Last week, a joint working group with participants from the Environmental Policy and Well Stimulation committees submitted comments to the Environmental Protection Agency (EPA) about 1,4-Dioxane and the recent draft supplement to the risk evaluation from 2020.
In December 2020, the EPA published its final risk evaluation for 1,4-Dioxane. However, recognizing the need to assess previously unexamined exposure pathways, the EPA drafted a supplement, published in July 2023. This supplement could potentially impact the sector, as it may include fluids used in drilling and stimulation activities in oil and gas production where trace amounts of 1,4-Dioxane may be present, even though it is not intentionally added.
The Energy Workforce comments push back on EPA’s exposure assumptions for the hydraulic fracturing condition used in the draft supplement as incorrect. We suggest that the EPA use actual data on the hydraulic fracturing condition of use and then complete its risk evaluation based at least in part on that information. As part of the comments, Energy Workforce makes three recommendations:
- EPA should not finalize the supplement to the risk evaluation and the risk determination until it provides a meaningful opportunity (not just a single 60-day notice period) for stakeholders to gather and, in some cases, develop information that EPA should consider before making its final risk determination.
- EPA needs to factor the average likelihood of hydraulic fracturing worker exposure occurring into its analysis.
- EPA has risk results for dermal exposure scenarios with and without gloves, and since gloves are worn during chemical handling activities, EPA should reduce the calculated risks by a factor of 20.
In terms of next steps, EPA is holding a four-day virtual public meeting this week for the Science Advisory Committee on Chemicals (SACC) to review the 2023 draft supplement risk evaluation. The feedback from this session will help refine the EPA’s methods for assessing exposure and evaluating population risks.
If you are interested in joining the Environmental Policy or Well Stimulation committees to engage on this subject, contact Senior Director Energy Policy Maria Suarez-Simmons.
Maria Suarez-Simmons, Senior Director Energy Policy, writes about industry-specific policies for the Energy Workforce & Technology Council. Click here to subscribe to the Energy Workforce newsletter, which highlights sector-specific issues, best practices, activities and more.