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Chemicals in Oil and Gas Operations

TEDX Public Comments

TEDX participates in public comment periods to educate government agencies on unconventional oil and gas operations and the risks to public health. The following are brief summaries of comment letters that TEDX has submitted to government agencies, with links to download the letters in full.


TEDX comment letter to the BLM on the Draft Resource Management Plan and Draft Environmental Impact Statement for the Uncompahgre Field Office, Colorado. Download PDF submitted 11/1/16.

The Resource Management Plan (RMP) for the BLM Uncompahgre Field Office guides the management direction for over 675,000 acres in southwest Colorado. This draft RMP discusses the Alternatives considered and outlines the BLM’s Preferred Alternative.

TEDX believes the Preferred Alternative did not adequately address the risks to public health from increased oil and gas development in the Planning Area. Over 300 peer-reviewed articles have been published on health and ecological impacts from unconventional oil and gas development since the BLM started the RMP update. Since fracking was not addressed in the RMP and little air quality data is available from the Planning Area, it is not possible for the BLM to determine the risk posed to human and environmental health. Given that the BLM did not consider a No-Leasing Alternative, the BLM should, at a minimum, adopt the North Fork Alternative Plan regarding fluid mineral leasing in the North Fork Valley, and the BLM should apply this conservation framework to cover leasing throughout the Planning Area.


TEDX comment letter to the BLM on the Waste Prevention, Production Subject to Royalties, and Resource Conservation: Proposed Rule (BLM-2016-0001). Download PDF submitted 4/21/16.

From the Summary: The Bureau of Land Management (BLM) is proposing new regulations to reduce waste of natural gas from venting, flaring, and leaks during oil and natural gas production activities on onshore Federal and Indian leases.

TEDX supports the BLM’s efforts to regulate methane emissions from oil and gas development on public lands. These proposed regulations will not only decrease methane emissions but also nonmethane volatile organic compounds (NMVOCs). Public health can be adversely impacted through exposure to the NMVOCs that surface with methane during oil and gas development. This includes through direct exposure to NMVOCs, through the formation of ozone, and from chemicals released during flaring.


TEDX comment letter to the EPA on the Oil and Natural Gas Sector: National Emission Standards for Hazardous Air Pollutants (EPA–HQ–OAR–2015–0747). Download PDF submitted 3/11/16.

From the Summary: This action requests information related to hazardous air pollutant (HAP) emissions from sources in the oil and natural gas production and natural gas transmission and storage segments of the oil and natural gas sector. In 2012, the Environmental Protection Agency (EPA) revised the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Oil and Natural Gas Production Facilities and the Natural Gas Transmission and Storage Facilities major source categories. This action requests additional data and information that was not available at that time.

TEDX is concerned about the lack of sufficient research on HAPs and the potential health impacts from chronic low level exposure to air emissions. The EPA needs to adopt strict emission standards to reduce worker and community exposure to HAPs from all new and existing sources throughout the full cycle of development.


TEDX response to the Draft Environmental Impact Statement (DEIS) for the Bull Mountain Master Development Plan (DOI-BLM-CO-S050-2013-0022-EIS), Gunnison County, CO. Download PDF submitted 04/16/15.

The Bull Mountain Unit MDP describes the exploration and development of up to 146 natural gas wells, 4 water disposal wells, and associated infrastructure on federal and private mineral leases. An MDP provides information common to multiple planned wells, including drilling plans, Surface Use Plans of Operations, and plans for future production. MDPs are typically prepared for a planned cluster of wells and associated facilities near, or for multiple in-fill wells scattered throughout, an oil and gas unit or field. They have information on associated facilities, such as roads, pipelines, utility corridors, and compressor stations.

TEDX commented on the DEIS, arguing that it did not take into account many recently published peer-reviewed articles on air quality and natural gas operations. Research shows that the bottom-up modeling and generic emissions reporting used by the BLM can underestimate air pollution and so misrepresent potential health effects and impacts on ozone levels. Ground and surface water and waste disposal provide additional pathways for contamination of resources leading to adverse health and ecological effects. These comments include TEDX research on potential health effects from the chemicals proposed to be used during development of these wells and also chemicals that have been detected in pit residues.


TEDX comment letter on the Hydraulic Fracturing Chemicals and Mixtures; Advance Notice of Proposed Rulemaking (EPA-HQ-OPPT-2011-1019). Download PDF submitted 09/16/14.

From the Summary: In its response to a citizen petition submitted under section 21 of the Toxic Substances Control Act (TSCA), EPA indicated that as a first step, it would convene a stakeholder process to develop an approach to obtain information on chemical substances and mixtures used in hydraulic fracturing. To gather information to inform EPA’s proposal, the Agency is issuing this advance notice of proposed rulemaking (ANPR) and initiating a public participation process to seek comment on the information that should be reported or disclosed for hydraulic fracturing chemical substances and mixtures and the mechanism for obtaining this information.

TEDX recommended strong regulations for full public disclosure of 100% of the ingredients used in hydraulic fracturing fluids, drilling muds, and all above ground operations. Concerned citizens, workers, public health and medical professionals, and others should have instant access to this information to assist them in making decisions regarding their health and safety, and that of the environment.


TEDX response to the Environmental Assessment for the Fram Whitewater Master Development Plan (DOI-BLM-CO-130-2012-0003-EA), Mesa County, CO. Download PDF submitted 7/31/13.

From the Introduction: The Whitewater MDP proposes a four year program of oil and gas exploration on federal leases in Mesa County (the Proposed Action). Fram proposes to drill up to 108 wells on 12 new well pads. The Proposed Action consists of construction, operation, maintenance, and abandonment of well pads, wells, roads, gas gathering pipelines, oil gathering pipelines, and produced water gathering pipelines.

