EPA - HQ - OAR - 2010 - 0505 | 1 P.O. Box 994 Pinedale, Wyoming 82941 307 - 367 - 3670 ~*~ www. uppergreen.org

Docket ID Number EPA - HQ - OAR - 2010 - 0505 Mr. Bruce Moore Office of Air Quality Planning and Standards Environmental Protection Agency 109 T.W. Alexander Dr. Research Triangle Par k, North Carolina 27711 moore.bruce@epa.gov October 15 , 2010 Dear Mr. Moore : W e appreciate the EPA ’s interest in establishing a dialog among government, the affected industry, and other interested members of th e public. With this letter, we provide additional information for your consideration, subsequent to the public meeting held by EPA in Denver, Colorado on August 3, 2010, and the EPA site visit to the Pinedale Anticline Natural Gas Field outside our town of Pinedale, Wyoming. Per your email, we provide this information in the hope that it may be useful to EPA in its review of new source performance standards (NSPS), and national emission standards for hazardous air pollutants (NESHAP). The Upper Green Riv er Alliance is based in Pinedale, Wyoming . Our organization’s staff, board and supporters live and work adjacent to and downwind of the Pinedale Anticline (permitted for over 5,1 00 natural gas wells) and Jonah Natural Gas Field (permitted for over 3,500 n atural gas wells ) : two of the most productive gas fields in the nation. In addition to other natural gas fields operating in Sublette County, including Moxa Arch and Big Piney/LaBarge, four new natural gas projects are proposed in our valley’s airshed : t he Normally Pressured Lance Project (3,500 wells); Rands Butte Project (3 helium, methane, and H2S wells plus CO2 injection); LaBarge infill project (8 38 wells) and Plains Exploration & Production project (136 wells). Altogether, approval of these projects will almost double the number of gas wells and infrastructure contributing to existing ozone, HAP and VOC levels in the valley. Our air quality and quality of life have been and continue to be negatively impact ed by the oil and natural gas production in these fields, as well as by natural gas processing; natural gas transmission; and natural gas distribution. These impacts are detailed below.EPA - HQ - OAR - 2010 - 0505 | 2 Hazardous A ir P ollutants Regarding the national emission standards for hazardous air pollutants from oil and natural gas production facilities, we believe that stronger EPA standards would help regulate what has become an alarming trend in Pinedale’s previously pristine air quality. The Sublette County Air Toxics Inhalation Project was initiated in 2008. T he intent of the sampling program is to collect samples sufficient to describe the exposure of the general population of Sublette County to Hazardous Air Pollutants (HAPs), formaldehyde, and ozone, requiring sampling in towns and other populated areas of t he county. A total of fifteen (15) HAPs and formaldehyde sampling sites are in place, nine (9) within urban areas in the county and six (6) boundary locations. To see a map of the sampling sites go to : http://deq.state.wy.us/out/downloads/Sublette%20Co%20MAP%20 - %20JAN09.pdf . The Pinedale Air Toxics monitoring site is situated close to (within one mile of) schools, daycare centers, churches, businesses, and other plac es where people congregate. This is also true of the monitoring sites in Marbleton, Big Piney, La Barge, and Boulder. The final quarter ly report for the Sublette County Air Toxics Inhalation Project was filed at the Wyoming DEQ AQD website on May 28, 20 10 here: http://deq.state.wy.us/aqd/Ozone/5 - 2810%20%20Sublette%20County%20Air%20Toxics%201st%20Quarter%202010%20Report.pd f . D ata on page 119 indicate that the following HAPs (with CAS numbers) are present at the Pinedale monitoring site : 1,1,2 - Trichloroethane ; 1,1 - Dichloroethane (75 - 34 - 3) ; 1,2,4 - Trimethylbenzene (95 - 63 - 6) ; 1,2 - Dichloroethane (107 - 06 - 2) ; 1, 3,5 - Trimethylbenzene (108 - 67 - 8); 2,2,4 - Trimethylpentane (540 - 84 - 1) ; 2 - Butanone (Methyl Ethyl Ketone) (78 - 93 - 3) ; 2 - Propanol (67 - 63 - 0) ; 4 - Ethyltoluene (622 - 96 - 8); 4 - Methyl - 2 - pentanone (108 - 10 - 1) ; Acetone (67 - 64 - 1) ; Benzene (71 - 43 - 2) ; Chloroethane (75 - 00 - 3) ; Chloromethane (74 - 87 - 3) ; Cyclohexane (110 - 82 - 7); Ethanol (64 - 17 - 5) ; Ethyl Benzene (100 - 41 - 4) ; Freon 11 (75 - 69 - 4) ; Freon 12 (75 - 71 - 8) ; Heptane (142 - 82 - 5) ; Hexane (110 - 54 - 3) ; m,p - Xylene (108 - 38 - 3/106 - 42 - 3) ; Methylene Chloride (75 - 09 - 2) ; o - Xylene (95 - 47 - 6) ; Tetrachloroethene (12 7 - 18 - 4) ; Toluene (108 - 88 - 3) ; and Vinyl Chloride (75 - 01 - 4). W hile the final report was due in August 2010, neither the Wyo. Dept. of Environmental Quality , Wyo. Dept. of Health, nor Sublette County have provided the public with a final report on Hazardou s Air Pollutants to which residents are continually exposed during natural gas production ongoing in our area . Ozone Non - attainment During the years 2005 - 2008, unusual wintertime o zone levels in the Upper Green River Basin exceeded the EPA 8 - hour standa rd of .075 ppm, prompting Governor Freudenthal to submit a recommendation to EPA for ozone non - attainment designation . During the winter of 2008, ozone levels were as high as 122 ppb : higher than in Denver or Los Angeles. Lightly populated Sublette Count y, Wyoming has ~ 9,000 full - time residents . In 2008, on five occasionsEPA - HQ - OAR - 2010 - 0505 | 3

