure pathway to COPCs from hydraulic fracturing is the inhalation of pollutants released to air. The COPCs discussed above typically come from the following processes: Drilling: NOx from engines, thermal oxidation; VOCs, PM from engines; VOCs and HAPs from well venting and flowback Completion: VOCs and HAPs from hydraulic fracturing; NOx from engines, thermal oxidation Production: VOCs, HAPs and H2S from production equipment, work overs, blowdowns, pipelines, leaks from components, flanges, tanks and trucks; NOx from engines and heaters; PM from engines 53 TERRA MENTIS 5. AIR, SOIL AND WATER ANALYSES FOR FUTURE POTENTIAL CONDITIONS This section provides a brief description of the COPCs that might potentially be released to air, soil and water under the future scenario of hydraulic fracturing during oil and gas production in the City of Fort Collins. Currently, hydraulic fracturing in Fort Collins is used for oil extraction. Given the type of oil and gas resources beneath Fort Collins, oil extraction is more likely in the future. However, hydraulic fracturing for gas extraction near Fort Collins is increasing, especially in Weld County, which borders the City. While the same process may be used, leading to the release of the same COPCs, gas extraction typically leads to a different mix of COPCs. 5.1 RELEASES TO AIR FROM GAS EXTRACTION Methane, hazardous air pollutants (HAPs) such as benzene, toluene, ethylbenzene and xylenes (BTEX), trimethylbenzenes and a host of aliphatic (straight chain) hydrocarbons, and other chemical releases to air are routine and on-going at most oil and gas wells. Methane releases are more common with gas wells. Methane is released primarily from venting during drilling, workovers, and blowdowns; tanks, process equipment and component leaks, and has been shown to represent a loss of up to seven percent (7%) of a well’s gas production (Howarth et al, 2012). In their statement of basis for Colorado’s Regulation Number 7, concerning, “The control of ozone via ozone precursors and control of hydrocarbons via oil and gas emissions,” Section XIX indicates that 1996 estimated annual nationwide methane emissions are approximately 31 billion cubic feet (Bcf) from the production sector, 16 Bcf from the processing sector, and 14 Bcf from the transmission sector (5 CCR 1001-9). Released methane will migrate from the well into the atmosphere. Methane is a naturally occurring hydrocarbon found at low levels in marshes, surface water and groundwater. Methane is of low human health risk, but it is of concern in ozone nonattainment areas because it is an ozone precursor. Methane represents a risk of explosion at levels over its Lower Explosive Limit (LEL) (five percent (5 %) in air). If release rates reach levels that are 54 TERRA MENTIS too high, remediation of the well is required, although no wellhead screening process is currently required by the COGCC (COGCC, 2014). While this document does not address regulations, it should be noted that Colorado Regulation Number 7 (5 CCR 1001-9) has provisions that require reporting of methane and VOCs emissions, with the goal of reducing ozone precursor chemicals because of ozone nonattainment in parts of Denver, Boulder, Weld and Larimer Counties. These reporting requirements will provide general data on methane and VOC releases, but will not provide location specific methane or VOC concentration data for the area subject to reporting. 5.2 RELEASES TO WATER FROM GAS EXTRACTION In historical situations and in other States, methane gas migration has been shown to impact drinking water wells; local oil producers have been found responsible and were required to provide clean drinking water. However, this has only occurred in cases where groundwater methane was previously established or large amounts of methane were released, and groundwater is relatively close to methane producing zones. VOCs can migrate with methane and may contaminate groundwater aquifers under specific conditions of close proximity, leaking or ruptured well casings, and spills. 5.3 RELEASES TO SOIL FROM GAS EXACTION Methane can migrate and accumulate as soil gas, and historically has led to home explosions. The EPA has previously stepped into situations where methane proves immediately dangerous to structural safely. VOCs can migrate with methane and may contaminate soil under specific conditions of leaking or ruptured well casings, and spills. 55 TERRA MENTIS 6. FURTHER CONCERNS As oil and gas development comes closer to urban centers and residential areas, other concerns need to be considered besides the ingestion of and contact with dangerous chemicals. Increased truck traffic through neighborhoods and on city roads can increase noise, pollution and utility wear. The increased contact between citizens and wells can have a direct effect on social cohesion within a community and aesthetic concerns of neighboring citizens. Recent increases in earthquakes in Colorado have also prompted public concern for the connections between oil and gas and induced seismicity. Finally, recent drought conditions in Colorado and around the United States have highlighted concerns by citizens as to the amount of water that is used by the oil and gas industry, especially during seasons when water is scarce. 6.1 TRUCK TRAFFIC The process of fracking can require a large number of trucks to bring equipment onto the well site. This can be as many at 400 truck trips per site, which varies depending on whether fracturing is occurring, how productive the wells might be, and the methods by which oil is moved from the site (ANL, 2013). At the current locations of the Fort Collins oil wells, heavy truck traffic is not common because they have already been constructed and fractured. However, the wells are located within residential areas and heavy truck traffic may prove to be a noise nuisance and a heavy diesel pollutant source if further fracturing or new development occurs. As a health concern these are low as the levels of both PM and emissions from diesel combustion should not be regularly occurring and should be in levels lower than other pollutants within the City of Fort Collins. 6.2 SOCIAL DIMENSIONS The oil and gas work can affect the social fabric of communities that have fracking. This is due to several factors. First, the proximity to oil and gas can cause personal views on oil and gas development to be a dominating issue of discussion and dissension between neighbors. These issues can highlight differences and conflicts within neighborhoods. Secondly, 56 TERRA MENTIS increased oil and gas activity can cause unrest with the proximity of the wells to individual houses. These proximities can have effects on quality of life and housing prices. In most cases housing prices will decrease due to proximity to wells due to the recent publicity of health concerns related to fracking. House worth can be directly connected to personal satisfaction and happiness due to the connection many draw between personal assets and success. 6.3 AESTHETIC ASPECTS Aesthetic aspects of oil and gas drilling must be considered due to the importance of issues such as noise and light pollution, which can be a major concern to citizens. Current regulations require the mitigation of aesthetic concerns by painting the equipment to match the landscape, high fences to hide equipment, and the addition of natural obstacles (trees or shrubs) in locations near to residences. However, it is unreasonable to expect the complete camouflage of a multi-acre well pad. Besides the visual aesthetics of natural gas, bacteria within a well produce hydrogen sulfide and can cause a detectable and irritating smell to those who reside near a well or well activities. This can negatively affect the resident’s enjoyment of their property and the outdoors. This is also a driver of housing cost decreases. A positive nascence, industrial sites may provide incentive for young children to visit the site when located near residences. For instance heavy machinery, especially pump jacks can prove attractive to children and adolescents. It is therefore important to close off areas that may be of interest to children, and post signs warning adults of dangers. 6.4 INDUCED SEISMICITY Induced seismicity is a prominent concern, especially in Fort Collins and neighboring cities like Greeley. As research stands currently, induced seismicity has not been linked to the process of hydraulic fracturing (Keranen et al., 2014). However, it has been linked to Class II deep well injection. This utilizes the process of injecting wastewater into deep wells at high pressure to dispose of wastewater. There has been seismic activity measured in Colorado and 57 TERRA MENTIS near Fort Collins. There has also been increased seismic activity in other parts of the country connected to the disposal of water at high pressures (Keranen et al., 2014). The nearest injection wells are located in Weld County and have been under heavy scrutiny as of May 2014 due to recent earthquakes in the region (Magnitude 3.4 on May 31 st , 2014). Earthquake censors were installed in June 2014 to measure quakes as they happen (KUNC, 2014). 6.5 DROUGHT CONDITIONS Colorado frequently deals with drought conditions. Currently, water for active wells in Fort Collins is drawn from groundwater (Walsh, 2013). If drought conditions occur, oil and gas developers are not required to limit their usage of water due to shortages. This may cause a depletion of groundwater aquifers, depending on withdrawal volumes. This could take water from citizens but more likely from other industries such as ranching or farming. Another issue to consider is the potential future use of municipal or surface water sources for oil and gas development. 58 TERRA MENTIS 7. ENVIRONMENTAL CONSIDERATIONS This section briefly discusses the release of Greenhouse Gases (GHGs) and their potential impact on the environment. Greenhouse Gas emissions have been tied to climate change and transitively to increases in environmental hazards. As a progressive city, GHG is a major concern for the City of Fort Collins. Maintaining and enhancing the practices of a sustainable city depends on reducing emissions of GHGs. Fort Collins is currently investigating setting new goals on greenhouse emissions to 80 percent below 2005 levels by 2030 and carbon neutrality by 2050. These goals are aggressive in the face of a 4.9 percent population increase since 2011 and two consecutive years of increased carbon emissions. Despite 2013 increases, Carbon emissions have been reduced overall by 4.9 percent from the 2005 level but further steps must be taken to reach the 2030 goal. Oil and gas wells will produce varying amounts of GHGs throughout their lifetime. In the early stages of the lifetime of wells, diesel trucks, generators, and other heavy machinery will produce CO2 at levels similar to construction sites. The heavy truck traffic can contribute to city transportation emissions. Methane leakage from wells is a major concern for GHG release. Methane is between 105 and 108 times more effective as a GHG for the first 20 years (referred to as global warming potential (GWP)) (Howarth et al., 2012; C&EN, 2014). This high potential for global warming makes methane “the second largest contributor to human- caused global warming after carbon dioxide” (Howarth et al., 2012). One of the largest conflicts between researchers is the percentage of methane released from upstream well sites. Current estimates of the percentage of methane produced that ends up as fugitive methane emissions range from 0.6 to 4.0 percent with the EPA level set at 3.0 percent (Stephenson et al., 2011; Petron et al., 2012, Howarth et al., 2012). The most robust and applicable study is Petron et al. (2012 and 2013), which took place over a year and focuses on the Weld County wells and the Colorado Front Range. This study found that a range of 2.7 to 7.7 percent of natural gas is emitted from well sites with a best estimate at 4 percent. The study does not include any emissions that may result from transport and processing of natural gas off-site. 59 TERRA MENTIS The added GHG from current Fort Collins wells is considerably low, as they produce no more than 500 Mcf of methane a month. The percentage of produced natural gas that is released is important to consider if natural gas was ever produced within city limits. Considering the possibility that each well leaks 3 percent of its total produced methane (EPA estimation and middle of applicable study ranges) then a single well producing 100,000 Mcf of natural gas annually can expect to release 3,000 Mcf of gas in emissions. Some wells in Larimer County produce as much as 200,000 Mcf of natural gas in a year (COGCC, 2014). As the number of wells increases and the target of drilling includes natural gas, the amount of annual methane will significantly increase. The GHG emission goals of Fort Collins do not coincide with the prospect of increased natural gas drilling. With methane’s higher GWP over the short term, carbon reduction goals for 2030 and 2050 will be significantly affected. As noted above, the recent study by Thompson et al., 2014, has quantified air concentrations for urban and rural areas of Northern Colorado, in particular, Platteville was shown to have benzene levels greater than Denver (an urban setting) and non-methane hydrocarbon concentrations are also high. 60 TERRA MENTIS 8. ONGOING RESEARCH This section provides a brief overview of some of the key studies in Colorado, and other States, that are evaluating the amounts and types of chemicals in air due to oil and gas extraction (that might use hydraulic fracturing) and other sources, the risks associated with airborne chemicals, and other health-related studies. There are a number of ongoing scientific research projects that are applicable to the city of Fort Collins, either directly or indirectly. The authors are aware of the larger scale studies described below. Smaller scale studies, conducted by individual researchers of which the authors are unaware, may also be on-going. From a risk assessment perspective, the studies described below are designed to gather data for exposure assessment (i.e., how individuals or communities may be exposed to chemicals released during hydraulic fracturing), and for toxicity assessment (i.e., how these chemicals may adversely affect individuals or communities). Local studies are presented first, followed by national studies. Due to the on- going nature of these studies it is difficult to determine what the results might show. 8.1 NATIONAL AERONAUTICS AND SPACE ADMINISTRATION, COLORADO FRONT RANGE The Frappé Study (Front Range Air Pollution and Photochemistry Éxperiment; NCAR, 2014) is a collaborative effort between the Colorado Department of Public Health, CU-Boulder, CSU, UC Berkeley, and other universities, local agencies, National Center for Atmospheric Research (NCAR), National Aeronautics and Space Administration (NASA), and NOAA. The study uses aircrafts to measure tracers, methane and non-methane hydrocarbons at atmospheric levels, collect photochemical data via flyovers and measure ground concentrations throughout the flight area. The Flights began on July 16 th , 2014 and continued through August, 2014. The availability of the results and timeline for publication of the results are currently unknown. 61 TERRA MENTIS 8.2 NORTH FRONT RANGE EMISSIONS AND DISPERSION STUDY, COLORADO FRONT RANGE The North Front Range Emissions and Dispersion Study is a research project spearheaded by the Collett Research Group from the Department of Atmospheric Science at Colorado State University. Professor Jeffrey L. Collett, Jr. leads this research group, and the CDPHE funds the project. The research project focuses on oil and gas emissions using mobile air quality laboratories and high sensitivity air analysis equipment. This study is expected to be completed in 2016 (CSU, 2014) (Table 8-1). 8.3 NATIONAL SCIENCE FOUNDATION, ROCKY MOUNTAIN FRONT RANGE, COLORADO AND WYOMING The National Science Foundation is funding studies with scientists in the Front Range to study “Routes to Sustainability for Natural Gas Development and Water and Air Resources in the Rocky Mountain Region.” These studies focus on air quality impacts from methane and ozone, health effects related to proximity to wells, and methods and technologies of wastewater treatment. Research locations are focused on Colorado, Utah, and Wyoming. Professor Joseph Ryan of CU-Boulder coordinates these ongoing studies and results and papers associated with the research are released online as they become available (airwatergas.org). This meta-study in its entirety is expected to be completed at the end of 2018 (Table 8-1). 8.4 ENVIRONMENTAL DEFENSE FUND, COLORADO AND NATIONAL METHANE STUDY In 2012, The Environmental Defense Fund (EDF) provided support for 16 methane studies around the United States. These studies are targeted at understanding methane emissions in the context of climate change. Of the 16 studies, six of them target Colorado and the methane emissions from Colorado gas development. These studies work with CSU, CU-Boulder and National Oceanic and Atmospheric Association (NOAA) to provide a complete picture of methane emissions from the industry from production to distribution. The majority of the studies will use air-sampling data both upstream and downstream of leakage points (wells, storage facilities, processing plants, etc.). These studies will rely on atmospheric 62 TERRA MENTIS measurements and tracer gas to track ambient methane release as well as point source release. These studies are expected be published by the end of 2014 (EDF, 2014) (Table 8-1). 8.5 ENVIRONMENTAL PROTECTION AGENCY, NATIONAL DRINKING WATER STUDY An EPA Study is currently under way as the EPA portion of a Multi-Agency (EPA, DOE, and DOI) collaboration on unconventional oil and gas research. The EPA Study entitled “The Potential Impacts of Hydraulic Fracturing on Drinking Water Resources,” will focus on the interaction between hydraulic fracturing and drinking water. It will cover the stages of water acquisition, chemical mixing, well injection, wastewaters, and wastewater treatment and disposal. This study is done with the cooperation of industry partners and will include a case study location. This investigation will not create toxicity data for chemicals used in hydraulic fracturing, but will evaluate existing chemical profiles. A draft report of the findings is expected for public comment and review in early 2015 (Table 8-1). 8.6 HYDRAULIC FRACTURING AND ENDOCRINE DISRUPTERS IN GARFIELD COUNTY, COLORADO Dr. Susan Nagel, an associate professor of Obstetrics Gynecology and Women’s Health at the University of Missouri, has been studying hormones and endocrine-disrupting chemicals associated with water from hydraulic fracturing in Garfield County, Colorado. An abstract published in 2013, “hypothesized that a selected subset of chemicals used in natural gas drilling operations and also surface and ground water samples collected in a drilling-dense region of Garfield County, Colorado, would exhibit estrogen and androgen receptor activities. Water samples were collected, solid-phase extracted, and measured for estrogen and androgen receptor activities using reporter gene assays in human cell lines. Of the 39 unique water samples, 89%, 41%, 12%, and 46% exhibited estrogenic, antiestrogenic, androgenic, and antiandrogenic activities, respectively.” (Kassotis, et al., 2013). According to a community website update on July 7, 2014, Dr. Nagel has received additional funding and plans to continue her research in Garfield County. (Styx, 2014). 63 TERRA MENTIS 8.7 FLOWER MOUND’S CANCER CLUSTER, TEXAS HEALTH STUDY In response to residents' concerns about the health effects of natural gas drilling in the vicinity of Flower Mounds Texas, the health department conducted an analysis of cancer cases in two zip codes to address concerns after tests found cancer-causing benzene in the air around some drilling sites. The study reviewed cases of leukemia in children and adults, non-Hodgkin's lymphoma, childhood brain cancer and female breast cancer from 1998 to 2007 in two ZIP codes covering most of Flower Mound, TX. Texas State health officials found no evidence of a cancer cluster in Flower Mound, according to a study released in 2010. Researchers compared the findings with the number of expected cases based on statewide rates. The number of cases was within the statistically normal range except for breast cancer, the researchers found. Breast cancer cases were slightly higher than the number of expected cases. However, a review by a University of Texas at Austin researcher in the Virginia Environmental Law Journal (Rawlins, 2013) said the state was too quick to dismiss the study and that the State was doing little to identify “Hotspots.” Dr. Maria Morandi, a faculty affiliate and former research professor from the Center for Environmental Health Sciences at the University of Montana reanalyzed the data and found, with 95 percent certainty, that rates of childhood leukemia and childhood lymphoma in Flower Mound are significantly higher than expected; there is only a 1 in 20 chance that the difference is random. The discussions concerning the additional cases of cancer continue. 8.8 HOUSEHOLD SURVEY IN WASHINGTON COUNTY, PENNSYLVANIA HEALTH STUDY Dr. Peter Rabinowitz, formally of Yale University School of Medicine, New Haven, Connecticut, and now with the University of Washington, Seattle, Washington, recently published a study of health effects in the proximity of natural gas wells in Pennsylvania (Rabinowitz, et al., 2014). The conclusion of the study states: “The results of this study suggest that natural gas drilling activities could be associated with increased reports of dermal and upper respiratory symptoms in 64 TERRA MENTIS nearby communities and support the need for further research into health effects of natural gas extraction activities. Such research could include longitudinal assessment of the health of individuals living in proximity to natural gas drilling activities, medical confirmation of health conditions, and more precise assessment of contaminant exposures.” 8.9 HOW THESE STUDIES MIGHT AFFECT FORT COLLINS The studies described in Section 8.1 through Section 8.4 will provide data on hydrocarbons released, and air quality data on the Colorado Front Range air shed. They are also designed to explore relationships between hydraulic fracturing, hydrocarbon releases and ozone, which exceeds EPA’s acceptable concentration in the Front Range. While Fort Collins is affected by this air shed, and ozone non-attainability is an issue for Fort Collins residents, current oil extraction is expected to have an insignificant effect on air quality compared with hydraulic fracturing and gas extraction in Weld County. The results of these studies may be incorporated into an area-wide plan that might include Fort Collins. The EPA study described in Section 8.5 will provide data on hydraulic fracturing and groundwater, and would only be applicable to Fort Collins in a general sense. The studies described in Section 8.6 through Section 8.8 will provide data on the potential adverse health effects from hydrocarbons released during hydraulic fracturing. They are specifically relevant to Fort Collins because they investigate the relationship between chemicals released during hydraulic fracturing and potential adverse health effects. These data, with other health related data, might be used to establish the risks from a hydraulic fracturing chemical under investigation (e.g., benzene) at a particular concentration. This concentration might then be used to determine a level of acceptable exposure for the City of Fort Collins. 65 TERRA MENTIS TABLE 8-1 TIMELINE FOR ONGOING STUDIES RELATED TO OIL AND GAS DEVELOPMENT Study Task 2013 2014 2015 2016 2017 2018 Front Range (Section 8.1) Data Collection Data Publication CSU (Section 8.2) Funding Procurement Study Design Data Collection Results Health Impacts Analysis NSF (Section 8.3) Funding Procurement Study Design Data Collection Results Health Impacts Analysis EDF (Section 8.4) Funding Procurement Study Design Data Collection Results Health Impacts Analysis 66 TERRA MENTIS TABLE 8-1 (CONTINUED) TIMELINE FOR ONGOING STUDIES RELATED TO OIL AND GAS DEVELOPMENT Study Task 2013 2014 2015 2016 2017 2018 EPA (Section 8.5) Funding Procurement Study Design Data Collection Results Health Impacts Analysis Data Collection University of Missouri (Section 8.6) Results Health Impacts Analysis Publications-Ongoing Texas Health Study Ongoing Pennsylvania Health Study Ongoing 67 TERRA MENTIS 9. FINDINGS AND CONCLUSION The findings and conclusions presented in this sub-section were developed based on the material presented in this report, and the literature from which the facts were taken. Findings specific to the City of Fort Collins are presented first, followed by findings related to hydraulic fracturing in general. 9.1 FRAMEWORK FOR THE PROCESS AND FINDINGS The US EPA’s risk assessment process provides a framework for this support document because it uses a process accepted by regulatory agencies since the 1980s, it systematically considers all aspects of exposure, it evaluates potential adverse cancer and non-cancer health effects, and there are promulgated acceptable risk levels that are applicable in a public health setting. The EPA’s risk assessments have four parts: site characterization, exposure assessment, toxicity assessment and risk characterization. The use of this framework is directly applicable when considering exposure to chemicals from hydraulic fracturing in Fort Collins. 9.1.1 Site Characterization and the Hydraulic Fracturing Process Site characterization provides a summary of the site settings, and discusses chemicals present in air, surface water, groundwater and soil under background (unaffected) and under impacted conditions at a site where hydraulic fracturing might take place. Findings specific to Fort Collins: a. There are no published background site characterization data for air, groundwater, and soil around the existing Fort Collins oil wells. b. There are no published site characterization data for potential public health impacts from Fort Collins oil wells. c. Available COGC data suggest that current hydraulic fracturing practices in the Muddy J formation (extraction from sandstone, which is similar geology to that beneath Fort Collins) are significantly different from hydraulic fracturing practices used to extract natural gas from the surrounding Niobrara shale formation (Weld and Larimer County). 68 TERRA MENTIS d. Substantially lower volumes of fracturing fluid are used in the Muddy J (similar to Fort Collins) compared with the Niobrara formation (Weld and Larimer County). e. The lower volumes of fracturing fluids and pressures would likely result in lower volumes of flow-back water, and low emissions during fracturing and well completion at current and future potential oil wells developed in Fort Collins. Site Characterization and the Hydraulic Fracturing Process General Findings: f. Site characterization data at locations where hydraulic fracturing is used at oil and gas wells in Weld and Larimer County are generally poor. g. There are no site-specific studies that compare the magnitude of emissions from hydraulic fracturing in different geologic formations. h. There are studies showing that chemicals are routinely released to air from gas wells during and after hydraulic fracturing. And this is the primary exposure pathway for human health. 9.1.2 Exposure Pathways and Chemicals of Concern An exposure pathway is the means by which a chemical moves from it source (e.g., a well) to the exposed receptor (e.g., a resident). The chemicals of concern for hydraulic fracturing are a complex mixture of petroleum compounds and fracturing-fluids extracted or used in the oil and gas extraction process. Findings specific to Fort Collins: a. There are many factors influencing chemical exposures to a Fort Collins resident from an existing or future potential oil extraction well, these are uncharacterized at this time. b. Air related exposures are the most relevant exposure pathways for a resident; the point of exposure for quantifying an unacceptable exposure to fracturing- related chemicals is both undefined and uncharacterized at this time. However, in general, the closer the well is located to a resident the higher the exposure. c. Contamination of soil and water from a Fort Collins oil well would require a spill, leak or catastrophic failure to present a significant risk to human health. 69 TERRA MENTIS Exposure Pathways and Chemicals of Concern General Findings: d. Air exposure pathways are the primary exposure pathways for human health, and there are limited data characterizing this pathway. e. When uncontrolled, chemical emissions to air can be higher during the back- flow stage of hydraulic fracturing than during routine operations. f. Contamination of soil and water from oil and gas production would require a spill, leak or catastrophic failure to present a significant risk to human health. g. Exposure pathways relative to well decommissioning have not been characterized at this time. 9.1.3 Dose-response of Chemicals of Concern In the risk assessment process, the dose-response section describes a chemical’s adverse effect in humans, and quantifies the causal relationship for the effect. Two type of health effect are considered: potential cancer effects (such as benzene causing leukemia), and non- cancer effects (such as xylene causing nerve damage). Also, when two or more chemicals with the same effect are present, the effects are considered additive, and the toxicity of chemical mixtures is considered cumulative. Findings specific to Fort Collins: a. The types of chemicals released from a Fort Collins oil well are generally known, but data on the specific mix of chemicals is unavailable at this time. b. The petroleum chemicals benzene and 1,3-butadiene are present in emissions and have the potential to cause cancer in humans. These chemicals are likely to be the most important chemicals for long-term human health in Fort Collins, but data on these chemicals in background air, and from Fort Collins oil wells are unavailable at this time. c. The petroleum chemicals trimethylbenzenes, ethyl benzene and xylenes are likely to be the most important chemicals for non-cancer and short-term human health in Fort Collins, but data on these chemicals in background air and from Fort Collins oil wells are unavailable at this time. d. Fort Collins is located in an ozone non-attainment area, with respect to air quality. Ozone is known to cause respiratory problems including asthma, and 70 TERRA MENTIS decreased lung functioning in sensitive individuals, and children. The contribution of current and future potential oil and gas production in the Front Range is significant and several ongoing studies are assessing the impacts to air quality degradation and health. Contributions to regional ozone levels from oil and gas development specific to Fort Collins is a complex issue and cannot be assessed at this time. Dose-response of Chemicals of Concern General Findings: e. Studies at gas wells in Colorado (and other places) have shown that benzene, 1,3-butadiene and ethyl benzene potentially contribute significantly to human health risks during hydraulic fracturing, particularly the back-flow stage of well development. f. Benzene has been linked to an increase in childhood leukemia when the mother is exposed to benzene; however, an acceptable level of exposure for this sensitive health end-point has not been developed by health regulatory agencies. g. Studies at gas wells in Colorado (and other places) have shown that trimethyl benzenes, ethyl benzene and xylenes contribute significantly to human health risks during hydraulic fracturing, particularly the back-flow stage of well development. h. The toxicological dose-response of many of the chemical in hydraulic fracturing fluid are unknown at this time. However, many of these chemicals have low volatility and exposure to residents would be insignificant, except potentially, in the event of exposure to contaminated soil or water. i. Air emission sources in Weld and Larimer Counties have known releases of ozone producing gases. The degree to which these contribute to ozone non- attainment in Fort Collins cannot be assessed at this time. 9.1.4 Cancer Risks and Non-cancer Hazards In the risk assessment process, potential cancer risks are calculated as the probability of developing cancer over a lifetime due to long-term exposure to the chemicals in question. It is assumed that any level of exposure has a risk, and so Congress has agreed an acceptable 71 TERRA MENTIS risk range of one-in-ten thousand (1 in 10,000) to one-in-one million (1 in 1,000,000); the added probability of developing cancer over a lifetime. Non-cancer hazards are assumed to have an acceptable level of exposure, and the probability of an adverse effect is the ratio of the level of exposure to this acceptable level. It is presented as a fraction, or index with an acceptable Hazard Index of 1.0. Findings specific to Fort Collins: a. There are no cancer risk assessments available for Fort Collins background, or oil well-related exposures for potentially carcinogenic fracturing-related compounds at this time. b. Non-cancer hazard assessments are unavailable for Fort Collins background, or oil well-related exposures to trimethylbenzenes or other petroleum compounds at this time. Cancer Risks and Non-cancer Hazards General Findings: c. Studies at gas wells in Colorado (and other places) have shown that benzene, 1,3-butadiene and ethyl benzene, and other potential carcinogens increase the risks of developing cancer due to exposure to hydraulic fracturing chemicals, particularly the back-flow stage of well development. d. The US EPA has provided ranges of acceptable risks for chemical in air, soil and drinking water (called Regional Screening Levels). However, these have not been applied to hydraulic fracturing at this time. e. Therefore, there is a lack of agreement in the literature on the cleanup levels that might be used to determine what constitutes a contaminated medium for hydraulic fracturing related chemicals, and oil and gas extraction. f. There is also no recognized process for determining where and when goals for air, surface water and groundwater might be applied to hydraulic fracturing. 9.1.5 General Risk Factors There are other potential risk factors that might be considered when evaluating the risks from hydraulic fracturing and the chemicals used or produced by oil and gas extraction. Findings specific to Fort Collins: a. Fort Collins city water is not used for fracturing at this time. 72 TERRA MENTIS b. Fort Collins does not accept oil extraction wastewaters for waste disposal at this time. c. Apart from the moratorium, there are few restrictions preventing hydraulic fracturing in the City of Fort Collins. General Risk General Findings: d. The use of municipal and special district water for hydraulic fracturing is a common practice in Colorado’s Front Range. e. Publically Owned Treatment Works (POTW) accept waste waters from hydraulic fracturing, although the amount varies for each POTW based on the volume and toxicity of the oil and gas waste water. f. Even though the practice of disposing of oil and gas wastes (including the co- mingled well stimulation fluids) for land treatment and application, and for road spreading is not currently used in the City of Fort Collins, Colorado State law allows for these practices. There is little data available to evaluate if these practices pose a risk to surface water or groundwater aquifers, or residents living on the roads where this disposal method is a common practice. 9.2 CONCLUSIONS AND ENVIRONMENTAL STUDIES The primary conclusions from the body of data presented in the previous section of this report are that there are little environmental data characterizing background and/or potential impacts from the chemical released during hydraulic fracturing and oil extraction in Fort Collins. Therefore, it is not possible to predict potential human health impacts from current and future potential hydraulic fracturing, for the purpose of oil and gas extraction, within the City. Areas where there are little or no published environmental data include: • The characterization of background conditions (for air, water and soil) at well sites. • The characterization of current releases of chemicals (to air, water and soil) at well sites. 73 TERRA MENTIS • The concentrations of cancer and non-cancer causing chemicals at resident’s homes from wells. • The risks from these cancer and non-cancer causing chemicals at resident’s homes. • Acceptable levels of exposure and risk at resident’s homes. • The contribution of well releases to ozone concentrations. • The contribution of cancer and non-cancer causing chemicals to adverse health outcomes in Fort Collins from exposure to chemicals released during hydraulic fracturing in nearby Counties. As noted, there are data for sites in Colorado that may be applicable. This sub-section uses the risk assessment steps (described earlier) to identify areas where environmental and health studies might be conducted to answer some of the unresolved questions concerning exposure to chemicals from the hydraulic fracturing process. This is not a list of recommended studies. The scientific process requires that the objectives of any study be clearly identified at the outset, and the data collected be targeted to the goals of that study. The studies identified here could be undertaken to answer specific questions related to citizen exposure to chemicals from hydraulic fracturing. Some of the studies on the health effects of chemicals of concern would be prohibitively expensive and would normally be undertaken on a federal level. 9.2.1 Characterizing the Environmental Setting Characterizing the background environmental setting of current and future oil and gas extraction is important because it allows for a comparison of conditions before and after. If a moratorium on hydraulic fracturing is in effect, it would prove an ideal time period to collect data before making decisions related to local oil and gas and hydraulic fracturing regulations. Air As the primary route of exposure to chemicals released during hydraulic fracturing is to air, this is an important pathway of study. 74 TERRA MENTIS • Background air quality studies could be conducted at locations in and around Fort Collins to determine background air quality. Concurrent meteorological data might indicate background air chemical sources in the regional air shed. Ideally this would be a multi-year study that would characterize potential impacts from nearby gas extraction fields. Chemicals of interest might include markers for petroleum, natural gas, fracturing fluids; ozone and greenhouse gases; and particulate matter. The cost would range based on the study duration, the number of monitoring locations, the chemical analyte list and the level of reporting: An approximate cost might be $60,000 to $240,000 per 12 month period. • Oil well-related canister studies could be conducted at locations in and around Fort Collins oil wells to determine air quality impacts near sources of air pollutants in relation to the houses nearest to the existing wells. Representative residential exposure points would be selected in conjunction with meteorological monitoring locations and representative chemicals of concern. The cost would range based on the months of study, the number of location monitored, the chemical analyte list and the level of reporting: An approximate cost might be $60,000 to $240,000 per 12 month period. Groundwater • Groundwater monitoring is necessary to determine the baseline water quality of the shallow groundwater aquifer in locations near current oil extraction, and in locations where future potential oil and gas extraction may take place. Representative exposure points would be selected in conjunction with existing wells, city zoning and known oil and gas reserves. Representative groundwater physical chemistry parameters and chemicals of concern analyte lists would include markers for petroleum, fracturing fluids and natural minerals. The cost would vary based on the months of study, the number of locations/depths monitored, the chemical analyte list and the level of reporting: $120,000 to $240,000 per 12 month period. Subsequent years would be cheaper because of prior well construction. 75 TERRA MENTIS Soil • The monitoring of releases to soil would be unnecessary if a spill reporting requirement is implemented. 9.2.2 Environmental Exposure Pathways Air • Monitoring to characterize the environmental settings would provide a background data set against which releases to the environment might be measured. Monitoring routine and periodic releases to air is important and the monitoring program identified above could be used to monitor potential releases. Groundwater • Monitoring to characterize the environmental groundwater settings would provide a background data set against which releases to the environment might be measured. Potential releases to groundwater could only be effectively detected through a monitoring program. The program identified above could be used to monitor for these releases. Surface water • The monitoring of releases to surface water is likely unnecessary because the existing oil wells are not located near surface water and a spill reporting requirement would be adequate for this medium. However, future wells might be located near surface water and a monitoring program would help identify releases to surface water. The cost of such a program would be well-specific. 