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Protect Our Air, Homes, Farms: letter to EPA re fracking air pollution cites 22 toxic chemicals in 9 air samples

October 31, 2011

Protecting Our Waters is one of many organizational signatories to the clear, well-crafted letter below, backed up by solid research, which urges that all new fracking operations be situated at least 1/4 mile away from homes, farms, schools, playgrounds and businesses.  “Operations” means drilling, fracking, refining/compressing, and disposal.  Thanks to Global Community Monitor for initiating this letter.

While the 1/4 mile recommendation is conservative and does not go far enough (we know of families half a mile away from fracking operations who’ve gotten sick and are forced to live with contaminated water, risk of explosion, and sickening air), it would still be a great leap forward for public health and the environment if these recommendations were all passed.  Read on, after this note:

Happy Halloween — don’t let democracy turn into a ghost!  Please let your (federal) Senator and Representative know you support all the recommendations in this letter.  Write each one an individualized email this week — & ask them to demand a “no” vote from the federal Commissioner on the Delaware River Basin Commission (the Army Corps of Engineers) November 21st, while you’re at it! 

Re: Docket ID Number EPA–HQ– OAR–2010–0505 – Comments

Dear US EPA,

Please find enclosed comments supporting a strengthened set of regulations to control and prevent air pollution from natural gas development projects, including “fracking”.

Over the past decade, oil and natural gas exploration and production have grown at an unprecedented rate in the United States. Since necessary environmental and health regulations are not in place for this industry, residents living near oil and natural gas sites may be exposed to highly toxic chemicals on a regular basis, with their health at risk.

During 2010-11, Global Community Monitor (GCM), responding to citizen odor and health complaints, launched a community-based pilot environmental monitoring program in northwest New Mexico, southwest Colorado and western Colorado to document and measure air pollution from natural gas facilities. Through the course of this pilot study, residents, armed with their own air monitors, documented a potent mix of chemicals in nine air samples from different locations.

The sites in this program are all natural gas production and processing sites, although production of oil presents similar risks.  Air sampling for this project targeted many aspects of natural gas development.

Through the course of this study, several serious issues emerged:

Citizen samples exposed alarming levels of toxins in the air.

A total of 22 toxic chemicals were detected in the nine air samples, including four known carcinogens, toxins known to damage the nervous system, and respiratory irritants. The levels detected were in many cases significantly higher than what is considered safe by state and federal agencies. The levels of chemicals, including benzene and acrylonitrile, ranged from three to 3,000 times higher than levels established to estimate increased risk of serious health effects and cancer based on long-term exposure.

These air samples confirm the observations, experiences and first-hand complaints of residents.

Odors and health effects that have been reported for years were consistent with exposure to the chemicals found in the samples. These results underscore the need of regulatory agencies to take such complaints seriously, given the close proximity between the industry and its residential neighbors.

At least two cancer-causing chemicals, acrylonitrile and methylene chloride, were detected at high levels near natural gas operations. Neither chemical is associated with natural gas or oil deposits, but both seem to be associated with the use of hydraulic fracturing (fracking) products.

Resins acrylonitrile, 1, 3 butadiene and styrene (ABS) are suspected to be present in fracking additives.

Air emissions from natural gas production are largely unregulated and unmonitored,

despite being a significant source of air pollution. State and Federal air monitoring devices are located several miles from production sites, and test for criteria air pollutants rather than specific volatile organic compounds associated with natural gas exploration and production.

Oil and gas exploration and production operations are exempt from two key provisions of the Clean Air Act’s National Emissions Standards for Hazardous Air Pollutants, designed to protect public health. Because of these exemptions, the industry avoids complying with standards that are applied to other industries.

Based on the data gathered in this pilot study, highly toxic chemicals are permeating the air near homes, farms, schools, playgrounds, and town centers. Due to the lack of regulation and standards, key information about chemicals being used in the production process, including hydraulic fracturing is widely unavailable. Combined with the lack of appropriate air monitoring near production sites, citizen right-to-know is virtually non-existent.

Without registration of the chemicals by industry, neighbors of gas wells have no way of knowing what chemicals are stored on site, used during the industrial processes, vented to the air, water or land, or disposed nearby.

Recommendations

1. Given the proximity of residential and public property, any new sites –whether drilling, fracking, refining, or disposal – should be located at least one-quarter mile from homes, farms, schools, playgrounds, and businesses. This space would provide a buffer zone for industry to continue its operations while reducing community exposure to chemical contaminants.

2. The U.S. Environmental Protection Agency (EPA) should update air quality standards for oil and gas development, including the New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants, based on the principles of comprehensiveness, effectiveness, full health protection, forward looking, and enforceability.

3. Until strong new rules are in place, the oil and natural gas industry can and should voluntarily invest in equipment that reduces pollution escaping to the air. Such equipment is readily available and financially profitable for companies. These investments would increase efficiency and production and reduce cancer-causing chemicals from being emitted into the air in communities near production facilities – saving lives and protecting the health of neighboring families.

4. Current natural gas production and processing sites should have air monitors near all operations and equipment. All data should be made available to the public.

5. EPA and state agencies must enforce the current laws on the books vigorously and impose the maximum penalties available to create a culture that prioritizes public health.

Regulators should be accessible and fully funded to ensure their ability to protect public health and the environment.

As the natural gas industry continues to grow, so will the number of families neighboring and affected by the emissions. Industry and government leaders have a unique opportunity to address public health and environmental issues by implementing all of these recommendations. For coexistence between communities and industry to be possible, chemical exposure has to be immediately addressed.

A full copy of the report, GASSED!, is enclosed to be included as a comment as well.

Sincerely,

(Co-Signers) and

Denny Larson

Executive Director
Global Community Monitor: 10 Years and Still Fighting Dirty!
2001-2011 – Celebrate with us this November!

www.gcmonitor.org

PO BOX 1784, El Cerrito, CA 94530
+1-510-233-1870
denny@gcmonitor.org


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