Comment on:EPA’s Review of Air RegulationsAffecting the Oil and Natural Gas IndustryIntroductionsQEPAEnvironmental Health Consulting FirmFocus is Risk CommunicationKey PersonnelDollis Wright (CDC, ATSDR, NIOSH, State)TonyHavics( AIHA, WEEL, ASTM, E50)PurposeAnswer the question“Are oil and gas exploration and productionactivities impacting human health?”ApproachFill the data gaps:Are there confirmed exposuresIs there a potential for exposurePathway Analysis Risk AssessmentActual ExposuresProjected ExposuresPathway AnalysisReviewed TEDEX ReportAttended stakeholder meetingsLiterature review of ATSDR DocumentsLiterature review of Occupational ExposuresReviewed Garfield County Air Quality StudyReviewed CDPHE Screening Risk AssessmentReviewed CDPHE Health AssessmentReviewed Complaint Log (Garfield Co, COGCC, Industry)Requested Data from COGAWater well dataAssisted in design of COGA pit solids and fluids studyAssisted in design of Air sampling studyLiterature Review ATSDRSummary29 sites reviewed1 urgent public health hazard2 air concernsQEPA general conclusionsCompleted pathways essential tooperations posing a health hazardMany written in response to citizenconcerns about Oil & Gas activities.None confirmed their concernsLiterature Review of OccupationalStudiesSummaryNIOSH Health Hazard EvaluationsSociety for Petroleum Engineers E-LibraryNIOSH Oil & Gas program officeQEPA general conclusionNo specific chronic illnessassociated with oil & gasactivities other than silicosisAPI 27 year study, 19,000past and current employeesno evidence of increased cancer incidenceAdditional studies are neededCommentLong term occupational studiesVarious routes of exposureNo indication of chronic diseasePublic Health AssessmentsVarious health concernsNo correlation of illness or disease and site chemicalsCommunity Health Risk AnalysisRisk are posed under certain conditions–No Health crisis–results can help plan for the futureCOGA Risk AssessmentPit Solids, Fluids and Air in Colorado Energy BasinsRigorous QA/QC requirements50 Active drilling andfracingsitesNELAC certified laboratory>99% data usabilityAir StudyEPA protocols3rd party accredited independent laboratoryEPA approved analytical methodsSamplesupwind and downwind from drilling pads,downwind moved every hourAir SamplingDownwind site samples were not statisticallydifferent from upwind (in other words noadditional contribution from the pad operations)Hazard Quotients <1Reasonable maximum estimated (RME) risk downwindfrom the pads for Benzene was 1.8E-5 (18 in a millionRisk–Estimated Exposure dose below ATSDR lowestobserved exposure levelNo significant chronic health riskFinal CommentEncourage EPA to:Supportadditional environmentalinvestgationsCommunity health educationDetermine Real vs. Perceived issuesUse sound science as a basis for regulationsBenzene Air Risk

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