9.2.3 Production and Decommissioning Related Pathways • There is currently no published data on the levels of Naturally Occurring Radioactive Materials (NORMS) produced by groundwater from the oil- bearing formations beneath Fort Collins, and the degree to which equipment becomes “scaled” with precipitated NORMS. A study of this issue would 76 TERRA MENTIS allow the City to determine if special handling and disposal procedures are appropriate when dealing with scaled equipment from oil and gas wells. A study of NORMS would require industry participation, and would best be designed and conducted in conjunction with COGC and the CDPHE. The cost would range based on the number of sites and wells per site, the number of locations, the age, depth and equipment used at each well, the chemical analyte list and the level of reporting: An approximate cost might be $5,000 to $10,000 per site. 9.2.4 Toxicology and Health Studies At a minimum, the City’s First Responders should have information on the toxicity and dangers related to chemical that might be released in the event of a spill that might contaminate air, soil, surface water and groundwater. Additional toxicological studies are needed to understand the health effects of specific COPCs associated with fracturing fluids. This area of investigation falls to State and Federal Agencies and the oil and gas industry to prioritize research. The cost of an animal dose- response study might vary based on the duration, the number of animals/species, the route of administration and the number of chemicals tested: a typical long-term study on one chemical in one species is $1,000,000 to $5,000,000. • There are uncertainties in the long-term health effects of oil and gas chemicals such as benzene; especially, the potential health effect of maternal benzene exposure on childhood leukemia, a potentially sensitive human receptor. For a human study to provide information with sufficient statistical power and confidence for decision making, the design would include a large population of affected individuals, and a control population. This type of animal teratology study and/or human epidemiological study falls in the purview of the oil and gas industry or Federal regulatory agencies, and might cost $1,000,000 to $5,000,000. 77 TERRA MENTIS 9.3 OTHER OIL AND GAS QUESTIONS In addition to the collection of monitoring data, questions City managers might consider in the process of reviewing hydraulic fracturing for oil and gas development include: • Are there specific practices that could be employed to minimize, prevent or eliminate releases from wells with the goal of eliminating public exposure to COPCs? What power does the City have to implement these types of measures? • If the City has limited power, can the City bring these issues to the attention of the appropriate regulatory authority, and/or pursue alternative action/recourse? • Should any new application require a full background characterization prior to the City allowing for the construction of a new well? • When a well is decommissioned, are there data required before disposal in Fort Collins landfills is allowed? Has a level of “natural background” been defined along with an appropriate cleanup standard? • Are the measures in place sufficient to ensure local concerns are addressed, and adequate protections are available to residents adjacent to a well? • Should the City conduct a survey of existing private water supply wells to help identify potential areas of concern for exposure should new oil or gas exploration or production occur within City limits? • Emissions from flaring or venting are uncertain due to a lack of information regarding the frequency of occurrence. Would it be important to request this information from an operator as a part of an operator agreement? • Would it be worth requiring vapor controls on the temporary tanks to which flowback water is stored, thus preventing emissions from evaporative sources related to hydraulic fracturing? 78 TERRA MENTIS 10. 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EPA 240/B-06/002, Environmental Protection Agency, Office of Environmental Information, Washington D.C., February EPA, 2009 Benzene TEACH Summary, Toxicity and Exposure Assessment for Children's Health: Internet, Accessed in June; http://www.epa.gov/teach/ EPA, 2011 Background Indoor Air Concentrations of Volatile Organic Compounds in North American Residences (1990 – 2005): A Compilation of Statistics for Assessing Vapor Intrusion, EPA 530-R- 10-001, Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington D.C., June EPA, 2012 Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources, Progress Report, Environmental Protection Agency, EPA 601/R-12/011, December: Internet: Accessed in August; http://www2.epa.gov/sites/production/files/documents/hf-report20121214.pdf EPA, 2014a Oil and Gas Production Wastes, Environmental Protection Agency, Internet: Accessed in July; http://www.epa.gov/rpdweb00/tenorm/oilandgas.html EPA, 2014b Integrated Risk Information System, EPA On-line database; Accessed December; http://www.epa.gov/iris/ EPA, 2014c Ozone, EPA, On-line website; Accessed December; http://www.epa.gov/ozone/ 80 TERRA MENTIS EPA, 2014d Regional Screening Levels, EPA On-line database; Accessed November; http://www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/ Fort Collins, 2013 Climate Action Status Report, City of Fort Collins, Environmental Services, GHG assessment FracFocus, 2014 FracFocus: Chemical Disclosure Registry, An industry based GWPC and IOGCC website: Internet; Accessed in June; http://www.fracfocus.org/ Ft. 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State University Extension, PM 1963a: Internet; Wikipedia Accessed June Keranen et al., 2014 Sharp increase in central Oklahoma seismicity since 2008 induced by massive wastewater injection, Scienceexpress Reports, Pages 1-6, 10.11.1126/science.1255802, July: Internet accessed in July; http://www.sciencemag.org/content/early/recent Kassotis, et al., Estrogen and Androgen Receptor Activities of Hydraulic Fracturing Chemicals and Surface and Ground Water in a Drilling-Dense Region, Endocrinology, http://dx.doi.org/10.1210/en.2013-1697, December 16, 2013 KUNC, 2014 Researchers link quakes with Oklahoma wells, Colorado study ongoing: Internet Accessed, July; http://www.kunc.org/post/researchers-link-quakes-oklahoma- wells-colorado-study-ongoing Macy et al., 2014 Air concentrations of volatile compounds near oil and gas production: a community-based exploratory study, Environmental Health 2014, 13:82, Internet Accessed, December; http://www.ehjournal.net/content/13/1/82 McKenzie et al., 2012 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 McKinney et al., 1991 Parental occupations of children with leukemia in west Cumbria, north Humberside, and Gateshead. 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Journal of Geophysical Research: Atmospheres, Vol.118. 236-242, doi:1029/2012JD019497 Polzin, 2012 Niobrara Multi-Basin Oil Shale, Presentation to the City of Colorado Springs, Tudorpickering Holt and Company, January: Internet, Accessed; https://www.springsgov.com/units/boardscomm/OilGas/CO%20Springs%20TPH%20 Niobrara.pdf Rabinowitz et al., 2014 Proximity to natural gas wells and reported health status: results of a household survey in Washington County, Pennsylvania, Environmental Health Perspectives, 122, DOI:10.1289/ehp.1307732 Rawlins, 2013 Planning for Fracking on the Barnett Shale: Urban Air Pollution, Improving Health Based Regulations, and the Role of Local Government, Virginia Environmental Law Journal, 31, 228-308 Shaw, et al., 1984 Association of childhood leukemia with maternal age, birth order, and paternal occupation: A case-control study. Am.J.Epidemiol. 119(5): 788-795 Shu et al., 1988 A population-based case-control study of childhood leukemia in Shanghai, Cancer 62:635-644. Steffen et al., 2004 Acute childhood leukemia and environmental exposure to potential sources of benzene and other hydrocarbons; a case-control study. Occup. Environ. Med. Sep; 61(9): 773-8 Stephenson et al., 2011 Modeling the relative GHG emissions of conventional and shale gas production. Environ. Sci. Tech. 45: 10757-10764 Styx, 2014, From the Styx, by Peggy Tibbetts, Internet website: Access September 2014, http://fromthestyx.wordpress.com/2014/06/30/fracking-health-study-will-return-to- garfield-county/ 82 TERRA MENTIS Thompson et al., 2014 Influence of oil and gas emissions on ambient atmospheric non-methane hydrocarbons in residential areas of Northeastern Colorado, Elementa: Science of the Anthropocene, 2: 000035, doi: 10.12952/journal.elementa.000035 1 USGS, 1999 Naturally Occurring Radioactive Materials (NORM) in Produced Water and Oil-Field Equipment—An Issue for the Energy Industry, USGS Fact Sheet FS–142– 99, U.S. Department of the Interior, U.S. Geological Survey, September US House, 2011, Chemicals Used in Hydraulic Fracturing, United States House of Representatives Committee on Energy and Commerce Minority Staff, April Vengosh et al., 2014 A Critical Review of the Risks to Water Resources from Unconventional Shale Gas Development and Hydraulic Fracturing in the United States. Environ. Sci. Tech. February Walsh, 2013 Compliance Audit, Prospect Energy Operations in Fort Collins, Colorado, WALSH Project Number: WA-002011-0018-10TTO, October Weisel, et al., 1996 Biomarkers for environmental benzene exposure, Environmental Health Perspectives, 1996; 104 (Supplement 6): 1141–1146 Xiao et al., 1988 A Population-Based Case-Control Study of Childhood Leukemia in Shanghai. Cancer 62(3): 635-644 83 TERRA MENTIS APPENDICES 84 TERRA MENTIS APPENDIX A: FORT COLLINS OIL AND NORTHERN COLORADO GEOLOGIC FORMATIONS 85 TERRA MENTIS A. FORT COLLINS OIL AND NORTHERN COLORADO GEOLOGIC FORMATIONS Oil and gas extraction can only occur where there are hydrocarbon reserves contained in the underlying geology. Even though hydrocarbon extraction technologies are constantly improving, the reserves have to be present for wells to exist. This section provides a brief overview of the resources available. The Niobrara Shale is a shale rock formation underlying parts of Colorado and Wyoming. Oil and natural gas can be found at depths from 3,000 to 14,000 feet. Figure A-1 is a representation of depths within the Niobrara shale formation. FIGURE A-1 DIAGRAM OF DRILLING TO VARIOUS DEPTHS WITHIN NIOBRARA FORMATION SOURCE: www.naturalgasintel.com/niobraradjinfo 86 TERRA MENTIS The Niobrara is a new oil formation that is part of the Denver-Julesburg basin. It is an early oil formation that is being compared to the Bakken Shale. It can be seen from Figure A-2 that it is beneath Weld County and part of Larimer County. Currently there is only oil production within Fort Collins City limits in the Fort Collins Field, located in the northeast portion of the city, where oil extraction is from the Muddy J formation. Sandstone is the reservoir rock for petroleum generated by overlying source rocks, and generally the Muddy J formation is located between 7,600 to 8,400 ft. bgs and varies in thickness from 75 to 150 feet. The current oil extraction operations in the Fort Collins City limits are identified on Figure A-3 and Figure A-4 showing the four residential subdivisions that have been developed around the Fort Collins field. There are options available for further development, as shown in Figure A-4 and Figure A-5. In addition, north of Fort Collins, further development of the Muddy J formation has occurred. A.1 OIL AND GAS INFRASTRUCTURE Oil and gas are produced by drilling into shale or sandstone that contain hydrocarbon deposits. Shale is a tightly compacted geologic formation that does not easily allow the passage of gases or liquids and requires stimulation to release hydrocarbons. Permeability and porosity are generally much higher in sandstone than in shale. Fracturing is used to break open fractures in the shale or sandstone to allow better oil or gas passage and higher extraction rates. Fort Collins sits atop two major oil and gas producing layers, the Muddy J sandstone (7,600 feet bgs) and the Niobrara Shale formation (6,800 to 7,100 feet bgs) both contained within the Denver-Julesburg Basin area (Polzin, 2012). These layers of the Denver-Julesburg basin are outlined in Figure A-6. In Colorado, these formations produce around 66 million barrels (bbl.) of oil and 1.7 trillion cf (cubic feet) of gas a year (EIA, 2014). 87 TERRA MENTIS FIGURE A-2 THE NIOBRARA SHALE FORMATION IN COLORADO Source: Stratex Oil (www.stratex oil.com) 88 TERRA MENTIS FIGURE A-3 FORT COLLINS OIL EXTRACTION FIELDS AND NEIGHBORHOODS From: City of Fort Collins, Oil and Gas Information Presentation May 8, 3103 89 TERRA MENTIS FIGURE A-4 FORT COLLINS OIL EXTRACTION FIELDS AND RESIDENTIAL SUBDIVISIONS (Active wells- Red, inactive wells-Black) From: City of Fort Collins, Oil and Gas Information Presentation May 8, 3103 90 TERRA MENTIS FIGURE A-5 FORT COLLINS UDA NEIGHBORHOOD & ZONING MAP From: City of Fort Collins, Oil and Gas Information Presentation May 8, 3103 91 TERRA MENTIS FIGURE A-6 DENVER-JULESBURG SHALE LAYERS (Highlighting depths of Niobrara and Muddy J Sandstone) 92 TERRA MENTIS A.1.1 Current City Well Locations Oil development has occurred in Fort Collins since around 1925. There are seven producing wells and seven injection wells all managed by one operator located in northeast Fort Collins (Figure A-3 and A- 4). The wells in Fort Collins access the Muddy J sandstone and the Niobrara Shale. The wells in Fort Collins are targeted to produce oil and only produce a limited amount of natural gas as a by-product. These wells produce around 780,000 barrels (bbl.) (average) of oil and 4,200 Mcf (4,200,000 cubic feet) (average) of gas a year (COGCC, 2014; COGIS, 2014). The gas is either vented or flared and the oil is sold. The Fort Collins wells are fractured infrequently, most recently in 2012. A.1.2 Neighboring Extraction Fields Larimer County contains active wells outside of Fort Collins. Thirty-three of the 42 total wells in Larimer County are south of Fort Collins, near the city of Johnstown. Two other wells are located east of Fort Collins. These wells are on the other side of I-25 but within the county limits (FracFocus, 2014). Weld County contains one of the largest densities of wells in the country, containing around 18,000 total wells. These wells range in distance from Fort Collins. Within a 30-mile radius there are 542 wells located between Greeley and Fort Collins. Twenty of these wells are located between Windsor and Larimer County (within 8 miles) (FracFocus, 2014). Laramie County, Wyoming, borders Larimer County, Colorado to the north. There are a total of 21 wells between Cheyenne and the border of Colorado; however, all of these wells are located to the east of I-25. It is approximately 28 miles from Fort Collins to the Wyoming border and approximately 41 miles from Fort Collins to Cheyenne, Wyoming. A.1.3 Future Exploration Future exploration in and around Fort Collins depends greatly on any possible regulations set forward by the city of Fort Collins as well as on technological advances. The oil and gas plays in Larimer County extend from the eastern border to the western border of Fort Collins (EIA, 2014). The basins extend even further to the other side of the divide to the west of Fort Collins. Current technology would allow the drilling and access of hydrocarbons in the Julesburg-Denver Basin within and around the city of Fort Collins, however, this paper does 93 TERRA MENTIS not evaluate whether this is an economically viable option for an operator. Areas of moderate or high potential for exploration are shown in Figure A-7. If technologies allow for easier access and economic viability of drilling in the mountains it is possible development would occur to the west of Fort Collins, putting water resources under greater danger. The likelihood of this is also low because it is current practice not to drill on fault lines including mountains. Oil and gas industry officials have already shown interest in some areas of Fort Collins properties, mainly the Soapstone Prairie Natural Area and the Meadow Springs Ranch (Figure A-5). These areas are owned by the City and are located to the north outside of the City proper. These are flat, easily accessible lands that are sparsely populated to unpopulated making them ideal for oil and gas developers. Historically development has also been greatest around the I-25 corridor. This location makes it easy for trucks to access sites and is nearby to local pipelines. The Fort Collins Natural Areas program participated in the Mountains to Plains Energy by Design process developed by the State Land Board and other stakeholders to design an oil and gas leasing plan that would allow for reasonable energy development at these properties while achieving the biological, cultural, scenic and recreational resource conservation goals of local governments. 94 TERRA MENTIS FIGURE A-7 MODERATE AND HIGH POTENTIAL OF OIL AND GAS DEVELOPMENT OF ALL FORMATIONS 95 TERRA MENTIS APPENDIX B: HYDRAULIC FRACTURING CHEMICALS AND THEIR USES 96 TERRA MENTIS APPENDIX B-1 FRACTURING FLUID CHEMICALS AND THEIR USES TABLE B-1 FRACKING FLUID CHEMICALS AND THEIR USES Chemical Name CAS Chemical Purpose Product Function Hydrochloric Acid 007647-01-0 Helps dissolve minerals and initiate cracks in the rock Acid Glutaraldehyde 000111-30-8 Eliminates bacteria in the water that produces corrosive by-products Biocide Quaternary Ammonium Chloride 012125-02-9 Eliminates bacteria in the water that produces corrosive by-products Biocide Quaternary Ammonium Chloride 061789-71-1 Eliminates bacteria in the water that produces corrosive by-products Biocide Tetrakis Hydroxymethyl- Phosphonium Sulfate 055566-30-8 Eliminates bacteria in the water that produces corrosive by-products Biocide Ammonium Persulfate 007727-54-0 Allows a delayed break down of the gel Breaker Sodium Chloride 007647-14-5 Product Stabilizer Breaker Magnesium Peroxide 014452-57-4 Allows a delayed break down the gel Breaker Magnesium Oxide 001309-48-4 Allows a delayed break down the gel Breaker Calcium Chloride 010043-52-4 Product Stabilizer Breaker Choline Chloride 000067-48-1 Prevents clays from swelling or shifting Clay Stabilizer Tetramethyl ammonium chloride 000075-57-0 Prevents clays from swelling or shifting Clay Stabilizer Sodium Chloride 007647-14-5 Prevents clays from swelling or shifting Clay Stabilizer Isopropanol 000067-63-0 Product stabilizer and / or winterizing agent Corrosion Inhibitor Methanol 000067-56-1 Product stabilizer and / or winterizing agent Corrosion Inhibitor Formic Acid 000064-18-6 Prevents the corrosion of the pipe Corrosion Inhibitor Acetaldehyde 000075-07-0 Prevents the corrosion of the pipe Corrosion Inhibitor Petroleum Distillate 064741-85-1 Carrier fluid for borate or zirconate crosslinker Crosslinker Hydrotreated Light Petroleum Distillate 064742-47-8 Carrier fluid for borate or zirconate crosslinker Crosslinker Potassium Metaborate 013709-94-9 Maintains fluid viscosity as temperature increases Crosslinker Triethanolamine Zirconate 101033-44-7 Maintains fluid viscosity as temperature increases Crosslinker Sodium Tetraborate 001303-96-4 Maintains fluid viscosity as temperature increases Crosslinker Boric Acid 001333-73-9 Maintains fluid viscosity as temperature increases Crosslinker Zirconium Complex 113184-20-6 Maintains fluid viscosity as temperature increases Crosslinker Borate Salts N/A Maintains fluid viscosity as temperature increases Crosslinker Ethylene Glycol 000107-21-1 Product stabilizer and / or winterizing agent. Crosslinker Methanol 000067-56-1 Product stabilizer and / or winterizing agent. Crosslinker Polyacrylamide 009003-05-8 “Slicks” the water to minimize friction Friction Reducer Petroleum Distillate 064741-85-1 Carrier fluid for polyacrylamide friction reducer Friction Reducer Hydrotreated Light Petroleum 064742-47-8 Carrier fluid for polyacrylamide friction reducer Friction Reducer 97 TERRA MENTIS TABLE B-1 FRACKING FLUID CHEMICALS AND THEIR USES Distillate Methanol 000067-56-1 Product stabilizer and / or winterizing agent. Friction Reducer Ethylene Glycol 000107-21-1 Product stabilizer and / or winterizing agent. Friction Reducer Guar Gum 009000-30-0 Thickens the water in order to suspend the sand Gelling Agent Petroleum Distillate 064741-85-1 Carrier fluid for guar gum in liquid gels Gelling Agent Hydrotreated Light Petroleum Distillate 064742-47-8 Carrier fluid for guar gum in liquid gels Gelling Agent Methanol 000067-56-1 Product stabilizer and / or winterizing agent. Gelling Agent Polysaccharide Blend 068130-15-4 Thickens the water in order to suspend the sand Gelling Agent Ethylene Glycol 000107-21-1 Product stabilizer and / or winterizing agent. Gelling Agent Citric Acid 000077-92-9 Prevents precipitation of metal oxides Iron Control Acetic Acid 000064-19-7 Prevents precipitation of metal oxides Iron Control Thioglycolic Acid 000068-11-1 Prevents precipitation of metal oxides Iron Control Sodium Erythorbate 006381-77-7 Prevents precipitation of metal oxides Iron Control Lauryl Sulfate 000151-21-3 Used to prevent the formation of emulsions in the fracture fluid Non-Emulsifier Isopropanol 000067-63-0 Product stabilizer and / or winterizing agent. Non-Emulsifier Ethylene Glycol 000107-21-1 Product stabilizer and / or winterizing agent. Non-Emulsifier Sodium Hydroxide 001310-73-2 Adjusts the pH of fluid to maintains the effectiveness of other components, such as crosslinkers pH Adjusting Agent Potassium Hydroxide 001310-58-3 Adjusts the pH of fluid to maintains the effectiveness of other components, such as crosslinkers pH Adjusting Agent Acetic Acid 000064-19-7 Adjusts the pH of fluid to maintains the effectiveness of other components, such as crosslinkers pH Adjusting Agent Sodium Carbonate 000497-19-8 Adjusts the pH of fluid to maintains the effectiveness of other components, such as crosslinkers pH Adjusting Agent Potassium Carbonate 000584-08-7 Adjusts the pH of fluid to maintains the effectiveness of other components, such as crosslinkers pH Adjusting Agent Copolymer of Acrylamide and Sodium Acrylate 025987-30-8 Prevents scale deposits in the pipe Scale Inhibitor Sodium Polycarboxylate N/A Prevents scale deposits in the pipe Scale Inhibitor Phosphonic Acid Salt N/A Prevents scale deposits in the pipe Scale Inhibitor Lauryl Sulfate 000151-21-3 Used to increase the viscosity of the fracture fluid Surfactant Ethanol 000064-17-5 Product stabilizer and / or winterizing agent. Surfactant Naphthalene 000091-20-3 Carrier fluid for the active surfactant ingredients Surfactant Methanol 000067-56-1 Product stabilizer and / or winterizing agent. Surfactant Isopropyl Alcohol 000067-63-0 Product stabilizer and / or winterizing agent. Surfactant 2-Butoxyethanol 000111-76-2 Product stabilizer Surfactant 98 TERRA MENTIS APPENDIX B-2 CHEMICALS USED IN FRACKING HYDRAULIC FRACTURING: US HOUSE OF REPRESENTATIVES, COMMITTEE ON ENERGY AND COMMERCE 99 UNITED STATES HOUSE OF REPRESENTATIVES COMMITTEE ON ENERGY AND COMMERCE MINORITY STAFF APRIL 2011 CHEMICALS USED IN HYDRAULIC FRACTURING PREPARED BY COMMITTEE STAFF FOR: Henry A. Waxman Ranking Member Committee on Energy and Commerce Edward J. Markey Ranking Member Committee on Natural Resources Diana DeGette Ranking Member Subcommittee on Oversight and Investigations TABLE OF CONTENTS I. EXECUTIVE SUMMARY............................................................................1 II. BACKGROUND.............................................................................................2 III. METHODOLOGY........................................................................................4 IV. HYDRAULIC FRACTURING FLUIDS AND THEIR CONTENTS…..5 A. Commonly Used Chemical Components..................................................6 B. Toxic Chemicals………….......................................................................8 V. USE OF PROPRIETARY AND “TRADE SECRET” CHEMICALS.....11 VI. CONCLUSION..............................................................................................12 APPENDIX A.........................................................................................................13 1 I. EXECUTIVE SUMMARY Hydraulic fracturing has helped to expand natural gas production in the United States, unlocking large natural gas supplies in shale and other unconventional formations across the country. As a result of hydraulic fracturing and advances in horizontal drilling technology, natural gas production in 2010 reached the highest level in decades. According to new estimates by the Energy Information Administration (EIA), the United States possesses natural gas resources sufficient to supply the United States for approximately 110 years. As the use of hydraulic fracturing has grown, so have concerns about its environmental and public health impacts. One concern is that hydraulic fracturing fluids used to fracture rock formations contain numerous chemicals that could harm human health and the environment, especially if they enter drinking water supplies. The opposition of many oil and gas companies to public disclosure of the chemicals they use has compounded this concern. Last Congress, the Committee on Energy and Commerce launched an investigation to examine the practice of hydraulic fracturing in the United States. As part of that inquiry, the Committee asked the 14 leading oil and gas service companies to disclose the types and volumes of the hydraulic fracturing products they used in their fluids between 2005 and 2009 and the chemical contents of those products. This report summarizes the information provided to the Committee. Between 2005 and 2009, the 14 oil and gas service companies used more than 2,500 hydraulic fracturing products containing 750 chemicals and other components. Overall, these companies used 780 million gallons of hydraulic fracturing products – not including water added at the well site – between 2005 and 2009. Some of the components used in the hydraulic fracturing products were common and generally harmless, such as salt and citric acid. Some were unexpected, such as instant coffee and walnut hulls. And some were extremely toxic, such as benzene and lead. Appendix A lists each of the 750 chemicals and other components used in hydraulic fracturing products between 2005 and 2009. The most widely used chemical in hydraulic fracturing during this time period, as measured by the number of compounds containing the chemical, was methanol. Methanol, which was used in 342 hydraulic fracturing products, is a hazardous air pollutant and is on the candidate list for potential regulation under the Safe Drinking Water Act. Some of the other most widely used chemicals were isopropyl alcohol (used in 274 products), 2-butoxyethanol (used in 126 products), and ethylene glycol (used in 119 products). Between 2005 and 2009, the oil and gas service companies used hydraulic fracturing products containing 29 chemicals that are (1) known or possible human carcinogens, (2) regulated under the Safe Drinking Water Act for their risks to human health, or (3) listed as hazardous air pollutants under the Clean Air Act. These 29 chemicals were components of more than 650 different products used in hydraulic fracturing. 2 The BTEX compounds – benzene, toluene, xylene, and ethylbenzene – appeared in 60 of the hydraulic fracturing products used between 2005 and 2009. Each BTEX compound is a regulated contaminant under the Safe Drinking Water Act and a hazardous air pollutant under the Clean Air Act. Benzene also is a known human carcinogen. The hydraulic fracturing companies injected 11.4 million gallons of products containing at least one BTEX chemical over the five year period. In many instances, the oil and gas service companies were unable to provide the Committee with a complete chemical makeup of the hydraulic fracturing fluids they used. Between 2005 and 2009, the companies used 94 million gallons of 279 products that contained at least one chemical or component that the manufacturers deemed proprietary or a trade secret. Committee staff requested that these companies disclose this proprietary information. Although some companies did provide information about these proprietary fluids, in most cases the companies stated that they did not have access to proprietary information about products they purchased “off the shelf” from chemical suppliers. In these cases, the companies are injecting fluids containing chemicals that they themselves cannot identify. II. BACKGROUND Hydraulic fracturing – a method by which oil and gas service companies provide access to domestic energy trapped in hard-to-reach geologic formations — has been the subject of both enthusiasm and increasing environmental and health concerns in recent years. Hydraulic fracturing, used in combination with horizontal drilling, has allowed industry to access natural gas reserves previously considered uneconomical, particularly in shale formations. As a result of the growing use of hydraulic fracturing, natural gas production in the United States reached 21,577 billion cubic feet in 2010, a level not achieved since a period of high natural gas production between 1970 and 1974.1 Overall, the Energy Information Administration now projects that the United States possesses 2,552 trillion cubic feet of potential natural gas resources, enough to supply the United States for approximately 110 years. Natural gas from shale resources accounts for 827 trillion cubic feet of this total, which is more than double what the EIA estimated just a year ago.2 Hydraulic fracturing creates access to more natural gas supplies, but the process requires the use of large quantities of water and fracturing fluids, which are injected underground at high volumes and pressure. Oil and gas service companies design fracturing fluids to create fractures and transport sand or other granular substances to prop open the fractures. The composition of these fluids varies by formation, ranging from a simple mixture of water and sand to more complex mixtures with a multitude of chemical additives. The companies may use these 1 Energy Information Administration (EIA), Natural Gas Monthly (Mar. 2011), Table 1, U.S. Natural Gas Monthly Supply and Disposition Balance (online at www.eia.gov/dnav/ng/hist/n9070us1A.htm) (accessed Mar. 30, 2011). 2 EIA, Annual Energy Outlook 2011 Early Release (Dec. 16, 2010); EIA, What is shale gas and why is it important? (online at www.eia.doe.gov/energy_in_brief/about_shale_gas.cfm) (accessed Mar. 30, 2011). 3 chemical additives to thicken or thin the fluids, improve the flow of the fluid, or kill bacteria that can reduce fracturing performance.3 Some of these chemicals, if not disposed of safely or allowed to leach into the drinking water supply, could damage the environment or pose a risk to human health. During hydraulic fracturing, fluids containing chemicals are injected deep underground, where their migration is not entirely predictable. Well failures, such as the use of insufficient well casing, could lead to their release at shallower depths, closer to drinking water supplies.4 Although some fracturing fluids are removed from the well at the end of the fracturing process, a substantial amount remains underground.5 While most underground injections of chemicals are subject to the protections of the Safe Drinking Water Act (SDWA), Congress in 2005 modified the law to exclude “the underground injection of fluids or propping agents (other than diesel fuels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities” from the Act’s protections.6 Unless oil and gas service companies use diesel in the hydraulic fracturing process, the permanent underground injection of chemicals used for hydraulic fracturing is not regulated by the Environmental Protection Agency (EPA). Concerns also have been raised about the ultimate outcome of chemicals that are recovered and disposed of as wastewater. This wastewater is stored in tanks or pits at the well site, where spills are possible.7 For final disposal, well operators must either recycle the fluids for use in future fracturing jobs, inject it into underground storage wells (which, unlike the fracturing process itself, are subject to the Safe Drinking Water Act), discharge it to nearby surface water, or transport it to wastewater treatment facilities.8 A recent report in the New York 3 U.S. Environmental Protection Agency, Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs (June 2004) (EPA 816-R-04-003) at 4-1 and 4-2. 4 For instance, Pennsylvania’s Department of Environmental Protection has cited Cabot Oil & Gas Corporation for contamination of drinking water wells with seepage caused by weak casing or improper cementing of a natural gas well. See Officials in Three States Pin Water Woes on Gas Drilling, ProPublica (Apr. 26, 2009) (online at www.propublica.org/article/officials-in-three-states-pin-water-woes-on-gas-drilling-426) (accessed Mar. 24, 2011). 5 John A. Veil, Argonne National Laboratory, Water Management Technologies Used by Marcellus Shale Gas Producers, prepared for the Department of Energy (July 2010), at 13 (hereinafter “Water Management Technologies”). 6 42 U.S.C. § 300h(d). Many dubbed this provision the “Halliburton loophole” because of Halliburton’s ties to then-Vice President Cheney and its role as one of the largest providers of hydraulic fracturing services. See The Halliburton Loophole, New York Times (Nov. 9. 2009). 7 See EPA, Draft Hydraulic Fracturing Study Plan (Feb. 7, 2011), at 37; Regulation Lax as Gas Wells’ Tainted Water Hits Rivers, New York Times (Feb. 26, 2011). 8 Water Management Technologies, at 13. 4 Times raised questions about the safety of surface water discharge and the ability of water treatment facilities to process wastewater from natural gas drilling operations.9 Any risk to the environment and human health posed by fracturing fluids depends in large part on their contents. Federal law, however, contains no public disclosure requirements for oil and gas producers or service companies involved in hydraulic fracturing, and state disclosure requirements vary greatly.10 While the industry has recently announced that it soon will create a public database of fluid components, reporting to this database is strictly voluntary, disclosure will not include the chemical identity of products labeled as proprietary, and there is no way to determine if companies are accurately reporting information for all wells.11 The absence of a minimum national baseline for disclosure of fluids injected during the hydraulic fracturing process and the exemption of most hydraulic fracturing injections from regulation under the Safe Drinking Water Act has left an informational void concerning the contents, chemical concentrations, and volumes of fluids that go into the ground during fracturing operations and return to the surface in the form of wastewater. As a result, regulators and the public are unable effectively to assess any impact the use of these fluids may have on the environment or public health. III. METHODOLOGY On February 18, 2010, the Committee commenced an investigation into the practice of hydraulic fracturing and its potential impact on water quality across the United States. This investigation built on work begun by Ranking Member Henry A. Waxman in 2007 as Chairman of the Committee on Oversight and Government Reform. The Committee initially sent letters to eight oil and gas service companies engaged in hydraulic fracturing in the United States. In May 2010, the Committee sent letters to six additional oil and gas service companies to assess a 9 Regulation Lax as Gas Wells’ Tainted Water Hits Rivers, New York Times (Feb. 26, 2011). 10 Wyoming, for example, recently enacted relatively strong disclosure regulations, requiring disclosure on a well-by-well basis and “for each stage of the well stimulation program,” “the chemical additives, compounds and concentrations or rates proposed to be mixed and injected.” See WCWR 055-000-003 Sec. 45. Similar regulations became effective in Arkansas this year. See Arkansas Oil and Gas Commission Rule B-19. In Wyoming, much of this information is, after an initial period of review, available to the public. See WCWR 055- 000-003 Sec. 21. Other states, however, do not insist on such robust disclosure. For instance, West Virginia has no disclosure requirements for hydraulic fracturing and expressly exempts fluids used during hydraulic fracturing from the disclosure requirements applicable to underground injection of fluids for purposes of waste storage. See W. Va. Code St. R. § 34-5-7. 11 See Ground Water Protection Council Calls for Disclosure of Chemicals Used in Shale Gas Exploration, Ground Water Protection Council (Oct. 5, 2010) (online at www.wqpmag.com/Ground-Water-Protection-Council-Calls-for-Disclosure-of-Chemicals-in- Shale-Gas-Exploration-newsPiece21700) (accessed Mar. 24, 2011). 5 broader range of industry practices.12 The February and May letters requested information on the type and volume of chemicals present in the hydraulic fracturing products that each company used in their fluids between 2005 and 2009. The 14 oil and gas service companies that received the letter voluntarily provided substantial information to the Committee. As requested, the companies reported the names and volumes of the products they used during the five-year period.13 For each hydraulic fracturing product reported, the companies also provided a Material Safety Data Sheet (MSDS) detailing the product’s chemical components. The Occupational Safety and Health Administration (OSHA) requires chemical manufacturers to create a MSDS for every product they sell as a means to communicate potential health and safety hazards to employees and employers. The MSDS must list all hazardous ingredients if they comprise at least 1% of the product; for carcinogens, the reporting threshold is 0.1%.14 Under OSHA regulations, manufacturers may withhold the identity of chemical components that constitute “trade secrets.”15 If the MSDS for a particular product used by a company subject to the Committee’s investigation reported that the identity of any chemical component was a trade secret, the Committee asked the company that used that product to provide the proprietary information, if available. IV. HYDRAULIC FRACTURING FLUIDS AND THEIR CONTENTS Between 2005 and 2009, the 14 oil and gas service companies used more than 2,500 hydraulic fracturing products containing 750 chemicals and other components.16 Overall, these companies used 780 million gallons of hydraulic fracturing products in their fluids between 2005 and 2009. This volume does not include water that the companies added to the fluids at the well site before injection. The products are comprised of a wide range of chemicals. Some are seemingly harmless like sodium chloride (salt), gelatin, and citric acid. Others could pose a severe risk to human health or the environment. 12 The Committee sent letters to Basic Energy Services, BJ Services, Calfrac Well Services, Complete Production Services, Frac Tech Services, Halliburton, Key Energy Services, RPC, Sanjel Corporation, Schlumberger, Superior Well Services, Trican Well Service, Universal Well Services, and Weatherford. 13 BJ Services, Halliburton, and Schlumberger already had provided the Oversight Committee with data for 2005 through 2007. For BJ Services, the 2005-2007 data is limited to natural gas wells. For Schlumberger, the 2005-2007 data is limited to coalbed methane wells. 14 29 CFR 1910.1200(g)(2)(i)(C)(1). 15 29 CFR 1910.1200. 16 Each hydraulic fracturing “product” is a mixture of chemicals or other components designed to achieve a certain performance goal, such as increasing the viscosity of water. Some oil and gas service companies create their own products; most purchase these products from chemical vendors. The service companies then mix these products together at the well site to formulate the hydraulic fracturing fluids that they pump underground. 6 Some of the components were surprising. One company told the Committee that it used instant coffee as one of the components in a fluid designed to inhibit acid corrosion. Two companies reported using walnut hulls as part of a breaker—a product used to degrade the fracturing fluid viscosity, which helps to enhance post-fracturing fluid recovery. Another company reported using carbohydrates as a breaker. One company used tallow soap—soap made from beef, sheep, or other animals—to reduce loss of fracturing fluid into the exposed rock. Appendix A lists each of the 750 chemicals and other components used in the hydraulic fracturing products injected underground between 2005 and 2009. A. Commonly Used Chemical Components The most widely used chemical in hydraulic fracturing during this time period, as measured by the number of products containing the chemical, was methanol. Methanol is a hazardous air pollutant and a candidate for regulation under the Safe Drinking Water Act. It was a component in 342 hydraulic fracturing products. Some of the other most widely used chemicals include isopropyl alcohol, which was used in 274 products, and ethylene glycol, which was used in 119 products. Crystalline silica (silicon dioxide) appeared in 207 products, generally proppants used to hold open fractures. Table 1 has a list of the most commonly used compounds in hydraulic fracturing fluids. Table 1. Chemical Components Appearing Most Often in Hydraulic Fracturing Products Used Between 2005 and 2009 Chemical Component No. of Products Containing Chemical Methanol (Methyl alcohol) 342 Isopropanol (Isopropyl alcohol, Propan-2-ol) 274 Crystalline silica - quartz (SiO2) 207 Ethylene glycol monobutyl ether (2-butoxyethanol) 126 Ethylene glycol (1,2-ethanediol) 119 Hydrotreated light petroleum distillates 89 Sodium hydroxide (Caustic soda) 80 7 Hydraulic fracturing companies used 2-butoxyethanol (2-BE) as a foaming agent or surfactant in 126 products. According to EPA scientists, 2-BE is easily absorbed and rapidly distributed in humans following inhalation, ingestion, or dermal exposure. Studies have shown that exposure to 2-BE can cause hemolysis (destruction of red blood cells) and damage to the spleen, liver, and bone marrow.17 The hydraulic fracturing companies injected 21.9 million gallons of products containing 2-BE between 2005 and 2009. They used the highest volume of products containing 2-BE in Texas, which accounted for more than half of the volume used. EPA recently found this chemical in drinking water wells tested in Pavillion, Wyoming.18 Table 2 shows the use of 2-BE by state. Table 2. States with the Highest Volume of Hydraulic Fracturing Fluids Containing 2-Butoxyethanol (2005-2009) State Fluid Volume (gallons) Texas 12,031,734 Oklahoma 2,186,613 New Mexico 1,871,501 Colorado 1,147,614 Louisiana 890,068 Pennsylvania 747,416 West Virginia 464,231 Utah 382,874 Montana 362,497 Arkansas 348,959 17 EPA, Toxicological Review of Ethylene Glycol Monobutyl Ether (Mar. 2010) at 4. 