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 Park, North Carolina 27711

moore.bruce@epa.gov

October 15, 2010

Dear Mr. Moore:

We appreciate the EPA’s interest in establishing a dialog among government, the affected 

industry, and other interested members of the 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 River 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 5,100 natural gas wells) and Jonah Natural Gas Field (permitted for over 

3,500 natural 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: the Normally Pressured Lance

Project (3,500 wells); Rands Butte Project (3 helium, methane, and H2S wells plus CO2 

injection); LaBarge infill project (838 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 impacted 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 Air Pollutants

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. The 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 the 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 places where people congregate. This is also 

true of the monitoring sites in Marbleton, Big Piney, La Barge, and Boulder.

The final quarterly report for the Sublette County Air Toxics Inhalation Project was filed 

at the Wyoming DEQ AQD website on May 28, 2010 here: http://deq.state.wy.us/aqd/Ozone/5-

2810%20%20Sublette%20County%20Air%20Toxics%201st%20Quarter%202010%20Report.pd

f. 

Data 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 (127-18-4); Toluene (108-88-3); and Vinyl Chloride 

(75-01-4).

While 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 Hazardous 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 ozone levels in the Upper Green River 

Basin exceeded the EPA 8-hour standard 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. Lightlypopulated Sublette County, Wyoming has ~9,000 full-time residents. In 2008, on five occasions
EPA-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, the 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 distribution via: compressor stations, production sites, engines, heaters, tanks, 

dehydration units, pneumatic pumps, fugitives, drill rigs, completions, venting/blowdowns, truck 

loading, other sources, and on-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 appears that human 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 clinic visits and breathing problems when ozone levels are high. Unfortunately, the 

clinic keeps no cumulative, epidemiological data to our knowledge.

We also note 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-breath). 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 Sublette County gas production has increased, so too have levels of volatile organic 

compounds from most sources, including VOCs from pneumatic pumps, fugitive emissions, 

compressor station emissions, and drilling emissions. (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 pollutants to 

protect human health. We appreciate this opportunity to provide comments and look forward to 

continued dialogue with you and your colleagues at the EPA. 

Sincerely Yours,

/s/

Linda F. Baker

Executive Director
EPA-HQ-OAR-2010-0505 | 4

Attachment 1

(newer information may be available)

0

1000

2000

3000

4000

Total Sublette County Wells

Total Wells

0

200

400

600

Sublette County Wells 

Drilled

Wells Drilled 0

500000000

1E+09

1.5E+09

Sublette County Gas 

Production

Mcf Gas 0

5000000

10000000

Barrels

Sublette County Condensate 

Production

Condensate
EPA-HQ-OAR-2010-0505 | 5

0

2000

4000

6000

Tons

Sublette County Pneumatic 

Pump VOC Emissions

Pneumatic Pumps 0

1000

2000

3000

Tons

Sublette County Fugitive VOC 

Emissions

Fugitives 0

500

1000

1500

Tons

Sublette County Compressor 

Station VOC Emissions

Compressor Stations 0

200

400

Tons

Sublette County Drilling VOC 

Emissions

Drilling