EXHIBIT 2

TO DR. TAMI MCMULLIN'S PRE-FILED WITNESS TESTIMONY

COMPILATION OF BENZENE
MEASUREMENTS NEAR
WELLPADS IN COLORADO:
A COMPARISON TO HEALTH
GUIDELINE EXPOSURE VALUES
PREPARED BY:
CTEH, LLC
1114 WASHINGTON STREET, SUITE 201
GOLDEN, CO 80401

PREPARED FOR:
COLORADO OIL AND GAS ASSOCIATION
1800 GLENARM PLACE, SUITE 1100
DENVER, CO 80202

JULY 30, 2020

July 30, 2020 Page | ii
Table of Contents

1.0 Background and Objective ............................................................................................................ 1

2.0 Methods ........................................................................................................................................ 2
2.1 Data Compilation .............................................................................................................. 2
2.2 Data Analysis..................................................................................................................... 4
3.0 Results and Discussion................................................................................................................... 5
4.0 Conclusion ..................................................................................................................................... 6

List of Appendices
Appendix A - Comparison of benzene measurements to acute health guideline value

July 30, 2020 Page | iii

1.0 Background and Objective
Currently, state regulations in Colorado require that all new well or production facilities be located 500
feet or greater from building units (Colorado Oil and Gas Conservation Commission (COGCC) Rule #604).
Over the past decade, government, non-government, and individual stakeholders have raised concerns
about the potential for adverse health impacts to people living near oil and gas wellpads from inhalation
exposures to compounds released from oil and gas operations. In response to these concerns, the
Colorado Department of Public Health and Environment (CDPHE) conducted a review of the existing air
monitoring data in oil and gas areas in Colorado and conducted a comprehensive review of the existing
data between 2008-2017 1 In this report, CDPHE reviewed over 10,000 individual air measurements of
over 50 different oil and gas related volatile organic compounds (VOCs) collected between 350 – 3700
feet from wellpads during different operational phases. CDPHE added to these data in a companion
publication that evaluated over 30,000 air measurements of VOCs 2. Based on the available data, the
CDPHE concluded that there was no evidence that oil and gas operations in Colorado were resulting in
VOC levels that would cause acute or chronic non-cancer and cancer health effects. One of the limitations
of the findings from the CDPHE assessments, however, was that the existing data primarily represented
air measurements of VOCs during production or in regions with several active wellpads, with samples
collected during specific pre-production operations.

In 2019, CDPHE released findings from a modeling study that used emission rate data collected on
wellpads during different pre-production and production operations to generate estimates of air
concentrations of VOCs at different distance from a hypothetical wellpad. These air concentrations were
used to derive health risk estimates to hypothetical people living at the different distances. in the
Northern Front Range (NFR) and the Western slope during different operational phases 3. Consistent with
the findings from CDPHE’s evaluation of existing air data, the modeling study results indicated that
emissions from oil and gas wellpads resulted in average air concentrations of VOCs below those expected
to cause chronic cancer and non-cancer health effects at all distances out to 2000 feet from a wellpad.
There were, however, specific modeled operational and meteorological scenarios, only during flowback,
that resulted in model estimated maximum concentrations of a small sub-set of VOCs, including benzene,
that exceeded acute health guideline levels at distances up to 2000 feet from the wellpad. Although the
study findings are valuable in that they can inform prioritizing future research areas, the relevance of the
actual acute risk estimates are questionable, as the data used in the model were collected between 2014
– 2016 and the specific operational practices (e.g. enclosing or controlling flowback tanks) that were in
place during the study are unknown. [In addition, there has been significant state regulatory changes and
operators now typically employ more protective best management practices to further reduce emissions
since those data were collected.

Since the publication of the CDPHE review and the modeling study, several air monitoring studies have
been conducted by CDPHE, local public health agencies and operators. These studies have generated

1
https://drive.google.com/file/d/0B0tmPQ67k3NVVFc1TFg1eDhMMjQ/view
2
3
https://drive.google.com/file/d/1pO41DJMXw9sD1NjR_OKyBJP5NCb-AO0I/view
thousands of new data points collected in proximity to wellpads and in communities near wellpads during
discrete pre-production phases. The data from these studies provide important information for testing
the exposures and health risk conclusions of the 2019 modeling study.