18 EPA, Fact Sheet: January 2010 Sampling Results and Site Update, Pavillion, Wyoming Groundwater Investigation (Aug. 2010) (online at www.epa.gov/region8/superfund/wy/pavillion/PavillionWyomingFactSheet.pdf) (accessed Mar. 1, 2011). 8 B. Toxic Chemicals The oil and gas service companies used hydraulic fracturing products containing 29 chemicals that are (1) known or possible human carcinogens, (2) regulated under the Safe Drinking Water Act for their risks to human health, or (3) listed as hazardous air pollutants under the Clean Air Act. These 29 chemicals were components of 652 different products used in hydraulic fracturing. Table 3 lists these toxic chemicals and their frequency of use. Table 3. Chemicals Components of Concern: Carcinogens, SDWA-Regulated Chemicals, and Hazardous Air Pollutants Chemical Component Chemical Category No. of Products Methanol (Methyl alcohol) HAP 342 Ethylene glycol (1,2-ethanediol) HAP 119 Diesel 19 Carcinogen, SDWA, HAP 51 Naphthalene Carcinogen, HAP 44 Xylene SDWA, HAP 44 Hydrogen chloride (Hydrochloric acid) HAP 42 Toluene SDWA, HAP 29 Ethylbenzene SDWA, HAP 28 Diethanolamine (2,2-iminodiethanol) HAP 14 Formaldehyde Carcinogen, HAP 12 Sulfuric acid Carcinogen 9 Thiourea Carcinogen 9 Benzyl chloride Carcinogen, HAP 8 Cumene HAP 6 Nitrilotriacetic acid Carcinogen 6 Dimethyl formamide HAP 5 Phenol HAP 5 Benzene Carcinogen, SDWA, HAP 3 Di (2-ethylhexyl) phthalate Carcinogen, SDWA, HAP 3 Acrylamide Carcinogen, SDWA, HAP 2 Hydrogen fluoride (Hydrofluoric acid) HAP 2 Phthalic anhydride HAP 2 Acetaldehyde Carcinogen, HAP 1 Acetophenone HAP 1 Copper SDWA 1 Ethylene oxide Carcinogen, HAP 1 Lead Carcinogen, SDWA, HAP 1 Propylene oxide Carcinogen, HAP 1 p-Xylene HAP 1 Number of Products Containing a Component of Concern 652 19 According to EPA, diesel contains benzene, toluene, ethylbenzene, and xylenes. See EPA, Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs (June 2004) (EPA 816-R-04-003) at 4-11. 9 1. Carcinogens Between 2005 and 2009, the hydraulic fracturing companies used 95 products containing 13 different carcinogens.20 These included naphthalene (a possible human carcinogen), benzene (a known human carcinogen), and acrylamide (a probable human carcinogen). Overall, these companies injected 10.2 million gallons of fracturing products containing at least one carcinogen. The companies used the highest volume of fluids containing one or more carcinogens in Texas, Colorado, and Oklahoma. Table 4 shows the use of these chemicals by state. Table 4. States with at Least 100,000 Gallons of Hydraulic Fracturing Fluids Containing a Carcinogen (2005-2009) State Fluid Volume (gallons) Texas 3,877,273 Colorado 1,544,388 Oklahoma 1,098,746 Louisiana 777,945 Wyoming 759,898 North Dakota 557,519 New Mexico 511,186 Montana 394,873 Utah 382,338 2. Safe Drinking Water Act Chemicals Under the Safe Drinking Water Act, EPA regulates 53 chemicals that may have an adverse effect on human health and are known to or likely to occur in public drinking water systems at levels of public health concern. Between 2005 and 2009, the hydraulic fracturing companies used 67 products containing at least one of eight SDWA-regulated chemicals. Overall, they injected 11.7 million gallons of fracturing products containing at least one chemical regulated under SDWA. Most of these chemicals were injected in Texas. Table 5 shows the use of these chemicals by state. 20 For purposes of this report, a chemical is considered a “carcinogen” if it is on one of two lists: (1) substances identified by the National Toxicology Program as “known to be human carcinogens” or as “reasonably anticipated to be human carcinogens”; and (2) substances identified by the International Agency for Research on Cancer, part of the World Health Organization, as “carcinogenic” or “probably carcinogenic” to humans. See U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program, Report on Carcinogens, Eleventh Edition (Jan. 31, 2005) and World Health Organization, International Agency for Research on Cancer, Agents Classified by the IARC Monographs (online at http://monographs.iarc.fr/ENG/Classification/index.php) (accessed Feb. 28, 2011). 10 The vast majority of these SDWA-regulated chemicals were the BTEX compounds – benzene, toluene, xylene, and ethylbenzene. The BTEX compounds appeared in 60 hydraulic fracturing products used between 2005 and 2009 and were used in 11.4 million gallons of hydraulic fracturing fluids. The Department of Health and Human Services, the International Agency for Research on Cancer, and EPA have determined that benzene is a human carcinogen.21 Chronic exposure to toluene, ethylbenzene, or xylenes also can damage the central nervous system, liver, and kidneys.22 Table 5. States with at Least 100,000 Gallons of Hydraulic Fracturing Fluids Containing a SDWA- Regulated Chemical (2005-2009) State Fluid Volume (gallons) Texas 9,474,631 New Mexico 1,157,721 Colorado 375,817 Oklahoma 202,562 Mississippi 108,809 North Dakota 100,479 In addition, the hydraulic fracturing companies injected more than 30 million gallons of diesel fuel or hydraulic fracturing fluids containing diesel fuel in wells in 19 states.23 In a 2004 report, EPA stated that the “use of diesel fuel in fracturing fluids poses the greatest threat” to underground sources of drinking water.24 Diesel fuel contains toxic constituents, including BTEX compounds.25 EPA also has created a Candidate Contaminant List (CCL), which is a list of contaminants that are currently not subject to national primary drinking water regulations but are known or anticipated to occur in public water systems and may require regulation under the Safe Drinking Water Act in the future.26 Nine chemicals on that list—1-butanol, acetaldehyde, benzyl 21 U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry, Public Health Statement for Benzene (Aug. 2007). 22 EPA, Basic Information about Toluene in Drinking Water, Basic Information about Ethylbenzene in Drinking Water, and Basic Information about Xylenes in Drinking Water (online at http://water.epa.gov/drink/contaminants/basicinformation/index.cfm) (accessed Oct. 14, 2010). 23 Letter from Reps. Henry A. Waxman, Edward J. Markey, and Diana DeGette to the Honorable Lisa Jackson, Administrator, U.S. Environmental Protection Agency (Jan. 31, 2011). 24 EPA, Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs (June 2004) (EPA 816-R-04-003) at 4-11. 25 Id. 26 EPA, Contaminant Candidate List 3 (online at http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl3.cfm) (accessed Mar. 31, 2011). 11 chloride, ethylene glycol, ethylene oxide, formaldehyde, methanol, n-methyl-2-pyrrolidone, and propylene oxide—were used in hydraulic fracturing products between 2005 and 2009. 3. Hazardous Air Pollutants The Clean Air Act requires EPA to control the emission of 187 hazardous air pollutants, which are pollutants that cause or may cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental and ecological effects.27 Between 2005 and 2009, the hydraulic fracturing companies used 595 products containing 24 different hazardous air pollutants. Hydrogen fluoride is a hazardous air pollutant that is a highly corrosive and systemic poison that causes severe and sometimes delayed health effects due to deep tissue penetration. Absorption of substantial amounts of hydrogen fluoride by any route may be fatal.28 One of the hydraulic fracturing companies used 67,222 gallons of two products containing hydrogen fluoride in 2008 and 2009. Lead is a hazardous air pollutant that is a heavy metal that is particularly harmful to children’s neurological development. It also can cause health problems in adults, including reproductive problems, high blood pressure, and nerve disorders.29 One of the hydraulic fracturing companies used 780 gallons of a product containing lead in this five-year period. Methanol is the hazardous air pollutant that appeared most often in hydraulic fracturing products. Other hazardous air pollutants used in hydraulic fracturing fluids included formaldehyde, hydrogen chloride, and ethylene glycol. V. USE OF PROPRIETARY AND “TRADE SECRET” CHEMICALS Many chemical components of hydraulic fracturing fluids used by the companies were listed on the MSDSs as “proprietary” or “trade secret.” The hydraulic fracturing companies used 93.6 million gallons of 279 products containing at least one proprietary component between 2005 and 2009.30 27 Clean Air Act Section 112(b), 42 U.S.C. § 7412. 28 HHS, Agency for Toxic Substances and Disease Registry, Medical Management Guidelines for Hydrogen Fluoride (online at www.atsdr.cdc.gov/mhmi/mmg11.pdf) (accessed Mar. 24, 2011). 29 EPA, Basic Information about Lead (online at www.epa.gov/lead/pubs/leadinfo.htm) (accessed Mar. 30, 2011). 30 This is likely a conservative estimate. We included only those products for which the MSDS says “proprietary” or “trade secret” instead of listing a component by name or providing the CAS number. If the MSDS listed a component’s CAS as N.A. or left it blank, we did not count that as a trade secret claim, unless the company specified as such in follow-up correspondence. 12 The Committee requested that these companies disclose this proprietary information. Although a few companies were able to provide additional information to the Committee about some of the fracturing products, in most cases the companies stated that they did not have access to proprietary information about products they purchased “off the shelf” from chemical suppliers. The proprietary information belongs to the suppliers, not the users of the chemicals. Universal Well Services, for example, told the Committee that it “obtains hydraulic fracturing products from third-party manufacturers, and to the extent not publicly disclosed, product composition is proprietary to the respective vendor and not to the Company.”31 Complete Production Services noted that the company always uses fluids from third-party suppliers who provide an MSDS for each product. Complete confirmed that it is “not aware of any circumstances in which the vendors who provided the products have disclosed this proprietary information” to the company, further noting that “such information is highly proprietary for these vendors, and would not generally be disclosed to service providers” like Complete.32 Key Energy Services similarly stated that it “generally does not have access to the trade secret information as a purchaser of the chemical(s).”33 Trican also told the Committee that it has limited knowledge of “off the shelf” products purchased from a chemical distributor or manufacturer, noting that “Trican does not have any information in its possession about the components of such products beyond what the distributor of each product provided Trican in the MSDS sheet.”34 In these cases, it appears that the companies are injecting fluids containing unknown chemicals about which they may have limited understanding of the potential risks posed to human health and the environment. VI. CONCLUSION Hydraulic fracturing has opened access to vast domestic reserves of natural gas that could provide an important stepping stone to a clean energy future. Yet questions about the safety of hydraulic fracturing persist, which are compounded by the secrecy surrounding the chemicals used in hydraulic fracturing fluids. This analysis is the most comprehensive national assessment to date of the types and volumes of chemical used in the hydraulic fracturing process. It shows that between 2005 and 2009, the 14 leading hydraulic fracturing companies in the United States used over 2,500 hydraulic fracturing products containing 750 compounds. More than 650 of these products contained chemicals that are known or possible human carcinogens, regulated under the Safe Drinking Water Act, or listed as hazardous air pollutants. 31 Letter from Reginald J. Brown to Henry A. Waxman, Chairman, Committee on Energy and Commerce, and Edward J. Markey, Chairman, Subcommittee on Energy and Environment (Apr. 16, 2010). 32 Letter from Philip Perry to Henry A. Waxman, Chairman, Committee Energy and Commerce, and Edward J. Markey, Chairman, Subcommittee on Energy and Environment (Aug. 6, 2010). 33 E-mail from Peter Spivack to Committee Staff (Aug. 5, 2010). 34 E-mail from Lee Blalack to Committee Staff (July 29, 2010). 13 Appendix A. Chemical Components of Hydraulic Fracturing Products, 2005-200935 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical 1-(1-naphthylmethyl)quinolinium chloride 65322-65-8 1 1,2,3-propanetricarboxylic acid, 2-hydroxy-, trisodium salt, dihydrate 6132-04-3 1 1,2,3-trimethylbenzene 526-73-8 1 1,2,4-trimethylbenzene 95-63-6 21 1,2-benzisothiazol-3 2634-33-5 1 1,2-dibromo-2,4-dicyanobutane 35691-65-7 1 1,2-ethanediaminium, N, N'-bis[2-[bis(2-hydroxyethyl)methylammonio]ethyl]-N,N'- bis(2-hydroxyethyl)-N,N'-dimethyl-,tetrachloride 138879-94-4 2 1,3,5-trimethylbenzene 108-67-8 3 1,6-hexanediamine dihydrochloride 6055-52-3 1 1,8-diamino-3,6-dioxaoctane 929-59-9 1 1-hexanol 111-27-3 1 1-methoxy-2-propanol 107-98-2 3 2,2`-azobis (2-amidopropane) dihydrochloride 2997-92-4 1 2,2-dibromo-3-nitrilopropionamide 10222-01-2 27 2-acrylamido-2-methylpropanesulphonic acid sodium salt polymer * 1 2-bromo-2-nitropropane-1,3-diol 52-51-7 4 2-butanone oxime 96-29-7 1 2-hydroxypropionic acid 79-33-4 2 2-mercaptoethanol (Thioglycol) 60-24-2 13 2-methyl-4-isothiazolin-3-one 2682-20-4 4 2-monobromo-3-nitrilopropionamide 1113-55-9 1 2-phosphonobutane-1,2,4-tricarboxylic acid 37971-36-1 2 2-phosphonobutane-1,2,4-tricarboxylic acid, potassium salt 93858-78-7 1 2-substituted aromatic amine salt * 1 4,4'-diaminodiphenyl sulfone 80-08-0 3 5-chloro-2-methyl-4-isothiazolin-3-one 26172-55-4 5 Acetaldehyde 75-07-0 1 Acetic acid 64-19-7 56 Acetic anhydride 108-24-7 7 Acetone 67-64-1 3 Acetophenone 98-86-2 1 Acetylenic alcohol * 1 Acetyltriethyl citrate 77-89-4 1 Acrylamide 79-06-1 2 Acrylamide copolymer * 1 Acrylamide copolymer 38193-60-1 1 35 To compile this list of chemicals, Committee staff reviewed each Material Safety Data Sheet provided to the Committee for hydraulic fracturing products used between 2005 and 2009. Committee staff transcribed the names and CAS numbers as written in the MSDSs; as such, any inaccuracies on this list reflect inaccuracies on the MSDSs themselves. 14 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Acrylate copolymer * 1 Acrylic acid, 2-hydroxyethyl ester 818-61-1 1 Acrylic acid/2-acrylamido-methylpropylsulfonic acid copolymer 37350-42-8 1 Acrylic copolymer 403730-32-5 1 Acrylic polymers * 1 Acrylic polymers 26006-22-4 2 Acyclic hydrocarbon blend * 1 Adipic acid 124-04-9 6 Alcohol alkoxylate * 5 Alcohol ethoxylates * 2 Alcohols * 9 Alcohols, C11-15-secondary, ethoxylated 68131-40-8 1 Alcohols, C12-14-secondary 126950-60-5 4 Alcohols, C12-14-secondary, ethoxylated 84133-50-6 19 Alcohols, C12-15, ethoxylated 68131-39-5 2 Alcohols, C12-16, ethoxylated 103331-86-8 1 Alcohols, C12-16, ethoxylated 68551-12-2 3 Alcohols, C14-15, ethoxylated 68951-67-7 5 Alcohols, C9-11-iso-, C10-rich, ethoxylated 78330-20-8 4 Alcohols, C9-C22 * 1 Aldehyde * 4 Aldol 107-89-1 1 Alfa-Alumina * 5 Aliphatic acid * 1 Aliphatic alcohol polyglycol ether 68015-67-8 1 Aliphatic amine derivative 120086-58-0 2 Alkaline bromide salts * 2 Alkanes, C10-14 93924-07-3 2 Alkanes, C13-16-iso 68551-20-2 2 Alkanolamine 150-25-4 3 Alkanolamine chelate of zirconium alkoxide (Zirconium complex) 197980-53-3 4 Alkanolamine/aldehyde condensate * 1 Alkenes * 1 Alkenes, C>10 alpha- 64743-02-8 3 Alkenes, C>8 68411-00-7 2 Alkoxylated alcohols * 1 Alkoxylated amines * 6 Alkoxylated phenol formaldehyde resin 63428-92-2 1 Alkyaryl sulfonate * 1 Alkyl (C12-16) dimethyl benzyl ammonium chloride 68424-85-1 7 Alkyl (C6-C12) alcohol, ethoxylated 68439-45-2 2 Alkyl (C9-11) alcohol, ethoxylated 68439-46-3 1 Alkyl alkoxylate * 9 Alkyl amine * 2 15 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Alkyl amine blend in a metal salt solution * 1 Alkyl aryl amine sulfonate 255043-08-04 1 Alkyl benzenesulfonic acid 68584-22-5 2 Alkyl esters * 2 Alkyl hexanol * 1 Alkyl ortho phosphate ester * 1 Alkyl phosphate ester * 3 Alkyl quaternary ammonium chlorides * 4 Alkylaryl sulfonate * 1 Alkylaryl sulphonic acid 27176-93-9 1 Alkylated quaternary chloride * 5 Alkylbenzenesulfonic acid * 1 Alkylethoammonium sulfates * 1 Alkylphenol ethoxylates * 1 Almandite and pyrope garnet 1302-62-1 1 Aluminium isopropoxide 555-31-7 1 Aluminum 7429-90-5 2 Aluminum chloride * 3 Aluminum chloride 1327-41-9 2 Aluminum oxide (alpha-Alumina) 1344-28-1 24 Aluminum oxide silicate 12068-56-3 1 Aluminum silicate (mullite) 1302-76-7 38 Aluminum sulfate hydrate 10043-01-3 1 Amides, tallow, n-[3-(dimethylamino)propyl],n-oxides 68647-77-8 4 Amidoamine * 1 Amine * 7 Amine bisulfite 13427-63-9 1 Amine oxides * 1 Amine phosphonate * 3 Amine salt * 2 Amines, C14-18; C16-18-unsaturated, alkyl, ethoxylated 68155-39-5 1 Amines, coco alkyl, acetate 61790-57-6 3 Amines, polyethylenepoly-, ethoxylated, phosphonomethylated 68966-36-9 1 Amines, tallow alkyl, ethoxylated 61791-26-2 2 Amino compounds * 1 Amino methylene phosphonic acid salt * 1 Amino trimethylene phosphonic acid 6419-19-8 2 Ammonia 7664-41-7 7 Ammonium acetate 631-61-8 4 Ammonium alcohol ether sulfate 68037-05-8 1 Ammonium bicarbonate 1066-33-7 1 Ammonium bifluoride (Ammonium hydrogen difluoride) 1341-49-7 10 Ammonium bisulfate 7783-20-2 3 Ammonium bisulfite 10192-30-0 15 16 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Ammonium C6-C10 alcohol ethoxysulfate 68187-17-7 4 Ammonium C8-C10 alkyl ether sulfate 68891-29-2 4 Ammonium chloride 12125-02-9 29 Ammonium fluoride 12125-01-8 9 Ammonium hydroxide 1336-21-6 4 Ammonium nitrate 6484-52-2 2 Ammonium persulfate (Diammonium peroxidisulfate) 7727-54-0 37 Ammonium salt * 1 Ammonium salt of ethoxylated alcohol sulfate * 1 Amorphous silica 99439-28-8 1 Amphoteric alkyl amine 61789-39-7 1 Anionic copolymer * 3 Anionic polyacrylamide * 1 Anionic polyacrylamide 25085-02-3 6 Anionic polyacrylamide copolymer * 3 Anionic polymer * 2 Anionic polymer in solution * 1 Anionic polymer, sodium salt 9003-04-7 1 Anionic water-soluble polymer * 2 Antifoulant * 1 Antimonate salt * 1 Antimony pentoxide 1314-60-9 2 Antimony potassium oxide 29638-69-5 4 Antimony trichloride 10025-91-9 2 a-organic surfactants 61790-29-8 1 Aromatic alcohol glycol ether * 2 Aromatic aldehyde * 2 Aromatic ketones 224635-63-6 2 Aromatic polyglycol ether * 1 Barium sulfate 7727-43-7 3 Bauxite 1318-16-7 16 Bentonite 1302-78-9 2 Benzene 71-43-2 3 Benzene, C10-16, alkyl derivatives 68648-87-3 1 Benzenecarboperoxoic acid, 1,1-dimethylethyl ester 614-45-9 1 Benzenemethanaminium 3844-45-9 1 Benzenesulfonic acid, C10-16-alkyl derivs., potassium salts 68584-27-0 1 Benzoic acid 65-85-0 11 Benzyl chloride 100-44-7 8 Biocide component * 3 Bis(1-methylethyl)naphthalenesulfonic acid, cyclohexylamine salt 68425-61-6 1 Bishexamethylenetriamine penta methylene phosphonic acid 35657-77-3 1 Bisphenol A/Epichlorohydrin resin 25068-38-6 5 Bisphenol A/Novolac epoxy resin 28906-96-9 1 17 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Borate 12280-03-4 2 Borate salts * 5 Boric acid 10043-35-3 18 Boric acid, potassium salt 20786-60-1 1 Boric acid, sodium salt 1333-73-9 2 Boric oxide 1303-86-2 1 b-tricalcium phosphate 7758-87-4 1 Butanedioic acid 2373-38-8 4 Butanol 71-36-3 3 Butyl glycidyl ether 2426-08-6 5 Butyl lactate 138-22-7 4 C10-C16 ethoxylated alcohol 68002-97-1 4 C-11 to C-14 n-alkanes, mixed * 1 C12-C14 alcohol, ethoxylated 68439-50-9 3 Calcium carbonate 471-34-1 1 Calcium carbonate (Limestone) 1317-65-3 9 Calcium chloride 10043-52-4 17 Calcium chloride, dihydrate 10035-04-8 1 Calcium fluoride 7789-75-5 2 Calcium hydroxide 1305-62-0 9 Calcium hypochlorite 7778-54-3 1 Calcium oxide 1305-78-8 6 Calcium peroxide 1305-79-9 5 Carbohydrates * 3 Carbon dioxide 124-38-9 4 Carboxymethyl guar gum, sodium salt 39346-76-4 7 Carboxymethyl hydroxypropyl guar 68130-15-4 11 Cellophane 9005-81-6 2 Cellulase 9012-54-8 7 Cellulase enzyme * 1 Cellulose 9004-34-6 1 Cellulose derivative * 2 Chloromethylnaphthalene quinoline quaternary amine 15619-48-4 3 Chlorous ion solution * 2 Choline chloride 67-48-1 3 Chromates * 1 Chromium (iii) acetate 1066-30-4 1 Cinnamaldehyde (3-phenyl-2-propenal) 104-55-2 5 Citric acid (2-hydroxy-1,2,3 propanetricarboxylic acid) 77-92-9 29 Citrus terpenes 94266-47-4 11 Coal, granular 50815-10-6 1 Cobalt acetate 71-48-7 1 Cocaidopropyl betaine 61789-40-0 2 Cocamidopropylamine oxide 68155-09-9 1 18 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Coco bis-(2-hydroxyethyl) amine oxide 61791-47-7 1 Cocoamidopropyl betaine 70851-07-9 1 Cocomidopropyl dimethylamine 68140-01-2 1 Coconut fatty acid diethanolamide 68603-42-9 1 Collagen (Gelatin) 9000-70-8 6 Complex alkylaryl polyo-ester * 1 Complex aluminum salt * 2 Complex organometallic salt * 2 Complex substituted keto-amine 143106-84-7 1 Complex substituted keto-amine hydrochloride * 1 Copolymer of acrylamide and sodium acrylate 25987-30-8 1 Copper 7440-50-8 1 Copper iodide 7681-65-4 1 Copper sulfate 7758-98-7 3 Corundum (Aluminum oxide) 1302-74-5 48 Crotonaldehyde 123-73-9 1 Crystalline silica - cristobalite 14464-46-1 44 Crystalline silica - quartz (SiO2) 14808-60-7 207 Crystalline silica, tridymite 15468-32-3 2 Cumene 98-82-8 6 Cupric chloride 7447-39-4 10 Cupric chloride dihydrate 10125-13-0 7 Cuprous chloride 7758-89-6 1 Cured acrylic resin * 7 Cured resin * 4 Cured silicone rubber-polydimethylsiloxane 63148-62-9 1 Cured urethane resin * 3 Cyclic alkanes * 1 Cyclohexane 110-82-7 1 Cyclohexanone 108-94-1 1 Decanol 112-30-1 2 Decyl-dimethyl amine oxide 2605-79-0 4 Dextrose monohydrate 50-99-7 1 D-Glucitol 50-70-4 1 Di (2-ethylhexyl) phthalate 117-81-7 3 Di (ethylene glycol) ethyl ether acetate 112-15-2 4 Diatomaceous earth 61790-53-2 3 Diatomaceous earth, calcined 91053-39-3 7 Dibromoacetonitrile 3252-43-5 1 Dibutylaminoethanol (2-dibutylaminoethanol) 102-81-8 4 Di-calcium silicate 10034-77-2 1 Dicarboxylic acid * 1 Didecyl dimethyl ammonium chloride 7173-51-5 1 Diesel * 1 19 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Diesel 68334-30-5 3 Diesel 68476-30-2 4 Diesel 68476-34-6 43 Diethanolamine (2,2-iminodiethanol) 111-42-2 14 Diethylbenzene 25340-17-4 1 Diethylene glycol 111-46-6 8 Diethylene glycol monomethyl ether 111-77-3 4 Diethylene triaminepenta (methylene phosphonic acid) 15827-60-8 1 Diethylenetriamine 111-40-0 2 Diethylenetriamine, tall oil fatty acids reaction product 61790-69-0 1 Diisopropylnaphthalenesulfonic acid 28757-00-8 2 Dimethyl formamide 68-12-2 5 Dimethyl glutarate 1119-40-0 1 Dimethyl silicone * 2 Dioctyl sodium sulfosuccinate 577-11-7 1 Dipropylene glycol 25265-71-8 1 Dipropylene glycol monomethyl ether (2-methoxymethylethoxy propanol) 34590-94-8 12 Di-secondary-butylphenol 53964-94-6 3 Disodium EDTA 139-33-3 1 Disodium ethylenediaminediacetate 38011-25-5 1 Disodium ethylenediaminetetraacetate dihydrate 6381-92-6 1 Disodium octaborate tetrahydrate 12008-41-2 1 Dispersing agent * 1 d-Limonene 5989-27-5 11 Dodecyl alcohol ammonium sulfate 32612-48-9 2 Dodecylbenzene sulfonic acid 27176-87-0 14 Dodecylbenzene sulfonic acid salts 42615-29-2 2 Dodecylbenzene sulfonic acid salts 68648-81-7 7 Dodecylbenzene sulfonic acid salts 90218-35-2 1 Dodecylbenzenesulfonate isopropanolamine 42504-46-1 1 Dodecylbenzenesulfonic acid, monoethanolamine salt 26836-07-7 1 Dodecylbenzenesulphonic acid, morpholine salt 12068-08-5 1 EDTA/Copper chelate * 2 EO-C7-9-iso-, C8-rich alcohols 78330-19-5 5 Epichlorohydrin 25085-99-8 5 Epoxy resin * 5 Erucic amidopropyl dimethyl betaine 149879-98-1 3 Erythorbic acid 89-65-6 2 Essential oils * 6 Ethanaminium, n,n,n-trimethyl-2-[(1-oxo-2-propenyl)oxy]-,chloride, polymer with 2-propenamide 69418-26-4 4 Ethanol (Ethyl alcohol) 64-17-5 36 Ethanol, 2-(hydroxymethylamino)- 34375-28-5 1 Ethanol, 2, 2'-(Octadecylamino) bis- 10213-78-2 1 20 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Ethanoldiglycine disodium salt 135-37-5 1 Ether salt 25446-78-0 2 Ethoxylated 4-nonylphenol (Nonyl phenol ethoxylate) 26027-38-3 9 Ethoxylated alcohol 104780-82-7 1 Ethoxylated alcohol 78330-21-9 2 Ethoxylated alcohols * 3 Ethoxylated alkyl amines * 1 Ethoxylated amine * 1 Ethoxylated amines 61791-44-4 1 Ethoxylated fatty acid ester * 1 Ethoxylated nonionic surfactant * 1 Ethoxylated nonyl phenol * 8 Ethoxylated nonyl phenol 68412-54-4 10 Ethoxylated nonyl phenol 9016-45-9 38 Ethoxylated octyl phenol 68987-90-6 1 Ethoxylated octyl phenol 9002-93-1 1 Ethoxylated octyl phenol 9036-19-5 3 Ethoxylated oleyl amine 13127-82-7 2 Ethoxylated oleyl amine 26635-93-8 1 Ethoxylated sorbitol esters * 1 Ethoxylated tridecyl alcohol phosphate 9046-01-9 2 Ethoxylated undecyl alcohol 127036-24-2 2 Ethyl acetate 141-78-6 4 Ethyl acetoacetate 141-97-9 1 Ethyl octynol (1-octyn-3-ol,4-ethyl-) 5877-42-9 5 Ethylbenzene 100-41-4 28 Ethylene glycol (1,2-ethanediol) 107-21-1 119 Ethylene glycol monobutyl ether (2-butoxyethanol) 111-76-2 126 Ethylene oxide 75-21-8 1 Ethylene oxide-nonylphenol polymer * 1 Ethylenediaminetetraacetic acid 60-00-4 1 Ethylene-vinyl acetate copolymer 24937-78-8 1 Ethylhexanol (2-ethylhexanol) 104-76-7 18 Fatty acid ester * 1 Fatty acid, tall oil, hexa esters with sorbitol, ethoxylated 61790-90-7 1 Fatty acids * 1 Fatty alcohol alkoxylate * 1 Fatty alkyl amine salt * 1 Fatty amine carboxylates * 1 Fatty quaternary ammonium chloride 61789-68-2 1 Ferric chloride 7705-08-0 3 Ferric sulfate 10028-22-5 7 Ferrous sulfate, heptahydrate 7782-63-0 4 Fluoroaliphatic polymeric esters * 1 21 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Formaldehyde 50-00-0 12 Formaldehyde polymer * 2 Formaldehyde, polymer with 4-(1,1-dimethyl)phenol, methyloxirane and oxirane 30704-64-4 3 Formaldehyde, polymer with 4-nonylphenol and oxirane 30846-35-6 1 Formaldehyde, polymer with ammonia and phenol 35297-54-2 2 Formamide 75-12-7 5 Formic acid 64-18-6 24 Fumaric acid 110-17-8 8 Furfural 98-01-1 1 Furfuryl alcohol 98-00-0 3 Glass fiber 65997-17-3 3 Gluconic acid 526-95-4 1 Glutaraldehyde 111-30-8 20 Glycerol (1,2,3-Propanetriol, Glycerine) 56-81-5 16 Glycol ethers * 9 Glycol ethers 9004-77-7 4 Glyoxal 107-22-2 3 Glyoxylic acid 298-12-4 1 Guar gum 9000-30-0 41 Guar gum derivative * 12 Haloalkyl heteropolycycle salt * 6 Heavy aromatic distillate 68132-00-3 1 Heavy aromatic petroleum naphtha 64742-94-5 45 Heavy catalytic reformed petroleum naphtha 64741-68-0 10 Hematite * 5 Hemicellulase 9025-56-3 2 Hexahydro-1,3,5-tris(2-hydroxyethyl)-s-triazine (Triazine) 4719-04-4 4 Hexamethylenetetramine 100-97-0 37 Hexanediamine 124-09-4 1 Hexanes * 1 Hexylene glycol 107-41-5 5 Hydrated aluminum silicate 1332-58-7 4 Hydrocarbon mixtures 8002-05-9 1 Hydrocarbons * 3 Hydrodesulfurized kerosine (petroleum) 64742-81-0 3 Hydrodesulfurized light catalytic cracked distillate (petroleum) 68333-25-5 1 Hydrodesulfurized middle distillate (petroleum) 64742-80-9 1 Hydrogen chloride (Hydrochloric acid) 7647-01-0 42 Hydrogen fluoride (Hydrofluoric acid) 7664-39-3 2 Hydrogen peroxide 7722-84-1 4 Hydrogen sulfide 7783-06-4 1 Hydrotreated and hydrocracked base oil * 2 Hydrotreated heavy naphthenic distillate 64742-52-5 3 Hydrotreated heavy paraffinic petroleum distillates 64742-54-7 1 22 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Hydrotreated heavy petroleum naphtha 64742-48-9 7 Hydrotreated light petroleum distillates 64742-47-8 89 Hydrotreated middle petroleum distillates 64742-46-7 3 Hydroxyacetic acid (Glycolic acid) 79-14-1 6 Hydroxyethylcellulose 9004-62-0 1 Hydroxyethylethylenediaminetriacetic acid, trisodium salt 139-89-9 1 Hydroxylamine hydrochloride 5470-11-1 1 Hydroxypropyl guar gum 39421-75-5 2 Hydroxysultaine * 1 Inner salt of alkyl amines * 2 Inorganic borate * 3 Inorganic particulate * 1 Inorganic salt * 1 Inorganic salt 533-96-0 1 Inorganic salt 7446-70-0 1 Instant coffee purchased off the shelf * 1 Inulin, carboxymethyl ether, sodium salt 430439-54-6 1 Iron oxide 1332-37-2 2 Iron oxide (Ferric oxide) 1309-37-1 18 Iso amyl alcohol 123-51-3 1 Iso-alkanes/n-alkanes * 10 Isobutanol (Isobutyl alcohol) 78-83-1 4 Isomeric aromatic ammonium salt * 1 Isooctanol 26952-21-6 1 Isooctyl alcohol 68526-88-0 1 Isooctyl alcohol bottoms 68526-88-5 1 Isopropanol (Isopropyl alcohol, Propan-2-ol) 67-63-0 274 Isopropylamine 75-31-0 1 Isotridecanol, ethoxylated 9043-30-5 1 Kerosene 8008-20-6 13 Lactic acid 10326-41-7 1 Lactic acid 50-21-5 1 L-Dilactide 4511-42-6 1 Lead 7439-92-1 1 Light aromatic solvent naphtha 64742-95-6 11 Light catalytic cracked petroleum distillates 64741-59-9 1 Light naphtha distillate, hydrotreated 64742-53-6 1 Low toxicity base oils * 1 Maghemite * 2 Magnesium carbonate 546-93-0 1 Magnesium chloride 7786-30-3 4 Magnesium hydroxide 1309-42-8 4 Magnesium iron silicate 1317-71-1 3 Magnesium nitrate 10377-60-3 5 23 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Magnesium oxide 1309-48-4 18 Magnesium peroxide 1335-26-8 2 Magnesium peroxide 14452-57-4 4 Magnesium phosphide 12057-74-8 1 Magnesium silicate 1343-88-0 3 Magnesium silicate hydrate (talc) 14807-96-6 2 Magnetite * 3 Medium aliphatic solvent petroleum naphtha 64742-88-7 10 Metal salt * 2 Metal salt solution * 1 Methanol (Methyl alcohol) 67-56-1 342 Methyl isobutyl carbinol (Methyl amyl alcohol) 108-11-2 3 Methyl salicylate 119-36-8 6 Methyl vinyl ketone 78-94-4 2 Methylcyclohexane 108-87-2 1 Mica 12001-26-2 3 Microcrystalline silica 1317-95-9 1 Mineral * 1 Mineral Filler * 1 Mineral spirits (stoddard solvent) 8052-41-3 2 Mixed titanium ortho ester complexes * 1 Modified alkane * 1 Modified cycloaliphatic amine adduct * 3 Modified lignosulfonate * 1 Monoethanolamine (Ethanolamine) 141-43-5 17 Monoethanolamine borate 26038-87-9 1 Morpholine 110-91-8 2 Mullite 1302-93-8 55 n,n-dibutylthiourea 109-46-6 1 N,N-dimethyl-1-octadecanamine-HCl * 1 N,N-dimethyloctadecylamine 124-28-7 3 N,N-dimethyloctadecylamine hydrochloride 1613-17-8 2 n,n'-Methylenebisacrylamide 110-26-9 1 n-alkyl dimethyl benzyl ammonium chloride 139-08-2 1 Naphthalene 91-20-3 44 Naphthalene derivatives * 1 Naphthalenesulphonic acid, bis (1-methylethyl)-methyl derivatives 99811-86-6 1 Natural asphalt 12002-43-6 1 n-cocoamidopropyl-n,n-dimethyl-n-2-hydroxypropylsulfobetaine 68139-30-0 1 n-dodecyl-2-pyrrolidone 2687-96-9 1 N-heptane 142-82-5 1 Nickel sulfate hexahydrate 10101-97-0 2 Nitrilotriacetamide 4862-18-4 4 Nitrilotriacetic acid 139-13-9 6 24 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Nitrilotriacetonitrile 7327-60-8 3 Nitrogen 7727-37-9 9 n-Methylpyrrolidone 872-50-4 1 Nonane, all isomers * 1 Non-hazardous salt * 1 Nonionic surfactant * 1 Nonyl phenol ethoxylate * 2 Nonyl phenol ethoxylate 9016-45-6 2 Nonyl phenol ethoxylate 9018-45-9 1 Nonylphenol 25154-52-3 1 Nonylphenol, ethoxylated and sulfated 9081-17-8 1 N-propyl zirconate * 1 N-tallowalkyltrimethylenediamines * 1 Nuisance particulates * 2 Nylon fibers 25038-54-4 2 Octanol 111-87-5 2 Octyltrimethylammonium bromide 57-09-0 1 Olefinic sulfonate * 1 Olefins * 1 Organic acid salt * 3 Organic acids * 1 Organic phosphonate * 1 Organic phosphonate salts * 1 Organic phosphonic acid salts * 6 Organic salt * 1 Organic sulfur compound * 2 Organic titanate * 2 Organiophilic clay * 2 Organo-metallic ammonium complex * 1 Other inorganic compounds * 1 Oxirane, methyl-, polymer with oxirane, mono-C10-16-alkyl ethers, phosphates 68649-29-6 1 Oxyalkylated alcohol * 6 Oxyalkylated alcohols 228414-35-5 1 Oxyalkylated alkyl alcohol * 1 Oxyalkylated alkylphenol * 1 Oxyalkylated fatty acid * 2 Oxyalkylated phenol * 1 Oxyalkylated polyamine * 1 Oxylated alcohol * 1 Paraffin wax 8002-74-2 1 Paraffinic naphthenic solvent * 1 Paraffinic solvent * 5 Paraffins * 1 Perlite 93763-70-3 1 25 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Petroleum distillates * 26 Petroleum distillates 64742-65-0 1 Petroleum distillates 64742-97-5 1 Petroleum distillates 68477-31-6 3 Petroleum gas oils * 1 Petroleum gas oils 64741-43-1 1 Phenol 108-95-2 5 Phenol-formaldehyde resin 9003-35-4 32 Phosphate ester * 6 Phosphate esters of alkyl phenyl ethoxylate 68412-53-3 1 Phosphine * 1 Phosphonic acid * 1 Phosphonic acid 129828-36-0 1 Phosphonic acid 13598-36-2 3 Phosphonic acid (dimethlamino(methylene)) 29712-30-9 1 Phosphonic acid, [nitrilotris(methylene)]tris-, pentasodium salt 2235-43-0 1 Phosphoric acid 7664-38-2 7 Phosphoric acid ammonium salt * 1 Phosphoric acid, mixed decyl, octyl and ethyl esters 68412-60-2 3 Phosphorous acid 10294-56-1 1 Phthalic anhydride 85-44-9 2 Pine oil 8002-09-3 5 Plasticizer * 1 Poly(oxy-1,2-ethanediyl) 24938-91-8 1 Poly(oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-, branched (Nonylphenol ethoxylate) 127087-87-0 3 Poly(oxy-1,2-ethanediyl), alpha-hydro-omega-hydroxy 65545-80-4 1 Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-(hexyloxy)-, ammonium salt 63428-86-4 3 Poly(oxy-1,2-ethanediyl),a-(nonylphenyl)-w-hydroxy-, phosphate 51811-79-1 1 Poly-(oxy-1,2-ethanediyl)-alpha-undecyl-omega-hydroxy 34398-01-1 6 Poly(sodium-p-styrenesulfonate) 25704-18-1 1 Poly(vinyl alcohol) 25213-24-5 2 Polyacrylamides 9003-05-8 2 Polyacrylamides * 1 Polyacrylate * 1 Polyamine * 2 Polyanionic cellulose * 2 Polyepichlorohydrin, trimethylamine quaternized 51838-31-4 1 Polyetheramine 9046-10-0 3 Polyether-modified trisiloxane 27306-78-1 1 Polyethylene glycol 25322-68-3 20 Polyethylene glycol ester with tall oil fatty acid 9005-02-1 1 Polyethylene polyammonium salt 68603-67-8 2 Polyethylene-polypropylene glycol 9003-11-6 5 26 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Polylactide resin * 3 Polyoxyalkylenes * 1 Polyoxyethylene castor oil 61791-12-6 1 Polyphosphoric acid, esters with triethanolamine, sodium salts 68131-72-6 1 Polypropylene glycol 25322-69-4 1 Polysaccharide * 20 Polyvinyl alcohol * 1 Polyvinyl alcohol 9002-89-5 2 Polyvinyl alcohol/polyvinylacetate copolymer * 1 Potassium acetate 127-08-2 1 Potassium carbonate 584-08-7 12 Potassium chloride 7447-40-7 29 Potassium formate 590-29-4 3 Potassium hydroxide 1310-58-3 25 Potassium iodide 7681-11-0 6 Potassium metaborate 13709-94-9 3 Potassium metaborate 16481-66-6 3 Potassium oxide 12136-45-7 1 Potassium pentaborate * 1 Potassium persulfate 7727-21-1 9 Propanol (Propyl alcohol) 71-23-8 18 Propanol, [2(2-methoxy-methylethoxy) methylethoxyl] 20324-33-8 1 Propargyl alcohol (2-propyn-1-ol) 107-19-7 46 Propylene carbonate (1,3-dioxolan-2-one, methyl-) 108-32-7 2 Propylene glycol (1,2-propanediol) 57-55-6 18 Propylene oxide 75-56-9 1 Propylene pentamer 15220-87-8 1 p-Xylene 106-42-3 1 Pyridinium, 1-(phenylmethyl)-, ethyl methyl derivatives, chlorides 68909-18-2 9 Pyrogenic silica 112945-52-5 3 Quaternary amine compounds * 3 Quaternary amine compounds 61789-18-2 1 Quaternary ammonium compounds * 9 Quaternary ammonium compounds 19277-88-4 1 Quaternary ammonium compounds 68989-00-4 1 Quaternary ammonium compounds 8030-78-2 1 Quaternary ammonium compounds, dicoco alkyldimethyl, chlorides 61789-77-3 2 Quaternary ammonium salts * 2 Quaternary compound * 1 Quaternary salt * 2 Quaternized alkyl nitrogenated compound 68391-11-7 2 Rafinnates (petroleum), sorption process 64741-85-1 2 Residues (petroleum), catalytic reformer fractionator 64741-67-9 10 Resin 8050-09-7 2 27 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Rutile 1317-80-2 2 Salt of phosphate ester * 3 Salt of phosphono-methylated diamine * 1 Salts of oxyalkylated fatty amines 68551-33-7 1 Secondary alcohol * 7 Silica (Silicon dioxide) 7631-86-9 47 Silica, amorphous * 3 Silica, amorphous precipitated 67762-90-7 1 Silicon carboxylate 681-84-5 1 Silicon dioxide (Fused silica) 60676-86-0 7 Silicone emulsion * 1 Sodium (C14-16) olefin sulfonate 68439-57-6 4 Sodium 2-ethylhexyl sulfate 126-92-1 1 Sodium acetate 127-09-3 6 Sodium acid pyrophosphate 7758-16-9 5 Sodium alkyl diphenyl oxide sulfonate 28519-02-0 1 Sodium aluminate 1302-42-7 1 Sodium aluminum phosphate 7785-88-8 1 Sodium bicarbonate (Sodium hydrogen carbonate) 144-55-8 10 Sodium bisulfite 7631-90-5 6 Sodium bromate 7789-38-0 10 Sodium bromide 7647-15-6 1 Sodium carbonate 497-19-8 14 Sodium chlorate 7775-09-9 1 Sodium chloride 7647-14-5 48 Sodium chlorite 7758-19-2 8 Sodium cocaminopropionate 68608-68-4 2 Sodium diacetate 126-96-5 2 Sodium erythorbate 6381-77-7 4 Sodium glycolate 2836-32-0 2 Sodium hydroxide (Caustic soda) 1310-73-2 80 Sodium hypochlorite 7681-52-9 14 Sodium lauryl-ether sulfate 68891-38-3 3 Sodium metabisulfite 7681-57-4 1 Sodium metaborate 7775-19-1 2 Sodium metaborate tetrahydrate 35585-58-1 6 Sodium metasilicate, anhydrous 6834-92-0 2 Sodium nitrite 7632-00-0 1 Sodium oxide (Na2O) 1313-59-3 1 Sodium perborate 1113-47-9 1 Sodium perborate 7632-04-4 1 Sodium perborate tetrahydrate 10486-00-7 4 Sodium persulfate 7775-27-1 6 Sodium phosphate * 2 28 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Sodium polyphosphate 68915-31-1 1 Sodium salicylate 54-21-7 1 Sodium silicate 1344-09-8 2 Sodium sulfate 7757-82-6 7 Sodium tetraborate 1330-43-4 7 Sodium tetraborate decahydrate 1303-96-4 10 Sodium thiosulfate 7772-98-7 10 Sodium thiosulfate pentahydrate 10102-17-7 3 Sodium trichloroacetate 650-51-1 1 Sodium tripolyphosphate 7758-29-4 2 Sodium xylene sulfonate 1300-72-7 3 Sodium zirconium lactate 174206-15-6 1 Solvent refined heavy naphthenic petroleum distillates 64741-96-4 1 Sorbitan monooleate 1338-43-8 1 Stabilized aqueous chlorine dioxide 10049-04-4 1 Stannous chloride 7772-99-8 1 Stannous chloride dihydrate 10025-69-1 6 Starch 9005-25-8 5 Steam cracked distillate, cyclodiene dimer, dicyclopentadiene polymer 68131-87-3 1 Steam-cracked petroleum distillates 64742-91-2 6 Straight run middle petroleum distillates 64741-44-2 5 Substituted alcohol * 2 Substituted alkene * 1 Substituted alkylamine * 2 Sucrose 57-50-1 1 Sulfamic acid 5329-14-6 6 Sulfate * 1 Sulfonate acids * 1 Sulfonate surfactants * 1 Sulfonic acid salts * 1 Sulfonic acids, petroleum 61789-85-3 1 Sulfur compound * 1 Sulfuric acid 7664-93-9 9 Sulfuric acid, monodecyl ester, sodium salt 142-87-0 2 Sulfuric acid, monooctyl ester, sodium salt 142-31-4 2 Surfactants * 13 Sweetened middle distillate 64741-86-2 1 Synthetic organic polymer 9051-89-2 2 Tall oil (Fatty acids) 61790-12-3 4 Tall oil, compound with diethanolamine 68092-28-4 1 Tallow soap * 2 Tar bases, quinoline derivatives, benzyl chloride-quaternized 72480-70-7 5 Tergitol 68439-51-0 1 Terpene hydrocarbon byproducts 68956-56-9 3 29 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Terpenes * 1 Terpenes and terpenoids, sweet orange-oil 68647-72-3 2 Terpineol 8000-41-7 1 Tert-butyl hydroperoxide 75-91-2 6 Tetra-calcium-alumino-ferrite 12068-35-8 1 Tetraethylene glycol 112-60-7 1 Tetraethylenepentamine 112-57-2 2 Tetrahydro-3,5-dimethyl-2H-1,3,5-thiadiazine-2-thione (Dazomet) 533-74-4 13 Tetrakis (hydroxymethyl) phosphonium sulfate 55566-30-8 12 Tetramethyl ammonium chloride 75-57-0 14 Tetrasodium 1-hydroxyethylidene-1,1-diphosphonic acid 3794-83-0 1 Tetrasodium ethylenediaminetetraacetate 64-02-8 10 Thiocyanate sodium 540-72-7 1 Thioglycolic acid 68-11-1 6 Thiourea 62-56-6 9 Thiourea polymer 68527-49-1 3 Titanium complex * 1 Titanium oxide 13463-67-7 19 Titanium, isopropoxy (triethanolaminate) 74665-17-1 2 Toluene 108-88-3 29 Treated ammonium chloride (with anti-caking agent a or b) 12125-02-9 1 Tributyl tetradecyl phosphonium chloride 81741-28-8 5 Tri-calcium silicate 12168-85-3 1 Tridecyl alcohol 112-70-9 1 Triethanolamine (2,2,2-nitrilotriethanol) 102-71-6 21 Triethanolamine polyphosphate ester 68131-71-5 3 Triethanolamine titanate 36673-16-2 1 Triethanolamine zirconate 101033-44-7 6 Triethanolamine zirconium chelate * 1 Triethyl citrate 77-93-0 1 Triethyl phosphate 78-40-0 1 Triethylene glycol 112-27-6 3 Triisopropanolamine 122-20-3 5 Trimethylammonium chloride 593-81-7 1 Trimethylbenzene 25551-13-7 5 Trimethyloctadecylammonium (1-octadecanaminium, N,N,N-trimethyl-, chloride) 112-03-8 6 Tris(hydroxymethyl)aminomethane 77-86-1 1 Trisodium ethylenediaminetetraacetate 150-38-9 1 Trisodium ethylenediaminetriacetate 19019-43-3 1 Trisodium nitrilotriacetate 18662-53-8 8 Trisodium nitrilotriacetate (Nitrilotriacetic acid, trisodium salt monohydrate) 5064-31-3 9 Trisodium ortho phosphate 7601-54-9 1 Trisodium phosphate dodecahydrate 10101-89-0 1 Ulexite 1319-33-1 1 30 Chemical Component Chemical Abstract Service Number No. of Products Containing Chemical Urea 57-13-6 3 Wall material * 1 Walnut hulls * 2 White mineral oil 8042-47-5 8 Xanthan gum 11138-66-2 6 Xylene 1330-20-7 44 Zinc chloride 7646-85-7 1 Zinc oxide 1314-13-2 2 Zirconium complex * 10 Zirconium dichloride oxide 7699-43-6 1 Zirconium oxide sulfate 62010-10-0 2 Zirconium sodium hydroxy lactate complex (Sodium zirconium lactate) 113184-20-6 2 * Components marked with an asterisk appeared on at least one MSDS without an identifying CAS number. The MSDSs in these cases marked the CAS as proprietary, noted that the CAS was not available, or left the CAS field blank. Components marked with an asterisk may be duplicative of other components on this list, but Committee staff have no way of identifying such duplicates without the identifying CAS number. TERRA MENTIS END OF REPORT 101 Real Estate Valuation Services Phase 1-Fracking Impact Study Fort Collins, CO DATE OF REPORT August 1, 2014 Wayne L. Hunsperger, MAI, SRA Jean C. Townsend HUNSPERGER & WESTON, LTD. 6 Inverness Court East, Suite 120 Englewood, Colorado 80112 August 1, 2014 Mr. John Duval, Esq. Senior Assistant City Attorney City of Fort Collins P. O. Box 580 Fort Collins, CO 80522 Impact of Hydraulic Fracturing Dear Mr. Duval: Pursuant to our Professional Services Agreement, I am pleased to convey the following report. I emphasize that my role in this study is as a real estate appraiser; as such, I am bound by the Uniform Standards of Professional Practice, even though the report contains no opinion of value. The report that follows consists of nine major topics in addition to a complete bibliography of the literature reviewed. Although Hunsperger & Weston, Ltd. is referred to as the “Professional” in the Professional Services Agreement, the report was prepared jointly between Wayne L. Hunsperger and sub-contractor, Jean C. Townsend, President of Coley/Forrest, Inc. Based on our review of the literature, Ms. Townsend and I have summarized our observations in Section 2. In general, the study of property value impacts related to hydraulic fracturing is in its infancy. To date, few scholarly property impact studies have been published, but the literature does suggest that a negative environmental event associated with fracking will likely have an adverse impact on property values in proximity to the event. Thank you for the opportunity of working on this assignment. If you have questions or comments, please do not hesitate to contact me or Ms. Townsend. Respectfully submitted, Wayne L. Hunsperger, MAI, SRA Hunsperger & Weston, Ltd. PAGE 1 Table of Contents 1. Assignment ................................................................................................................................... 