we received the state’s very first “ozone advisories” from the Dept. of Environmental Quality, cautioning residents to avoid prolonged, outdoor activities, especially resident youth, th e elderly, and those with existing respiratory conditions. According to Wyo. DEQ, high ozone levels in the Upper Green River Basin occur as a result of unique weather conditions, combined with emissions from natural gas processing , transmission , and d istribution via: c ompressor s tations , production s ites , e ngines, heaters, tanks, dehydration units, pneumatic pumps, fugitives, drill rigs, completions, venting/blowdowns, truck loading , other s ources , and o n - road / non - road mobile sources . (See slide 26 here: http://deq.state.wy.us/aqd/Ozone/Pinedale%20Public%20Meeting%20on%20January%2021%20 2010%20EI%20v4.pdf

) In our community, it appear s that h uman health can be severely compromised when ozone levels exceed .060 ppm. Ozone can trigger asthma attacks, reduce lung function, and even cause premature death. At our small health clinic (we have no hospital), a registered nurse who wishes to remain anonymous has reported that she notices and records in patient records increases in clin ic visits and breathing problems when ozone levels are high. Unfortunately, the clinic keeps no cumulative, epidemiological data to our knowledge. We also not e the anecdotal story of a previously healthy, long - time resident, John Mionczynski that appeared in a recent edition of High Country News: “Out of breath” ( http://www.hcn.org/blogs/goat/out - of - bre ath ). John has recently developed emphysema and asthma, and must leave his home downwind of natural gas field emissions whenever ozone levels exceed .060 ppm. Where does one go when the air is too toxic to breathe? Volatile Organic Compounds As Subl ette County gas production has increased, so too have levels of volatile organic compounds from most sources, including VOCs from p neumatic p ump s, f ugitive e missions , c ompressor s tation e missions , and d rilling e missions . ( See Attachment 1) We hope this information, with specific examples of emissions and demographic data, and our personal experience with exposure to emissions from natural gas development , will assist the EPA in establishing stronger national emission standards for hazardous air pollutant s to protect human health. We appreciate this opportunity to provide comments and look forward to continued dialogue with you and you r colleagues at the EPA. Sincerely Yours, /s/ Linda F. Baker Executive DirectorEPA - HQ - OAR - 2010 - 0505 | 4 Attachment 1 (newer information may be available)EPA - HQ - OAR - 2010 - 0505 | 5