TEDX asked the BLM to do a full Environmental Impact Statement (EIS) to address the potential significant decline in air quality in west-central Colorado. Ozone precursors will be released affecting human and ecological health. The EIS needs to assess damage and calculate economic loss from damage to trees and vegetation on the national forest as well as on the row crops, alfalfa, vegetables and fruit grown in Delta County, CO.


TEDX protest letter to the Colorado State BLM Director regarding the Finding of No Significant Impact on the Environmental Assessment (FONSI), Delta and Gunnison Counties, CO (DOI-BLM-CO-S050-2012-0009-EA). Download PDF submitted 12/13/12.

From the FONSI: The Bureau of Land Management (BLM) Uncompahgre Field Office (UFO) prepared an Environmental Assessment that analyzed the effects of the proposed lease sale of up to 22 parcels (29,891 acres) located in Gunnison and Delta Counties for the February 2013 Oil and Gas Lease Sale. The Environmental Assessment considered a range of alternatives including the Proposed Action, Preferred Alternative, and No Action. The BLM determined that the Preferred Alternative with the mitigation measures will not have a significant effect on the human environment, individually or cumulatively with other actions in the general area.

TEDX responded to the FONSI telling the BLM to take into consideration the increased air impacts from volatile organic compounds (VOCs) released during new natural gas development, in addition to the ongoing release of VOCs from coal mine methane drainage wells and existing gas wells in the lease sale area. Research shows that many of the VOCs are associated with adverse acute and chronic health effects. It would be irresponsible to move forward with more leasing for natural gas development in the North Fork of the Gunnison River Valley before a comprehensive ambient air quality study is completed.


TEDX comment letter to the Colorado Oil and Gas Conservation Commission (COGCC) on the 2012 Setback Rulemaking- Establishing New and Amended Rules for Statewide Setbacks. Download PDF submitted 11/13/12.

From the Notice of Rulemaking Hearing: The COGCC will consider additions and amendments to establish new and amended rules for statewide setbacks applicable to drilling and well servicing operations, high density areas and designated outside activity areas, and aesthetic and noise control regulations.

TEDX asked for a one mile setback to protect the health of residents. Results from a recently published TEDX paper report that natural gas “fingerprint” chemicals were detected 0.7 miles from an active drill site. Polycyclic aromatic hydrocarbons were found at elevated levels and have been associated with multiple adverse developmental health outcomes. The COGCC must take into consideration the possible aggregate and cumulative health hazards posed by the non-methane hydrocarbons in the raw gas from both current and future natural gas development in the area.


TEDX response to the Environmental Assessment for the August 2012 federal Oil and Gas Lease Sale, Delta and Gunnison Counties, CO (DOI-BLM-CO-S050-2012-0009-EA)Download PDF submitted 04/20/12.

From the Introduction: The Bureau of Land Management (BLM) Uncompahgre Field Office (UFO) has prepared this Environmental Assessment (EA) to disclose and analyze the environmental effects of the proposed sale of 22 parcels (29,812 acres) during the August 2012 oil and gas lease sale. The BLM may choose to: a) offer all of the nominated parcels for sale, b) offer a subset of the parcels for sale, or c) not offer any parcels at this time. The final decision on which parcels will be sold will be made by the State Director.

TEDX asked the BLM to do a complete air quality assessment including the non-methane volatile organic compounds (VOCs) currently being released by the coal mines in the lease area, and to provide projections for increased coal removal and fugitive raw methane emissions and their impact on air quality.


TEDX response to the BLM Interested Party Letter regarding the Nomination of 30,000 acres in the North Fork of the Gunnison River Valley for the August 9, 2012 Federal Oil and Gas Lease Sale, Delta and Gunnison Counties, CO. Download PDF submitted 02/07/12.

From the Interested Party Letter: The Bureau of Land Management (BLM) Uncompahgre Field Office is seeking input regarding the August 9, 2012 oil and gas lease sale nominations for 22 parcels of Federal mineral estate… contain[ing] approximately 30,000 acres of which 29,100 acres are primarily located in BLM managed lands near Crawford, Hotchkiss, Paonia and Somerset and the Paonia Reservoir State Park.

TEDX responded asking that all leases be withdrawn due to the potential air pollution and associated health effects to residents from natural gas development. Sources of air pollution include volatile organic compounds (VOCs) used during well development and maintenance, exhaust from mobile and stationary equipment, fugitive gases surfacing with the methane, evaporation pits, and ozone production. 


Letter submitted by Theo Colborn on the frack fluid ingredient 2-BE RE: An Analysis of Possible Increases in Exposure to Toxic Chemicals in Delta County, Colorado Water Resources as the Result of Gunnison Energy's Proposed Coal Bed Methane Extraction ActivityDownload PDF submitted 10/22/02.

The letter addresses the physical properties, direct and indirect health effects, and environmental effects of 2-BE, a component of fracturing fluid proposed for use in the development of coalbed methane wells in Delta County, Colorado. The risks from drinking water contamination of 2-BE must be considered, and multiple recommendations are included to protect drinking water resources.


TEDX comments to the Colorado Oil and Gas Conservation Commission (COGCC) on the 2008 Rulemaking, a comprehensive revision of rules regarding oil and gas operations. Download PDF submitted 09/09/09.

TEDX asks the COGCC to adopt meaningful regulations regarding full disclosure of the chemicals used during oil and natural gas operations including the disclosure of chemical weights and volume. A 2,000 foot setback for homes and water resources from these operations is the minimum acceptable distance to protect public health.