2 2. Observations ................................................................................................................................. 3 3. Fracking Impacts and Property Values ..................................................................................... 4 4. Shale Oil and Gas Locations and Production Volumes .......................................................... 8 5. Sources of Information ............................................................................................................... 9 6 Analytical Methods Applied in Cited Literature................................................................... 13 7. Technical Resources and Specialists ....................................................................................... 16 8. Data Gaps to Complete A Property Impact Analysis ........................................................... 16 9. Alternative Methods and Approaches to fill Data Gaps ...................................................... 20 10. Bibliography of Literature Reviewed ...................................................................................... 22 11. Annotated Bibliography ........................................................................................................... 39 PAGE 2 1. ASSIGNMENT This assignment:  provides results of a literature and resources search relative to Ballot Measure 2A which imposes a 5-year moratorium on hydraulic fracturing in the City of Fort Collins1 (Sections 2 through 7, Sections 10 and 11);  identifies data gaps that would be necessary to describe potential property value impacts in Fort Collins that would also be acceptable in a court of law and approaches to complete an analysis of property value impacts attributable to fracking (Sections 8 and 9). For purposes of this report, the definition of hydraulic fracturing and its potential, associated harms is set out in Section 2 of the citizen-initiated ordinance proposed in Ballot Measure 2A that was adopted by the City’s voters on November 5, 2013. It reads: “The well stimulation process known as hydraulic fracturing is used to extract deposits oil, gas, and other hydrocarbons through the underground injection of large quantities of water, gels, acids or gases; sands or other proppants, and chemical additives, many of which are known to be toxic.” The people of Fort Collins seek to protect themselves from the harms associated with hydraulic fracturing, including threats to public health and safety, property damage and diminished property values, poor air quality, destruction of landscape, and pollution of drinking and surface water.” In Colorado as well as elsewhere in the US, authors report that 90% or more of shale oil and gas production currently uses hydraulic fracturing or fracking technology to enhance production volumes. In this literature review, the definition of hydraulic fracturing or fracking is intended to be consistent Section 2 of the citizen-initiated ordinance. It is assumed that “harms associated with hydraulic fracturing”, also in Section 2, are illustrative of potential harms and are not intended to be confined to only those impacts mentioned. 1 Ballot Measure 2A, approved by Fort Collins voters in November 6, 2013 “An ordinance placing a moratorium on hydraulic fracturing and the storage of its waste products within the City of Fort Collins or on lands under its jurisdiction for a period of five years, without exemption or exception, in order to fully study the impacts of this process on property values and human health, which moratorium can be lifted upon a ballot measure approved by the people of the City of Fort Collins and which shall apply retroactively as of the date this measure was found to have qualified for placement on the ballot.“ PAGE 3 2. OBSERVATIONS Based on our review of the literature, we offer these observations.  (Production Volume from Shale Formations) Not only has natural gas production increased substantially, but also the percent of production from shale formations has increased exponentially due to fracking technology that now enables cost-effective production from shale gas plays. Those involved in improving production methods, crafting regulations, performing inspections, measuring impacts and drafting scholarly analyses are “playing catchup.” Due to the rapid increase in the use of fracking shale gas formations, there is insufficient information at this time to evaluate the cumulative effects.  (Types of Incidents and Impacts) There are documented incidents of events from fracking shale oil and gas with potentially harmful impacts to humans, crops and livestock. Some cause- and-effect relationships have been challenged by industry specialists. Since there is relatively little “baseline” information, prior to fracking, it can be difficult to “prove” that a fracking event was the cause of an adverse condition. ( Hall, 2013)  (Relationship to Property Values) If an event is reported to be harmful to humans, crops or livestock and the event is publicized, then the literature suggests that it is reasonable to anticipate that, all other things being equal, the event will have an adverse impact on property values, due to real or perceived effects on the number of future buyers, the prices buyers are willing to pay, the insurability of the property and ability to secure a mortgage. (Jackson, 2002; Peters, 2013; Sucich, 2012)  (Scholarly Analyses.) There are a handful of scholarly analyses regarding shale oil and gas activity and its impact on property values. (See Section 6.) In all analyses reviewed, the relationship is adverse unless royalty or lease payments to property owners are greater than anticipated adverse impacts to property values. In a number of these studies, the impacts of fracking overlap with impacts associated with conventional oil and gas operations in general. That is, the studies purport to measure the impacts of fracking but include effects such as proximity to wells, disturbed surface areas and noise & light, etc. associated with the conventional drilling operations. There are also several scholarly analyses of the broader economic impact of shale oil and gas development on communities. These generally show broad positive impacts to the community as a whole; the duration of these community impacts varies over time.  (Frequency of Adverse Events) The frequency of reported adverse events per individual gas well drilled with fracking technology appears to be relatively small. However, the stigma associated with proximity to a shale oil or gas well that has been fracked is relatively, broadly publicized. Also, as the number of wells fracked increases, the probability of an % of Natural Gas from Shale Formations in United States 2000 1.6% 2005 4.0% 2010 22.8% 2015 (est) 40.4% Source: US EIA, DOE/EIA-013 (2012) PAGE 4 adverse event occurring also increases.  (Regulations and Disclosures) Colorado has in place some of the most stringent requirements associated with fracking of any state in the country, including groundwater sampling, well pressure monitoring, secondary containment system development, in addition to disclosure of all chemical additives unless they constitute a trade secret. (www.cogcc.state.co.us) Chemical additives constitute 0.1% to 1% of the hydraulic fracturing fluid. At higher levels of concentration, many have hazardous qualities.  (Appraisal Methodology) The appraisal literature identifies commonly used methodologies to study impacts to value on a universe of properties. The body of literature is augmented by the Uniform Standards for Professional Practice, which provides guidelines for usage. Together they generally satisfy the standards for admissibility of evidence in a court of law. (Jackson, 2004; Jackson, 2005)  (Property Value Impacts Affected by Buyer / Seller Information) Impacts on property value from a detrimental condition may be viewed on a continuum. Property value is generally lowest when the condition occurs, before the extent of damage has been characterized. As more becomes known about the problem and how to mitigate it, value tends to recover. (Bell, 2008, page 21) With respect to fracking impacts, studies are ongoing and risks might not be fully characterized. As more data becomes available, good or bad, market perceptions will likely change, as will impacts to value. Consequently, a 2015 or 2016 damage study may well produce different results relative to a 2014 study that measures market attitudes in the current knowledge base.  (Perceptions about real estate, positive or negative, drive market value) Perception is reality. Therefore, if someone thinks it is dangerous to live next to a nuclear power plant, eat apples, etc., the value to that person of a home near a nuclear power plant, an apple, etc., will be reduced regardless of whether any real danger exists or not. (Slovic, 2001, page 176) It is not the facts regarding a risk that creates property value diminution, but rather the perception of a risk or negative image. Thus, the media plays more of a role in shaping stigma than does the science. (Slovic, 2001, page 183) 3. FRACKING IMPACTS AND PROPERTY VALUES There are many ways to categorize impacts potentially attributable to fracking and their effects on property values. Based on a review of the literature, this report organizes impact information into two broad categories: General Impacts and Health, Safety and Welfare Impacts. In addition, cited documents that also reference federal or state regulations or public policy issues are identified. PAGE 5  General Impacts. Some impacts affect the community or local economy as a whole. These broad impacts may also have an inconsistent impact on individual properties, depending on their location and land use. These are labeled General Impacts.  Health, Safety and Welfare Impacts. There are also impacts that affect the health, safety and welfare of residents, landowners and businesses. - Some impacts occur most prominently prior to or during well drilling or re- drilling and fracking processes while other impacts occur during long-term operations and maintenance of the well site. Wells might be re-fracked multiple times during their productive life. - Some impacts, such as noise and light impacts, occur relatively close to the well site and affect nearby property; earthquakes, can occur in areas removed from the well site; some impacts such as groundwater contamination and air emissions, can occur either close to or in locations away from the well site. - Most negative impacts accrue to the surface rights holder; positive impacts accrue to the mineral rights holder through lease or royalty payments. In Colorado, it is not unusual for the surface rights holder to be different from the mineral rights holder. The mineral rights holder is dominant in situations where there are conflicts. Any property impact might be “real”, perceived or anticipated. Stigma2, which is an adverse public perception regarding a property, can affect property values. (Flynn, 2004) These impacts might affect homes, vacant land, businesses, agricultural property, schools, or parks. No individual document in this literature search provides definitive information about a condition, a finding, an incident, or a cause-and-effect circumstance. However, each document contributes to an understanding about potential impacts or the perception of impacts on property. The types of impacts identified in the table below are taken from an amalgamation of the entire body of literature. Specific references by impact type may be found in the Annotated Bibliography spreadsheet attached to this report. 2 The Dictionary of Real Estate Appraisal (Appraisal Institute, 5th ed., 2010, page 187) defines stigma as “An adverse public perception regarding a property with a condition (e.g., environmental contamination, a grisly crime) that exacts a penalty on the marketability of the property and may also result in a diminution in value”. PAGE 6 TYPES OF IMPACTS TO PROPERTY VALUES REFERENCED IN THE LITERATURE TYPE EXPLANATION OR DESCRIPTION GENERAL IMPACTS Natural Resource Production The volume of shale oil and gas production in the US, relative to other oil and gas, coal, or other natural resource development in increasing rapidly. Some authors remark that increased domestic production volume lessens US dependence on foreign energy. Economic Impacts Oil and gas production generates jobs and increases demand for housing, lodging, and retail as well as the need for related public and private sector services. The literature indicates that these are generally favorable economic impacts that a community will likely experience, particularly during well construction. The duration of these impacts may change over time. Greenhouse Gas Natural gas is a hydrocarbon gas mixture consisting primarily of methane, which is a greenhouse gas. Fracking flowback may result in methane leakage. Water Quantity The process of fracking requires substantial volumes of water per well relative to conventional oil and gas production. Each well that is fracked can require 2 to 8 million gallons, depending on its location. Wells may be fracked multiple times over their productive life. In some portions of the country, there are concerns about the availability of water supply and depletion of ground water aquifers. HEALTH, SAFETY AND WELFARE IMPACTS Air Emissions Air emissions of methane, benzene, radon, and other volatile organic compounds (VOCs) can occur at all stages of shale oil and gas development including well construction; fracking; fracked wastewater flowback, storage or treatment; use of compression equipment, and; transmission. Chemical Exposure In addition to air emissions, exposure to hazardous chemicals can occur due to compounds in fracking fluid that leak or spill during delivery to the well site, fracking and fracking flowback. Fracked wastewater that returns to the surface (15% to 80%) might be stored in on-site ponds, or delivered via truck or pipeline to a wastewater holding pits, wastewater injection wells or treatment facilities. The remainder of fracked wastewater remains below surface. Crop and Livestock Some report that ozone from fracking can diminish crop productivity and that fracking chemicals may be ingested by farm animals. Also, dust and exhaust produced by vehicles used in fracking has been reported to trigger livestock death from “dust pneumonia.” Earthquakes Fracking and the underground disposal of fracked wastewater may trigger earthquakes. Earthquakes may increase in intensity, the longer the fracking fluid is in the ground. Land Use Future land use planning—zoning, densities, setbacks, well buffers, etc.—will be influenced by drilling activity. PAGE 7 TYPES OF IMPACTS TO PROPERTY VALUES REFERENCED IN THE LITERATURE TYPE EXPLANATION OR DESCRIPTION Light & Noise Pollution Lighting: 24-7 lighting of well-head and fenced property plus fume flares at the well-head Noise: Construction truck traffic and drilling activity; operations noise from compressors, mechanical and electrical equipment. Mineral & Surface Rights & Royalties In Colorado, landowner surface rights are separate from mineral rights. Mineral rights owners may use the surface property to extract oil and gas. If there is a conflict, then the mineral estate prevails. Revenue from leasing and royalties accrue to the mineral rights holder. Mortgages and Property Insurance Some lenders will not provide mortgages for property adjacent to oil and gas wells. Fannie Mae and Freddie Mac require prior approval of a drilling lease; otherwise, the mortgage guarantee is in default. Some insurance carriers will not insure damage from fracking. Truck Traffic This impact can occur during well exploration, well construction and fracking as well as continuing during wastewater disposal and routine maintenance. Wells that are fracked require significantly more truck deliveries relative to wells that are not fracked because of the water volume requirements. Visual Disturbance There are visual impacts attributable to the presence of drilling rigs, water towers, fencing, etc. for any oil and gas development. Additional equipment is on-site for a period of time, if a well is fracked. Water Quality Contamination of ground or surface water might occur at any step of the process: water acquisition, water withdrawal, chemical mixing, well injection, fracked wastewater flowback, and fracked waste water disposal. PAGE 8 4. SHALE OIL AND GAS LOCATIONS AND PRODUCTION VOLUME The literature cited in this report refers to instances of oil and gas impacts in at least 12 states. These are listed below. The fifteen states that contain the majority of major shale formations are listed below. California Colorado Montana New Mexico New York North Dakota Ohio Oklahoma Pennsylvania Texas Utah Wyoming The map that follows, created by the US Department of Energy, provides locations of major shale formations in the United States. About 20 states contain shale formations. Due to recent technological advances attributable to fracking, it is now cost-effective to produce natural gas from shale gas formations. In the US, the amount of natural gas production attributable to shale gas has increased from 1.5% in 2000, to 22.8% in 2010 and is forecasted to reach 40.4% by 2015. (US Energy Information Administration, 2014) These results are highlighted in the graph to the right. Source: U.S. EIA, DOE/EIA-0131(2012) PAGE 9 5. SOURCES OF INFORMATION Historic and Current Literature and Resources Review. This review includes:  Peer-reviewed journal articles;  Working papers, prepared by academics;  White papers, prepared by researchers and consulting firms;  Documents produced by federal and state governments, universities, and trade organizations, and;  News reports from notable news organizations. It excludes undocumented third party opinions. This is a wide variety of data sources and documents that increases on a weekly basis; this report and bibliography is a representation of what is available at this time. Most documents have not been peer-reviewed by scholars. Nevertheless, the entire body of literature is available to real estate market participants and to some degree shapes their perceptions about fracking. The authors of this report do not represent that any of these documents is correct or incorrect. Sources of information were researched proactively from appraisal organizations, oil and gas industry organizations, environmental and resource oriented organizations, government resources, newspapers and news organizations and publications, colleges and universities, and generically via key word web search engines such as Google, Ask and Bing. This list also represents the organizations that have written about potential property value impacts attributable to fracking. Appraisal Professional Trade Associations & Trade Journals: American Institute of Minerals Appraisers – Minerals Valuation Resources The Appraisal Journal The Appraisal Foundation Oil and Gas Industry Organizations: American Petroleum Institute – Energy from Shale Coloradans for Responsible Energy Development Colorado Oil and Gas Association EnergyFromShale.com Fracking Insider Groundwater Protection Council Interstate Oil and Gas Compact Commission Interstate Petroleum Institute of America StudyFracking.com Real Estate Trade Associations & Trade Publications: National Association of Realtors PAGE 10 Journal of Real Estate Literature Realtor Magazine Other Publications: American Banker Proceedings of the National Academy of Sciences Private Environmental Organizations. There are several national or regional-scale environmental organizations that have either authored reports, sponsored seminars, funded research performed by others or maintain web sites on fracking with property value information. Most are private nonprofit organizations. One, FracFocus, is a chemical registry managed by two quasi-governmental trade organizations. AirWaterGas (www.airwatergas.org) Cooperative Institute for Research in Environmental Sciences (www.cires.colorado.edu) Center for Sustainable Shale Development (www.sustainableshale.org) Center of the American West (www.centerwest.org) Earthworks (www.earthworksaction.org) Environment America (www.environmentamerica.org) Environmental Defense Fund (www.edf.org) FracFocus (www.fracfocus.org) Pacific Institute (www.pacinst.org) Resources for the Future (www.rff.org) State Review of Oil and Natural Gas Environmental Regulations (www.strongerinc.org) Western Resource Advocates (www.westernresourceadvocates.org) Colleges and Universities. A number of universities in the US and Canada have individuals who have become specialists in oil and gas and/or fracking impacts on property values. Notable among these are: Bucknell University Carnegie Mellon University Cleveland State University Colorado State University Columbia University Law School Cornell University Duke University Harvard Law School Marietta College Ohio State University & Law Journal Pennsylvania State University Stanford University Law School University of Calgary University of Colorado University of Denver University of North Texas University of Pittsburgh University of Texas – Austin University of Texas at San Antonio Wilfrid Laurier University News Organizations. The primary national and Colorado-based news organizations that have published articles about fracking and its potential impacts on property values are listed below. PAGE 11 NATIONAL NEWS ORGANIZATIONS COLORADO NEWS ORGANIZATIONS Bloomberg National Geographic National Public Radio – StateImpact ProPublica Reuters The New York Times Time Magazine Wall Street Journal Vanity Fair Fort Collins Coloradan Northern Colorado Business Report The Denver Business Journal The Denver Post The Colorado Independent The Colorado Observer One national newspaper, The New York Times, has invested a substantial effort to identify more than 30,000 pages (their account) of documents, classified by topic. These documents can be accessed here: http://www.nytimes.com/interactive/2011/02/27/us/natural-gas-documents-1-intro.html Federal and State Governments. A number of Federal and State governments impose regulations or have published findings about fracking and its impacts. Due to several federal exemptions, state and local governments bear primary responsibility for oil and gas regulations on private land. Two sources provide a comprehensive discussion of the federal and State regulatory environment. (Ground Water Protection Council, 2009; Neslin, 2013; Wiseman, 2012) FEDERAL GOVERNMENT: STATE OF COLORADO: US Department of Energy US Energy Information Administration US Environmental Protection Agency US Bureau of Land Management CO Department of Public Health and Environment CO Division of Water Resources CO Oil and Gas Conservation Commission CO Oil and Gas Commission In addition there are two multi-state organizations that have published information about shale oil and gas production and fracking.  The Interstate Oil and Gas Compact Commission is a multi-state government agency, formed in 1925 by an interstate compact.  The Ground Water Protection Council, formed in 1983, is a nonprofit 501(c)(6) whose members consist of state ground water regulatory agencies. Research Underway. In addition to these resources, there are two multi-faceted research initiative now under way that might provide important information and insight. PAGE 12 National Science Foundation. In October 2012, as part of its Science, Engineering and Education for Sustainability (SEES) work, the National Science Foundation announced two $12 million awards to two Sustainability Research Networks (SRNs); each are led by a university.  The University of Colorado Boulder and eight partner organizations have been retained to explore “ways to maximize the benefits of natural gas development while minimizing potential negative effects on human communities and ecosystems.” This study is also referred to as the AirWaterGas study. A particularly germane component of this study effort is a hedonic pricing analysis comparing thousands of data points going back to 1998 in an attempt to isolate the effects on property values related to wells that have been fracked. This study component is led by CU-Boulder economist Catherine Keske and is expected to be completed in 2015.  Penn State University and nine other universities and research institutions have been retained to study “sustainable climate risk management strategies.” Environmental Defense Fund. Also in 2012, The Environmental Defense Fund (EDF) announced its plans to spearhead its largest scientific project to date to understand from where and how much ethane is lost across the US natural gas supply chain. The collaborative effort involves about 100 universities, research institutions and companies and is divided into 16 distinct projects. Completion of all studies is expected later in 2014. The first study has been released (Allen, 2013). This study measured methane emissions at well pads during the extraction phase of the natural gas supply chain. It contains some of the first measurements collected from hydraulically fracture wells. Four of the 16 projects involve either the University of Colorado or Colorado State University.  NOAA – CU Boulder – Denver Flyover Study. This NOAA led effort will measure methane emissions in Colorado’s most active oil and gas field using aircraft flying over the basin.  NOAA – CU Boulder Barnett Flyover Study. This study will measure atmospheric concentrations of hydrocarbons to quantify regional methane emissions in the Barnett shale formation in Texas.  Colorado State University Transmission and Storage Study. This study will measure methane lost during long-distance transportation and storage of natural gas. PAGE 13  Colorado State University Gathering and Processing Study. This study will quantify national methane emissions associated with natural gas industry’s gathering infrastructure and procession plants. US Environmental Protection Agency. In 2011, the EPA began research under its Plan to Study the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources. Eighteen research projects are underway; each study focuses on a different primary research question. In September 2012, a progress report was released. (USEPA, December 2012) 6. ANALYTICAL PROPERTY VALUATION METHODS APPLIED IN LITERATURE CITED Much has been written about fracking and its potential impacts on property values. Most work has been published only in the last 5 to 7 years as fracking technology has become used more widely in the United States and elsewhere. In part because this topic is relatively new to the research and analytical community, the majority of work to date has not been published in peer-reviewed and scholarly journals. However, the work contributes to the body of information about fracking and its real, perceived or anticipated impact on property values. Real estate property values are influenced by the perception of the buyer or seller, regardless of whether the underlying source is from a scholarly journal or expert. ANALYTICAL METHODS APPLIED IN LITERATURE CITED TYPE EXPLANATION Anecdotal / Incident / Event Report on individual incident or event. Contingent Valuation This is a survey-based technique used for the valuation of non-market resources, such as the impact of contamination. Typically, the survey asks how much money people would be willing to pay (or willing to accept) to maintain the existence of (or be compensated for the loss of) an environmental feature. PAGE 14 ANALYTICAL METHODS APPLIED IN LITERATURE CITED TYPE EXPLANATION Hedonic Price Analysis This analytical technique uses the premise that that price is determined both by internal characteristics of the good being sold and external factors affecting it. The hedonic pricing model is used to estimate the extent to which each factor affects the price. In this type of application, hedonic price analysis estimates the marginal willingness to pay for specific adverse conditions Regression Analysis This is a statistical method for estimating the relationships among variables, when the focus is on the relationship between a dependent variable and one or more independent variables. Regression analysis helps one understand how the value of the dependent variable (such as housing price) changes when any one of the independent variables is varied, while the other independent variables are held fixed. This technique is often a part of a hedonic price analysis. Survey Research Telephone, in-person or mail-in survey of impacted individuals that own affected property. Surveys may be informal, such as in-person confirmation of transaction details or formal, based on a statistically significant sample corrected for bias. Analysis – Secondary Research Analysis of information compiled from other resources; also known as meta- analysis. Property Value Analyses Using Primary Empirical Data. In addition to many types of individual findings and summaries of prior studies that are presented in the Annotated Bibliography, our research has identified six reports that used empirical data to consider the impacts of oil and gas exploration on property values and applied analytical methods that are generally acceptable in a court of law. Except for the LaPlata County study, all reference fracking impacts, which actually overlap with the impacts of the entire drilling operation including well proximity, lights & noise, etc.  LaPlata County, Colorado (2001). Having a well on a property was associated with a 22% reduction in the value of the property; having a well within 550 feet increased its value; having a well between 551 and 2,600 feet had a negative impact. Authors attributed the positive impact (within 550 feet) due to a spacing order and setback conditions that prevented additional well drilling close to existing wells. This study measures the impacts of oil and gas operations on property values, specifically related to coal bed methane, which is significantly different from conventional oil and gas production or unconventional production that uses fracking technology. The report is included because of the methodology applied and its Colorado context. The term PAGE 15 “hydraulic fracturing” is not mentioned in the study. (Bortz, Brown and Coddington, 2001)  Alberta, Canada (2005). Authors found a statistically significant inverse relationship between property values and the presence of oil and gas facilities within about 2.5 miles of rural residential properties of between 4% and 8%, with the potential to double the impact, depending on the nearby industrial activities. The term “hydraulic fracturing” is not mentioned in the article. (Boxall, et. al., 2005)  Flower Mound, Texas (2011). The authors found that within Flower Mound, for properties in excess of $250,000, proximity to a well had an adverse impact of 3% to 14% on values. Also, there was an adverse impact on the time required to sell a property. The authors used the term fracking one time, but weren’t specific as to whether the well sites used in the data base were a product of fracking. (Integra Realty Resources, 2011)  Weld County Colorado (2013). This study attempted to determine whether risk perceptions associated with hydraulic fracturing are capitalized into housing prices in Weld County. Price-distance relationships were studied at all stages of the drilling process. Housing sales data from 2009 through 2012 were plotted and compared to (fracked) well locations. Low level adverse impacts were found in rural locations as a function of distance; low level adverse impacts were found in urban locations as a function of the number and density of wells. (Bennett, Ashley , 2013)  Texas and Florida (2013). Using contingent valuation survey research, the research shows a 5% to 15% reduction in bid values for homes located proximate to fracking scenarios, depending on the petroleum-friendliness of the venue and proximity to the drilling site. The authors use the term “fracking” in a broad context to include the process itself and all potential harm there from, including proximity to well sites. (Throupe, et.al, 2013)  Pennsylvania and New York (2014). The authors found strong evidence of negative net impacts on the prices of properties that are dependent on private water wells located near shale gas development, presumably facilitated through the process of fracking; the negative impacts become more pronounced (-16.7%) when the well is within 1 km. At a broader geographic scale, (20 km from shale gas wells) there is a small positive impact likely due to the boost to the local economy. Undrilled well permits can offset these benefits due to an aesthetic dis-amenity. (Muehlenbachs, et.al., 2014) PAGE 16 7. TECHNICAL RESOURCES AND SPECIALISTS A thorough study of the effects of environmental impacts on the value of a large population of properties commonly involves a “team” approach comprised of various specialties, in addition to an appraiser and economist. TYPE OF SPECIALIST FUNCTION OR SPECIALTY Geographic Information Systems Layer data from various sources on a common format map; produce results; provide precise distance calculations Econometrician Develop regression model specifications; produce analysis, measuring statistical significance of various potential correlations. Geologist/Hydro-geologist Provide well location and aquifer data Survey Research Specialist / Statistician Frame survey research questions; pull sample from valid sources; recommend method; calculate appropriate sample sizes; conduct survey; analyze results 8. DATA GAPS TO COMPLETE A PROPERTY IMPACT ANALYSIS Literature Cited. While literature that references potential environmental and property value impacts associated with fracking is abundant, the direct correlation between fracking impacts and property values is more sparsely documented in a careful manner. About one-third of the literature cited in the bibliography (Section 10) address impacts to property values.  Among these documents, only a few are also supported by recognized methods of valuation using empirical data that could be acceptable in a court of law. (See Section 6.)  The annotated bibliography (Section 11) identifies which of these documents use the term “fracking” in its remarks about property values and which do not. Among the three-fourths that use the term “fracking”, some authors do not appear to distinguish carefully between fracking and conventional oil and gas development without fracking. Others authors, such as Bennett, Muehlenbachs and Throupe, specifically measure or reference impacts to wells that have been fracked. Almost all authors reference impacts on property values as a function of distance to a well. Some discuss impacts from fracking in the sense that the process generates more wells; density of fracked wells can negatively or positively impact property values. PAGE 17  There are three documents that refer to specific impacts of fracking on property values. The law firm Ballard Spahr prosecuted a case involving the uncertainty of the composition of fracking chemicals (National Association of Realtors, 2014). A second article puts forth the legal theory that as fracking fluids fill fissures that extend off the drilling site, there may be a legal claim for trespass (Pierce, 2010). Another paper recounts a legal case against Cabot Oil & Gas based on the claim that properties were contaminated by fracking chemicals (Rubikam, 2012).  None of these documents is specific to Fort Collins. A Colorado State University Study (Bennett, 2013) is the most proximate geographically, since it applies data from Weld County. This author points out that her research on sales data and proximity to fracked wells provides correlations between variables but does not address causation and does not distinguish between properties receiving or not receiving royalties. She concludes with a recommendation for further study. Fracking Impacts Isolated. If Fort Collins pursues an analysis of property value impacts, it will be important to focus on potential impacts on property values that are consistent with the definition of fracking and its associated harms, as articulated in Section 2 associated with Ballot Measure 2A, approved by voters on November 5, 2013. (See Section 1.) More specifically, the analysis should address only impacts associated with fracking and its associated harms and exclude impacts that might be associated more generally with conventional oil and gas development. In some circumstances, the presence of fracking might trigger an incremental impact relative to conventional oil and gas development without fracking. These incremental impacts might be marginal or substantial. In other circumstances, fracking might trigger a different type of impact that is not present without fracking. Based on a broad review of the literature, only some of which appears in scholarly peer-reviewed journals, the table below illustrates some potential types of impacts attributable to fracking. POTENTIAL, ILLUSTRATIVE IMPACTS THAT MIGHT BE ATTRIBUTABLE TO FRACKING RELATIVE TO CONVENTIONAL OIL & GAS DEVELOPMENT (Includes A Sampling of Documents that Reference the Impact) Marginal Incremental Impacts - Light and noise impacts might be greater with fracking because the drilling and construction stage is longer. (Broomfield, 2012; Resource Media, 2014; Woodyard, 2014) PAGE 18 POTENTIAL, ILLUSTRATIVE IMPACTS THAT MIGHT BE ATTRIBUTABLE TO FRACKING RELATIVE TO CONVENTIONAL OIL & GAS DEVELOPMENT (Includes A Sampling of Documents that Reference the Impact) Significant Incremental Impacts - Truck traffic may be substantially greater because water delivery associated with fracking may generate the need for more loaded one-way truck trips. (Barton, 2013; Felsburg, 2012) - Water requirements for fracking might be substantially greater than water requirements for conventional oil and gas development. (Freyman, 2014; Belanger, 2012; Riddington, 2013; CO Div. of Natural Resources, unknown date) Different Impacts - Use of chemicals added to fracking fluids that are toxic to human and animals and related, potential surface and ground water contamination and air emissions. (Horwath, 2011; Cooley, 2012; Minor, 2013; Riddington, 2013; Phillips, 2011; Throupe, 2013; Warner, 2012; Greene, 2013) - Presence of fracking fluids in the ground may generate earthquakes. (Brandes, 2014; Knox, 2014; McGarr, 2014; Nowlin, 2014; Frazell, 2014; Findley, 2012; Connelly, no date ) If pursued, the analysis should make these distinctions to the fullest extent possible. That said, measuring impacts on property values is analyzed in a social science setting that measures how property owners might and have responded to circumstances. It is not prepared in a hard science setting conducted in a laboratory where variables can be isolated and controlled absolutely. Possible Components of a Fort Collins Study. Assuming the need for a study that is specific to Fort Collins and consistently aligned with the Ballot Measure, information necessary to a property impact study would likely include but not be limited to the following. 1) Base layer GIS maps illustrating: topographic conditions; physical features of the land, including view sheds; zoning districts; comprehensive planning maps; oil and gas well locations; fracking storage sites; delivery system locations; and geologic and hydro- geologic conditions. 2) Multiple List Service sales and listing data, as well as sales data compiled by the Larimer County Assessor. Weld County data may be used as a surrogate or to augment Larimer County information. GIS maps of the sales data relative to oil & gas related improvements. 3) Survey research results relative to potential purchasers’ willingness to buy or motivations behind actual purchaser’s actions. PAGE 19 Keeping in mind the rules of evidence established by Daubert v. Merrell Dow Pharmaceuticals, Inc. and People v. Shreck, a work plan to measure the impacts of fracking on property values suitable for litigation might involve the following procedures or techniques: 1) Survey Research Survey research may be used formally or informally, quantitatively or qualitatively to determine market participants’ likely responses to land use, technological or environmental conditions or risks. Survey responses are typically used to test the results of other quantitative methods or may be used to measure how much people would be willing to pay for property affected or unaffected by an environmental dis-amenity. The courts have imposed rigid standards for the admissibility of quantitative results. Fort Collins-Specific Survey Research Recommendations. Based on the limitations and lessons learned from prior research and on the need manage the analysis to fit Fort Collins’ unique circumstances, we propose two specific types of survey research be conducted, if the City pursues an analysis.  