CDPHE (2017) and McMullin et al. (2018) have published health risk evaluations of all available air
monitoring data collected near oil and gas wellpads and in oil and gas regions across Colorado between
2008 – 2017. The objective of this study was to expand on these reports by compiling all available air
monitoring data collected since CDPHE’s public health evaluations of air data. and use these data to
conduct a risk-based screening evaluation of the potential public health impacts from the levels of
benzene measured near wellpads during discrete pre-production operations. Benzene was the only VOC
evaluated in this preliminary assessment because air monitoring studies conducted to date have
repeatedly demonstrated that benzene, of all oil and gas related VOCs, is the main driver of potential
public health risks, including risks to sensitive susceptible populations.

2.0 Methods
2.1 Data Compilation
CTEH compiled new air monitoring data collected between 2017 – 2020 that were not included in those
previous reports. The data included in this report represent measured concentrations of benzene
collected near a specified wellpad or in a community nearby a specified wellpad during a discrete
operational phase. A summary of the study information is provided in Table 1. Study details are provided
in Appendix A. The following provides a brief discussion of the data sources evaluated and included in this
report.

• Peer-reviewed literature: Using the same inclusion criteria as those outlined in McMullin et. al.
(2018)4, no additional data were identified.

• Oil and gas operator commissioned studies: Oil and gas operators voluntarily provided redacted
data to COGA for inclusion in this report. Approximately 900 individual samples were collected
between 2019-2020 at 15 different wellpads located in the NFR and Western Slope. All the
operator studies collected air samples for continuous 24-hour periods ranging from
approximately 5-30 days during different operational phases (drilling, hydraulic fracturing,
millout, flowback, and production). Wellpad sampling locations ranged from <100 feet to
approximately 500 feet from the source area(s) on the wellpad. The size of the wellpads differed
across studies and some of the wellpads did not have complete or any sound walls during the
operations. The wellpads also ranged in the number of wells being developed on a pad and the
current best management practices implement by the operator. The density of residential areas
also differed across wellpads. For some of the wellpads with nearby residential areas,
measurements in the community were also collected concurrent with the wellpad perimeter
samples.
 • CDPHE: CDPHE have conducted several community air monitoring investigations near wellpads
collected approximately 5,600 samples between 2016 – 2020. These data were collected using
CDPHE’s mobile laboratory, which was generally positioned in a single location at distances
ranging from approximately 700-4000 feet from a wellpad community. Samples were collected
continuously in 30-45-minute intervals. Studies were conducted during pre-production and
production operations for variable durations depending on the study. 4 The CDPHE data presented
in this report represent only the maximum concentrations reported by CDPHE, as all the raw data
were not readily accessible in the publicly available reports. have been conducted for all pre-
production and production phases.

• Local Governments: CTEH located publicly available reports from three cities and counties. Based
on the available information. This data included approximately 120 24-hour, or 1-week samples
collected between 250 – 5100 feet from a wellpad. The entire datasets were not included in the
publicly available reports and, therefore, the maximum values reported by local governments
were included in this analysis as a health-protective screening approach.

o City and County of Broomfield (CCOB): CCOB collected 1-week air data during pre-
production activities on specific wellpads or in communities near wellpads. Data were
collected at various distances within the wellpad property boundaries outside of the
sound walls and in the nearby communities.5

o Town of Erie: The town of Erie collected air samples during different pre-production
activities on a wellpad in proximity to residential communities. These data were collected
over one-week time periods 6.

o Garfield County: Garfield County collected data near a wellpad with producing wells in
Battlement Mesa. Two one-week downwind samples were collected per month 7. The
samplers were in proximity to the production tanks, but the precise distance could not be
located. For the purposes of this study, the distance was presumed to be approximately
500 feet.

4
https://www.colorado.gov/pacific/cdphe/oil-and-gas-community-investigations
5 https://broomfield.ajax-analytics.com/
6 https://www.erieco.gov/922/Air-Quality-Noise-Monitoring-Reports
7 https://www.garfield-county.com/air-quality/
Table 1. Summary of new data collected between 2017 – 2020 by operational phase

# unique wellpads/
Approx. # of Range of Distances from
phase
Operational Phases Samples wellpads (feet)
11
Drilling 1628 175 - 4624
Hydraulic Fracturing 721 8 250 - 4624
Millout 1287 5 273 -4624
Flowback 2182 13 175- 5100
Production 764 4 175 – 1300
TOTAL 6,582 41 175 - 5100

2.2 Data Analysis

Benzene air measurements were categorized by site location, phase of operation, sampling duration,
approximate distance from center of wellpad, and region. All operator benzene measurements were
reported in this study. The data from the CDPHE and the local governments, however, only reported
maximum and average values in their publicly available reports. As a health protective screening-level
evaluation of the data, if the entire dataset were not publicly available, the maximum detected
concentration of benzene in air across all sampling locations and days for each study was included in this
analysis. The default assumption in this screening assessment also conservatively assumes a person could
breathe the measured benzene concentration in outdoor air continuously up to two weeks at the
sampling location.

