Remarks

by Elizabeth Comeaux

of Denver

at EPA Hearing

on 09/28/2011 My name

is Elizabeth Comeaux,

I’m

a Colorado attorney
and resident

of this state for 40 years.

I grew
up in
a part of the country where shrimpers

and oil rig roughnecks gathered

at the family table on Sunday afternoon.

I want

to thank you for bringing

us together

to coordinate

the economic interests represented

by the oil and gas industry
and

a demanding consumer public, with everyone’s interest

in breathing, living, and having

a planet

on which to do both. First,

I would like to emphasize

the importance

of unbiased scientific data. Independent scientists
like Dr. Theo Colborn
and Dr. Wilma Subra should have

a considerable
voice alongside scientists who are directly

or indirectly commissioned

by the industry.

I recommend

the compilation

of peer reviewed scientific articles

at Dr. Colborn’s website www.endocrinedisruption.com

for

a meticulous scientific survey

of the VOCs and other toxics and their biological effect
on living things like us. This website gives

a long list of illnesses caused

by airborne toxins from products known

to be used

in fracking fluids. One such illness, cancer,
has stricken
my family like many others. Saturday when my brothers walk the Race for the Cure

in Houston,

the printout

of’ their friends and relations stricken with cancer goes from their chest

to their knees. The last thing we need

is an increase

in known carcinogens

in the air! Independent scientific data

is essential! Second,

I would like your cost-benefit analysis

to be what

I would call sober. Please really weigh the costs

to public health and ecological services,

on the one hand, with the economic benefits

of the industry,

on the other. Investigations

such
as published

in the July 25 issue of High Country News suggest that

it is a fallacy

to believe that opening
the floodgates

to oil and gas drilling here will make those products more securely available

for use here. The industry value

at stake

is really

a rush
to
a global market,
not national security.

So the cost-benefit analysis should soberly consider

the economic values

as against
the health
of babies, without weighting

the economics

side of the equation based
on national security. Third,

a real urgency,

as you know,

is climate change. The cost-benefit analysis should consider

the very significant costs of lost opportunity

in research
and development.

The industry

is capable

of transitioning

to the renewable energy economy
that

is most desperately needed. Granted, some natural
gas will be needed during
the transition, while infrastructure

is put in place

to handle fluctuations

in solar and wind. Regulations

of our government should help redirect most of the research
and development

to ramping

up renewables!

Be alert
to the tendency

of industry
and consumers alike

to indulge

an addictive preoccupation

with oil and gas, distracting

the technological capacities

of the industry into fossil fuels, and delaying

the urgently needed transition

to renewahies. And this

is so important

is my fourth point. The 1.1 million wells
on the EPA’s slide show

as basis fbr the proposed
rule are 2009 numbers. Today
we are midway through 2011. And the industry says they are going

to he fracking

up

a storm!
An industry hydrologist

said
at
a hearing

in Douglas County this summer that.
in the next 10-20 years, they expect

to drill 20,000 wells

in the northeast quadrant

of the state alone! The industry presentation

at the Colorado Water Resources Review Committee hearing this summer expands

on that prediction. http://wxvw.colorado.gov/cs/Satellite?hlohcolurldata&hlohheaden=apil

ication°’2 lpdi&blob kev=id&hlohtahlevIungoBlohs&hlohwhere=l

251 736903762&sshinarv=rtrue

TheseRemarksbyElizabethComeauxofDenveratEPAHearingon09/28/2011projectionsdonotappeartobeaddressedinthebaselineofnewlyfrackedandre-frackedwellsthatsupportthepresentruleproposal.Sothethreattolifeandhealthareinalllikelihoodmuchworsethananticipatedwhentherulewasdrafted.Thisleadstomyfifthpoint.Cumulativeimpact.Understandably,theproposalwillbeenforcedsite-by-site.Buttheeffectonpublichealthandtheviabilityoflifeoccursbasedoncumulativeeffect.Pleaselookattheproposalsforaddressingcumulativeimpact.Youcanfindtheminanysearchofthelawreviewliterature.ThewebsiteoftheScienceandEnvironmentalHealthNetworkisagoodplacetostart.www.selm.orgAndsixth,pleaseconsidertheeffect,onthebiosphereandtheclimate,ofunearthingalivingecosystemthatexistsbuthasnotbeenstudied.Dr.SandraSteingraber,onSeptember15inaforumonNewYork’sFingerLakes,commentedthatsomebiologistsarebeginningtostudytheeffectofstrangecreaturesintheshalewhosebehavioristhoughttohavearoleinstabilizingclimate.Pleaseconsidertheconsequencesoflarge-scaletinkeringwithsomethingwedonotunderstandatallbecausewehaveneverhadtostudyit.http://wwv.voutube.com/wach?v=eu1u3hUhkOurpastignorancehasgottenusinawholeheapoftroublealready,butitistoolateinthegametowinkorlookasideasifwearenottheresponsibleones!Sotosumupmysixpoints:1.Useunbiasedscientificdata,highlightingindependentscientists.2.Besoberinthecost-benefitanalysis:Don’tweighttheindustrysidefornationalsecurity.3.Therealurgencyisclimatechange,andtherealcostislostR&I)opportunity.Refocusindustryresourcesonrampinguprenewables.4.Updatethenumbers.5.Cumulativeimpact.6.Don’tmesswithMotherNatureuntilwereallyknowwhatwearedoing!Ithankyoufortrying.Thankyouforclaimingresponsibilityforoneofthesoaringenvironmentalandpublichealthissuesofourdecade.,Andthankyouforhelpingustomakethispublicrecord.