Survey of Fort Collins Residents. This survey would be used to measure the potential willingness of Fort Collins residents to pay for properties near wells that have been fracked. The analysis would be based on hypothetical circumstances presented in the survey since there have not been enough fracked wells near or in the City to establish a population based on proximity to fracked wells from which to draw a statistically significant sample. This survey would explore differences between fracked and conventional exploration and production practices, as well as possible. A discussion about surveying respondents other than residents who might purchase property should occur before the survey research methodology is finalized.  Survey of Weld County Purchasers. After identifying properties purchased in Weld County locations near fracked wells and the history of the well(s), this survey would explore purchaser’s motivations and attributable price adjustments, if any, to the presence of a fracked well(s), including but not limited to the type of property, knowledge of whether a well is present or was fracked, mineral and water rights ownership, price adjustment, if any, because of the presence of fracked well, reasons for the price adjustment, as appropriate, other purchaser motivations. The results of this analysis would be used in the GIS-based regression analysis, explained below. To our knowledge, this type of survey has not been conducted. Most research more simply correlates land sales to well proximity without knowledge about the purchaser’s motivations. This survey might be a challenging, multi-step data collection process, since the owners might first be reached via mail. PAGE 20 2) Case Study Analysis Case Study Analysis is a sub-set of the Sales Comparison Approach often used in appraising real estate. It involves the use of analogous situations when direct sale comparables are not available, and is particularly useful in area wide analysis like the one anticipated by the City of Fort Collins. Sales in another case study location involving a similar environmental situation are studied to estimate how the marketplace there responded to similar environmental issues. Case studies may be drawn from the appraisal literature or developed by the appraiser. 3) Paired Data Analysis Paired Data Analysis is based on the premise that when two properties are equivalent in all respects but one, the value of the single difference can be measured by the difference in price between the two properties. In simple terms, a sale property adjacent to an oil or gas well may be paired against the sale of a more removed property to determine the effect on price of the well. 4) GIS-based Regression Analysis (Hedonic Price Analysis) Regression analysis is a statistical technique in which a mathematical equation can be derived to quantify the relationship between a dependent variable and one or more independent variables. The model is especially effective in concert with GIS maps that allow property values to be measured as a function of distance or proximity to any number of attributes that make up property value. For example, prices may be analyzed as a function of proximity to or visibility of oil and gas wells. The appraisal profession has adopted standards of practice that must be adhered to in the development of the above described methods. The guiding document is Advisory Opinion 9 to the Uniform Standards of Professional Practice. The profession recognizes the benefits of developing multiple appraisal techniques, as have the courts. Each serves as a check on the other, and the resulting conclusion may be more credible. Advisory Opinion 9 also recognizes that it may be necessary to obtain the assistance of additional consultants in order to develop competent and credible results. In this case, it will likely be necessary to obtain the assistance of a GIS/mapping expert, an econometrician or statistician, a survey research expert and a hydro-geologist, among others. 9. ALTERNATIVE METHODS TO FILL DATA GAPS While the techniques described above are commonly used to value the impact of an environmental dis-amenity, an alternative technique, called Contingent Valuation, is referenced in the appraisal literature. This method was originally developed to value what economists refer to as public goods for which there is no observable market. The obvious application PAGE 21 particularly relates to valuation of natural resources. For example, “willingness to pay” questions such as, “How much would you pay to see a wolf in the wild?” may be asked as part of a survey questionnaire. Because of the subjectivity of questions and answers, the National Oceanic and Atmospheric Administration (NOAA) has produced strict guidelines for the use of Contingent Valuation. Many in the appraisal profession question the usefulness of the technique in a quantitative way when there is an abundance of actual market data. Nonetheless, the technique provides a good qualitative measure of buyer preferences. PAGE 22 10. BIBLIOGRAPHY OF LITERATURE REVIEWED Adgate, John L., Bernard D. Goldstein, Lisa M. McKenzie. “DRAFT - NRC Shale Gas Committee Workshop #1: Extended Abstract to Proposed White Paper: Public Health Risks of Shale Gas Development.” Colorado School of Public Health, University of Colorado Denver and University of Pittsburgh Graduate School of Public Health, May 17, 2013. http://catskillcitizens.org/learnmore/PublicHealthAdgateAbstract.pdf. Alcock, Amy. “How Hydraulic Fracturing affects Property Values.” March 2013. http://savewestcoastnl.files.wordpress.com/2013/04/fracking-impact-on-property-values- march2013-research.pdf. ALL Consulting. Modern Shale Gas Development in the United States: A Primer. Prepared by the Ground Water Protection Council for the U.S. Department of Energy – Office of Fossil Energy and the National Energy Technology Laboratory, DE-FG26-04NT15455. April 2009. http://energy.gov/sites/prod/files/2013/03/f0/ShaleGasPrimer_Online_4-2009.pdf. Allen, David T., Vincent M. Torres, James Thomas, David W. Sullivan, Matthew Harrison, Al Hendler, et al. “Measurements of methane emissions at natural gas production sites in the United States.” Proceedings of the National Academy of Sciences. October 29, 2013, Vol. 110, No 44, 17768-17773. American Petroleum Institute. Facts about Shale Gas. Accessed June 17, 2014. http://www.api.org/policy-and-issues/policy-items/exploration/facts_about_shale_gas American Petroleum Institute, Hydraulic Fracturing – Unlocking America’s Natural Gas Resources, April 2014. http://www.api.org/oil-and-natural-gas-overview/exploration- and-production/hydraulic-fracturing/~/media/Files/Oil-and-Natural-Gas/Hydraulic- Fracturing-primer/Hydraulic-Fracturing-Primer-2014-lowres.pdf. American Petroleum Institute. “Shale Energy: 10 Points Everyone Should Know”, October 2013. http://www.api.org/~/media/Files/Policy/Hydraulic_Fracturing/Hydraulic- Fracturing-10-points.pdf. Appraisal Standards Board. “Uniform Standards of Professional Appraisal Practice – 2014 – 2015 Edition, Advisory Opinion 9.” The Appraisal Foundation, effective January 1, 2014 through December 31, 2015. http://www.uspap.org/ Armbrister, Molly. “Drilling Casts Shadow on Home Mortgages.” Northern Colorado Business Report. March 7, 2014. PAGE 23 Baen, John S. PhD. “Lessons Learned from the North Texas Barnett Shale: In Regards to the Pennsylvania Marcellus Shale, the Jewel of the Northeastern US. Presentation at Northeastern PA Meeting, November 18-19, 2008 for Center of Urban Studies and Pennsylvania Senate Hearing. http://www.institutepa.org/PDF/Marcellus/baen.pdf. Baen, John S., PhD. “The Impact of Mineral Rights and Oil and Gas Activities on Agricultural Land Values.” The Appraisal Journal, January 1996, 68 – 75. http://www.tlma.org/pdf/news_impact.pdf. Baen, John S., Ph.D. Lessons Learned from the North Texas Barnett Shale: In Regards to the Pennsylvania Marcellus Shale, the Jewel of the Northeastern U.S. University of North Texas, College of Business. Presented at Center for Urban Studies and Pennsylvania Senate Hearing. November 18-19, 2008. Bailey, A.J. “The Fayetteville Shale Play and the Need to Rethink Environmental Regulation of Oil and Gas Development in Arkansas.” Arkansas Law Review, Vol. 63:815-848, 2010. http://lawreview.law.uark.edu/wp-content/uploads/2011/02/baileyforweb.pdf. Bamberger, Michelle, Robert E. Oswald. “Impacts of Gas Drilling on Human and Animal Health.” March 2012. New Solutions: A Journal of Environmental and Occupational Health Policy, Vol. 22, No. 1, 2012, 51-77. http://www.psehealthyenergy.org/data/Bamberger_Oswald_NS22_in_press.pdf Barton, John A., P.E. “Presentation to House Appropriations Subcommittee on Budget Transparency and Reform.” Texas Department of Transportation, March 11, 2013. http://ftp.dot.state.tx.us/pub/txdot-info/energy/presentation_031113.pdf Bateman, Christopher. “A Colossal Fracking Mess.” Vanity Fair, June 21, 2010. http://www.vanityfair.com/business/features/2010/06/fracking-in-pennsylvania-201006 Beans, Laura. “How Fracking Decreases Property Value.” Earthworks, July 22, 2013. http://www.dontfractureillinois.net/how-fracking-decreases-property-value/. Belanger, Laura. Fracking our Future – Measuring Water & Community Impacts from Hydraulic Fracturing. Prepared by Western Resource Advocates. June 2012. http://www.westernresourceadvocates.org/frackwater/WRA_FrackingOurFuture_2012.p df Bell, Randall, MAI. Real Estate Damages: Applied Economics and Detrimental Conditions Second Edition. Appraisal Institute, 2008. Bennett, Ashley. The Impact of Hydraulic Fracturing on Housing Values in Weld County, Colorado: A Hedonic Analysis. Thesis submitted to Colorado State University. Summer 2013. PAGE 24 http://digitool.library.colostate.edu///exlibris/dtl/d3_1/apache_media/L2V4bGlicmlzL2R 0bC9kM18xL2FwYWNoZV9tZWRpYS8yNDc4NTI=.pdf Bern, Marc J., Tate J. Kunkle. “A plaintiff’s primer on litigating natural gas cases.” Westlaw Journal. Vol. 31, Issue 23. June 8, 2011. http://www.napolibern.com/documents/A_plaintiffs_primer_on_litigating_natural_gas_ cases.pdf Birol, Fatih. Golden Rules for a Golden Age of Gas – World Energy Outlook – Special Report on Unconventional Gas. Paris: International Energy Agency. 2012. http://www.worldenergyoutlook.org/media/weowebsite/2012/goldenrules/weo2012_gol denrulesreport.pdf Brown, Bortz, & Coddington. LaPlata County Impact Report. Submitted to LaPlata County, C Colorado. October 2002. http://www.co.laplata.co.us/departments_elected_officials/planning/natural_resources_oil_gas /impact_report Boxall, Peter C., Wing H. Chan, Melville L. McMillan. “The Impact of Oil and Natural Gas Facilities on Rural Residential Property Values: A Spatial Hedonic Analysis.” Wilfrid Laurier University, subsequently published in Resources & Energy Economics, 27, 248- 269, 2005. http://www.wilfridlaurieruniversity.ca/documents/6444/2005-01EC.pdf Boyer, Elizabeth W., Bryan R. Swistock, James Clark, Mark Madden, Dana E. Rizzo. The Impact of Marcellus Gas Drilling on Rural Drinking Water Supplies. Pennsylvania State University, October 2011. http://www.rural.palegislature.us/documents/reports/Marcellus_and_drinking_water_2 012.pdf Brandes, Heide. “There’s Now a Run on Quake Insurance in Fracking-Heavy Oklahoma.” Business Insider. May 1, 2014. Brandes, Heide, Jon Herskovitz. “Quake warning adds new worries to tornado-prone Oklahoma.” Reuters. May 8, 2014. http://www.reuters.com/article/2014/05/08/us-usa- oklahoma-earthquakes-idUSBREA470PW20140508. Broomfield, Mark. Support to the Identification of Potential Risks for the Environment and Human Health Arising from Hydrocarbons Operations Involving Hydraulic Fracturing in Europe. Prepared for the European Commission – DG Environment. AEA/R/ED57281; Issue No. 17c. October 8, 2012. http://ec.europa.eu/environment/integration/energy/pdf/fracking%20study.pdf PAGE 25 Bryson, Donna. (Contributor) “Energy boom puts wells in America’s Backyards.” Council for a Secure America, reprinted by The Wall Street Journal. October 29, 2013. http://councilforasecureamerica.org/energy-boom-puts-wells-in-americas-backyards/. Burnham, Andrew, Jeongwoo Han, Corrie E. Clark, Michael Wang, Jennifer B. Dunn, Ignasi Palou-Rivera. “Life-cycle greenhouse gas emissions of shale gas, natural gas, coal and petroleum.” Environment Science Technology. 46(2):619-627. January 17, 2012. Erratum in Environment Science Technology 46(13:7430 and 46(4): 2482. http://pubs.acs.org/doi/abs/10.1021/es201942m Cathles III, Lawrence M., Larry Brown, Milton Taam, Andrew Hunter. “A Commentary on ‘The Greenhouse-Gas Footprint of Natural Gas in Shale Formations’.” Climatic Change, Accepted October 21, 2011. http://www.geo.cornell.edu/eas/PeoplePlaces/Faculty/cathles/Natural%20Gas/2012%20C athles%20et%20al%20Commentary%20on%20Howarth.pdf Cathles, L. M. Assessing the Greenhouse Impact of Natural Gas. Submitted to G3, January 2, 2011. http://www.geo.cornell.edu/eas/PeoplePlaces/Faculty/cathles/Natural%20Gas/Cathles- %20Assessing%20GH%20Impact%20Natural%20Gas.pdf Cavanaugh, Marge. “University of Colorado-Boulder-led research network explores natural gas development effects, while Penn State-centered network focuses on sustainable climate risk management strategies.” National Science Foundation Press Release 12-185, October 2, 2012. http://www.nsf.gov/news/news_summ.jsp?cntn_id=125599 Cockerham, Sean, “Fracking can hurt property values of nearby homes with wells, study suggests.” McClatchy DC, November 6, 2012. http://www.mcclatchydc.com/2012/11/06/173814/fracking-can-hurt-property-values.html Colborn, Theo, Carol Kwiatkowski, Kim Schultz, Mary Bachran. “Natural Gas Operations from a Public Health Perspective.” Human and Ecological Risk Assessment, 17:1039-1056, September 4, 2010. Coloradans for Responsible Energy. What is Fracking? www.studyfracking.com Colorado Division of Water Resources, the Colorado Water Conservation Board, the Colorado Oil and Gas Conservation Commission. Water Sources and Demand for the Hydraulic Fracturing of Oil and Gas Wells in Colorado from 2010 through 2015. Undated. https://cogcc.state.co.us/Library/Oil_and_Gas_Water_Sources_Fact_Sheet.pdf Colorado Oil and Gas Association. COGA – Hydraulic Fracturing Whitepaper. November 26, 2012. Accessed via www.COGA.org. PAGE 26 Colorado Oil and Gas Association. The Basics: Colorado Water Supply and Hydraulic Fracturing. Accessed via www.coga.org Colorado Oil and Gas Conservation Commission. “Background Report.” October 29, 2010, www.colorado.gov/cogcc. Colorado Oil and Gas Conservation Commission. Hydraulic Fracturing. (Power Point) Produced by Colorado Oil and Gas Conservation Commission. May 2011. https://cogcc.state.co.us/Announcements/Hot_Topics/Hydraulic_Fracturing/COGCC_FR ACING_briefing_052011.pdf Conlin, Michelle. “U.S. Drilling and Fracking Boom Leaves Some Homeowners in a Big Hole.” Reuters, posted December 12, 2013; updated February 12, 2014. http://www.reuters.com/article/2013/12/12/us-fracking-homeowners-analysis- idUSBRE9BB0GS20131212 Conlin, Michelle. Brian Grow. “Special Report: U.S. builders hoard mineral rights under new homes.” Reuters, October 9, 2013. http://www.reuters.com/article/2013/10/09/us-usa- fracking-rights-specialreport-idUSBRE9980AZ20131009 Connelly, Kelly, David Barer, Yana Skorobogatov. “How Oil and Gas Disposal Wells Can Cause Earthquakes.” StateImpact Texas, undated http://stateimpact.npr.org/texas/tag/earthquake/ Considine, Timothy J., Robert W. Watson, Nicholas B. Considine. The Economic Opportunities of Shale Energy Development. Energy Policy and the Environment Report, No. 9, May 2011. http://www.manhattan-institute.org/pdf/eper_09.pdf Conversations for Responsible Economic Development. How do Pipeline Spills Impact Property Values? Accessed June 2014, www.CredBC.ca. Cooley, Heather, Kristina Donnelly. Hydraulic Fracturing and Water Resources: Separating the Frack from the Fiction. Pacific Institute. June 2012. http://pacinst.org/wp- content/uploads/sites/21/2014/04/fracking-water-sources.pdf Cranch, William, Margaret Holden, Shaun Goho, Kate Konschnik. Responding to Landowner Complaints of Water Contamination from Oil and Gas Activity: Best Practices. 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Summer 2012, 205-209. http://www.real- analytics.com/AO-9%20and%20CV.pdf Jaffe, Mark. “When drought occurs, fracking and farming collide.” The Denver Post, .February 9, 2014. http://www.denverpost.com/business/ci_25089583/when-drought-occurs- fracking-and-farming-collide Jiang, Mohan, W. Michael Griffin, Chris Hendrickson, Paulina Jaramillo, Jeanne VanBriesen, Aranya Venkatesh. “Life cycle greenhouse gas emissions of Marcellus shale gas.” Environmental Research Letters 6 (2011) 034014. August 5, 2011. http://iopscience.iop.org/1748-9326/6/3/034014/fulltext/ PAGE 30 Jones, Stephanie K. “Case Before Ohio Court May Impact Future Coverage for Fracking Liability.” Insurance Journal. January 27, 2014. http://www.insurancejournal.com/news/midwest/2014/01/27/318565.htm/ Keep Tap Water Safe.org. Lists of Bans Worldwide. 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February 6-8, 2012. http://fracfocus.org/sites/default/files/publications/hydraulic_fracturing_101.pdf Klemow, Kenneth M., Ph.D., Ned Fetcher, Ph.D. “Greenhouse Gas Emissions Associated with Marcellus Shale.” The Institute for Energy & Environmental Research for Northeastern Pennsylvania, Version 3: December 9, 2011. http://energy.wilkes.edu/PDFFiles/Reports/IEER.GHG.V3.pdf Knox, Tom. “Fracking-earthquake link may impact insurance policies.” Columbus Business Journal. April 18, 2014. http://www.bizjournals.com/columbus/blog/2014/04/fracking- earthquake-link-may-impact-insurance.html?page=all. Krupp, Fred. “Don’t Just Drill, Baby --- Drill Carefully.” Foreign Affairs. May/June 2014 Issue. LaPlata County League of Women Voters. LWVCO Fracking Study Consensus Session and Power Point. February 7, 2013. http://www.lwvlaplata.org/files/composite-fracking-study-text2- 9-13.pdf; http://www.lwvlaplata.org/files/hydrofracturing-consensusslides2-9-13.pdf Lipscomb, Joseph B. PhD, MAI, J. R. Kimball, MAI. “The Effects of Mineral Interests on Land Appraisals in Shale Gas Regions.” The Appraisal Journal, Vol. 80, Fall 2012, 318-329. http://eres.scix.net/data/works/att/eres2012_037.content.pdf Lustgarten, Abrahm. “Buried Secrets: Is Natural Gas Drilling Endangering U.S. Water Supplies” ProPublica, corrected November 19, 2008. http://www.propublica.org/article/buried-secrets-is-natural-gas-drilling-endangering- us-water-supplies-1113 PAGE 31 Lustgarten, Abrahm. “Hydrofracked? One Man’s Mystery Leads to a Backlash Against Natural Gas Drilling.” ProPublica. February 25, 2011. http://www.propublica.org/article/hydrofracked-one-mans-mystery-leads-to-a-backlash- against-natural-gas-drill/single Lustgarten, Abrahm. “Pa. Residents Sue Gas Driller for Contamination, Health Concerns.” ProPublica, November 20, 2009, http://www.propublica.org/article/pa-residents-sue-gas- driller-for-contamination-health-concerns-1120. Lynn, Steve. “Water transporters ride the oil boom.” Northern Colorado Business Report. April 5, 2013. http://www.ncbr.com/article/20130405/EDITION/130409944. Matthews, Kristy E., William H. Desvousges. The Truth, the Partial Truth, or Anything But the Truth: Survey Reliability and Property Valuation. Presented at Symposium on Environmental & Property Damages: Standards, Due Diligence, Valuation & Strategy, Toronto, Ontario. April 4-6, 2002. http://www.real-analytics.com/Surveys.pdf McElvish, James. “Shale Gas Impact Fees in Pennsylvania Communities.” Washington & Jefferson College, the Environmental Law Institute. April 10, 2014. http://www.rff.org/Documents/Events/Seminars/140410-McElfish-presentation.pdf McGarr, A., J. Rubinstein. “Factors that Enhance the Likelihood of Fluid Injection-Induced Earthquakes Large Enough to be Felt.” USGS, Menlo Park, May 1, 2014. Presented at the Seismological Society of America (SSA) Conference. Abstract only. McKenzie, Lisa M. Roxana Z. 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PAGE 33 Muoio, Danielle. “Duke researchers show dip in home value caused by nearby fracking.” Duke Chronicle, November 15, 2012. http://www.dukechronicle.com/articles/2012/11/16/duke- researchers-show-dip-home-value-caused-nearby-fracking National Association of Realtors. “Fracking: A Growing Threat to Home Values.” Realtor Mag – Daily Real Estate News. April 23, 2014. http://realtormag.realtor.org/daily- news/2014/04/23/fracking-growing-threat-home-values Neslin, Dave. Generating the Energy We Need While Protecting the Environment We treasure: The Regulatution of Hydraulic Fracturing in the United States. Prior version presented at Rocky Mountain Mineral Foundation’s Special tribute on International Mining and Oil and Gas Law, Development and Investment in Cartagena, Colombia. April 2013. http://www.americanbar.org/content/dam/aba/administrative/environment_energy_reso urces/resources/neslin_fracking_US.authcheckdam.pdf Notte, Jason. Fracking Leaves Property Values Tapped Out. 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Hydraulic Fracturing Ban: The Economic Impact of a Statewide Fracking Ban in Colorado. Leeds School of Business, University of Colorado – Boulder. March 2014. http://www.oilandgasbmps.org/docs/CO90-Economic-Impact- Of-Fracking-Moratorium.pdf PAGE 38 Woodyard, Chris. “Exxon Mobile CEO: “No Fracking Near My Backyard.” USA Today. February 2, 2014. http://www.usatoday.com/story/money/business/2014/02/22/exxon- mobil-tillerson-ceo-fracking/5726603/ Wright, Daniel, MAI, Dalton Vann. Flower Mound Well Site Impact Study. Prepared for the Town of Flower Mound. August 17, 2010. http://www.flower- mound.com/DocumentCenter/View/1456 Page 1 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Health Risks of Shale Gas Development Adgate, et. al NRC Shale Gas Committee Workshop #1 - Draft Paper 5/17/2013 4 General Summarizes literature on human health risks associated with shale gas development in US. Loss of property values mentioned. Calls for more research. "There is a substantal public concern and uncertainties that need to be addressed…" x x x x Yes x How Hydraulic Fracturing Affects Property Values Alcock Unknown unknown 6 New Foundland Considers issues that may affect property values related to fracking in response to a proposal by Shoal Point Energy. x x x x x Yes x x Modern Shale Gas Development in the United States: A Primer ALL Consulting, through Ground Water Protection Council Page 2 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Impacts of Gas Drilling on Human and Animal Health Bamberger, et. al New Solutions: A Journal of Environmental and Occupational Health 3/1/2012 27 Colorado, Louisiana, Texas, New York, Ohio, Pennsylvania Because animals often are exposed continually to air, soil and groundwater, they can be sentinels to monitor impacts to human health. These authors interviewed animal owners who live near gas drilling operations and identified which aspects of the drilling process may lead to health problems. x Presentation to House Appropriations Subcommittee Committee on Budget Transparency and Reform Page 3 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations The Impact of Oil and Natural Gas Facilities on Rural Residential Property Values: A Spatial Hedonic Anlaysis Boxall, et.al Wilfrid Laurier University, Business and Economics, 2005-01- EC, Waterloo 7/26/2014 38 Central Alberta, Calgary Summarizes the results of a hedonic analysis used to measure property value impacts to rural residential property in Alberta, Canada by virtue of proximity to oil and natural gas facilities. The analysis showed that property values were negatively correlated with the number of sour gas wells and flaring oil batteries within 4km of the property. These facilities had a significant effect on sale price. x No The Impact of Marcellus Gas Drilling on Rural Drinking Water Page 4 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations University of Colorado Boulder- led research network explores natural gas development effects Cavanaugh National Science Foundation 10/2/2013 5 Colorado, Pennsylvania Announces two NSF sponsored studies regarding natural gas development. CU study will focus on effects on air and water resources in the Rocky Mountain region. There are 8 partners including CO School of Mines, CSU, National Renewable Energy Laborartory, NOAA, CO School of PUblic Health, CA State Poly Tech. x x x Hudraulic Fracturing (Power Point) CO Oil and Gas Conservation Commission Colorado Oil and Gas Conservation Commission Page 5 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations The Economic Opportunities of Shale Energy Development Considine Center for Energy Policy and the Environment, at the Manhattan Institute Mary 2011 36 Pennsylvania Reviews environmental violations regelated to shale production from the Pennsylvania Department of Environmental Production. The value of the (adverse) environmental impacts is far smaller than the economic benefits. New York should consider lifting its moritorium. x x x x x Hydraulic Fracturing and Water Resources: Separating the Frack from the Fiction Cooley and Donnelly The Pacific Institute 6/1/2012 35 General Summarizes interviews to understand key issues regarding environmental and social impacts of fracking relative to water and systhesis of existing research. Issues: water withdrawals, groundwater contamination, wastewater management, truck traffic, surface spills, Page 6 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Economic Assessment Report for the Supplemental Generic Environmental Impact Statement on New York State's Oil, Gas and Solution Mining Regulatory Program Ecology and Environment, Inc. Prepared for the New York State of Environmental Conservation 8/1/2011 251 New York Examines the impact of gas drilling on property values by reviewing five prior studies. Conclusion: Residential properties in close promimity to new gas wells would likely see some downward pressure on price; this pressure would be particularly acute for residential properties that do not own subsurface mineral rights. There is a positive impact where owners receive royalty payments. Adverse contruction impacts include noise and vigration impacts and trucks servicing the wells. Gas compressor stations may generate noise and air emissions. The regional Page 7 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Hydraulic Fracturing Contamination Claims: Problems of Proof Hall Ohio State Law Journal, Volume 74 2013 15 General Addresses problems of proof in hydraulic fracturing contamination claims, methods for avoiding these problems and a procedure courts use in an effort to quickly resolve cases in which plaintiffs lack evidence to support an essential element of their claim. x Environmental Hazards and Residential property Values: Evidence from a Major Pipeline Event Hansen, et al. Land Economics, 82,4,529-541 2006 21 Bellingham Washington Uses housing market data to test the impact of pipeline accident and a pipeline that is accident-free on property values. Both carry hazardous liquids. In atsence of a highly- Page 8 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Surveys, Market Interviews and Environmental Stigma Jackson The Appraisal Journal Fall 2004 11 General Distinguishes between surveys and market interviews. Market interviews are used as secondary or supporting documentation for market data. Surveys are dependent upon statistically valid samples and correction for bias. The criteria for admissibility of survey results in court are more rigorous. x No Advisory Opinion 9 and Contingent Valuation Jackson The Appraisal Journal Summer 2012 5 General For the contingent valuation method, generally a survey instrument is read to a sample of property owners who are each asked their willingness to pay for a contaminated property or willingness to accept some environmental impact to their property. Respondent answers are aggregated to provide a diminution range or value attributable to the alleged contamination. A significant portion of appraisers believes that this method falls outside the guidelines or Advisory 9 to the Uniform Standards of Professional Practice. x No Page 9 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Fracking-Earthquake Link May Impact Insurance Policies Knox Columbus Business First 4/1/2014 3 General The Ohio Department of Natural Resources acknowledgement of a “probable” link between earthquakes and fracking could lead to higher insurance costs. x Don't Just Drill, Baby --- Drill Carefully Krupp Foreign Affairs May / June 2014 6 United States This article summarizes recently emerging concerns about the net environmental effects of natural gas production and progress regarding environmental protections. x x x La Plata County League of Women Voters Fracking Study League of Women Voters LaPlata County 3/1/2013 39 Colorado This study that is underway investigates the impact of Page 10 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Fractured Communities Michaels Riverkeepers 9/1/2010 40 8 states Describes hundreds of case studies demonstrating that industrial gas drilling, including horizontal drilling using fracturing, results in significant adverse environmental impacts. x x x x x x x x x Local Government Fracking Regulations: A Colorado Case Study Minor Stanford Environmental Law Journal, Vol 33:1, pp 59-120 2013 62 Colorado Uses Colorado as a case study to recite the impacts associated with fracking, including heavy usage of water, groundwater contamination, dust, the use of carcinogenic chemicals, etc., and discusses the cities' rights to regulate the process. x x x x x The Future of Natural Gas Moniz, et, al. Massachusets Instutte of Technology 2011, estimate 178 General Explores how uncertanties (greenhouse gas emission, Page 11 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Generating the Energy We need while protection the Environmen We Treature: the regulation of Hydraulic Fracturing in the United States Neslin americanbar.org 46 General Discusses how hydraulic fracturing provides important benefits, but also raises environmental concerns. This article summarizes benefits and concerns associated with hydraulic fracturing. Identifies public benefits as : 1) energy production, 2) ecomomic improvement and 2) greenhouse gas reduction. Identifies public concerns as: 1) water contamination, 2) air omissions (two conflicting studies in Colorado), 3) chemical exposure and 4) other concerns such as earthquakes and traffic nuisances. Summarizes federal and state regulations and notes that the regulatory environment is becoming more strict. x x x x x x x xx x x x Fracking Leaves Property Values Tapped Out Notte msnmoney.com August 2013 8/21/2013 2 General Page 12 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Dimock PA - "Ground Zero" in the Fight Over Fracking Phillips StateImpact - Pennsylvania; a NPR member station report unknown 4 Dimock, PA Reports on one resident (Fiorentino) whose backyard water well blew up. Also describes Consent Order and Agreement between DEP and Cabot including pay loss in property values. x x Yes x Trepass Issues in a Shale Play Pierce Development Issues in the Major Shale Plays, Paper 7, Rocky Mt. Mineral Law Foundation, 2010 12/6/2010 16 General Describes trespass claims in a shale play that can occur when activities cross a property boundary or designated drilling window that is established by an oil and gas conservation authority. x Yes Fracking Moritorium could cost Boulder County $1 billion, study Page 13 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Understanding the Marcellus Shale Supply Chain Seydor, et al University of Pittsburgh Katz Graduate School of Business 5/1/2012 72 Pennsylvania Describes the market supply chain from leasing through drilling, transportation, storage, distribution and marketing. x How Will Fracking Affect Your Property Value (and Mortgage)? Sucich zillow.com/blog CATEGORY:TIPS & ADVICE 8/1/2012 3 New York Cites an August 2011 Economic Assessment Report for the State of New York finding that in general properties may benefit from increased economic activity associated with oil and gas production, but some property values nearest the wells may decrease. The author notes that Fannie Mae and Freddie Mac require borrowers to secure consent before signing a gas lease. Author also notes that a lender benefits from a lease on mortgaged property because bonus proceeds and revenue from gas Page 14 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Deadliest Danger Isn't at the Rig but on the Road Urbina New York Times 5/14/2012 6 West Virginia Reports on trucker fatalities due to long hours. 500 to 1,500 truck trips per well are required because fracking requires millions of gallons of water. National Transportation Safety Board strongly opposes oil field exemptions because they raise the risk of crashes. x x x Annual Energy Outlook 2014 US EIA US EIA 5/7/2014 12 US Summarizes historical information about consumption, national gas production and natural gas pricing and provides forecasts that the EIA prepared. x Evaluation of Impacts to Underground Sources of Drinking Water of Hydraulic Fracturing of Coalbed Methane Reservoirs US EPA US Environmental Protection Agency EPA 816r04003. 6/1/2004 22 General Based on information collected and reviewed, EPA concludes in 2004 that the injection of hydraulic fracturing fluids into coalbed methane posed little or no threat. EPA Page 15 of 15 ANNOTATED BIBLIOGRAPHY (Sorted by Author) TITLE AUTHOR PUBLICATION Date Page Est. AREA STUDIED ABSTRACT Natural Resource Production Economic Impacts Greenhouse Gas Water Quantity Air Emissions Chemical Exposure Crop & Livestock Contamination Geologic / Earth- quakes Land Use Light or Noise Pollution Mineral & Surface Rights & Royalties Mortgage & Insurance Property Value Property Values with Fracking Reference Truck Impacts Visual Disurbance Water Quality Other Federal State Local Public Policy General Impacts Health, Safety & Welfare Impacts Regulations Hydraulic Fracturing Ban: The Economic Impact of a Statewide Fracturing Ban in Colorado Wobbekind, et.al Univ. of Colorado Boulder Leeds School of Business 3/1/2014 33 Colorado Focuses on the economic impacts of a potential statewide ban on fracking. This paper provides an overview of the political landscape surrounding the industry, quantifies the current production and economic activities as reported via public sources, and quantifies the economic impacts of a statewide ban on fracking activities. The report concludes that a statewide fracking ban would prove damaging to the Colorado economy, setting the state back an average of 68,000 jobs in the first five years and $8 billion in GDP. Over the long term (2015-2040), the impact of a ban would result in average 93,000 fewer jobs and $12 billion in lower GDP when compared to a baseline scenario. x x Exxon Mobile CEO: No Fracking Near My Backyard DRAFT City of Fort Collins Data Summary Report H2S and VOC Air Monitoring Project November 15, 2013 - February 15, 2014 Prepared for: City of Fort Collins Environmental Services Department 215 N. Mason Street Fort Collins, CO 80524 Prepared by: December 30, 2014 DRAFT i TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1-1 2.0 SITE SPECIFICATIONS 2-1 3.0 DATA SUMMARIES 3-1 3.1 Meteorological Summaries 3-1 3.2 Hydrogen Sulfide 3-7 3.3 Volatile Organic Compounds 3-8 3.3.1 VOC Data Summary 3-8 3.3.2 Regional Comparisons 3-13 3.3.3 Screening Level Comparison for HAPS 3-17 4.0 CONCLUSIONS 4-1 APPENDIX A AIR MONITORING PLAN A-1 APPENDIX B TIME SERIES PLOTS FOR HOURLY DATA B-1 APPENDIX C METHANE AND SNMOC CONCENTRATIONS (24-HOUR AVGS) C-1 DRAFT ii LIST OF FIGURES Figure Page 2-1 Map depicting City of Fort Collins monitoring sites. 2-3 2-2 NE Fort Collins monitoring sites including the Well Pad (WPFC) site (top left), the Tank Battery (TBFC) site (top right) and the Hearth Fire (HFFC) site (bottom) 2-5 2-3 VOC sample canisters located at the City Park (CPFC) site (left) and the Mason Street (MSFC) site (right). 2-6 3-1 Map overlaid with wind roses depicting wind speed and direction measured at the NE Fort Collins Monitoring sites between November 15, 2013 and February 15, 2014 3-2 3-2 Location of CSU Weather Station relative to downtown City Park and Mason Street sites 3-3 3-3 Wind Roses Plots Representing Downtown Sites and NE Sites for Dates Corresponding to VOC Samples (11/24/13 and 12/18/13) 3-4 3-4 Wind Roses Plots Representing Downtown Sites and NE Sites for Dates Corresponding to VOC Samples (12/30/13 and 01/11/14) 3-5 3-5 Wind Roses Plots Representing Downtown Sites and NE Sites for Dates Corresponding to VOC Samples (01/23/14) 3-6 3-6 Average benzene concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014 3-11 3-7 Average toluene concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014 3-11 3-8 Average propane concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014. 3-12 3-9 Average ethane concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014 3-12 3-10 Average methane concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014 3-13 3-11 Regional comparison of average BTEX concentrations 3-16 3-12 Regional comparison of average light alkane concentrations 3-16 DRAFT iii LIST OF TABLES Table Page 2-1 Monitoring Site Coordinates 2-3 2-2 Parameters Monitored by Site 2-4 3-1 H2S Monitoring Results 3-7 3-2 H2S Calibration Reports 3-7 3-3 Select VOCs, Average Concentration 3-10 3-4 Select VOCs, Average Concentration for Regional Comparisons 3-15 3-5 Tank Battery HAPS Summary 3-18 3-6 Well Pad HAPS Summary 3-18 3-7 City Park HAPS Summary 3-19 3-8 Mason Street HAPS Summary 3-19 DRAFT 1-1 1.0 INTRODUCTION Between November 15, 2013 and February 15, 2014, the City of Fort Collins performed a short term air quality monitoring assessment which was designed to help characterize ambient air quality in and around existing oil and gas operations within City limits. This project was funded jointly by the City of Fort Collins and Memorial Resource Development, LLC (MRD). Air Resource Specialists, Inc. (ARS) was the primary contractor for this effort, and laboratory analysis was performed by the Eastern Research Group, Inc. (ERG). This 90-day study included continuous monitoring for hydrogen sulfide (H2S) and meteorology, along with several 24-hour air samples which were analyzed for a number of speciated volatile organic compounds (VOCs). To ensure scientifically defensible data, monitoring systems adhered to operational protocols established and accepted by the U.S. Environmental Protection Agency (EPA). Additional background information on the project and methodology is included in the Air Monitoring Plan, which is provided as Appendix A. Any questions regarding this report should be addressed to: The City of Fort Collins Environmental Services Department 215 N. Mason Street Fort Collins, CO 80524 (970) 221-6600 DRAFT 2-1 2.0 SITE SPECIFICATIONS Monitoring for this effort was performed between November 15, 2013 and February 15, 2014 at a total of five (5) locations. Monitoring was conducted at three (3) sites in NE Fort Collins near existing oil and gas operations, and two (2) sites in downtown Fort Collins. Figure 2-1 presents a map of the monitoring sites, and Table 2-1 presents site coordinates. Parameters monitored at each site are listed in Table 2-2. Figure 2-2 presents photos of monitoring systems at the NE sites, and Figure 2-3 presents photos of the canister samplers at the downtown sites. Site characteristics are described below. NE Fort Collins Sites • Well Pad (WPFC) site: The Well Pad site was located just north of the Richard’s Lake subdivision, in an open field with an active well pad in a secure fenced location. • Hearth Fire (HFFC) site: The Hearth Fire site was located within the Hearth Fire subdivision, in a fenced area with an active well. • Tank Battery (TBFC) site: The Tank Battery site was located on Memorial Resource Development property near the north entrance to the Hearthfire development and co-located with the oil and gas production infrastructure, including storage tanks. Downtown Fort Collins Sites • City Park (CPFC) site: The City Park site was located within the fenced perimeter of the City Park pool off of City Park Drive and near Mulberry Street. • Mason Street (MSFC) site: The Mason Street location was located on the roof of a Colorado State University maintenance building near the intersection of Mason and Pitkin streets. This site was chosen to represent downtown because it is collocated with existing particulate monitoring run by the Colorado Department of Health and Environment (CDPHE), and offered secure access. The three (3) stations in NE Fort Collins continuously monitored hydrogen sulfide (H2S) and meteorological parameters using a system of stations owned by Denbury Resources, Inc., and leased per a separate agreement between Denbury and the City for the duration of this effort. The Denbury systems were designed with Environmental Protection Agency (EPA) Prevention of Significant Deterioration (PSD) grade meteorological sensors and H2S sensors which were originally designed to trigger H2S exposure alarms at high concentrations. Monitoring for speciated non-methane organic carbon compounds (SNMOCs) and methane (CH4) (subsets of VOCs), was conducted at the Tank Battery and Well Pad sites in NE Fort Collins, and at both downtown sites (City Park and Mason Street). Siltek® evacuated stainless steel canisters were manually deployed at each monitoring site every 12 days in accordance with EPA’s prescribed 12-day monitoring schedule. During this period, five (5) DRAFT 2-2 canister samples were collected at each site and analyzed at ERG laboratories following EPA’s Compendium Methods TO-12, augmented with CH4 analysis. DRAFT 2-3 Figure 2-1. Map depicting City of Fort Collins monitoring sites. Table 2-1 Monitoring Site Coordinates Site Name Latitude (°N) Longitude (°W) Well Pad (WPFC) 40° 37’ 45” 105° 02’ 39” Hearth Fire (HFFC) 40° 37’ 56” 105° 03’ 12” Tank Battery (TBFC) 40° 38’ 16” 105° 03’ 60” City Park (CPFC) 40° 35’ 00” 105° 06’ 17” Mason Street (MSFC) 40° 34’ 17” 105° 04’ 46” HFFC Met., & H2S TBFC Met., H2S & VOC WPFC Met., H2S & VOC CPFC VOC MSFC VOC DRAFT 2-4 Table 2-2 Parameters Monitored by Site Parameter Method Sampling Frequency Tank Battery Site, Fort Collins SNMOC TO-12 24-hour (1/12 day) Methane ASTM D1946 24-hour (1/12 day) H2S Electrochemical Sensor Hourly Meteorology Various Hourly Well Pad Site, Fort Collins SNMOC TO-12 24-hour (1/12 day) Methane ASTM D1946 24-hour (1/12 day) H2S Electrochemical Sensor Hourly Meteorology Various Hourly Hearth Fire Site, Fort Collins H2S Electrochemical Sensor Hourly Meteorology Various Hourly City Park Site, Fort Collins SNMOC TO-12 24-hour (1/12 day) Methane ASTM D1946 24-hour (1/12 day) Mason Street Site, Fort Collins SNMOC TO-12 24-hour (1/12 day) Methane ASTM D1946 24-hour (1/12 day) DRAFT 2-5 Figure 2-2. NE Fort Collins monitoring sites including the Well Pad (WPFC) site (top left), the Tank Battery (TBFC) site (top right) and the Hearth Fire (HFFC) site (bottom). DRAFT 2-6 Figure 2-3. VOC sample canisters located at the City Park (CPFC) site (left) and the Mason Street (MSFC) site (right). DRAFT 3-1 3.0 DATA SUMMARIES 3.1 Meteorological Summaries Meteorological data, including wind speed and wind direction, were collected along with H2S and VOC measurements at the NE Fort Collins sites to better understand the local conditions and transport of air pollutants. Time series plots including hourly averages of H2S and all monitored meteorological parameters are provided in Appendix B, Time Series Plots for Hourly Data. Figure 3-1 presents a map overlaid with wind roses, which depict wind direction and wind speed measured at each of the NE Fort Collins monitoring sites between November 15, 2013 and February 15, 2014. The direction of the bar signifies the direction the wind is coming from, the length of the bars indicate the cumulative frequency from each direction, and the colors indicate wind speed. The wind roses show that winds at the NE Fort Collins sites were influenced mostly by flow from the north and northwest. Wind pattern at the Tank Battery and Hearth Fire sites were nearly identical, while winds at the Well Pad site were from similar directions, but at higher speeds. For this study, meteorological measurements were collected at the NE Fort Collins sites, but not at the downtown Fort Collins sites. For reference in comparison to VOC sample data at the downtown sites, meteorological conditions are presented here using data from a CSU weather station (http://ccc.atmos.colostate.edu/~autowx/), which is located between the CPFC and MSFC sites as depicted in Figure 3-2. A total of five (5) 24-hour VOC samples were collected between November 24, 2013 and January 23, 2014. For reference, Figures 3-3 through 3-5 present wind rose plots representing wind direction and wind speed for both the downtown and NE sites on the VOC sample dates. DRAFT 3-2 Wind Rose Map November 15, 2013 – February 15, 2014 Wind Speed (m/s) Figure 0.3-5-1. 