All available benzene samples were compared to the acute health guideline value (or minimum risk level
(MRL)) for benzene of 9 parts per billion (ppb) derived by Agency for Toxic Substances and Disease Registry
(ATSDR), a federal public health agency of the U.S. Department of Health and Human Services. According
to ATSDR, the MRL represents “an estimate of the daily human exposure to a hazardous substance that is
likely to be without appreciable risk of adverse non-cancer health effects over a specified duration of
exposure. These substance-specific estimates, which are intended to serve as screening levels, are used
by ATSDR health assessors and other responders to identify contaminants and potential health effects
that may be of concern at hazardous waste sites. It is important to note that MRLs are not intended to
define clean up or action levels for ATSDR or other federal or state agencies 8”. The acute MRL is
appropriate for comparing to exposure periods up to 14 days. In sum, these values are not to be used as
predictors of harmful (adverse) health effects, but rather as screening levels to identify circumstances that
may warrant additional investigation.

8
https://www.atsdr.cdc.gov/mrls/index.asp
3.0 Results and Discussion
CTEH located 6,582 air samples of benzene that were collected during air monitoring studies conducted
between 2017-2020 with the objective of measuring VOC concentrations near active wellpads and/or in
surrounding communities during different pre-production and production phases. The data represent 23
wellpads in the NFR and the Western Slope.

Within the data considered in this report, benzene measurements ranged between approximately 175-
5,100 feet from the center of the wellpad. The data also represent a range of different oil and gas
wellpads, and activities conducted under current best management practices. Most data were collected
during pre-production, as this was identified by the CDPHE and COGCC as high priority for further data
collection.

• Drilling: Approximately 1,700 air measurement were collected during drilling operations at distances
ranging from 175 – 4,624 feet the wellpad. All benzene measurements during drilling were below
ATSDR acute MRL of 9ppb.

• Hydraulic Fracturing (HF): Over 700 air measurement were collected during HF operations at
distances ranging from 250 – 4,624 feet from a wellpad. All benzene measurements during HF
operations were below the ATSDR acute MRL of 9ppb.

• Millout: Over 1,280 air measurements have been collected during millout operations at distances
ranging from 273 – 4624 feet from a wellpad. All benzene measurements during millout were below
the ATSDR acute MRL of 9ppb.

• Flowback: Over 1,900 air samples have been collected during flowback operations at distances
ranging from 175-5,100 feet. Out of 1,900 measurements, one measurement of benzene slightly
exceeded ATSDRs acute MRL. This exceedance represented a single 45-minute maximum benzene
concentration that was measured by CDPHE at approximately 1,100 feet from a wellpad during
flowback. 9” Apart from the single maximum measurement, all other benzene measurements collected
during that CDPHE study were below ATSDRs acute MRL.

• Production: Over 750 air measurements have been collected during flowback operations at distances
ranging from 175-1300 feet. All benzene measurements during production were below the ATSDR
acute MRL of 9ppb.

9
CDPHE Public Health Consultation Bella Romero https://drive.google.com/file/d/18Bl7UnNgxw6v_9_OI7o47H_Ekx0kyx7J/view
4.0 Conclusion
To date, the 2017 CDPHE public health screening assessment and the 2019 CDPHE modeling study have
provided the main body of information on actual or hypothetical air concentrations of benzene and other
VOCs that may be emitted during oil and gas pre-production and production activities. Although both
studies had strengths and limitations, the intent of those preliminary studies was to provide decision
makers with information from which they could narrow the focus of where to look more closely. Based
on the findings from those studies, there has been consensus across multiple stakeholders that there was
a need to collect air monitoring data from high quality air studies designed to measure VOC
concentrations, including benzene, across different operational phases, types of operations, regions and
shorter timeframes at closer distances from wellpads. In response to the need for additional wellpad
specific data, state and local public health agencies and industry operators have conducted several studies
during pre-production operational phases over the past three years. The aim of this study was to compile
the data on benzene from these publicly available reports and industry studies and compare those data
to federal established acute health guideline values.