4L/Goodluck!Godblessyourwork! a4ElizabethAComeaux,ColoradoAttorney#8674FormerChiefAdministrativeLawJudge01’StatePersonnelBoard,retiredfromColoradoDeptoflaborFormerProgramAdministrator.CenterforEarthJurisprudenceCo—Coordinator.LorettoEarthNetworkMember.Healthy(3ulfKrewe.(jullRestorationNetworLResidence221SouthOsceolaSt.Denver,CO80219720-379-7864libhvcomeau\ieniuileomTestimony

on IPA’s Proposed Rule for “Oil and Natural (as Sector: New SoUrce Performance Standards

and National Fmission Standards

for Hazardous

Air Pollutants Reviews” Docket Number

E PA—[IQ—OA
R—2() 10—0505; FRL—9456—2 Presented

by

l’ Ii zaheth Paranhos Attorney Consul (ant br Fnvironmeiital l)el’ense lund September

28. 2011 Public

I learing 1)enver, Colorado My name

is Ilizaheth Paranhos
and

I am

a consultant

br Environmental I)e1inse Fund (LI)F).

a non—partisan environmental organization

with more than 700.000 members nationwide.

11)1

is dedicated

to working toward innovative cost—effective solutions

to environmental problenis. building

on

a foundation

of sound science, economics.

and law. ‘[hank you fi)r the opportunity

to testify today. EPAs Proposed Rule for ne national clean air standards

for oil and natural gas represents

a critical step toward protecting public health and (he environment
from harmful

ai i’bome contaminants.

‘Ihe standards
will not only reduce

air pollution through highly cosi—eltective

air pollution controls.

hut avoid the needless waste ofa valuable domestic energy source

by preventing leaks and venting

of natural gas, the development of which

is expanding briskly across the

( 1.5. Further, they will standardize many common sense practices
and technologies already implemented

in states such
as Colorado

and Wyoming. and that are being used by many natural
gas companies throughout

the country. Strong
air emission standards

are vitally important

to protect human health and the environment Oil and gas exploration

and production

is rapidly expanding

into new locations across diverse portions

of the country
due
to technological developments

that have made extraction

of previously untapped unconventional resources,
such
as shale gas. feasible.

‘I he lack of adequate national—level emission standards pOSeS

a serious threat

to people and communities across the I. J.S. since exploration

and production activities emit

a number

of hazardous

air pollutams

and other airborne contaminants known

to negatively affect human health and the environment.

For example. wintertime ozone levels

in excess

of the nations health—based

air quality standards have been recorded

in remote parts of Wyoming

and

1. Jtah, where little industrial activity other than oil and gas production occurs. l’he high exceedanees

in these rural, previously pristine. pails of Wyoming

and tab are higher than levels recorded

in some
of’ the most heavily polluted cities. Further,

oil and gas activities

are the largest source

of’ U.S. methane emissions

i potent greenhouse

gas itli

a warming potential

25 times that of’ carbon dioxide over the long—term
(100 cars) and 72 times over the short-term

(20 years). The good news

is that there are existing, cost—effective solutions

at hand. LPA’s proposal builds from regulations already

in place

in states such
as (‘() and WY. Further. lPA.

in cooperation

# with oil and gas companies,



# has identi tied more 

# than

1 (tO technologies

and best management 

# practices

to reduce CiliiSSiOiiS 

# froni upstream WtivitieS,

a number

of which flwm the basis for EPA’s proposed rules. These technologies 

# reduce gas losses. resulting

in greater recovery
and sale of iiatural gas, and thus increased economic gains-- 

# and the return

on the initial investment for 

# many

of these practices

is someti lies
S short



# as

a t\v months and almost 

# always less than 

# two years. Smart 

# standards would ensure that our domestic resources

are 

# being used wisely. EOF supports ElA’s proposal
and recommends

it be strengthened EPA’s proposal

is an important
first step
in securing cleaner

air and more efficient industry practices.