2 Map overlaid 2-4 with wind 4-roses 6 depicting 6-wind 8 speed and 8-10 direction measured >10 at the NE Fort Collins Monitoring sites between November 15, 2013 and February 15, 2014. DRAFT 3-3 Figure 3-2. Location of CSU Weather Station relative to downtown City Park and Mason Street sites. CSU Weather Station CPFC MSFC DRAFT 3-4 November 24, 2013 CSU Weather Station (downtown) NE Fort Collins (TBFC) Calm (<0.2 m/s): 4.2% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Calm (<0.2 m/s): 8.3% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW December 18, 2013 CSU Weather Station (downtown) NE Fort Collins (TBFC) Calm (<0.2 m/s): 0.0% 0% 10% 20% 30% N NNE NE ENE E ESE SE DRAFT 3-5 December 30, 2013 CSU Weather Station (downtown) NE Fort Collins (TBFC) Calm (<0.2 m/s): 0.0% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Calm (<0.2 m/s): 4.2% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW January 11, 2014 CSU Weather Station (downtown) NE Fort Collins (TBFC) Calm (<0.2 m/s): 0.0% 0% 10% 20% 30% N NNE NE ENE E ESE SE DRAFT 3-6 January 23, 2014 CSU Weather Station (downtown) NE Fort Collins (TBFC) Calm (<0.2 m/s): 4.2% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Calm (<0.2 m/s): 20.8% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Wind Speed (m/s) Figure 3-0.5. 5-2 Wind Rose 2-Plots 4 Representing 4-6 Downtown 6-8 Sites and NE 8-Sites 10 for Dates >10 Corresponding to VOC Samples (01/23/14). DRAFT 3-7 3.2 Hydrogen Sulfide Hydrogen sulfide (H2S) was monitored at the three (3) NE Fort Collins sites (TBFC, HFFC, and WPFC) during this study. The monitoring system was leased by the City from Denbury Resources, Inc. With a monitor resolution of 1 part per million (ppm), the H2S monitors used in these systems are capable of reporting H2S levels greater than 0.5 ppm. H2S is an odorous and toxic compound that has been detected near oil and gas operations in the Hearthfire neighborhood and the site operator has received odor complaints from some neighbors. Hydrogen sulfide odors can be detected at levels as low as 0.01 ppm and toxic effects can be exhibited at concentrations from 10 ppm and higher. Table 3-1 lists data collection statistics and summary results. No H2S levels were detected at high enough levels for an instrument response (>0.5 ppm) during this monitoring period. Note that odors from H2S can be detected at levels much lower than 0.5 ppm, so it is possible that H2S odors occurred without an instrument response. Table 3-1 City of Fort Collins H2S Monitoring Results November 15, 2013 – February 15, 2014 Site No. Possible (hours) No. Collected % Collected Max Value Detected (ppm) Tank Battery 2232 2228 99.8% 0 Well Pad 2232 2232 100% 0 Hearth Fire 2232 2232 100% 0 Table 3-2 lists calibration check results for the instruments. Instrument response was tested against a calibration standard before the monitoring period began (11/12/2013), during the monitoring period (01/29/14) and after the monitoring period ended (02/19/2014). Calibration check results indicated that instruments were responding to the reference standard between 8% low and 20% high. Because H2S was not monitored at levels high enough for an instrument reading, these calibration biases did not affect reported results. Table 3-2 City of Fort Collins H2S Calibration Results Date Reference Standard (ppm H2S) Instrument Response (ppm H2S) (% deviation) Hearth Fire Well Pad Tank Battery 11/12/2013 25.1 24 (-4%) 25 (0%) 25 (0%) 1/29/2014 25.1 23 (-8%) 24 (-4%) 28 (+12%) 2/19/2014 25.1 23 (-8%) 24 (-4%) 30 (+20%) DRAFT 3-8 3.3 Volatile Organic Compounds Volatile organic compounds (VOCs) consist of a multitude of carbon- and hydrogen- based chemicals that exist in the gas phase or can evaporate from liquids. VOCs can react in the atmosphere to form ozone and particulate matter, and a subset of VOCs are also considered Hazardous Air Pollutants (HAPs); which are compounds that are known or believed to cause human health effects. For summary purposes here, select VOC compounds are grouped into classifications with similar characteristics, as described below: • BTEX Parameters: These compounds consist of benzene, toluene, ethyl-benzene and xylenes. These are parameters of interest because they are part of a subset of VOC compounds designated by the EPA as hazardous air pollutants (HAPs). BTEX compounds are commonly associated with motor vehicles, but can also have sources associated with oil and gas production. • Light Alkanes: Alkanes are the simplest hydrocarbons, consisting of only carbon and hydrogen with single bonds. Light alkanes, which include alkanes with up to five carbon atoms (ethane, propane, iso/n-butane and iso/n-pentane), along with methane, are primary components of natural gas and gasoline vapors. These compounds are not considered HAPs, but in large concentrations can contribute to odor issues and have potential to contribute to ozone formation. • Methane: Methane is not considered a HAP, but is associated with oil and gas development and is of interest because of its potency as a greenhouse gas and to a lesser extent, its role in ozone formation. Methane is a pollutant that persists in the atmosphere for long periods of time (~12 years), so a background concentration of methane is present globally even in remote locations. This section presents a summary of VOC measurements, including comparisons to regional measurements and HAP screening values. Methane and SNMOC Concentrations (Appendix B) lists minimum, maximum, and average concentrations of all detected methane and SNMOC compounds by site. 3.3.1 VOC Data Summary Air samples were collected for VOC analysis at two (2) of the NE Fort Collins sites (TBFC and WPFC) and at the two (2) downtown sites (CPFC and MSFC). A total of five (5) samples were collected at each site per EPA’s 1-12 day schedule (http://www.epa.gov/ttnamti1/calendar.html) for 24-hour periods, and analyzed off-site by ERG laboratories. The first of five (5) samples was collected on November 24, 2013, and the last sample was collected on January 23, 2014. The sample scheduled for December 6, 2013 was not collected due to extreme cold weather. Two duplicate canister samples were collected, which included a duplicate at the CPFC site on December 18, 2013, and at the WPFC site on December DRAFT 3-9 30, 2013. A subset of VOCs, referred to as Speciated Non-Methane Hydrocarbons (SNMOCs), along with methane, were analyzed according to EPA Compendium Method TO-12. Table 3-3 lists average concentrations by site for several individual compounds measured. Due to the very low concentrations of benzene, toluene, ethylbenzene, and xylene and select light alkanes detected in the samples, these results are presented in parts per billion by volume (ppbV). Because methane is prevalent in the atmosphere in much higher concentrations, these results are presented in parts per million by volume (ppmV). Figures 3-6 through 3-10 depict daily average concentrations for select compounds of interest. Figures 3-6 and 3-7 present daily averages for benzene and toluene, two of the BTEX compounds which are commonly associated with urban sources such as vehicle exhaust, but can also be associated with oil and gas development activities. These parameters averaged highest at the downtown sites, with concentrations slightly higher at the Mason Street site than the City Park site. The highest daily concentration was recorded at all sites on December 18, 2013. Wind rose plots for this day (Figure 3-3) indicate low wind speeds, which is indicative of stagnant conditions which allow pollutants to build up rather than dispersing. Figures 3-8 and 3-9 present propane and ethane, two of the light alkanes commonly associated with oil and gas development activities. These compounds were highest at the Tank Battery site, while concentrations at the Well Pad site were comparable with the downtown sites. The highest light alkane concentrations at all four (4) sites were measured on January 11, 2014. Wind rose plots for this day (Figure 3-9) indicate that winds were predominantly from the west at the downtown sites, and from both the northwest and southeast at the NE sites. Figure 3-10 presents concentrations of methane measured at the site in units of ppmV. Methane concentrations at all sites were comparable in magnitude, averaging slightly lower at the NE well pad site than the tank battery and downtown sites. DRAFT 3-10 Table 3-3 Select VOCs, Average Concentration November 24, 2013 – January 23, 2014 Pollutant Tank Battery (TBFC) Well Pad (WPFC) City Park (CPFC) Mason Street (MSFC) BTEX Parameters (ppbV) Benzene 0.27 0.23 0.41 0.43 Toluene 0.37 0.42 0.72 0.80 Ethylbenzene 0.05 0.05 0.10 0.12 Xylenes 0.13 0.13 0.32 0.38 Select Light Alkanes (ppbV) Ethane 21.30 16.20 16.68 18.61 Propane 28.67 14.43 11.81 14.25 n-Butane 13.34 6.24 5.70 7.26 n-Pentane 3.68 4.27 1.89 2.36 Methane (ppmV) Methane 2.43 2.13 2.35 2.39 DRAFT 3-11 Figure 3-6. Average benzene concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014. Figure 3-7. Average toluene concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014. DRAFT 3-12 Figure 3-8. Average propane concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014. Figure 3-9. Average ethane concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014. DRAFT 3-13 Figure 3-10. Average methane concentrations measured at the City of Fort Collins monitoring sites between November 24, 2013 and January 23, 2014. 3.3.2 Regional Comparisons This section contains comparisons of data collected during this study to several similar VOC data subsets collected in Colorado. Regional studies summarized here include: • Current Study, Fort Collins (Winter 2013-14): Averages of VOC data collected for the current study during the 2013-14 winter period, including the two NE Fort Collins sites (Tank Battery and Well Pad) and the two downtown Fort Collins sites (City Park and Mason Street). These averages represent five (5) 24-hour samples collected between November 24, 2013 and January 23, 2014. • Fort Collins (Summer 2006): Data were collected in the summer of 2006 by the Colorado Department of Public Health and Environment (CDPHE) at a site in Fort Collins located at 3416 LaPorte Ave. Averages represent three (3) samples collected during daytime hours (1-4pm) between July 19 and July 28, 2006. • Platteville and Denver (Winter 2013-14): Data were collected by CDPHE at a site in Platteville, Colorado, near a number of oil and gas wells in Weld County, and a site in downtown Denver, Colorado. These samples are collected on a 1 in 6 day schedule, and for this comparison, only samples collected between November 2013 and January 2014 are included in these averages, representing fifteen (15) 24-hour samples. DRAFT 3-14 • Erie (Summer 2013): These concentrations represent recently published data from a study which looked at the influence of oil and gas emissions on air quality near Erie, Colorado, published by Thompson et al.1 Averages represent 30 samples collected at residences in and around Erie, Colorado between March and June of 2013. Data provided by CDPHE (Fort Collins 2006, Platteville and Denver), were analyzed by the same analytical laboratory used for this study (ERG Laboratories). For the Erie study, VOC samples were analyzed using similar methods at the Institute of Arctic and Alpine Research (INSTAAR) laboratory at University of Colorado, Boulder. Table 3-4 and Figures 3-11 and 3-12 depict a comparison of the BTEX parameters, and select light alkane compounds. For the Fort Collins data, comparisons show concentrations of BTEX parameters and light alkanes in summer of 2006 were lower that the concentrations collected during the current winter study. Although different sites and time periods are represented, s this is consistent with comparisons noted in the article published by Thompson et al., which notes that higher concentrations of VOC compounds generally occur during the wintertime in this region, due in part to the prevalence of stable boundary layer conditions and temperature inversions in the wintertime, and lower VOC compound depletion due to photoreactivity as compared to summertime. For the Denver and Plattevelle data, only measurements collected between November 2013 and January 2014 are presented in averages here, in order to be consistent with the sampling period of the current study. For the BTEX parameters, data at the Denver and Platteville sites averaged about twice the concentrations of the Fort Collins sites. These parameters are generally associated with urban sources, but are also emitted from various industrial and oil and gas related activities. For the light alkanes, the Tank Battery site in Fort Collins measured the highest of the Fort Collins sites, but had average concentrations about 10 times lower than averages reported for the Platteville site, which is located near gas development in the Greater Wattenberg Field in Weld County, Colorado. As noted previously, emissions of these light alkanes are primarily associated with natural gas development, though vehicles can emit small amounts of these compounds. Light alkane averages collected at the Tank Battery site were slightly higher than those collected in Erie, but the Erie measurements were made during the summer when concentrations of these compounds are generally lower due to photoreactivity. 1 Chelsea R. Thompson, Jacques Heber and Detlev Helmig, “Influence of Oil And Gas Emissions on Ambient Atmospheric Non-Methane Hydrocarbons in Residential Areas of Northeastern Colorado,” Elementa: Science of the Anthropocene, November 14, 2104 DRAFT 3-15 Table 3-4 Select VOCs, Average Concentration Regional Comparisons Pollutant Tank Battery Well Pad City Park Mason Street Fort Collins Denver Platteville Erie Winter 2013-14 Summer 2006 Winter 2013-14 Summer 2013 BTEX Parameters (ppbV) Benzene 0.27 0.23 0.41 0.43 0.08 0.42 0.68 0.57 Toluene 0.37 0.42 0.72 0.80 0.12 1.27 1.29 0.43 Ethylbenzene 0.05 0.05 0.10 0.12 0.03 0.17 0.12 0.05 m/p-Xylene 0.13 0.13 0.32 0.38 0.09 0.56 0.51 0.17 Select Light Alkanes (ppbV) Ethane 21.30 16.20 16.68 18.61 3.38 14.77 138.68 27.00 Propane 28.67 14.43 11.81 14.25 1.94 7.14 104.78 18.50 n-Butane 13.34 6.24 5.70 7.26 1.08 3.47 51.71 8.09 n-Pentane 3.68 4.27 1.89 2.36 0.36 1.64 17.31 2.55 Methane (ppmV) Methane 2.43 2.13 2.35 2.39 N/A 2.52 3.55 N/A 3-15 DRAFT 3-16 Figure 3-11. Regional comparison of average BTEX concentrations. Figure 3-12. Regional comparison of average light alkane concentrations. 3-16 DRAFT 3-17 3.3.3 Screening Level Comparison for HAPS National ambient air quality standards do not exist for VOCs or HAPs, but the EPA has developed a screening level methodology to evaluate potential exposures of public health concern based on air monitoring data for HAPs. EPA has also developed Air Toxics Risk Assessment procedures and risk factors for both acute and chronic exposures to HAPs. In addition, exposure levels and thresholds developed by from the Agency for Toxic Substances and Disease Registry (ATSDR), the Occupational Safety and Health Administration (OSHA), the California Air Resources Board (CARB), the National Institute for Occupational Safety and Health (NIOSH), and others can be used to determine potential risks from exposure to air toxics. A comparison of air monitoring results to published air toxic screening levels is presented here using guidance published by the EPA in the document A Preliminary Risk-Based Screening Approach for Air Toxics Monitoring Data Sets (October 2010), including May 9, 2014 updates to the data tables from that report. This information is presented for relative comparison purposes only and is not intended to imply that a screening level risk analysis or a comprehensive risk assessment was completed for this project. Of the 79 VOC compounds measured at sites in Fort Collins, eight (8) compounds had chronic inhalation screening values available from the 2010 EPA guidance. For data collected between November 2013 and January 2014, each pollutant’s measured concentration was compared to its associated chronic inhalation screening value. Tables 3-5 through 3-8 present the HAPs compounds measured for each site, and indicate the number of detections, the screening value used, and number of samples above screening values. For the Fort Collins sites, two (2) of the measured HAPs, 1,3-butadiene and benzene, had 24-hour averages measured above screening values. Both of these compounds measured higher at the downtown site than at the NE Fort Collins sites. Additionally, of the HAPS measured, only n-hexane measured higher at the NE Fort Collins sites than the downtown sites, but measurements of n-hexane were well below the screening level. Note that the screening level comparison presented here is not a substitute for a thorough risk assessment. These comparisons are designed to be very conservative, and represent comparisons of 24-hour averages to values that were designed for evaluation of chronic risks, which assume a lifetime of exposure. Because these comparisons are very conservative, pollutants that measure above these chronic screening levels do not necessarily pose a health risk. DRAFT 3-18 Table 3-5 Tank Battery HAPs Summary 11/24/2013-1/23/2014 Pollutant Number Detections Min. Max. Avg * Chronic Inhalation Screen Value (µg/m3) No. of Samples Above Screen (µg/m3) Value 1,3-Butadiene 2 0.03 0.06 0.03 0.033 1 Benzene 5 0.23 0.38 0.27 0.128 5 Ethylbenzene 5 0.02 0.11 0.05 0.4 0 m-Xylene/p- Xylene 5 0.06 0.25 0.13 10 0 Isopropylbenzene 0 ND ND 0.01 40 0 n-Hexane 5 0.42 2.78 1.23 70 0 Styrene 0 ND ND 0.03 100 0 Toluene 5 0.19 0.68 0.37 500 0 *Averages are adjusted for non-detects (ND) using ½ of the minimum detection limit. Table 3-6 Well Pad HAPs Summary 11/24/2013-1/23/2014 Pollutant Number Detections Min. Max. Avg * Chronic Inhalation Screen Value (µg/m3) No. of Samples Above Screen (µg/m3) Value 1,3-Butadiene 2 0.03 0.04 0.03 0.033 1 Benzene 5 0.17 0.31 0.23 0.128 5 Ethylbenzene 5 0.02 0.12 0.05 0.4 0 m-Xylene/p- Xylene 5 0.05 0.26 0.13 10 0 Isopropylbenzene 0 ND ND 0.01 40 0 n-Hexane 5 0.27 1.90 0.76 70 0 Styrene 0 ND ND 0.03 100 0 Toluene 5 0.16 1.03 0.42 500 0 *Averages are adjusted for non-detects (ND) using ½ of the minimum detection limit. DRAFT 3-19 Table 3-7 City Park HAPs Summary 11/24/2013-1/23/2014 Pollutant Number Detections Min. Max. Avg * Chronic Inhalation Screen Value (µg/m3) No. of Samples (µg/m3) Above Screen 1,3-Butadiene 5 0.03 0.13 0.06 0.033 4 Benzene 5 0.31 0.69 0.41 0.128 5 Ethylbenzene 5 0.05 0.20 0.10 0.4 0 m-Xylene/p- Xylene 5 0.17 0.71 0.32 10 0 Isopropylbenzene 0 ND ND 0.01 40 0 n-Hexane 5 0.39 0.76 0.55 70 0 Styrene 0 ND ND 0.03 100 0 Toluene 5 0.40 1.57 0.72 500 0 *Averages are adjusted for non-detects (ND) using ½ of the minimum detection limit. Table 3-8 Mason Street HAPs Summary 11/24/2013-1/23/2014 Pollutant Number Detections Min. Max. Avg * Chronic Inhalation Screen Value (µg/m3) No. of Samples (µg/m3) Above Screen 1,3-Butadiene 5 0.03 0.15 0.07 0.033 4 Benzene 5 0.30 0.79 0.43 0.128 5 Ethylbenzene 5 0.05 0.26 0.12 0.4 0 m-Xylene/p- Xylene 5 0.15 0.81 0.38 10 0 Isopropylbenzene 1 0.01 0.01 0.01 40 0 n-Hexane 5 0.36 0.99 0.68 70 0 Styrene 0 ND ND 0.03 100 0 Toluene 5 0.35 1.71 0.80 500 0 *Averages are adjusted for non-detects (ND) using ½ of the minimum detection limit. DRAFT 4-20 4.0 Conclusions Meteorological and air monitoring was conducted at three sites near oil and gas activities and two sites in downtown Fort Collins to collect baseline data representative of current air quality conditions in these areas. Meteorological conditions, including wind speed and direction, were continuously monitored at the three sites near oil and gas development. The predominant wind direction for all three locations was from the north-northwest with typical wind speeds in the 1-4 m/s range. Winds were light and conditions were stagnant during two of the sampling episodes with the highest VOC concentrations. Hydrogen sulfide was continuously monitored at three sites near existing oil and gas development to address neighborhood concerns and odor complaints associated with this pollutant. Hydrogen sulfide was not detected at a level above 0.5 ppm at any of the monitoring sites. Although hydrogen sulfide odor can be detected below this level, concentrations typically associated with health impacts were not observed during this project. A number of volatile organic compounds were sampled at four locations for five 24-hour sampling episodes. The air samples were analyzed for eighty different compounds. Benzene, toluene, ethylbenzene, and xylene (BTEX) concentrations at the four locations were compared as this group of pollutants are related to urban environments highly influenced by motor vehicle emissions, and can also be related to gas extraction and processing operations. BTEX concentrations were found to be slightly higher at the two downtown locations. This may indicate that concentrations at the downtown sites are more influenced by motor vehicle emissions and other industrial processes typical of an urban setting than the more rural locations where the oil and gas sites were located. Concentrations of light alkanes and methane were also evaluated for differences between the downtown sites and the oil and gas sites. Ethane, propane, and n-butane concentrations were slightly higher at the tank battery site than the other three locations. Concentrations of these compounds at this site may be influenced by truck loading operations from the oil product storage tanks or other venting sources. No significant difference in methane concentrations between the four sites was observed, indicating that site concentrations are primarily influenced by regional background methane concentrations. BTEX, light alkane, and methane concentrations were also compared to three other recent studies that included measurements of these compounds in the Front Range region. Measurements from the Fort Collins study were lower than measurement of the same compounds during the same period at Denver and Platteville sites. Hazardous air pollutant concentrations from the four locations were compared to screening level concentrations used by EPA and other agencies in health impact assessments. The purpose of this comparison was to provide a relative comparison of the 24-hour sampling concentrations to conservative lifetime exposure levels. A health impacts analysis was not performed nor was a risk assessment conducted as part of this project. Two HAPs were measured at concentrations above the screening levels; 1,3-butadiene and benzene. Higher concentrations DRAFT 4-21 of these pollutants were measured at the downtown sites than the oil and gas sites. The highest HAP concentration observed was for n-hexane at the tank battery site and was measured at an order of magnitude lower than the corresponding screening level. DRAFT A-1 Appendix A Air Monitoring Plan DRAFT Nove CITY OF Mon H2S Air Mon ember 15, 20 Pr Novem FORT COL nitoring Plan S and VOC nitoring Pro 013 – Febru repared by mber 20, 201 LLINS n oject uary 15, 201 13 14 A-2 DRAFT Monitoring Plan i TABLE OF CONTENTS Section Page 1.0 BACKGROUND 1-1 2.0 OBJECTIVES 2-1 3.0 SITE LOCATIONS 3-1 3.1 Northeast Fort Collins Sites 3-1 3.2 Downtown Fort Collins Sites 3-7 4.0 MONITORING PROCEDURES 4-1 3.1 Continuous Hydrogen Sulfide (H2S) and Meteorological Monitoring 4-1 3.2 VOC Monitoring 4-3 APPENDIX A SNMOC Target Compounds A-1 APPENDIX B ARS Quality Assurance Documents B-1 APPENDIX C ERG Quality Assurance Documents C-1 APPENDIX D Canister Sampling Field Protocol D-1 A-3 DRAFT Monitoring Plan 1-1 1.0 BACKGROUND The City of Fort Collins in engaging in a short term (90-day) air quality monitoring effort designed to help characterize ambient air quality in and around existing oil and gas operations within City limits. While current oil and gas development within City limits is limited, technology innovations have prompted increased development in surrounding communities, which has in turn increased concerns about air quality effects related to oil and gas operations. This monitoring project has been designed to address requests by City Council to provide information regarding current air quality conditions and pollutants of concern in the area of existing oil and gas operations, and help provide a starting point to begin to address citizen inquiries and concerns. Note that this effort is not a comprehensive monitoring effort, as it will represent only select pollutants over a 90-day period. Additionally, the current effort will not address potential health effects for monitored concentrations, but will provide preliminary analysis for possible future health related analysis. The monitoring effort will begin November 15, 2013 and is scheduled to continue for 90- days through February 15, 2014. The study will focus on characterizing concentrations of Hydrogen Sulfide (H2S) and concentrations of specific Volatile Organic Compounds (VOCs) commonly associated with oil and gas operations, to include methane (CH4) and some hazardous air pollutants (HAPs). This monitoring plan addresses all monitoring and data analysis procedures applied for this study, and procedures have been designed to meet protocols established by the US Environmental Protection Agency (EPA). Participants in this monitoring effort are listed below. • The City of Fort Collins is the prime authority for this monitoring effort. City staff will provide site operators to deploy and retrieve canister samples. The City will also provide final data and report review. • Memorial Resource Development LLC (MRD) will also provide final data and report review. The City and MRD will fund the program jointly. • Air Resource Specialists, Inc. (ARS) is the primary contractor, and will coordinate all aspects of the monitoring effort. ARS is responsible for the installation of monitoring equipment, calibration of continuous air quality instrumentation, data collection and validation for continuous parameters, and coordination of canister sampling. ARS will also provide a final written data report along with validated data files. • Eastern Research Group, Inc. (ERG) will support canister sample analysis, including canister preparation, shipping, receiving and processing of samples. A-4 DRAFT Monitoring Plan 2-1 2.0 OBJECTIVES This air monitoring project has been designed to help characterize the ambient air quality in and around existing oil and gas operations within Fort Collins city limits. This short-term study will include continuous monitoring of Hydrogen Sulfide (H2S) and meteorology, and will also include several discreet 24-hour air samples that will be analyzed for a number of speciated volatile organic compounds (VOCs) commonly associated with oil and gas activity. To ensure scientifically defensible data, monitoring systems will adhere to operational protocols established and accepted by the EPA. The objectives of this study include: • Document and characterize local scale concentrations of air pollutants typically associated with oil and gas development, including H2S and VOCs concentrations. These data will be used to provide the citizens of Fort Collins and the Fort Collins City Council with a point of reference to develop a better understanding of air quality conditions in the vicinity of existing oil and gas operations. • Begin to address concerns expressed by Council and citizens regarding the current status of air quality in neighborhoods surrounding existing oil and gas operations, and to advise on how the City can best manage impacts of air pollution caused by development. This study was also designed, in part, to comply with select components of an Operator Agreement, originally drafted May 29, 2013 between the City of Fort Collins and Prospect Energy, governing the Fort Collins Field and Undeveloped Acreage (UDA) west of Anheuser- Busch (available at http://www.fcgov.com/oilandgas/). Although the agreement was originally drafted between the City and Prospect Energy, an affiliate of Memorial Resource Development (MRD), Memorial Production Partners LP, acquired Prospect Energy on October 1, 2013. As successors to Prospect Energy, requirements in the Operator’s Agreement also extend to MRD. The following objectives are specific to requirements in the Operator’s Agreement: • Augment “snapshot” measurements currently made by the Operators using hand-held H2S monitoring instruments, as per the Amended Oil and Gas Operator Agreement (see Appendix A, Paragraph 21, Subparagraph j), with more robust H2S measurements that include better temporal and spatial resolution, and include meteorological measurements to better characterize pollutant transport. • Fulfill, in part, baseline monitoring requirements in the City’s Oil and Gas Operator Agreement (see Appendix A, Paragraph 21, Subparagraph h), which specifies that the city shall monitor “air quality” for a 5-day sampling period, at sampling locations to include upwind and downwind of the oil and gas development area, in City Park and at one additional location in downtown Fort Collins. A-5 DRAFT Monitoring Plan 3-1 3.0 SITE LOCATIONS This section describes the monitoring locations and rationale for site selection for this effort. Selected monitoring sites include three locations in and around northeast Fort Collins oil and gas operations, and two sites in downtown Fort Collins. Table 3-1 presents the coordinates for the selected monitoring sites. Additional site selection and description details are described in this section. Table 3-1 Site Locations Site Name Latitude (°N) Longitude (°W) Well Pad, NE Fort Collins 40° 37’ 45” 105° 02’ 39” Hearth Fire, NE Fort Collins 40° 37’ 56” 105° 03’ 12” Tank Battery, NE Fort Collins 40° 38’ 16” 105° 03’ 60” City Park, downtown Fort Collins 40° 35’ 00” 105° 06’ 17” Mason Street, downtown Fort Collins 40° 34’ 17” 105° 04’ 46” 3.1 NORTHEAST FORT COLLINS SITES Site locations in NE Fort Collins were selected to represent concentrations of H2S and VOCs near existing oil and gas operations in the City. Figure 3-1 presents a map of the Oil and Gas Fields which overlap Fort Collins city limits in the northeastern most part of the city. Potential sites were limited to oil and gas areas within city limits and the growth management area. For siting considerations, predominant wind direction in the area was assessed using a representative site. To represent the NE Fort Collins oil and gas development area, nearby meteorological data were obtained from CSU’s Agriculture, Research Development and Education Center (ARDEC) research site near the Budweiser plant, approximately 2 miles east of the eastern boundary of the oil and gas field (data available from http://aes- ardec.agsci.colostate.edu/). Figure 3-2 presents quarterly wind roses constructed from wind speed and direction measurements at the ARDEC site in 2012. The wind roses show that the predominant winds at the site from the North, with some northwesterly and southeasterly flow. Along with considerations for wind direction, potential monitoring site locations were constrained to secure areas in close proximity to oil and gas operations, the availability of access roads, minimal obstacles to the wind, and close proximately to residential areas where pollutant exposer concerns are the greatest. Site locations were not limited by available power, as all sites were configured to run remotely using solar panels and batteries, as described in Section 4.0. Figure 3-3 shows the three monitoring locations selected in NE Fort Collins overlaid with a wind rose located at the ARDEC site showing winds measured between November 15, 2012 A-6 DRAFT Monitoring Plan 3-2 and February 15, 2013 (consistent with the proposed November, 2013 through February, 2014 monitoring period). All sites were selected cooperatively with City of Fort Collins staff, and all sites are located within the secure fence-lines used for oil and gas operations in the area. Figures 3-4 through 3-6 shows zoomed in satellite views of the monitoring locations indicating the proximately to oil and gas operations and surrounding neighborhoods. The sites are labeled as follows: • Well Pad site (WPFC): The Well Pad site is located just north of the Richard’s Lake subdivision, in an open field with an active well pad. • Hearth Fire site (HFFC): The Hearth Fire site is located within the Hearth Fire subdivision, in a fenced area with an active well. • Tank Battery site (TBFC): The Tank Battery site is located near some of the production infrastructure, including the storage tanks. All three of these sites were configured to monitor continuous H2S and meteorology. The Well Pad and Tank Battery sites, which are approximately orientated along with the northwesterly/southeasterly wind flow, will also include VOC samples. A-7 DRAFT Monitori Figure 3- ing Plan -1. Map oof Oil and GGas Fields in Northeast Fort Collins. 3-3 A-8 DRAFT Monitoring Plan 3-4 CSU ARDEC Site 2012 Wind Speed (m/s) 0.5-2 2-4 4-6 6-8 8-10 Figure 3-2. 2012 Wind Roses For the CSU ARDEC Site in Northeast Fort Collins. Calm (<0.5 m/s): 0.9% January 2012 - March 2012 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Calm (<0.5 m/s): 0.3% April 2012 - June 2012 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Calm (<0.5 m/s): 1.6% July 2012 - September 2012 0% 10% 20% 30% N NNE NE DRAFT Monitoring Plan 3-5 Figure 3-3. NE Fort Collins Monitoring Locations Depicted With a Wind Rose Showing Predominant Wind Direction Measured at the Nearby CSU ARDEC Site Between November 2012 and February 2013. A-10 DRAFT Monitoring Plan 3-6 Figure 3-4. The Well Pad (WPFC) Site in NE Fort Collins. Figure 3-5. The Hearth Fire (HFFC) Site in NE Fort Collins. A-11 DRAFT Monitoring Plan 3-7 Figure 3-5. The Tank Battery (TBFC) Site in NE Fort Collins. 3.2 DOWNTOWN FORT COLLINS SITES Site locations in downtown Fort Collins were selected to represent VOC concentrations near more urban Fort Collins sources for reference as compared to the VOC samples in and near oil and gas operations. As per the May 29, 2013 Operator’s Agreement, sites were selected to satisfy requirements for “Baseline Air Quality Monitoring” over a five day sampling period at sampling locations to include City Park and “one location downtown, such as New Belgium Brewery or Wild Boar Coffee” (see Appendix A, Paragraph 21, Subparagraph h). Sites within these constraints were also required to be in secure areas, with availability of access roads, and minimal obstacles to the wind. Figure 3-6 shows the two (2) monitoring locations selected in downtown Fort Collins, which were selected cooperatively with City of Fort Collins staff. Figures 3-7 and 3-8 show zoomed in satellite views of the downtown monitoring locations, which are labeled as follows: • City Park (CPFC) Site: The location chosen for the city park site was the City Park pool. The pool is not in use during the winter season, so it offered a secure fenced location. • Mason Street (MSFC) Site: A downtown location was chosen existing particulate monitoring run by the Colorado Department of Health and Environment (CDPHE) because the location offered additional parameter monitoring, and secure access. This A-12 DRAFT Monitoring Plan 3-8 location was chosen as opposed to New Belgium Brewery or Wild Boar Coffee locations suggested in the Operator’s Agreement. Figure 3-5. The City Park (CPFC) Site in downtown Fort Collins. A-13 DRAFT Monitoring Plan 3-9 Figure 3-5. The Mason Street (MSFC) Site in downtown Fort Collins. A-14 DRAFT Monitoring Plan 4-1 4.0 MONITORING PROCEDURES For this study, ARS will install and operate equipment at five monitoring sites for a 90- day period, to include: • Three stations near oil and gas operations in Fort Collins equipped to continuously monitor meteorology (including wind speed and wind direction) and H2S, with VOC samples collected at two of these locations. • Two stations with VOC samples at the downtown Fort Collins locations. Specific monitoring procedures are presented in this section. 