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.
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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
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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
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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
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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
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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
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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.”
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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.
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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.
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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).
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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?
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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
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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.
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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).
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TERRA MENTIS
FIGURE 2-3
MODEL OF POTENTIAL EXPOSURES FROM OIL AND GAS EXTRACTION
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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
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TERRA MENTIS
FIGURE 2-5
GENERIC CONCEPTUAL SITE MODEL FOR OIL EXTRACTION
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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,
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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
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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.
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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.
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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.
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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.
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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
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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).
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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
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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.
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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
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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
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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).
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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.
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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
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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
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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.
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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.
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• 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.
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• 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.
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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
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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.
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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?
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APPENDICES
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APPENDIX A:
FORT COLLINS OIL AND NORTHERN COLORADO GEOLOGIC
FORMATIONS
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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
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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
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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
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x x x x Yes x
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Alcock Unknown unknown 6 New
Foundland
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x x x x x Yes x x
Modern Shale Gas Development
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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
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TITLE AUTHOR PUBLICATION Date
Page
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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
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Truck Impacts
Visual Disurbance
Water Quality
Other
Federal
State
Local
Public
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TITLE AUTHOR PUBLICATION Date
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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
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Colorado Oil and Gas
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TITLE AUTHOR PUBLICATION Date
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AREA
STUDIED ABSTRACT
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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
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Property Values with
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Truck Impacts
Visual Disurbance
Water Quality
Other
Federal
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Local
Public
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Greenhouse Gas
Water Quantity
Air Emissions
Chemical Exposure
Crop & Livestock
Contamination
Geologic / Earth-
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Land Use
Light or Noise
Pollution
Mineral & Surface
Rights & Royalties
Mortgage &
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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%)
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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
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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.
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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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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.
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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