This current analysis of all 6,500 benzene measurements collected on over 20 different wellpads between
2017-2020 indicates that over 99.9% of measurements were below the federally established ATSDR acute
MRL of 9ppb. Of all phases and across all studies, only one single 45-minute benzene measurement
exceeded the guideline value. This sample represented the maximum concentrations that was measured
by CDPHE’s mobile laboratory during flowback operations at a sampling location 1,100 feet from the
wellpad of interest. Based on an evaluation of the all the data collected during that study, CDPHE
concluded that “acute and chronic health hazards are below an immediate level of concern and are not
likely to harm peoples’ health9”. Additionally, this single measurement is inconsistent with the benzene
measurements collected during flowback at locations less than 1,100 feet from a wellpad, which were all
below ATSDR’s MRL (Appendix A). It is also important to note that ATSDR’s acute MRL is defined as the air
concentration that is likely to be without appreciable risk of adverse non-cancer health effects over an
exposure period of approximately 1-14 days. 10 Therefore, an exceedance of the MRL does not indicate
that health effects will occur at that measured level. Rather, all state and federal health guideline values,
including ATSDR’s acute MRL, represent an exposure level of benzene that is orders of magnitude below
where adverse health effects have been observed in animals and humans 11. As stated by ATSDR, “health
guidance values must be thought of in the context of their intended role as mere screening or trigger

10
The starting point for deriving the acute ATSDR MRL of 9ppb was the exposure level at which adverse effects were
observed in a mouse study (10,200 ppb). ATSDR then applied a 1000-fold “safety factor” to this value to account for
the potential for humans to be more sensitive than animals, for human sensitivities across more susceptible
populations., and for differences in observed effects from high exposure levels to low and differences in exposure
durations, environmentally relevant exposure levels.
11
ATSDR Toxicological profile for benzene. https://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=40&tid=14
values, in which they serve as a tool for assisting in the determination of whether further evaluation of a
given potential exposure scenario is warranted 12.”

The findings from this study are consistent with the findings from CDPHE’s 2017 report and 2018
publication, which evaluated data collected between 2011-2016 and determined that all benzene
measurements were below federal acute health guideline values. Based on the overall weight of evidence
from the current data, acute exposures to the measured benzene concentrations in the air at distances
ranging from 175 – 5,100 feet from wellpads during drilling, hydraulic fracturing, millout, flowback and
production are not likely to harm peoples’ health.

12Risher and DeRosa. (1997). The precision, uses, and limitations of public health guideline values. Human and Ecological Risk
Assessment: Vol. 3, No.5, pp. 681-700.
 Appendix A
Comparisons of Benzene
Measurements to Acute Health
Guideline Values
Benz
eneConcentr
ationsbyOperat
ionalPhaseandDi
stanc
efr
om Wel
lpad
Si
te-
spec
ificAirStudiesi
nCol
oradobetween2017-2020
Oper
ati
onPhase

10
ATSDRAc
uteHeal
thGui
del
ineVal
ue(
9ppb)

ppb)
8
i
atons(

6
r
ent

Dr
ill
ing
onc
enec

4
Benz

10
ATSDRAc
uteHeal
thGui
del
ineVal
ue(
9ppb)
ppb)

8
i
atons(

6
r
ent

Hydr
aul
icFr
act
uri
ng
onc
enec

4
Benz

10
ATSDRAc
uteHeal
thGui
del
ineVal
ue(
9ppb)
ppb)

8
i
atons(

6
n
DJBasi

r
ent

Mi
ll
out
onc
enec

4
Benz

10
ATSDRAc
uteHeal
thGui
del
ineVal
ue(
9ppb)
ppb)

8
i
atons(

6
r
ent

Fl
owbac
k
onc
enec

4
Benz

10
ATSDRAc
uteHeal
thGui
del
ineVal
ue(
9ppb)
ppb)

8
i
atons(

6
r
ent

Pr
oduc
tion
onc
enec

4
Benz

10
ATSDRAc
uteHeal
thGui
del
ineVal
ue(
9ppb)
ppb)

8
ons(
n
eBasi

i
at

6
r
ent
eanc

Dr
ill
ing/
Flowbac
k
onc
c

enec
Pi

4
Benz

0 500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500
Feetf
rom wel
lpadc
ent
er

CTEH,LLC
Lastupdated:7/
10/
2020