4.1 CONTINUOUS HYDROGEN SULFIDE (H2S) AND METEOROLOGICAL MONITORING The TBFC, HFFC and WPFC stations in NE Fort Collins will monitor H2S and meteorological parameters using a system of stations that was previously procured and assembled at ARS headquarters for Denbury Resources, Inc., and leased as per a separate agreement between Denbury and the City for the duration of this monitoring effort. These systems were designed to be rugged, reliable, and equipped with Environmental Protection Agency (EPA) prevention of significant deterioration (PSD) grade meteorological sensors. The primary component of these systems are continuous H2S monitors, with meteorological parameters including wind speed, wind direction, temperature and relative humidity. Table 4-1 presents a list of equipment and measurement methods used for this study, along with performance specifications. Note that detection of an H2S odor (normally described as resembling a rotten egg smell) may not coincide with a sensor response. The H2S sensors used for this study were originally configured to trigger alarms at levels considered harmful to human health, where a low alarm level for personal exposure monitors might be typically be set to somewhere between 5 and 10 ppm. Odors from H2S can be detected at levels lower than 0.5 ppm, which may be reported as 0 ppm due to analyzer detection limits. All ARS standard operating procedures for installation, verification and operation of air quality and meteorological parameters are fully documented, as listed in Appendix B. General procedures include: • All equipment will be calibrated upon installation according to EPA guidelines, and a final calibration check will be performed before removal at the end of the study period • All calibration and verification results will be fully documented in field log sheets • ARS will perform monthly H2S calibration checks using an H2S reference standard Continuous data from these stations will be downloaded daily by ARS staff via a radio telemetry system via IP Cellular Modems. Data are reviewed each business day to assess the A-15 DRAFT Monitoring Plan 4-2 operational integrity of the systems. If any data inconsistences or suspected instrument issues are noted during data review, ARS will assess necessary corrective actions and notify City staff. Figure 4-1. Hydrogen Sulfide and Meteorolgical Monitoring Station. A-16 DRAFT Monitoring Plan 4-3 Table 4-1 Equipment and Measurement Methods Continuous Air Quality Parameters Parameter Sample Height Manufacturer/ Model Averaging Period Measurement Range Accuracy Measurement Method Hydrogen Sulfide (H2S) 1 meter (HFFC and TBFC) or 3 meter (WPFC) Millennium II Transmitter and H2S Sensor Model: ST322X- 100-ASSY 1-hour 0-50 ppm ± 1.0 ppm Electrochemical Sensor Ambient Temperature (AT) 1 meter (HFFC and TBFC) or 3 meter R.M. Young 41342VC 1-hour -50°C – 50°C ± 0.3 (at 0°C) Platinum resistive temperature devise (RTD) Relative Humidity (RH) 1 meter (HFFC and TBFC) or 3 meter Rotronics HC2S3 1-hour 0-100% ± 2% (at 20°C) Hygromer Vector Wind Speed (VWS) 1 meter (HFFC and TBFC) or 3 meter R.M. Young 05305 1-hour 0-45 m/s ± .2 m/s or 1% of FS Propeller, Starting threshold = 0.58 DRAFT Monitoring Plan 4-4 primary components of natural gas and gasoline vapors. These compounds are not considered HAPs, but in large concentrations can contribute to odor issues and have potential to contribute to ozone formation. • Methane (CH4), which is not considered a HAP, but is associated with oil and gas development, and of interest because of its potential as a greenhouse gas. ARS will facilitate the collection and analysis of 22 24-hour integrated volatile organic compound (VOC) samples which will include 5 events at each of 4 sites, and 2 collocated/duplicate samples. Siltek® evacuated stainless steel canisters will be manually deployed at each monitoring site every 12 days on the EPA prescribed 1/12 day schedule, as shown in Figure 4-2 for 2013. Samples will begin on November 24, 2013, and continue through January 11, 2014 to include sample dates of 11/24, 12/6, 12/18, 12/30 and 1/11. ARS proposes to subcontract laboratory analysis of VOC compounds to the Eastern Research Group, Inc. (ERG) laboratories, who also provide VOC analysis support as part of the larger EPA Urban Air Toxics Monitoring Program (UATMP) and National Air Toxics Trends Station (NATTS) Networks. Complete references for ERG laboratory methods are provided in Appendix C. General procedures include: • City staff will be responsible for deploying and retrieving the canister samples. Canisters will be shipped by ERG to ARS headquarters in Fort Collins, where City staff will retrieve canisters for deployment. City staff will return canisters and chain- of-custody forms to ARS headquarters, and ARS will ship to ERG. ARS will fully train City staff for deployment of canisters following the canister deployment protocol provided in Appendix D. ARS will provide all support equipment, forms and other supplies. • Sample canisters will be shipped to ERG labs after sampling as soon as practical after collection, typically within 24 hours. Canisters will be analyzed at ERG using GC/FID analysis with MSD verification following TO-12 guidelines for SNMOC compounds. Canister samples will also be analyzed following ASTM D1946 methodology using GC/FID analysis for CH4. ERG will provide validated final data concentration files to ARS and City staff. A-18 DRAFT Monitori Figure 4- ing Plan -2. EPA shown 2013 Monit n in pink. toring Scheddule, Wheree 1/12 day prescribed ssample date 4-5 es are A-19 DRAFT Monitoring Plan 5-1 5.0 DATA ANALYSIS, EVALUATION AND REPORTING To ensure scientifically defensible data, all data analysis and evaluation will follow EPA protocols where applicable. For continuous parameters (H2S and meteorology) ARS will apply fully documented data management techniques to yield the highest quality data collection and validation. References to ARS data validation methods are listed in Appendix B, where data are validated to Final (Level-1) validation as described in SOP 3450, Ambient Air Quality and Meteorological Monitoring Data Validation. Meteorological data for the PSD-grade monitoring stations are validated according to PSD guidelines at ARS, where specific validation criteria are listed in Table 5-1. All VOC canister sample analysis and evaluation is managed at the ERG analytical laboratory according to ERG quality assurance documentation listed in Appendix C. Laboratory procedures for follow EPA Compendium Methods TO-12 for SNMOC analysis and method ASTM D1946 for CH4 analysis. ARS will provide a brief written data summary report and associated digital data files to City staff within 90-days of project completion. Only validated data, as per ARS SOP 3450, Ambient Air Quality and Meteorological Monitoring Data Validation (listed in Appendix B), will be provided in the final report. Data analysis provided in the report will include: • Final validated data and concentrations for each measured pollutant, provided in both report tables and in separate digital files. • Time series plots including meteorology, H2S, and VOCs. • Wind roses for the entire period and wind roses for high and low H2S and VOC periods. • Reports will also include copies of field documentation including log sheets, calibration results, quality control checks, and descriptions of maintenance performed. Note that, while the proposed work will not directly consider potential health impacts of monitored parameters, these data will be available for possible future health impact assessments. For this analysis, per direction by City staff, ARS will report concentrations using any requested metrics that may be comparable to risk analysis thresholds (e.g., EPA defined risk-based screening thresholds for air toxics). A-20 DRAFT Monitoring Plan 5-2 Table 5-1 Calibration and Validation Criteria – Continuous Parameters Measurement Calibration Method Frequency Criteria EPA Acceptance Criteria ARS Calibration Acceptance Criteria ARS Validation Acceptance Criteria H2S Collocated comparisons to a reference standard Monthly Concentration Difference N/A ≤ ± 1 ppm ≤ ± 5 ppm Temperature Collocated comparisons to a certified transfer standard Upon install and removal Temperature Difference ≤ ± 0.5ºC ≤ ± 0.5ºC ≤ ± 0.5 ºC Relative Humidity Collocated comparisons to a certified transfer standard Upon install and removal Relative Humidity Difference ≤ ±7% ≤± 5% ≤± 7% Wind Speed Rotational rate at zero and five upscale speed levels using a selectable speed anemometer drive, starting threshold test with torque wheel Upon install and removal Difference <± 0.2 m/s <± 0.2 m/s <± 0.2 m/s Wind Direction Alignment using two landmarks, orientation to true north, and linearity with a directional protractor, starting threshold test with torque wheel Upon install and removal Reference Alignment Difference Total Alignment Difference Linearity DRAFT Monitoring Plan A-1 APPENDIX A – MONITORING PLAN SNMOC TARGET COMPOUNDS ERG Application of EPA TO-12 Canister Analysis A-22 DRAFT Monitoring Plan B-1 APPENDIX B – MONITORING PLAN AIR RESOURCE SPECIALISTS, INC. Quality Assurance Documents (Continuous Air Quality and Meteorological Parameters) The following standard operating procedures (SOPs), technical instructions (TIs), and checklist instructions (CIs) are used in executing this program. Note that project-specific documents have not been written; this project relies in part on SOPs, TIs, and CIs that have been prepared to support other field studies. The general policies and instructions outlined in these procedures, however, are relevant to the current monitoring effort, and as such, the listed SOPs, TIs, and CIs are suitable for this particular study. Copies of all the following documents are available from ARS upon request. Number Title Regulatory Citation SOP 3001 Procedures for Quarterly Maintenance to an Ambient Air Monitoring Station (Version 0.1, January 2008) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 11.0 SOP 3050 Siting of Ambient Air Quality Monitoring Stations (Version 0.2, November 2009) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 6.0 SOP 3100 Calibration of Ambient Air Quality Analyzers (Version 2.3, November 2009) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 12.0 40 CFR 50 SOP 3150 Calibration and Routine Maintenance of Meteorological Monitoring Systems (Version 3.6 November 2009) EPA QA Handbook for Air Pollution Measurement Systems Vol. IV TI 3150-2113 Calibration and Routine Maintenance of R.M. Young Temperature/Delta Temperature Systems (Version 0.3, June 2002) EPA QA Handbook for Air Pollution Measurement Systems Vol. IV, Section 3.0 CI 3176-3121 Weekly Station Visit: Relative Humidity Sensor (Vaisala) (Version 2, January 2011) EPA QA Handbook for Air Pollution Measurement Systems Vol. IV, Section 5.0 SOP 3350 Collection of Ambient Air Quality and Meteorological Monitoring Data and Site Documentation (Version 1.6, October 2013) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 5.0 and 14.0 TI 3350-4000 Collection of Ambient Air Quality and Meteorological Monitoring Data via Modem (Version 3.0, October 2013) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 14.0 SOP 3450 Ambient Air Quality and Meteorological Monitoring Data Validation (Version 3.1, October 2013) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 17.0 TI 3450-5000 Ambient Air Quality and Meteorological Monitoring Data – Level 0 Validation (Version 1.8, October 2013) Guidance on Environmental Data Verification and Data Validation (QA/G-8) TI 3450-5010 Ambient Air Quality and Meteorological Monitoring Data DRAFT Monitoring Plan C-1 APPENDIX C – MONITORING PLAN EASTERN RESEARCH GROUP Quality Assurance Documents (VOC Canisters Samples) The following quality assurance manuals will be used in executing this program. These documents were written by the analytical laboratory, Eastern Research Group and their general policies and instructions are applied to the Fort Collins VOC sampling effort. Copies of all the following documents are available from ERG upon request. Number Title ERG-MOR-024 Standard Operating Procedure for Preparing, Extracting, and Analyzing DNPH Carbonyl Cartridges by Method TO-11A ERG-MOR-045 Standard Operating Procedure for Sample Receipt at the ERG Chemistry Laboratory ERG-MOR-046 Field Procedure for Collecting Speciated and/or Total Nonmethane Organic Compounds Ambient Air Samples Using the ERG SNMOC Sampling System ERG-MOR-047 Field Procedure for Collecting Ambient Carbonyl Compounds Samples Using the ERG C Sampling System ERG-MOR-060 Standard Operating Procedure for PDFID Sample Analysis by Method TO-12 ERG-MOR-061 Standard Operating Procedure for Standard Preparation Using Dynamic Flow Dilution System ERG-MOR-062 Standard Operating Procedure for Sample Canister Cleaning ERG-MOR-079 Standard Operating Procedure for Sample Login to the Laboratory Information Management System A-24 DRAFT Monitoring Plan D-1 APPENDIX D – MONITORING PLAN CANISTER SAMPLING FIELD PROTOCOL Standard Operation Procedures for Monitoring SNMOC in Ambient Air Using the EPA Compendium Method TO-12 Required Equipment: 1. TO-Can Canisters (1 per site) 2. flow controllers (1 per site) Vacuum Range: 29.9 to 7 in Hg Sample Time: 1440 min (24-hr) Air Volume: 4 to 6 L Sampling Procedure: Sample Start-up Procedures 1. Begin recording the “Lab Pre-Sample” section of the Toxics/SNMOC Sample Data Sheet • Site Codes: Well Pad = WPFC, Tank Battery = TBFC, Mason St. = MSFC, City Park = CPFC • City/State: Fort Collins, CO • AQS Code: N/A • Collection Date: The date sample is started • Options: SNMOC is ‘Yes’. Toxics is ‘No’ • Canister Number: Record the number from outside the canister • Lab Initial Can Pressure: Will be filled out by lab • Date Can Cleaned: Will be filled out by lab • Cleaning Batch Number: Will be filled out by lab • Duplicate Event: ‘Yes’ or ‘No’ • Duplicate Can Number: Record canister number from the corresponding duplicate canister 2. Remove gold cap from canister using a wrench. Save and store. 3. Remove silver caps from both ends of the flow controller. Save and store. 4. Connect the flow controller to the canister and tighten screw using a wrench 5. Begin recording the “Field Setup” section of the Toxics/SNMOC Sample Data Sheet • Operator: Operator’s Last Name • Sys#: PR number from flow regulator • Setup Date: The date sample was started. Also record time sample was started. • Field Initial Can Pressure: Record from pressure meter after flow controller is turned ‘on’ • MFC Setting: Leave Blank • Elapsed Timer Reset: N/A • Canister Valve Opened: Write ‘Yes’ after flow controller is turned ‘on’ A-25 DRAFT Monitoring Plan D-2 6. Set canister on a flat surface approximately ½ to 1 m off the ground/rooftop 7. Turn dial counterclockwise (on) until a vacuum is established and finish recording information in the “Field Setup” section of the Toxics/SNMOC Sample Data Sheet Sample Recovery Procedures 1. Begin recording the “Field Recovery” section of the Toxics/SNMOC Sample Data Sheet • Recovery date: The date sample ended. Also record time sample ended. • Field Final Can Pressure: Record from pressure meter before flow controller is turned ‘off’ • Sample Duration: Write “24” if a successful sample was achieved • Elapsed Time: Calculate total elapsed time (min) from start and end times • Canister Valve Opened: Write ‘Yes’ after flow controller is turned ‘off’ 2. Turn dial clockwise (off) and finish recording information in the “Field Setup” section of the Toxics/SNMOC Sample Data Sheet A-26 DRAFT Monitoring Plan D-3 Example SNMOC Canister Chain-of-Custody Form A-27 DRAFT B-1 Appendix B Time Series Plots for Hourly Data November 15, 2013 - February 15, 2014 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 DRAFT 0 350 700 1050 1400 SOL(W/m2) 0 350 700 1050 1400 NetRad(W/m2) -30 -10 10 30 50 TMP 10m (degC) -6.0 -3.0 .0 3.0 6.0 DTP 10m-2m degC -30 -10 10 30 50 TMP 2m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 DRAFT 0 350 700 1050 1400 SOL(W/m2) 0 350 700 1050 1400 NetRad(W/m2) -30 -10 10 30 50 TMP 10m (degC) -6.0 -3.0 .0 3.0 6.0 DTP 10m-2m degC -30 -10 10 30 50 TMP 2m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 DRAFT 0 350 700 1050 1400 SOL(W/m2) 0 350 700 1050 1400 NetRad(W/m2) -30 -10 10 30 50 TMP 10m (degC) -6.0 -3.0 .0 3.0 6.0 DTP 10m-2m degC -30 -10 10 30 50 TMP 2m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 DRAFT 0 350 700 1050 1400 SOL(W/m2) 0 350 700 1050 1400 NetRad(W/m2) -30 -10 10 30 50 TMP 10m (degC) -6.0 -3.0 .0 3.0 6.0 DTP 10m-2m degC -30 -10 10 30 50 TMP 2m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S(ppm) 250 260 270 280 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S(ppm) 250 260 270 280 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S(ppm) 250 260 270 280 DRAFT -30 -10 10 30 50 TMP 10m (degC) 0 5 10 15 20 SWS (m/s) 0 5 10 15 20 VWS (m/s) 0 5 10 15 20 PWS (m/s) 0 90 180 270 360 VWD (deg) 0 25 50 75 100 SDWD 10m (deg) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S(ppm) 250 260 270 280 DRAFT C-1 Appendix C Methane and SNMOC Concentrations (24-Hour Averages) November 24, 2013 - January 23, 2014 DRAFT C-2 Table C-1 Methane Concentrations November 24, 2013 – January 23, 2014 Site Concentration (ppmV) Average 11/24/2013 12/18/2013 12/30/2013 1/11/2014 1/23/2014 Tank Battery 2.23 2.52 2.59 2.22 2.61 2.43 Well Pad 1.86 2.24 2.2 2.32 2.04 2.13 City Park 2.38 2.41 2.57 2.2 2.18 2.35 Mason Street 2.39 2.55 2.13 2.64 2.26 2.40 DRAFT  Table C-2 City of Fort Collins SNMOC Monitoring Tank Battery (TBFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects 1,2,3-Trimethylbenzene (526-73-8) 5 2 0.01 0.02 0.01 1,2,4-Trimethylbenzene (95-63-6) 5 5 0.03 0.09 0.06 1,3,5-Trimethylbenzene (108-67-8) 5 3 0.02 0.03 0.02 1,3-Butadiene (106-99-0) 5 2 0.03 0.06 0.03 1-Butene (106-98-6) 5 0 0.00 0.03 1-Decene (872-05-9) 5 0 0.00 0.02 1-Dodecene (112-41-4) 5 0 0.00 0.03 1-Heptene (592-76-7) 5 0 0.00 0.02 1-Hexene (592-41-6) 5 1 0.03 0.03 0.03 1-Nonene (124-11-8) 5 3 0.02 0.03 0.02 1-Octene (111-66-0) 5 3 0.02 0.04 0.02 1-Pentene (109-67-1) 5 5 0.02 0.06 0.03 1-Tridecene (2437-56-1) 5 0 0.00 0.02 1-Undecene (821-95-4) 5 1 0.01 0.01 0.02 2,2,3-Trimethylpentane (564-02-3) 5 1 0.02 0.02 0.02 2,2,4-Trimethylpentane (540-84-1) 5 0 0.00 0.01 2,2-Dimethylbutane (75-83-2) 5 5 0.02 0.04 0.03 2,3,4-Trimethylpentane (565-75-3) 5 4 0.01 0.04 0.02 2,3-Dimethylbutane (79-29-8) 5 5 0.05 0.15 0.10 2,3-Dimethylpentane (565-59-3) 5 5 0.03 0.19 0.09 2,4-Dimethylpentane (108-08-7) 5 5 0.02 0.08 0.04 2-Ethyl-1-butene (760-21-4) 5 0 0.00 0.02 2-Methyl-1-butene (563-46-2) 5 3 0.03 0.05 0.03 2-Methyl-1-pentene (763-29-1) 5 0 0.00 0.02 2-Methyl-2-butene (513-35-9) 5 1 0.03 0.03 0.02 2-Methylheptane (592-27-8) 5 5 0.03 0.22 0.09 2-Methylhexane (591-76-4) 5 5 0.10 0.41 0.25 2-Methylpentane (107-83-5) 5 5 0.41 1.12 0.84 3-Methyl-1-butene (563-45-1) 5 0 0.00 0.02 3-Methylheptane (589-81-1) 5 5 0.02 0.14 0.06 3-Methylhexane (589-34-4) 5 2 0.25 0.52 0.17 3-Methylpentane (96-14-0) 5 5 0.21 0.63 0.44 4-Methyl-1-pentene (691-37-2) 5 0 0.00 0.01 Acetylene (74-86-2) 5 5 0.53 0.94 0.73 a-Pinene (80-56-8) 5 0 0.00 0.01 Benzene (71-43-2) 5 5 0.23 0.38 0.27 b-Pinene (127-91-3) 5 0 0.00 0.02 cis-2-Butene (590-18-1) 5 2 0.02 0.03 0.02 cis-2-Hexene (7688-21-3) 5 0 0.00 0.02 cis-2-Pentene (627-20-3) 5 0 0.00 0.02 Cyclohexane (110-82-7) 5 5 0.26 1.02 0.54 Cyclopentane (287-92-3) 5 5 0.20 0.54 0.38 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-3 DRAFT Table C-2 (continued) City of Fort Collins SNMOC Monitoring Tank Battery (TBFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects Cyclopentene (142-29-0) 5 0 0.00 0.05 Ethane (74-84-0) 5 5 18.40 29.70 21.30 Ethylbenzene (100-41-4) 5 5 0.02 0.11 0.05 Ethylene (74-85-1) 5 5 1.10 2.34 1.71 Isobutane (75-28-5) 5 5 2.80 10.28 5.12 Isobutene (115-11-7) 5 0 0.00 0.02 Isobutylene (115-11-7) 5 0 0.00 0.02 Isopentane (78-78-4) 5 5 1.95 5.40 3.96 Isoprene (78-79-5) 5 3 0.03 0.04 0.03 Isopropylbenzene (98-82-8) 5 0 0.00 0.01 m-Diethylbenzene (141-93-5) 5 0 0.00 0.02 Methylcyclohexane (108-87-2) 5 5 0.19 1.23 0.53 Methylcyclopentane (96-37-7) 5 5 0.31 1.14 0.74 m-Ethyltoluene (620-14-4) 5 4 0.02 0.05 0.02 m-Xylene/p-Xylene (108-38-3/106-42-3) 5 5 0.06 0.25 0.13 n-Butane (106-97-8) 5 5 7.70 21.35 13.34 n-Decane (124-18-5) 5 4 0.03 0.07 0.03 n-Dodecane (112-40-3) 5 4 0.01 0.01 0.01 n-Heptane (142-82-5) 5 5 0.15 1.03 0.40 n-Hexane (110-54-3) 5 5 0.42 2.78 1.23 n-Nonane (111-84-2) 5 5 0.02 0.11 0.05 n-Octane (111-65-9) 5 5 0.06 0.45 0.19 n-Pentane (109-66-0) 5 5 2.12 5.64 3.68 n-Propylbenzene (103-65-1) 5 1 0.02 0.02 0.01 n-Tridecane (629-50-5) 5 0 0.00 0.01 n-Undecane (1120-21-4) 5 4 0.01 0.02 0.02 o-Ethyltoluene (611-14-3) 5 3 0.01 0.03 0.02 o-Xylene (95-47-6) 5 5 0.02 0.10 0.06 p-Diethylbenzene (105-05-5) 5 0 0.00 0.01 p-Ethyltoluene (622-96-8) 5 2 0.02 0.03 0.02 Propane (74-98-6) 5 5 19.03 43.67 28.67 Propylene (115-07-1) 5 5 0.24 0.63 0.38 Propyne (74-99-7) 5 0 0.00 0.02 Styrene (100-42-5) 5 0 0.00 0.03 Toluene (108-88-3) 5 5 0.19 0.68 0.37 trans-2-Butene (624-64-6) 5 1 0.07 0.07 0.02 trans-2-Hexene (4050-45-7) 5 0 0.00 0.02 trans-2-Pentene (646-04-8) 5 2 0.02 0.02 0.02 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-4 DRAFT Table C-3 City of Fort Collins SNMOC Monitoring Well Pad (WPFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects 1,2,3-Trimethylbenzene (526-73-8) 5 3 0.01 0.04 0.02 1,2,4-Trimethylbenzene (95-63-6) 5 5 0.03 0.09 0.06 1,3,5-Trimethylbenzene (108-67-8) 5 2 0.03 0.03 0.02 1,3-Butadiene (106-99-0) 5 2 0.03 0.04 0.03 1-Butene (106-98-6) 5 0 0.00 0.03 1-Decene (872-05-9) 5 0 0.00 0.02 1-Dodecene (112-41-4) 5 0 0.00 0.03 1-Heptene (592-76-7) 5 0 0.00 0.02 1-Hexene (592-41-6) 5 3 0.02 0.03 0.03 1-Nonene (124-11-8) 5 3 0.01 0.02 0.01 1-Octene (111-66-0) 5 3 0.02 0.03 0.02 1-Pentene (109-67-1) 5 4 0.03 0.07 0.04 1-Tridecene (2437-56-1) 5 0 0.00 0.02 1-Undecene (821-95-4) 5 0 0.00 0.03 2,2,3-Trimethylpentane (564-02-3) 5 0 0.00 0.01 2,2,4-Trimethylpentane (540-84-1) 5 0 0.00 0.01 2,2-Dimethylbutane (75-83-2) 5 4 0.03 0.33 0.09 2,3,4-Trimethylpentane (565-75-3) 5 3 0.01 0.05 0.02 2,3-Dimethylbutane (79-29-8) 5 5 0.03 0.08 0.06 2,3-Dimethylpentane (565-59-3) 5 5 0.03 0.13 0.06 2,4-Dimethylpentane (108-08-7) 5 5 0.01 0.04 0.02 2-Ethyl-1-butene (760-21-4) 5 0 0.00 0.02 2-Methyl-1-butene (563-46-2) 5 0 0.00 0.02 2-Methyl-1-pentene (763-29-1) 5 0 0.00 0.02 2-Methyl-2-butene (513-35-9) 5 2 0.05 0.07 0.04 2-Methylheptane (592-27-8) 5 4 0.02 0.05 0.03 2-Methylhexane (591-76-4) 5 5 0.07 0.39 0.23 2-Methylpentane (107-83-5) 5 5 0.26 0.62 0.47 3-Methyl-1-butene (563-45-1) 5 0 0.00 0.02 3-Methylheptane (589-81-1) 5 5 0.01 0.04 0.03 3-Methylhexane (589-34-4) 5 2 0.12 0.32 0.10 3-Methylpentane (96-14-0) 5 5 0.13 0.36 0.24 4-Methyl-1-pentene (691-37-2) 5 0 0.00 0.01 Acetylene (74-86-2) 5 5 0.46 1.31 0.73 a-Pinene (80-56-8) 5 2 0.03 0.03 0.02 Benzene (71-43-2) 5 5 0.17 0.31 0.23 b-Pinene (127-91-3) 5 0 0.00 0.02 cis-2-Butene (590-18-1) 5 3 0.02 0.03 0.02 cis-2-Hexene (7688-21-3) 5 0 0.00 0.02 cis-2-Pentene (627-20-3) 5 0 0.00 0.02 Cyclohexane (110-82-7) 5 5 0.16 0.52 0.26 Cyclopentane (287-92-3) 5 5 0.12 1.19 0.35 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-5 DRAFT Table C-3 (continued) City of Fort Collins SNMOC Monitoring Well Pad (WPFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects Cyclopentene (142-29-0) 5 0 0.00 0.05 Ethane (74-84-0) 5 5 11.60 23.85 16.20 Ethylbenzene (100-41-4) 5 5 0.02 0.12 0.05 Ethylene (74-85-1) 5 5 0.88 2.89 1.67 Isobutane (75-28-5) 5 5 1.80 7.52 3.45 Isobutene (115-11-7) 5 0 0.00 0.02 Isobutylene (115-11-7) 5 0 0.00 0.02 Isopentane (78-78-4) 5 2 1.18 8.20 1.88 Isoprene (78-79-5) 5 2 0.02 0.21 0.06 Isopropylbenzene (98-82-8) 5 0 0.00 0.01 m-Diethylbenzene (141-93-5) 5 0 0.00 0.02 Methylcyclohexane (108-87-2) 5 5 0.14 0.37 0.23 Methylcyclopentane (96-37-7) 5 5 0.16 0.46 0.31 m-Ethyltoluene (620-14-4) 5 3 0.02 0.05 0.03 m-Xylene/p-Xylene (108-38-3/106-42-3) 5 5 0.05 0.26 0.13 n-Butane (106-97-8) 5 5 4.50 8.72 6.24 n-Decane (124-18-5) 5 3 0.03 0.05 0.03 n-Dodecane (112-40-3) 5 3 0.01 0.01 0.02 n-Heptane (142-82-5) 5 5 0.10 0.30 0.17 n-Hexane (110-54-3) 5 5 0.27 1.90 0.76 n-Nonane (111-84-2) 5 5 0.02 0.04 0.03 n-Octane (111-65-9) 5 5 0.05 0.10 0.08 n-Pentane (109-66-0) 5 5 1.27 14.32 4.27 n-Propylbenzene (103-65-1) 5 1 0.01 0.01 0.01 n-Tridecane (629-50-5) 5 0 0.00 0.01 n-Undecane (1120-21-4) 5 4 0.01 0.02 0.01 o-Ethyltoluene (611-14-3) 5 2 0.01 0.02 0.01 o-Xylene (95-47-6) 5 5 0.02 0.10 0.06 p-Diethylbenzene (105-05-5) 5 0 0.00 0.01 p-Ethyltoluene (622-96-8) 5 3 0.01 0.03 0.02 Propane (74-98-6) 5 5 9.83 19.73 14.43 Propylene (115-07-1) 5 5 0.20 0.69 0.43 Propyne (74-99-7) 5 0 0.00 0.02 Styrene (100-42-5) 5 0 0.00 0.03 Toluene (108-88-3) 5 5 0.16 1.03 0.42 trans-2-Butene (624-64-6) 5 3 0.03 0.08 0.04 trans-2-Hexene (4050-45-7) 5 0 0.00 0.02 trans-2-Pentene (646-04-8) 5 3 0.01 0.02 0.02 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-6 DRAFT Table C-4 City of Fort Collins SNMOC Monitoring City Park (CPFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects 1,2,3-Trimethylbenzene (526-73-8) 5 3 0.02 0.05 0.02 1,2,4-Trimethylbenzene (95-63-6) 5 5 0.07 0.28 0.13 1,3,5-Trimethylbenzene (108-67-8) 5 5 0.03 0.10 0.05 1,3-Butadiene (106-99-0) 5 5 0.03 0.13 0.06 1-Butene (106-98-6) 5 0 0.00 0.03 1-Decene (872-05-9) 5 0 0.00 0.02 1-Dodecene (112-41-4) 5 0 0.00 0.03 1-Heptene (592-76-7) 5 0 0.00 0.02 1-Hexene (592-41-6) 5 1 0.02 0.02 0.03 1-Nonene (124-11-8) 5 2 0.01 0.01 0.01 1-Octene (111-66-0) 5 2 0.02 0.03 0.02 1-Pentene (109-67-1) 5 5 0.03 0.08 0.05 1-Tridecene (2437-56-1) 5 0 0.00 0.02 1-Undecene (821-95-4) 5 0 0.00 0.03 2,2,3-Trimethylpentane (564-02-3) 5 4 0.01 0.02 0.02 2,2,4-Trimethylpentane (540-84-1) 5 5 0.04 0.18 0.08 2,2-Dimethylbutane (75-83-2) 5 5 0.03 0.07 0.04 2,3,4-Trimethylpentane (565-75-3) 5 5 0.03 0.08 0.04 2,3-Dimethylbutane (79-29-8) 5 5 0.06 0.15 0.09 2,3-Dimethylpentane (565-59-3) 5 5 0.06 0.21 0.10 2,4-Dimethylpentane (108-08-7) 5 5 0.03 0.07 0.05 2-Ethyl-1-butene (760-21-4) 5 0 0.00 0.02 2-Methyl-1-butene (563-46-2) 5 3 0.05 0.11 0.05 2-Methyl-1-pentene (763-29-1) 5 0 0.00 0.02 2-Methyl-2-butene (513-35-9) 5 5 0.05 0.14 0.08 2-Methylheptane (592-27-8) 5 5 0.04 0.10 0.06 2-Methylhexane (591-76-4) 5 5 0.14 0.44 0.24 2-Methylpentane (107-83-5) 5 5 0.40 0.83 0.57 3-Methyl-1-butene (563-45-1) 5 0 0.00 0.02 3-Methylheptane (589-81-1) 5 5 0.03 0.10 0.05 3-Methylhexane (589-34-4) 5 2 0.23 0.51 0.17 3-Methylpentane (96-14-0) 5 5 0.20 0.49 0.30 4-Methyl-1-pentene (691-37-2) 5 0 0.00 0.01 Acetylene (74-86-2) 5 5 1.06 2.56 1.50 a-Pinene (80-56-8) 5 5 0.01 0.06 0.04 Benzene (71-43-2) 5 5 0.31 0.69 0.41 b-Pinene (127-91-3) 5 0 0.00 0.02 cis-2-Butene (590-18-1) 5 5 0.03 0.16 0.07 cis-2-Hexene (7688-21-3) 5 0 0.00 0.02 cis-2-Pentene (627-20-3) 5 3 0.02 0.04 0.02 Cyclohexane (110-82-7) 5 5 0.21 0.41 0.29 Cyclopentane (287-92-3) 5 5 0.11 0.21 0.15 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-7 DRAFT Table C-4 (continued) City of Fort Collins SNMOC Monitoring City Park (CPFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects Cyclopentene (142-29-0) 5 0 0.00 0.05 Ethane (74-84-0) 5 5 13.20 24.45 16.68 Ethylbenzene (100-41-4) 5 5 0.05 0.20 0.10 Ethylene (74-85-1) 5 5 1.64 4.96 2.88 Isobutane (75-28-5) 5 5 1.78 3.55 2.41 Isobutene (115-11-7) 5 0 0.00 0.02 Isobutylene (115-11-7) 5 0 0.00 0.02 Isopentane (78-78-4) 5 5 1.46 2.96 2.05 Isoprene (78-79-5) 5 5 0.02 0.06 0.03 Isopropylbenzene (98-82-8) 5 0 0.00 0.01 m-Diethylbenzene (141-93-5) 5 0 0.00 0.02 Methylcyclohexane (108-87-2) 5 5 0.13 0.30 0.22 Methylcyclopentane (96-37-7) 5 5 0.22 0.49 0.31 m-Ethyltoluene (620-14-4) 5 5 0.04 0.17 0.08 m-Xylene/p-Xylene (108-38-3/106-42-3) 5 5 0.17 0.71 0.32 n-Butane (106-97-8) 5 5 4.10 8.62 5.70 n-Decane (124-18-5) 5 5 0.02 0.06 0.04 n-Dodecane (112-40-3) 5 3 0.01 0.01 0.02 n-Heptane (142-82-5) 5 5 0.13 0.41 0.23 n-Hexane (110-54-3) 5 5 0.38 0.76 0.55 n-Nonane (111-84-2) 5 5 0.02 0.07 0.04 n-Octane (111-65-9) 5 5 0.07 0.16 0.10 n-Pentane (109-66-0) 5 5 1.34 2.62 1.89 n-Propylbenzene (103-65-1) 5 3 0.01 0.04 0.02 n-Tridecane (629-50-5) 5 0 0.00 0.01 n-Undecane (1120-21-4) 5 5 0.01 0.03 0.02 o-Ethyltoluene (611-14-3) 5 5 0.02 0.08 0.04 o-Xylene (95-47-6) 5 5 0.07 0.27 0.12 p-Diethylbenzene (105-05-5) 5 0 0.00 0.01 p-Ethyltoluene (622-96-8) 5 5 0.02 0.08 0.04 Propane (74-98-6) 5 5 8.73 18.17 11.81 Propylene (115-07-1) 5 5 0.37 1.18 0.67 Propyne (74-99-7) 5 0 0.00 0.02 Styrene (100-42-5) 5 0 0.00 0.03 Toluene (108-88-3) 5 5 0.40 1.57 0.72 trans-2-Butene (624-64-6) 5 5 0.03 0.19 0.10 trans-2-Hexene (4050-45-7) 5 0 0.00 0.02 trans-2-Pentene (646-04-8) 5 5 0.02 0.09 0.04 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-8 DRAFT Table C-5 City of Fort Collins SNMOC Monitoring Mason Street (MSFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects 1,2,3-Trimethylbenzene (526-73-8) 5 4 0.02 0.07 0.03 1,2,4-Trimethylbenzene (95-63-6) 5 5 0.06 0.33 0.15 1,3,5-Trimethylbenzene (108-67-8) 5 5 0.02 0.12 0.06 1,3-Butadiene (106-99-0) 5 5 0.03 0.15 0.07 1-Butene (106-98-6) 5 0 0.00 0.03 1-Decene (872-05-9) 5 0 0.00 0.02 1-Dodecene (112-41-4) 5 0 0.00 0.03 1-Heptene (592-76-7) 5 0 0.00 0.02 1-Hexene (592-41-6) 5 3 0.02 0.04 0.03 1-Nonene (124-11-8) 5 5 0.01 0.03 0.02 1-Octene (111-66-0) 5 4 0.03 0.05 0.03 1-Pentene (109-67-1) 5 5 0.04 0.12 0.07 1-Tridecene (2437-56-1) 5 0 0.00 0.02 1-Undecene (821-95-4) 5 0 0.00 0.03 2,2,3-Trimethylpentane (564-02-3) 5 1 0.02 0.02 0.02 2,2,4-Trimethylpentane (540-84-1) 5 5 0.04 0.20 0.08 2,2-Dimethylbutane (75-83-2) 5 5 0.03 0.08 0.05 2,3,4-Trimethylpentane (565-75-3) 5 5 0.02 0.11 0.04 2,3-Dimethylbutane (79-29-8) 5 5 0.05 0.19 0.11 2,3-Dimethylpentane (565-59-3) 5 5 0.05 0.25 0.11 2,4-Dimethylpentane (108-08-7) 5 5 0.02 0.08 0.05 2-Ethyl-1-butene (760-21-4) 5 0 0.00 0.02 2-Methyl-1-butene (563-46-2) 5 5 0.03 0.14 0.07 2-Methyl-1-pentene (763-29-1) 5 0 0.00 0.02 2-Methyl-2-butene (513-35-9) 5 5 0.06 0.16 0.09 2-Methylheptane (592-27-8) 5 5 0.05 0.14 0.08 2-Methylhexane (591-76-4) 5 5 0.20 0.74 0.35 2-Methylpentane (107-83-5) 5 5 0.42 1.10 0.69 3-Methyl-1-butene (563-45-1) 5 0 0.00 0.02 3-Methylheptane (589-81-1) 5 5 0.03 0.12 0.06 3-Methylhexane (589-34-4) 5 2 0.21 0.65 0.19 3-Methylpentane (96-14-0) 5 5 0.19 0.63 0.36 4-Methyl-1-pentene (691-37-2) 5 0 0.00 0.01 Acetylene (74-86-2) 5 5 0.97 2.73 1.59 a-Pinene (80-56-8) 5 2 0.02 0.06 0.02 Benzene (71-43-2) 5 5 0.30 0.79 0.43 b-Pinene (127-91-3) 5 0 0.00 0.02 cis-2-Butene (590-18-1) 5 5 0.03 0.22 0.10 cis-2-Hexene (7688-21-3) 5 1 0.01 0.01 0.02 cis-2-Pentene (627-20-3) 5 4 0.02 0.06 0.03 Cyclohexane (110-82-7) 5 5 0.20 0.55 0.31 Cyclopentane (287-92-3) 5 5 0.14 0.28 0.18 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-9 DRAFT Table C-5 (continued) City of Fort Collins SNMOC Monitoring Mason Street (MSFC) 11/25/2013-1/24/2014 (every twelfth day) Detected Compound (CAS Number) Concentration (ppbV) Minimum Maximum Average* Sample Count # Samples # Detects Cyclopentene (142-29-0) 5 0 0.00 0.05 Ethane (74-84-0) 5 5 14.20 28.30 18.61 Ethylbenzene (100-41-4) 5 5 0.05 0.26 0.12 Ethylene (74-85-1) 5 5 1.82 6.00 3.24 Isobutane (75-28-5) 5 5 1.94 4.50 3.06 Isobutene (115-11-7) 5 0 0.00 0.02 Isobutylene (115-11-7) 5 0 0.00 0.02 Isopentane (78-78-4) 5 1 1.62 1.62 0.33 Isoprene (78-79-5) 5 5 0.02 0.07 0.04 Isopropylbenzene (98-82-8) 5 1 0.01 0.01 0.01 m-Diethylbenzene (141-93-5) 5 0 0.00 0.02 Methylcyclohexane (108-87-2) 5 5 0.17 0.41 0.27 Methylcyclopentane (96-37-7) 5 5 0.23 0.61 0.39 m-Ethyltoluene (620-14-4) 5 5 0.03 0.20 0.09 m-Xylene/p-Xylene (108-38-3/106-42-3) 5 5 0.15 0.81 0.38 n-Butane (106-97-8) 5 5 4.65 10.88 7.26 n-Decane (124-18-5) 5 5 0.02 0.07 0.04 n-Dodecane (112-40-3) 5 3 0.01 0.03 0.02 n-Heptane (142-82-5) 5 5 0.15 0.52 0.28 n-Hexane (110-54-3) 5 5 0.36 0.99 0.68 n-Nonane (111-84-2) 5 5 0.02 0.08 0.04 n-Octane (111-65-9) 5 5 0.07 0.18 0.11 n-Pentane (109-66-0) 5 5 1.65 3.36 2.36 n-Propylbenzene (103-65-1) 5 2 0.02 0.05 0.02 n-Tridecane (629-50-5) 5 0 0.00 0.01 n-Undecane (1120-21-4) 5 5 0.01 0.04 0.02 o-Ethyltoluene (611-14-3) 5 5 0.01 0.09 0.04 o-Xylene (95-47-6) 5 5 0.06 0.31 0.14 p-Diethylbenzene (105-05-5) 5 0 0.00 0.01 p-Ethyltoluene (622-96-8) 5 5 0.02 0.09 0.04 Propane (74-98-6) 5 5 10.10 22.27 14.25 Propylene (115-07-1) 5 5 0.43 1.63 0.83 Propyne (74-99-7) 5 0 0.00 0.02 Styrene (100-42-5) 5 0 0.00 0.03 Toluene (108-88-3) 5 5 0.35 1.71 0.80 trans-2-Butene (624-64-6) 5 4 0.09 0.30 0.14 trans-2-Hexene (4050-45-7) 5 1 0.02 0.02 0.02 trans-2-Pentene (646-04-8) 5 5 0.02 0.11 0.05 *Samples reported as non-detects (ND) were included in averages as 1/2 minimum detection limits. C-10 290 300 H2S TMP(degK) 02/01 02/02 02/03 02/04 02/05 02/06 02/07 02/08 02/09 02/10 02/11 02/12 02/13 02/14 02/15 02/16 02/17 02/18 02/19 02/20 02/21 02/22 02/23 02/24 02/25 02/26 02/27 02/28 Date Hearth Fire Fort Collins - H2S and Met Data February 2014 B-13 290 300 H2S TMP(degK) 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 01/10 01/11 01/12 01/13 01/14 01/15 01/16 01/17 01/18 01/19 01/20 01/21 01/22 01/23 01/24 01/25 01/26 01/27 01/28 01/29 01/30 01/31 Date Hearth Fire Fort Collins - H2S and Met Data January 2014 B-12 290 300 H2S TMP(degK) 12/01 12/02 12/03 12/04 12/05 12/06 12/07 12/08 12/09 12/10 12/11 12/12 12/13 12/14 12/15 12/16 12/17 12/18 12/19 12/20 12/21 12/22 12/23 12/24 12/25 12/26 12/27 12/28 12/29 12/30 12/31 Date Hearth Fire Fort Collins - H2S and Met Data December 2013 B-11 290 300 H2S TMP(degK) 11/01 11/02 11/03 11/04 11/05 11/06 11/07 11/08 11/09 11/10 11/11 11/12 11/13 11/14 11/15 11/16 11/17 11/18 11/19 11/20 11/21 11/22 11/23 11/24 11/25 11/26 11/27 11/28 11/29 11/30 Date Hearth Fire Fort Collins - H2S and Met Data November 2013 B-10 SDWD 10m (deg) -2.0 -1.0 .0 1.0 2.0 Vert WS (m/s) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 290 300 H2S TMP(degK) 02/01 02/02 02/03 02/04 02/05 02/06 02/07 02/08 02/09 02/10 02/11 02/12 02/13 02/14 02/15 02/16 02/17 02/18 02/19 02/20 02/21 02/22 02/23 02/24 02/25 02/26 02/27 02/28 Date Well Pad Fort Collins - H2S and Met Data February 2014 B-9 SDWD 10m (deg) -2.0 -1.0 .0 1.0 2.0 Vert WS (m/s) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 290 300 H2S TMP(degK) 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 01/10 01/11 01/12 01/13 01/14 01/15 01/16 01/17 01/18 01/19 01/20 01/21 01/22 01/23 01/24 01/25 01/26 01/27 01/28 01/29 01/30 01/31 Date Well Pad Fort Collins - H2S and Met Data January 2014 B-8 SDWD 10m (deg) -2.0 -1.0 .0 1.0 2.0 Vert WS (m/s) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 290 300 H2S TMP(degK) 12/01 12/02 12/03 12/04 12/05 12/06 12/07 12/08 12/09 12/10 12/11 12/12 12/13 12/14 12/15 12/16 12/17 12/18 12/19 12/20 12/21 12/22 12/23 12/24 12/25 12/26 12/27 12/28 12/29 12/30 12/31 Date Well Pad Fort Collins - H2S and Met Data December 2013 B-7 SDWD 10m (deg) -2.0 -1.0 .0 1.0 2.0 Vert WS (m/s) 0 25 50 75 100 RH(%) 500 550 600 650 700 BAR(mmHg) 0 1 2 3 4 5 H2S (ppm) 250 260 270 280 290 300 H2S TMP(degK) 11/01 11/02 11/03 11/04 11/05 11/06 11/07 11/08 11/09 11/10 11/11 11/12 11/13 11/14 11/15 11/16 11/17 11/18 11/19 11/20 11/21 11/22 11/23 11/24 11/25 11/26 11/27 11/28 11/29 11/30 Date Well Pad Fort Collins - H2S and Met Data November 2013 B-6 290 300 H2S TMP(degK) 02/01 02/02 02/03 02/04 02/05 02/06 02/07 02/08 02/09 02/10 02/11 02/12 02/13 02/14 02/15 02/16 02/17 02/18 02/19 02/20 02/21 02/22 02/23 02/24 02/25 02/26 02/27 02/28 Date Tank Battery Fort Collins - H2S and Met Data February 2014 B-5 290 300 H2S TMP(degK) 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 01/10 01/11 01/12 01/13 01/14 01/15 01/16 01/17 01/18 01/19 01/20 01/21 01/22 01/23 01/24 01/25 01/26 01/27 01/28 01/29 01/30 01/31 Date Tank Battery Fort Collins - H2S and Met Data January 2014 B-4 290 300 H2S TMP(degK) 12/01 12/02 12/03 12/04 12/05 12/06 12/07 12/08 12/09 12/10 12/11 12/12 12/13 12/14 12/15 12/16 12/17 12/18 12/19 12/20 12/21 12/22 12/23 12/24 12/25 12/26 12/27 12/28 12/29 12/30 12/31 Date Tank Battery Fort Collins - H2S and Met Data December 2013 B-3 290 300 H2S TMP(degK) 11/01 11/02 11/03 11/04 11/05 11/06 11/07 11/08 11/09 11/10 11/11 11/12 11/13 11/14 11/15 11/16 11/17 11/18 11/19 11/20 11/21 11/22 11/23 11/24 11/25 11/26 11/27 11/28 11/29 11/30 Date Tank Battery Fort Collins - H2S and Met Data November 2013 B-2 – Preliminary Validation (Version 2.1, October 2013) Guidance on Environmental Data Verification and Data Validation (QA/G-8) TI 3450-5020 Ambient Air Quality and Meteorological Monitoring Data – Final Validation (Version 3.1, October 2013) Guidance on Environmental Data Verification and Data Validation (QA/G-8) SOP 3650 IMC Staff’s Maintenance Responsibilities for the Ambient Air Quality Data Base Management System (AQDBMS) (Version 2.3, March 2012) EPA QA Handbook for Air Pollution Measurement Systems Vol. II, Section 14.0 A-23 Starting Threshold N/A ≤± 5º N/A N/A ≤±2º ≤± 5º ≤± 5º Manufacturer Specification N/A ≤± 5º ≤± 5º Meteorological monitoring follows PSD requirements, in accordance with EPA QA Handbook for Air Pollution Measurement Systems: Vol IV. Monitoring Plan 5-2 A-21 m/s Vector Wind Direction (VWD) 1 meter (HFFC and TBFC) or 3 meter R.M. Young 05305 1-hour 0-360° ± 3% Vane Standard Deviation of Wind Direction (SDWD) 1 meter (HFFC and TBFC) or 3 meter N/A 1-hour N/A N/A Calculated from wind direction using Yamartino method 4.2 VOC MONITORING Monitoring for Speciated Non-Methane Organic Carbon compounds (SNMOCs), a subset of volatile organic compounds (VOCs) and the additional analysis of methane (CH4) will conducted at the HFFC and TBFC sites in NE Fort Collins, and at both downtown site. A list of SNMOC compounds measured is presented in Appendix A. Five canister samples will be collected at each site on EPA’s 1/12 day sampling schedule. Canisters will be analyzed at ERG laboratories following EPA’s Compendium Methods TO-12, augmented with CH4 analysis. Specific VOC parameters analyzed will include: • BTEX compounds, which consist of benzene, toluene, ethyl-benzene and xylenes. These are parameters of interest because they are part of a subset of VOC compounds designated by the EPA as hazardous air pollutants (HAPs). • Light alkanes, including ethane, propane, iso/n-butane and iso/n-pentane, which are A-17 ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Calm (<0.5 m/s): 1.5% October 2012 - December 2012 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW A-9 SSE S SSW SW WSW W WNW NW NNW Calm (<0.2 m/s): 4.2% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Wind Speed (m/s) Figure 3-0.4. 5-2 Wind Rose 2-Plots 4 Representing 4-6 Downtown 6-8 Sites and NE 8-Sites 10 for Dates >10 Corresponding to VOC Samples (12/30/13 and 01/11/14). SSE S SSW SW WSW W WNW NW NNW Calm (<0.2 m/s): 8.3% 0% 10% 20% 30% N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW Wind Speed (m/s) 0.5-2 2-4 4-6 6-8 8-10 >10 Figure 3-3. Wind Rose Plots Representing Downtown Sites and NE Sites for Dates Corresponding to VOC Samples (11/24/13 and 12/18/13). Woodyard USA Today 2/1/2014 2 Texas Exxon Mobil's CEO has joined a lawsuit to stop construction of a water tower near his home that would be used to in the fracking process to drill for oil.The lawsuit contends the project would create "a noise nuisance and traffic hazards." x x Yes x x Flower Mound Well Site Impact Study Wright Prepared for Town of Flower Mound, TX 8/17/2010 108 Texas Consultation report about the impact of natural gas wells on improved residential properties, consistent with appraisal practices. Conclusion: residential properties valued at about $250,000 and immediately adjacen to wells sites can have a negative 3% to 14% impact on value. Valuation impact dissipates at around 1,000 feet. x yes x also reviewed incidents of drinking water well contamination believed to be associated with hydraulic fracturing and found no confirmed cases that were linked to fracturing fluid injection into coalbed methane wells or subsequent underground movement of fracturing fluids. These conclusions have since been contested and EPA is in the process of updating their study. x x Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources - Progress Report US EPA EPA 601R- 12/011 12/1/2012 278 Colorado, North Dakota, Pennsylvania, Texas "The purpose of the study is to assess the potential impacts of hydraulic fracturing on drinking water resources, if any, and to identify the driving factors that may affect the severity and frequency of such impacts" x x EPA Issues Updated, Achieveable Air Pollution Standards for Oil and Gas + US EPA US Environmental Protection Agency 4/18/2012 3 General EPA finalized standards to reduce air pollution associated with oil and natural gas production. "As wells are being prepared for production, they emit volatile organic compounds (VOCs) which contribute to smog formation an air toxics. Methane, a constituent of natural gas, is a greenhouse gas. x x Hydraulic Fracturing Research Study US EPA US EPA, Office of Research and Development 6/1/2010 2 General Summarizes what fracking is, the connection between water and fracking, and why EPA is studying fracking. x x EPA Completes Drinking Water Sampling in Dimrock PA US EPA US Environmental Protection Agency Press Release 7/25/2012 1 Pennsylvania EPA determined that there are not levels of contaminents present that would require additional action by the Agency. x The Seismic Link Between Fracking and Earthquakes Walsh Time Magazine, electronic edition 5/1/2014 3 Ohio, Oklahoma, Kansas Reports information about earthquakes and new research released by the Siesmological Society of America, showing disposal wells are changing stress on existing faults, inducing earthquakes. x A Retropersective Review of Shale Gas Development in the United States Wang, et.al. Resources For the Future 4/1/2013 42 United States Provides historical production information, and describes market considerations. He concludes: " sound environmental regulations are needed to make shale production sustainable. x Geochemical Evidence for Possible Natural Migration of Marcellus Formation brine to shallow aquifers in Pennsylania Warner et al. Proceedings of the National Academy of Sciences, vol 109, 7/24/2012 15 Pennsylvania Describes concerns about the potential for migration of stray gas, metal-rich formation brines, and hydraulic fracturing and/or flowback fluids to drinking water aquifers. The presence of these fluids suggests conductive pathways and specific geostructural and/or hydrodynamic regimes in northeastern Pennsylvania that are at increased risk for contamination of shallow drinking water resources. x x Pipelines and Property Values: An Eclectic Review of the Literature Wilde Journal of Real Estate Li Fall 2012 21 General Finds that there is no credible evidence based on actual sales data that proximity to pipelines reduces property values. x No Fracking Regulation Applied Wiseman Duke Environmental Law and Policy Forum 2012 24 General Describes state regulations and finds that states have core regulatory responsibilities and face a daunting tasks as activity, need for inspections and violations increase. Improved analysis of existing violations and envorcement is needed. x production are subject lien. x x Yes x Our Drinking Water at Risk Sumi Oil and Gas Accountability Project, a project of Earthworks 4/1/2005 76 General Reviewed the 2004 EPA study and found that there is insufficient information for EPA to conclude that hydraulic fracturing does not pose a threat to drinking water. x Boulder County Could be Liable for $1 billion in petro "takings" Svaldi The Denver Post 6/12/2014 2 Boulder County, Colorado Summarizes information released by National Association of Royalty Owners. Boulder County could owe royalty owners $1 billion or more if they ban oil and bas development. x Fracking Wastewater Disposal Linked to Remotely Triggered Quakes Than National Geographic 7/11/2013 3 Texas, Oklahoma & Colorado Impact in Chile, Japan & Indonesia References articles in Science and from researchers at Columbia University. Earthquakes in other countries linked to wastewater injection in CO, TX, and OK--- called "dynamic triggering" x An Analysis of The Economic Potential for Shale Formations in Ohio Thomas, et al. Cleveland State University; Ohio State University; Marietta College Undated, 2014? 