Health Risks from Particulate Matter Air Pollution Related to Frac Sand Mining and Processing By way of introduction,

I am a medical doctor and have been a faculty presenter and regular attendee at the annual Making the Connection conference jointly sponsored by the University of Wisconsin School of Medicine and Public Health, Physicians for Social Responsibility, the Wisconsin Environmental Health Network, and others. I am also a current resident of Fillmore County, Minnesota and an asthmatic. Accordingly, I have both a professional and keen personal interest in the adverse health effects of respirable airborne pollutants. From this perspective, I would respectfully bring to the attention of those deliberating the regulation of frac sand mining and processing the following summary points, largely based upon important research being carried out by Dr. Crispin Pierce at the University of Wisconsin Eau Claire, and presented at the Making the Connection 2013 conference earlier this month. 1. Fact: Of the several health risks with frac sand, exposure to respirable particulate matter (PM) is arguably of greatest concern. Known problems from exposure to PM include difficulty in breathing, decreased lung function, aggravated asthma, bronchitis, cardiac arrhythmias (irregular heart beat), heart attacks, lung cancer, and premature deaths. The incidence of such problems increases linearly with length of time of exposure and the concentration of PM in the air. 2. Fact: Particle size is important. While visible dust may be annoying, it is only particles of less than or equal to 2.5 micrometer diameter PM2.5 (which includes crystalline silica) that are able to reach the lung alveoli (the delicate air sacs deep in the lung where gas exchange occurs) and cause damage. 3. Fact: There is poor correlation between concentration measurements of larger particulate matter, e.g., PM10, and the health-hazardous PM2.5. One cannot correlate presence or absence of observable dust with concentration of respirable PM. 4. Fact: Frac sand mining and processing generate PM through blasting, loading, hauling, crushing, and transporting. For example, fence line measurements of PM2.5 carried by Dr. Pierce and his team out at the Chippewa Falls processing plant showed concentrations consistently exceeding the EPA standard for annual exposure, from the start of plant construction through full operation. On one sampling day, with slight wind and regular truck and train activity, measured fence line levels exceeded the EPA standard for 24 hour exposure, and remote monitoring some 15 miles distant showed levels exceeding the standard for annual exposure. 5. Fact: Our local sand largely comprises large coarse grains. This is the sand coveted by industry and from a health perspective may also be considered good sand. In the processing of mined sand, this good sand is what is kept by the industry. The leftover waste is concentrated small grain sand. From a health perspective, waste

sand ought to be considered a hazardous waste definitely not something youd want in your grandchilds sand box. Transporting waste sand from the processing site back to the mining site and using it for reclamation may indeed pose the greatest risk in the entire process. To date, there are no monitoring data to assess the extent of this risk or the efficacy of proposed mitigation procedures. 6. Calculation: Based upon a. the measured silica concentration in respirable dust (PM2.5) samples in Wisconsin (14.5%) b. the State of California adopted reference concentration for respirable silica (3 micrograms per m3) and c. the EPA annual standard of PM2.5 exposure (12 micrograms per m3) measurement and enforcement of the current EPA standard is likely to protect against the adverse health risks of frac sand PM exposure. (14.5% x 12 = 1.74, i.e., <3) Summary plea: From an immediate health perspective, I would not argue that frac sand mining and processing never be done, but rather that if it were done, it should be done in a way that is health conscious and protective. The citizens of Minnesota should not be canaries in the coal mine. There are sufficient data to show that mining and processing as it is currently being done in Wisconsin is health hazardous generation of PM2.5 pollutants consistently exceeds acceptable levels. Continual monitoring and strict enforcement of the EPA standard, at all sites, in all phases of mining, transporting, processing, and reclamation activity is critical. (From an industry-neutral perspective, I would also point out that while we clearly know a problem exists, we dont have the full picture of the exact sources of the problem. Is truck traffic on gravel roads worse than on paved roads? Is loading waste sand on trucks the major source of PM pollution? etc. More precisely localized monitoring would more precisely define problem areas and allow for more efficient mitigation.) Thank you in advance for your careful consideration of this important topic. David R Webb, MD, FAASP, FACSM February 21, 2013 For further information, discussion of his original research, and/or critical review of the relevant scientific studies, please contact: Crispin Pierce, PhD Associate Professor/Program Director, Department of Public Health Professions 244 Nursing University of Wisconsin Eau Claire Eau Claire, WI 54702-4004 (715) 836-5589 piercech@uwec.edu http://www.uwec.edu/piercech