81 Utica Shale formation in ohio Provides descriptive information about major (upstream) investments needed, including buying mineral rights, new road construction ($1.1 million per drilling location with 6 to 8 well pads), drilling costs $5 -$6 million per well) and midstream infrastructure requirements. Economic impacts from this investment was estimated using an input-output model. Finds that the development will result in increased land and property values. x x x Yes A Review of Hydro "Fracking" and its Potential Effects on Real Estate Throupe, et.al. Journal of Real Estate Literature 2013 28 Colorado and other oil and gas states Presents an overview of fracking; summarizes federal and state disclosure and management regulations; and, evaluation potential surface and subsurface effects. Based on survey results, found 5-15% discount in bid value for homes. x x x x Yes x x x x Economic Impact of the Eagle Ford Shale Tunstall, et al. UT at San Antonio - Institute for Economic Development 5/1/2012 88 14 counties in Texas Using an input-output model, economic impacts of upstream, midstream and downstream impacts from oil and gas and pipeline construction on a 20 county region were measured. Analysis measured jobs, payroll, gross regional product, local government revenues and state revenues. Some economic impact management advice is included. x x x x Energy Boom Puts Wells in America's Backyards Bryson Wall Street Journal 10/29/2013 6 Colorado, Texas WSJ obtained data from 2.3 million wells in 11 states. > 15 million Americans live within a well that has been drilled and fracked since 2000. x x x x Ozone Mitigation Efforts Continue in Sublette County, Wyoming Urbigkit Star Tribune 3/9/2011 2 Wyoming Ozone levels in county exceed national air quality standards. Wyoming Department of Environmental quality stated elevated ozone is primarily due to local emissions from oil and gas development activities. Production companies pledge to pursue more voluntary actions to reduce emissions. x "Rush to Drill for Natural Gas Creates Conflicts with Mortgages" Urbina New York Times 10/20/2011 6 New York Describes issues with technical defaults in mortgages with gas leases and related issues with Fannie Mae and Freddie Mac. x Yes says Proctor Denver Business Journal 6/12/2014 2 Boulder County, CO Summarizes study by Netherland, Sewell & Associates for the National Association of Royalty Owners. Estimates what royalty owners might be not receive due to a moritorium on new oil and gas wells in Boulder County x Andarko Petroleum invests in reducing footprint, truck traffic in northern Colorado Proctor Denver Business Journal 5/19/2014 3 Colorado Summarizes Anadarko plans to drill multiple wells on single pad, use closed loop or pitless operations, frack from a "stim center", use "field gas" for compression pumps, construct pipelines to carry water to and from well site to reduce impacts x x x x Homeowners and Gas Drilling Leases: Boon or Bust? Radow New York State Bar Assn. Journal Nov./Dec., 2011 Nov / Dec 2011 12 New York and Pennsylvania Summarizes the risks associated with mortgages on properties where fracking may occur. For example, signing a gas lease may be a violation of the terms of the mortgage and homeowners insurance generally excludes the type of damages that may occur with fracking. The use of fracking expanded when congress exempted it from environmental laws governing safe water and/or (now known as the Halliburton loophole). x x x x x x Yes x Letter Nederland, Sewell & Associates to NARO Rees, Green National Association of Royalty Owners 6/3/2014 3 Boulder County, CO Estimates what royalty (mineral rights) owners might no treceive due to a permanent moritorium on new oil and gas wells in Boulder County. x Drilling vs. the American Dream: Fracking Impacts on Property Rights and Home Values Resource Media Resource Media 3/14/2014 9 Multiple: US & Canada Broadly scoped research on types of impacts related and regulartory issues related to fracking. Reports some property devaluations. Exxon CEO and House Majority Leader filed lawsuits. x x x x x x Yes x x x Fracking the American Dream: Drilling Decreases Property Value Resource Media, EcoWatch Resource Media, EcoWatch 11/13/2013 7 Various Cites anecdotal information about reductions in property value as well as cites some specific studies. For example, it references the 2002 LaPlata County study indicating a 22% loss in value to homes near coal-bed methane development. Also talks about difficulty in obtaining mortgages for properties with split estates and mentions Senate Bill 14-009 in the Colorado Legislature that would require sellers to notify prospective homebuyers about separated mineral rights. x x x x x Yes x Fracking by the Numbers Ridlington, et al Environment America Research & Policy Center 10/1/2013 47 General Quantifes some key impacts of fracking to date, including the production of toxic wastewater, water use, chemicals use, air pollution, land damage and global warming emissions. x x x x x x x Dimock, PA Water Tests Conducted by EPA Amid Fracking Concerns Rubinkam Huffington Post 7/25/2012 2 Pennsylvania Reports that 32 of 36 Dimock households have agreed to a confidential settlement with Cabot Oil and Gas regarding contaminated well water. x x Yes x Blind Rush? Shale Gas Boom Proceeds Amid Human Health Questions. Schmidt Environmental Health Perspectives 8/1/2011 10 Texas, Pennsylvania, Colorado, General Provides extensive list of potential environmental impacts from fracking and oil & gas development and footnotes each source. x x x x Risk, Media and Stigma: Understanding Public Challenges to Modern Science and Technology Slovic Earthscan Publications 2001 395 + General This book characterizes the phenomenon of stigma associated with places, products and technologies that arise from the association with an abnormal or unnatural degree of risk. It emerged from several prior conferences. Different authors prepared each chapter. x Talks about difficulties obtaining financing and insurance on properties near drilling sites. More specifically, states that the 2005 Energy Policy Act exempted the fracking industry from violations under the Federal Safe Drinking Water Act. Notes that FHA prohibits financing homes within 300' of a property with an active or planned drilling site. Signing a gas lease or keeping hazardous material on property puts a mortgage in default. x x Yes x x Even in Wake of New Ohio Limits, Texas Regulators say Fracking Not Linked to Earthquakes Nowlin San Antonio Business Journal 4/17/2014 2 Texas Texas Railroad Commission say they have not found a link between fracing and tremblers, adding that geology differs between Ohio and Texas. x The Environmental Issues of Shale Gas Development - Current Situation and Countermeasures Ogawa The Institute of Energy Economics, Japan 11/1/2013 16 General Uses information from "major stakeholders" in shale gas development to outline the development process, describes mechanisms that induce major environmental effects and observes environmental risks inherent in shale gas development. x x x x x Methane contamination of drinking water accompanying gas- well drilling and hydraulic fracturing Osborn, et.al Proceedings of the National Academy of Scientists 4/14/2011 5 Pennsylvania & New York Documents systematic evidence for methane contamination of drinking water associated with shale-gas extraction in Pennsylvania and New York. x x Fracking Boom Gives Banks Mortgage Headaches Peters American Banker 11/12/2013 4 General Cites institutions refusing to make mortgages on land where oil or gas rights have been sold to an energy company. The mortgage agreement, used by Fannie Mae and Freddie Mac, states that "you cannot cause or permit any hazardous materials to be on your property and it specifically references oil and gas." A credit union said it would stop making mortgages on properties that have mineral rights "severed," and the union's president said that oil rigs on a piece of land would affect the values of neighboring properties.Also states that insurance companies cancel renewals when they find a [gas or oil] lease on the property. x x Yes Hydrocarbon Emissions Characterization in Colorado Front Range: A Pilot Study Petron Journal of Geophysical Research 3/1/2012 19 Colorado Reports results of daily air samples collected at the NOAA Boulder Atmospheric Observatory (BAO) in Weld County since 2007. Shows highly correlated alkane enhancements caused by a regionally distributed mix of sources in the Denver-Julesburg Basin. Petron said that "We may have been significantly underestimating methane emissions by this industry in this region." Researchers also found that emissions of benzene, a known carcinogen, are underestimated. Benzene is tracked and regulated by the Environmental Protection Agency (EPA). x x Colorado oil and gas wells emit more pollutants than expected Petron CIRES 3/1/2012 2 Colorado Gas operations in Weld County leaked about twice as much methane as previously estimates. The infrastructure was leaking other air pollutants, including benzene. x x x EPA Blames Fracking for Wyoming Groundwater Contamination Phillips State Impact Pennsylvania, A Reporting Project of NPR 12/1/2011 3 Pavillion, Wyoming Discusses contamination related to fracking particularly with respect to water pollution and methane generation. The direct link between fracking and groundwater contamination is resulting in creating new gas drilling regulations. x x costs of production, etc) lead to different possible outcomes. "The environmental impacts of shale development are challenging but manageable." x x The Housing Market Impacts of Shale Development Muehlenbachs www. voxeu.org 2/9/2014 3 Pennsylvania, New York Summarizes author's prior work (published in the National Bureau of Economic Research) with some updated resources. x x x x Yes x x The Housing Market Impacts of Shale Gas Development Muehlenbachs, et al. Resources for the Future RFF DP 13-39-REV 4/3/2014 50 Pennsylvania New York Analyzing data from Pennsylvania and New York, authors conclude that impacts from shale gas development vary with geographic scale, water source, well productivity and visibility. The authors estimate the impacts on groundwater- dependent homes to be large and negative and report evidence that major national mortgage lenders are refusing to make loans for properties proximate to shale gas wells, and insurance providers are refusing to issue policies on those houses. On the other hand, shale gas development can positively impact small towns through economic expansion. Boom-town growth may result in increased property values, and lease payments can provide a great source of income for many homeowners. The positive impacts of boom-town expansion generally are not long lived. Any long-term benefits from shale gas development are most likely to be realized nationally through increased energy security and low fuel costs. x x x x Yes x Shale Gas Development and Property Values: Differences Across Drinking Water Sources Muehlenbachs, et al. National Bureau of Economic Research 9/1/2012 38 Washington County, PA Focuses on groundwater risk associated with shale gas development. The authors found that proximity to wells increased housing values, though risk to groundwater fully offset those gains. By itself, groundwater risk reduces property values by up to 24%. Due to a dearth of lease data, the authors are unable to fully analyze the extent to which lease payments may mitigate the cost of groundwater risks. x x Yes x x RFF Research on Property Values and Truck Traffic; Impact on the Housing Market Muehlenbachs, et al. Resources for the Future Presentation 4/10/2014 22 Pennsylvania and New York Presents new work that quantifies the full housing market impacts of hydraulic fracturing. x Yes x Duke Researchers Shop Dip in Home Value Caused by Nearby Fracking Muoio Duke Chronicle 11/15/2012 3 Washington County, PA Summarizes a report authored by a Duke University professor (Christoper Timmins) and others. "Houses within the roughly one-mile radius experience an 11 percent property value boost because the fracking utility cannot drill without the jomeowners signing a lease" Homes with possibility of contaminated water forces property values to decrease by 24%. x x Yes x Fracking: A Growing Threat to Home Values National Association of Realtors Realtor Magazine April 2014 4/23/2014 1 General Discusses a webinar presented by attorneys from the law firm of Ballard Spahr stating that fracking is taking place in populated neighborhoods, and because of the unknown and potentially dangerous elements involved in fracking, is causing nearby home values to fall from 4-15%. x x x Yes x hydrofracturing for natural gas, oil, and methane on the State of Colorado and its citizens, and to discern what public policies are in place or need to be in place for this activity. x x x x x x The Effects of Mineral Interests on Land Appraisals in Shale Gas Regions Lipscomb, et.al The Appraisal Journal Fall 2012 12 North Central Texas Discusses appraisal complications when the mineral and surface estates are split. The mineral estate is dominant and trumps surface use. x No Buried Secrets: Is Natural Gas Drilling Endangering U.S. Water Supplies? Lustgarten ProPublica 11/19/2008 9 General Questions the result of an EPA study claiming that fracking posed no risk to drinking water. The EPA study formed the basis for the 2005 Federal Energy Policy Act. The author notes that more than 1000 cases of contamination have been documented by courts and state and local governments in Colorado, New Mexico, Alabama, Ohio and Pennsylvania. The EPA can't vouch for the safety of the drilling process because the chemicals in the drilling fluids are trade secrets. x Pa. Residents Sue Gas Driller for Contamination, Health Concerns Lustgarten ProPublica 11/20/2009 4 Dimock, PA 15 families filed lawsuit in federal district court against Cabot Oil and Gas to halt future drilling - drinking water contamination x Hydrofracked? One Man's Mystery Leads to a Backlash Against Natural Gas Drilling Lustgarten ProPublica 2/25/2011 25 Pavillion, Wyoming Extensive story about owners and EPA investigation regarding water contaminated potentially by by fracked wells. Mentions downward property adjustments by County Assessor x x Yes x x x Water Transporters ride the oil boom Lynn Northern Colorado Business Report 4/5/2013 3 Colorado Describes uptick in water trucking company activity in Weld County. New water tanker trucks are able to cary about 6,400 gallons of water. Some O&G producers are contructing pipelines in lieu of using trucks x x Shale Gas Impact Fees in Pennsylvania Communities McElfish Environmental Law Institute 4/10/2014 22 Pennsylvania Describes amount of impact fees and some uses of fees in Pennsylvania. x x x x Factors that Enhance the Liklihood of Fluid Injection- Induced Earthquakes Large Enough to be Felt McGarr, et al. USGS 5/1/2014 1 None referenced Felt earthquakes induced by fluid injection from wastewater disposal sometimes exceed 5.0 on the Richtor scale. The liklihood of induced earthquakes is largely independent of injection rate x x Human Health Risk Assessment of Air Emissions from Development of Unconventional Natural Gas Resources McKenzie, et.al. Science of the Total Environment www.elsevier.com/locat e/scitotenv 2/10/2012 9 Garfield County, Colorado Health risk study based on EPA guidance to estimate cancer risks for two populations: >1/2 mile from wells and =1/2 mile from wells. Authors found risk to be higher =1/2 mile from wells but recommend further study on health effects associated with air pollution. x x Pollution Fears Crush Home Prices Near Fracking Wells McMahon Forbes 4/10/2014 3 Pennsylvania New York Summarizes the January 2014 Muehlenbachs, Spiller & Timmons cited above. Shows a 22% loss in property value to houses on groundwater. The study makes no representation that wells contaminate groundwater; only measure the perception that they do. x x x Yes x Stigma Damages and Diminution of Property Claims in Environmental Class Actions McMeekin, et al Environmental Claims Journal 2012 28 General Explores environmental stigma damages and analyzes the growing use of class actions for recovery of the same. The article concludes with a discussion of specific strategies to challenge stigma damage claims in precertification discovery. x No Increased Stray Gas Abundance in a Subset of Drinking Water Wells Near Marcellus Shale Gas Extraction Jackson, et. al Proceedings of the National Academy of Sciences, Early Edition 12/17/2012 13 Pennsylvania Researchers analyzed 141 drinking water wells in northeastern Pennsylvania. Methane was detected in 82% with average concentrations 6 times higher for homes within 1 km of natural gas wells. Ethane was 23 times higher. x x When drought occurs, fracking and farming collide Jaffe The Denver Post Feruary 2014 4 Colorado Reports that in Colorado 97% of wells being drilled are in highly water-stressed areas. Operators are taking steps to conserve water. In some cases, water is being bid up to more than farmers can afford. x x Life Cycle Greehouse Gas Emissions of Marcellus Shale Gas Jiang, et al. Environmental Research Letters 6 (2011) 2011 9 Pennsylvania Estimates the life cycle of greenhouse gas emission from production of Marcellus shale natural gas and compares with the national average gas emissions prior to significant Marcellus shale development. Emissions of a shale well are above average domestic gas emissions. GHG emissions from shale gas have a lower life cycle than coal. x Case Before Ohio Court May Impact Future Coverage for Fracking Liability Jones Insurance Journal 1/27/2014 2 Ohio Discusses the Warren Drilling Co., Inc. v. ACE American Ins. Co. In 2008, where a homeowner's well had become contaminated by the hazardous fracking fluid and homeowner sued Warren Drilling, and the driller eventually settled with the homeowner.Warren Drilling then sued ACE for coverage under the insured’s energy pollution liability extension endorsement after the insurer refused to defend the case brought by the homeowner and indemnify the driller for its losses. The case is now before the court. x Keep Tap Water Safe (List of fracking bans) Keep Tap Water Safe exceroted from keeptapwatersafe.org Updated 5/21/2014 18 US and other countries Provides a list of moritoria and bans on oil and gas wells and fracking with extensive web links x x x Scientists Warn of Quake Risk From Fracking Operations Kiger National Geographic 5/2/2014 4 Mentioned: Oklahoma, Colorado, Ohio Author states that Colorado and other states have experienced earth quakes that have been linked to underground disposal of fracking wastewater. Sciemologist are warning that such quakes can be difficult to predict. x Hydraulic Fracturing 101: What Every Representative, Environmentalist, Regulator, (etc). Should know …. King Presented: SPE Hydraulic Fracturing Technology Conference 2/6/2012 80 General Provides an explanation of well development activities from construction to production with estimates of frac risk and alternatives to reduce risk. x x x x x x x x x x Greenhouse Gas Emissions Associated with Marcellus Shale Klemow The Institute for Energy and Environmental Research for Northeastern Pennsylvania 12/9/2011 6 Pennsylvania Summarizes the debate about shale gas greenhouse gas emissions (shale versus conventional gas and gas versus coal). Concludes that additional field research is needed. x x publicized event, location near a pipeline is not perceived as a significant environmental risk. Following an event, there was a significant negative effect. Distance from the pipeline and lapsed time were significant factors. x x No Effects of Natural Gas Production on Water Quality in Garfield County, Western Colorado Hill CU Honors Journal 7/3/1905 10 Garfield County, CO Describes how concerned citizens and stakeholders are speaking out about what they believe is negligence on the part of the industry in maintaining environmental quality and preventing contamination. This study hypothesizes that drilling and extraction processes may generate wastewater in concentrations that could be harmful to surface and groundwater quality. The study seeks to understand these impacts and determine if they do present a serious problem to regions experiencing natural gas activity.The study could make no real case for natural gas activity seriously impacting water quality in Garfield County. x x Fracking: The Operations and Environmental Consequences of Hydraulic Fracturing Holloway, et. al. Wiley Publishers 2013 359 + General Proposes to increae awareness of new and emerging technologies and various ramificantions. Author encourages energy companies to use this work as a means to educate the general population. Methane and the Greehouse-Gas Footprint of Natural Gas from Shale Formations Horwath, et al. Climatic Change Letters 3/13/2011 12 Texas, Louisiana, Colorado, Utah Studies the greehouse gas footprint of natural gas obtained by fracking. 3.5% to 7.9% of the methane from shale gas production escapes into the atmosphere and leeks over the lifetime of a well. These methane emissions are at least 30% more than those from conventional gas. The higher emissions occur during fracking as methane escapes from flow-back return fluids. x x Fracking up Huso Valuation Insights, Appraisal Institute 1st Qtr, 2012 5 Texas Notes that the effects of fracking are likely different depending on the depth of the wells and density of surrounding population. In rural areas of Texas, values went up as drilling commenced because of the increase in the value of mineral rights. In more dense populations, the opposite effect likely occurs. x x x Yes Evaluating Environmental Stigma with Multiple Regression Analysis Jackson The Appraisal Journal Fall 2005 7 General Describes how the use of multiple regression analysis has been likened to a form of the sales comparison approach. In a sale price regression analysis, the sale price (the dependent variable) is modeled as a function of a number of variables reflecting the property’s physical and market characteristics (independent or predictor variables). The method is widely accepted in the appraisal profession, but the model must be properly specified. x x No The Analysis of Environmental Case Studies Jackson The Appraisal Journal 1/1/2002 20 General When properly selected and analyzed, studies of similarly impacted properties (case studies) can provide useful information for analyzing environmentally impacted properties. The method is widely accepted and endorsed by the real appraisal profession. x No economic effect is of increasing values but not all proerties experience this. x x x Yes Douglas County Oil & Gas Production Transportation Impact Study Felsburg, Holt & Ullevig Prepared for Douglas County 1/24/2012 147 Douglas County, CO Describes potential impacts on roadways attributable to oil and gas development and productin x A Survey Approach for Demonstrating Stigma Effects in Property Value Litigation Flynn, et al. The Appraisal Journal Winter 2004 10 General Presents an approach for designing a survey to address stigma issues and meet the legal requirements for admitting survey data as evidence. x No Geologists: Fracking Likely Cause of Ohio Earthquakes Frazelll Time Magazine 4/12/2014 1 near Youngstown, Ohio Geologists report that tremors in Ohio's Applachian Mountains are linked to fracking, leading the state to issue strick permit conditions x Hydraulic Fracturing & Water Stress: Water Demand by the Numbers Freyman Ceres Report Feburary 2014 85 General Focuses primarily on water-related issues associated with hydraulic fracturing and unconventional shale or tight oil or gas formations. Notes that 89% of fracking water usage occurs in Garfield and Weld Counties. Each uses more than 1 billion gallons per year; total usage for Colorado is expected to be 6 billion gallons by 2015. Points out that 100% of wells in Colorado are located in high or extreme water stress areas. The effect of this water usage is driving up water prices, which in turn is likely to impact agricultural prices. x Water safe in town made famous by fracking - EPA Gardner Reuters 5/11/2012 1 Pennsylvania EPA plans to re-sample four wells where previous data showed levels of contaminants but EPA's testing found no need for action. x x Drilling and the American Dream: Your perfect home in a Colorado gas patch Greene The Colorado Independent 11/2/2013 9 Colorado Describes incident in Garfield County. Property owners alleged ground water contamination and recovered 40% of purchase price. Article mentions othere types of impacts in Colorado, including mortgage and insurance constraints. x x x x x Yes x x x State Oil and Gas Regulations Designed to Protect Water Resources Ground Water Protection Council Ground Water Protection Council 5/1/2009 65 General Identifies, quantifies and assesses the relative value of state oil and gas regulations. Does not evaluate the effectiveness of individual programs. x Long-term Effects of Income Specialization in Oil and Gas Extraction: The US West, 1980- 2011 Haggerty, et.al Headwaters Economics, Bozeman MT No Date 19 US West (CO, MT, NM, DK, Utah, WY) Evaluates the relationships between oil and natural gas specialization and socioeconomic well-being in a large sample of counties. Long-term oil and gas specialization is observed to have negative effects on change in per capita income, crime rate, and education rate. Participation in the early 1980s boom was positively associated with change in per capita income; however, the positive effect decreased the longer counties remain specialized in oil and gas. Findings contribute to a broader public dialogue about the consequences of resource specialization involving oil and natural gas and question the assumption that long-term oil and gas development confers economic advantages upon host communities. x x No Hydraulic Fracturing Litigation Is On The Rise Hagstrom Sedgwick Law, Hydraulic Fracturing Digest 9/1/2011 6 Pennsylvania, New York, Texas, North Dakota and Arkansas Article points out that litigation related to fracking is on the rise, particularly class action law suits. Legal theories include nuisance, trespass, breach of contract and in some cases even criminal liability. x x x Yes x x stormwater management. x x x x x "Responding to Landowner Complaints of Water Contamination from Oil and Gas Practices: Best Practices" Cranch, et. al Harvard Law School, Environmental Law Program 5/1/2014 59 CO, IL, NC, PA, NY, Ohio, WVA, WY Provides recommendations to implement policies to respond to landowner conplaints that shale oil or gas extraction contaminated private water supplies. x x How do Pipeline Spills Impact Property Values CRED Conversations for Responsible Economic Development (CRED) 9 Maryland, Texas, Ohio, Mexico, Washington, Canada, Michigan Investigates eight spills. In three cases, spills directly impacted properties; in two cases, the proximity and perceived impact devalued properties; in three cases, residents claimed losses but there is no independent confirmation. x x No Texas Jury Awards Nearly $3 million to Family Alleging Health Problems from Natural Gas Wells D'Angelo Fracking Insider.com 5/1/2014 1 Texas Describes decision where jury awarded $2.9 million to family for physical and mental pain and anguish,and loss of market value. Plaintiff alleged exposure to hazadous gases, chemicals and industrial wastes, foul odors and loud noise. Defendant (Aruba Petroleum) plans to challenge ruling. x x x x Yes Mortgages and Hydraulic Fracturing Derrick US Finance Post April 2014 4/3/2014 1 No. Carolina Pennsylvania Discusses how the mortgage industry has tightened its lending policies, consequently prohibiting properties with a well on them or properties that are the subject of leasing for the exploitation of unconventional fuels from receiving mortgages.Credit unions in North Carolina have decided not to approve mortgages on properties whose drilling rights are sold to third parties, as one CEO stated that their properties have been devalued. Quicken Loans, as well as other financial institutions in Pennsylvania, denied a loan secured by a mortgage on a person’s farm because there was a drill sites across the street, and according to a financial statement, “gas wells and any other structures in the surrounding lots… could significantly degrade the value of a property.” x x Yes The Truth, the Partial Truth or Anything but the Truth: Survey Reliability and Property Valuation Matthews, et.al. Paper prepared for Symposium on Environmental and Property Damages, Toronto April 4-6, 2002 38 General Provides reliability standards for Contingent Valuation surveys. x No Guide to Dimrock's Water Problems Detrow StateImpact - Pennsylvania; a NPR member station report 10/20/2011 2 Dimrock, PA Summarizesof prior events regarding property owners complaints about fracking. x Yes x EPA Takes First Step Toward Regulating Fracking Chemicals Drajem Bloomberg May 2014 5/9/2014 3 General Discusses how the EPA is considering tighter regulations of hydraulic fracturing and seeking public input on whether companies should be required to disclose the contents of fluids used in the oil and natural gas drilling technique. x x 5/1/2011 35 Colorado Defines fracking, summarizes regulations, provides information about inspections and complaints x x Water Sources and Demand for Hydraulic Fracuring of Oil and Gas Wells in Colorado from 2010 through 2014 CO Water Conservation Board and CO Oil and Gas Conservation Commission Prepared by the CO Division of Natural Resources unknown 5 Colorado Provides estimates of amount of acre feet needed per well start (5 AF, equivalent to 1,630,000 gallons of water. Discusses potential sources of water and related legal issues. x x Fracking Can Hurt Property Values of Nearby Homes With Wells, Study Suggests Cockerham mcclatchydc.com 11/1/2012 3 Washington County, PA Summarizes the September 2012 Muehlenbachs, et al. study cited above. x x Yes x x COGA - Hydraulic Fracturing Whitepaper Colorado Oil and Gas Association Colorado Oil and Gas Association 11/26/2012 4 Colorado Trade association description of fracking and summary of selected impact work. x Natural Gas Operations from a Public Health Perspective Colborn Human and Ecological Risk Assessment, 17: No 5, 1039-1056 9/4/2011 19 General Presents a list of 944 products containing 632 chemicals used during natural gas operations. The potential health effects of the 353 chemicals identified was researched. The results indicate that many chemicals used during the fracturing an drilling stages of gas opeations may have long-term health effects that are not immediately expressed. x x What is Fracking? Coloradans for Responsible Energy Coloradans for Responsible Energy Study Fracking General Discusses the process of hydraulic fracturing from start to finish. x x x x The Basics: Colorado Water Supply and Hydraulic Fracturing Colorado Oil and Gas Association Colorado Oil and Gas Association undated 2 Colorado Defines fracking action and the amount of water used, and provides a glossary of terms. x COGA - Hydraulic Fracturing Whitepaper Colorado Oil and Gas Association Colorado Oil and Gas Association 11/26/2012 4 Colorado Describes the fracking process, identifies studies that show frackign is safe, lists some concerns and explains why they are not problems. x "Background Report" Colorado Oil and Gas Conservation Commission Colorado Oil and Gas Conservation Commission 10/29/2010 4 Colorado Responds to the documentary,Gasland. Colorado wells in question contain only biogenic methane. Staff research question whether examples used in the documentary were accurately protrayed. x x x U.S. Drilling And Fracking Boom Leaves Some Homeowners In A Big Hole Conlin Reuters 12/12/2013 4 General Cites anecdotal stories about loss in value near drill sites, as well as references the Throupe and Spiller studies cited above. Author interpreted Spiller's 2014 study as concluding that homes within .6 miles of a well lost 16.7% in value. x x x x Yes x x x x Special Report: US Builders hoard mineral rights under new homes Conlin, et.al. Reuters 10/9/2013 9 Florida, Colorado and other states Homebuilders in Colorado, Florida and elsewhere are retaining mineral rights before selling homes. Some lenders deny mortgages to homes encumbered with leases. Insurance policies exclude coverage where mineral rights are severed. x x x Yes How Oil and Gas Disposal Wells Can Cause Earthquakes Connelly StateImpact Texas not provided 5 Texas Reports that the disposal of drilling wastewater used in fracking is scientifically linked to earthquakes (UT at Austin and SMU studies and USGS Earthquake Science Center) x Supplies Boyer, et al Pennsylania State University 10/1/2011 29 Pennsylvania Summarizes study of water quality in 233 private water wells in rural Pennsylvania before and after drilling shale gas wells. 40% of the wells failed at least 1 water quality standard before drilling occurred. Analysis did not find major influence from gas well drilling or hydrofracking. . x There's Now A Run On Quake Insurance In Fracking-Heavy Oklahoma Brandes Business Insider 5/1/2014 3 Oklahoma Discusses how the rate of earthquakes in Oklahoma has increased by about 50 percent since October 2013. Geologists say that fracking could be one of the causes. The USGS said that the water injection used in fracking can increase underground pressures, lubricate faults and cause earthquakes. x Quake Warning adds new worries to tornado-prone Oklahoma Brandes Reuters 5/8/2014 2 Oklahoma Reports that 183 earthquakes of 3.0 or greater have occurred since October 2013. Oklahoma Insurance Commission spokesperson said only 12% to 18% of homeowners have insurance that covers earthquakes x Support to the Identification of Potential Risks for the Enviornment and Human Health Arising from Hydrocarbons Operations Involving Hydraulic Fracturing in Europe. Broomfield European Commission - DG Denvionment, AEA/R/ED57281 Issue No 17x. 10/8/2012 297 Europe Sets out key environmental and health risk issues associated with the potential development and growth of high volume fracking in Europe and addresses impacts and risks over and above convention gas exploration.. x x x x x x x Yes x x x LaPlata County Impact Report - FINAL Brown, Bortz, Coddington LaPlata County 10/1/2002 99 Colorado Identifies potential impacts to and mitigation measures in La Plata County from the development of coall bed methane. "Based on the average property profile for the 544 transactions with potential effects of well proximity, the total impact in the year 2000 was estimated to be an average reduction in sales value of $1,200, a decrease of 0.7 percent." x x x x No x x Colorado Officials Question Link of Fracking Water disposal to Quakes Finley The Denver Post 12/4/2012 3 Colorado, New Mexico Article features remarks by Justin Rubinstein, USGS scientist, regarding the relationship between burial of drilling waste and earthquakes. New Mexico and Colorado incidents are cited. x Life-cycle greenhouse gas emissions of shale gas, natural gas, coal and petroleum Burnham, et al. Environmental Science Technology 1/17/2012 16 General Estimate the life-cycle greenhouse gas emissions. Analysis shows shale gas life-cycle emissions are 6% lower than convention gas. Due to the range in values, so there is statistical uncertainty whether shale gas emissions are lower than conventional gas. x x Assessing the Greenhouse Impact of Natural Gas Cathles Submitted to G3 1/7/2011 18 Texas, Louisiana, Colorado, Utah Rebuts the Horwath study. States that if the leakage rate of natural gas is 1% or less, then the substitution of natural gas reduces global warming by 40% of that which could be attained by the immediate transition to low carbon energy sources. x A Commentary on "The Greenhouse-Gas footprint of Natural Gas in Shale Formations" Cathles et al. Climate Change 1/2/2012 11 Texas, Louisiana, Colorado, Utah Rebuts Horwath study. States that the Horwath analysis is flawed; it overestimated the fugitive emissions associated with unconventional gas extraction and undervalued the contribution of "green technologies." x Barton Texas Department of Transportation 3/11/2013 Texas Provides data on number of trucks related to gas drilling and maintenance in Texas. 1,184 trucks to bring into production + 353 per year to maintain + 997 trucks every five years to refrac. x A Colossal Fracking Mess Bateman Vanity Fair 6/21/2010 9 Primarily Dimrock PA Presents an in- depth story of ground water contamination attributable to fracking x x x x How Fracking Decreases Property Value Beans Earthworks 7/1/2013 2 Pennsylvania Texas References Duke University Study that found the most significant factor in the impact of oil and gas development near residential property is whether water is piped in or sourced on-site from a well. The study (in Washington County, PA) found that property with on-site wells lost 13% of their value. Author mentions another study by Integra Realty Resources in Flower Mound, Texas that concluded properties with house less than 750' away from the drill site experienced an average sales price of 2-7%. x x x Yes Fracking our Future Belanger Western Resource Advocates 6/1/2012 28 Colorado This report describes oil and gas industry water needs, potential impacts and tradeoffs. Volume of water needed each year is equivalent to a sizeable water infrastructure project. Water is 100% consumptive. Recommendations are provided. x x x x Real Estate Damages: Applied Economic and Detrimental Conditions,2nd Edition Bell Appraisal Institute 2008 424 United States This book provides appraisers with a straightforward set of analytical tools to address complex valuation situations when properties are subject to detrimental conditions. x The Impact of Hydraulic Fracturing on Housing Values in Weld County, Colorado: A Hedonic Analysis Bennett CSU: Dept. of Agriculture and Resource Economics - for the Degree of Master of Science, Summer 2013 90 Weld County, CO This is a hedonic property study (based on a sample of 4,035 housing transactions between 2009 and 2012 in Weld County, CO) prepared at CSU to determine if fracking negatively affects property values. The results of the study show a low level of impact on housing values due to fracking related activities. The study found that rural property owners are affected by distance to drill sites but urban property are impacted by the volume of drill sites near the home. This suggests some policy regulation: the number of drill sites within a certain distance from another drill site may need to be regulated and minimum distances from residential properties may need to be set and/or increased in rural areas. The author suggests that any impacts from fracking are likely offset by economic gains from the industry. x x x x x x Yes x x A Plaintiff's Primer on Litigating Natural Gas Cases Bern, et.al. Westlaw Journal Enviornmental 6/8/2011 4 General Authors provide practical advice to lawyers retained by clients who want to file a complaint. x Yes Golden Rules for a Golden Age of Gas - World Energy Outlook - Special Report on Unconventional Gas Birol International Energy Agency 7/4/1905 150 General Proposes "golden rules" the for energy industry to address enviromental impacts such as fluid spills, greenhouse-gas emissions, groundwater contamination, air pollution, vehicle and equipment impacts, well abandonment, etc. x Prepared for US Department of Energy 4/1/2009 116 United States Provides technical information on and additional insight into the relationship between natural gas development, environmental protection, especially water resource management. x x Measurements of Methane Emissions at natural gas production sites in the US Allen Proceedings of the National Academy of Sciences 10/29/2013 84 United States This work reports direct measurements of methane emissions at 190 onshore natural gas sites in the US during the extraction phase of the supply chain. Total emissions are similar to recent EPA findings. However, emissions from certain sources, such as valves and compressors, were higher than the EPA figures.. x Shale Energy: 10 Points Everyone Should Know American Petroleum Institute American Petroleum Institute 10/1/2013 4 General Summarizes information about fracking, economic impacts, regulatory environment, safeguards and statements of no impact. x x x x x x x Facts about Shale Gas American Petroleum Institue American Petroleum Institue accessed 6/17/2014 2 General Provides brief summary about supply of unconventional natural gas resources. x Hydraulic Fracturing - Unlocking America's Natural Gas Resources American Petroleum Institue American Petroleum Institue 4/1/2014 21 General Describes fracking, importance of shale plays, state and federal regulations, water protection and usage, air emissions and environmental friendly practices. x x x x x x x Uniform Standards of Professional Appraisal Practice - 2014-2015 Edition - Advisory Opinioon 9 Appraisal Standards Board The Appraisal Foundation 7/6/1905 6 General Provides advice when appraising properties that may be impacted by environmental contamination x No Drilling Casts Shadow on Home Mortgages Armbrister Northern Colorado Business Report 3/7/2014 3 Colorado Author points out that it is becoming more and more difficult to obtain financing and insurance on properties being eyed for oil and gas development. Loans to be sold in the secondary market are particularly suseptible. The factors that can cause a loan on properties with a gas lease to be denied are: The agreement adversely impacts the use of the surface of the property, including dwellings; The property does not qualify for hazard insurance; The insurance premiums cause the monthly payment to exceed an acceptable debt- to-income ratio; Investor guidelines prohibit mineral leases. x Lessons Learned from the North Texas Barnette Shale: In Regards to the Pennsylvania Marcellus Shale, the Jewel of the Northeastern US Baen University of North Texas, College of Business, Dept. of Finance, Insurance, Real Estate and Law November 18, 19, 2008 68 Texas Considers the environmental costs/ benefits and lessons learned while limiting or reducing the environmental impact and loss in value of the suface estate. x x x x The Impact of Mineral Rights and Oil and Gas Activities on Agricultural Land Values Baen The Appraisal Journal 1/1/1996 9 General Describes potential impacts of oil and gas activity on agricultural lands, including reduced income, reduction in highest and best use, environmental contamination, stigma and other factors. x x x No x Fayettevile shale play and the need to rethink environmental regulation Bailey Arkansas Law Review 2010 34 Arkansas Discusses the use and regulation of hydraulic fracturing - focusing primarily on Arkansas. x x x Public Policy General Impacts Health, Safety & Welfare Impacts Regulations 44 Ingestion Dermal Inhalation Requires Contact with Surface Water Hydrocarbon Mediated Generation Ozone Inhalation All receptors Surface Water Shallow Groundwater SCALE/ SLUDGE NORMs NEARBY OPERATIONS Dust, vapors, ozone, diesel particulates, PM10, PM2.5 , etc., 27