It goes

a long way toward capturing

the multiple benefits achievable through
the implementation

of readily available technologies

and practices.

I lowever.

we believe that the standards could
be strengthened.

We are concerned

that the proposal fails
to reduce emissions from many existing 

# sources—— 

# as
a result. these sources will continue

to contribute

to unhealthy levels
of air pollution

for years

to come. EPA has also declined

to reduce methane emissions directly. While reductions

in this potent greenhouse

gas will occur

as
a co—benefit

of compliance with niwiy

of the proposed requirements. additional opportunities

to prevent waste
of natural gas. which

is primarily comprised

of methane, exist, hut were not included

ill 

# tile proposal.
EF)[’ applauds EPA’s efforts thus far. hut calls on the Agency

to address these concerns

in order

to 

# achieve greater health and environmental benefits
and reduce waste

of’

a valuable natural resource. Industr growth

is consistent with strong
air pollution regulations:

WY and (() We already know that achieving EPA’s proposed standards

is both possible
and cost—effective. The national proposed standards

are similar

to existing state—level regulations

in c’olorado

and Wyoming. where compliance

has not onl been feasible.
hut has been accompanied

by healthy growth

in the oil and naturai gas industries.

As explained yesterday

by Senior EDF economic policy analyst. Susanne Brooks

at the Pittshurg public hearing,
the industry

in both states has experienced considerable growth despite
the adoption

of state air pollution standards comparable to those proposed

by EPA.

In fact. man’
of the standards implemented

in (‘0 go further than those proposed

by EIA by requiring reductions from existing sources. Specifically: Existing gas—actuated pneumatic controllers located upstream

of gas processing plants

in areas out ol attainment
with the national health—based standard

for ozone must
be low—bleed.
Reg.

7. XVII. Elsewhere

in tile state. repaired devices must he low-bleed. (0GC(’ rule 805(h). • Existing natural
gas processing plants

in ozone nonattainment

areas must comply with the same federal leak detection
and repair standards
that apply

to new sources. Reg.

7. Xll.(i.3. • Existing produced water tanks with the potential

to emit

5 tons per year of V0(’s located

\ 

# ithin

a quarter mile
of certain public places

in the Piceance basin must control emissions

by 05%. (0(i(’(’
rule 805(h). In addition. Wyoming requires control

of emissions from certain sources
not sLibject

to EPA’s Proposed Rule, such

as pneumatic punips. produced \ater tanks and separation vessels.Wyoming

a SO requl res 98° control

ol emissions liom storage‘ essels instead

of 5% proposed by IPA. One area where 1PA’s proposal adds additional protections

(or (‘oloradans

and residents

of’ Wyoming

is with respect

to fugitive emissions (mm compressors which are not control
led under either state’s
air programs. In conclusion,

it is vitally important

for EIA

to enhance
the emission standards applicable to the natural
gas and crude
oil sector. These standards

will better protect families, communities

and the environment. Solutions

are not only available.

hut cost-effective,

and they can prevent
the waste

of
a valuable domestic energy resource.
L’L)l looks ior\\ ard t(i submitting more detailed comments

on the Proposed Rule

to liPA. ‘(‘hank you again tbr the opportunity

to testify’.

I am happy

to answer
an’ questions.

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-z 

# —My name

is Keli Kringel and

I am from La Veta, Co. There

is nothing technical

I can tell you that the EPA doesn’t airead know about the health and environmental threats presented

by natur gas fracking. Your website
has

a wealth oinformation,

for exampli the health hazards

of benzene. I also have no horrible personal experience

to share here, regarding ill effects

oil and gas operations have had on my health,

air or water YET... although

I know personally,

and oçmany people who do. If did,

I would

that even my one story of getting sick would

be enough

to warrant serious investigation

and action. The massive

ou of problems from fracking, including some serious health problems, cause and scope
of which are not fully understood,

by being ignorec starting

to make this situation appear nearly like

a form of genocide our nation. I also do not have the balance sheet

to prove the monetary costs

to

c side or the other of this regulatory change,
yet when

I read the EPA mission statement

“to protect human health and the environment”... have

to think that the money should

be

a main consideration

for EPA. It’s not theirjob..
The EPA

is one agency
the public should

tr to understand thealue

of clean air to breathe and clean water

to dri which ultimately

are the bottom bottom line to all living creatures

oi this planet. So all

I will do is thank you for proposing these regulations,

and sa that

I think you should

do them... and take the opportunity

to tell ye about what brought
me here, and request your help
to make things

n secure and protected

in the future. The town where

I live, La Veta, CO,

is a town of about 900
in Hueri County,
one of the least populated areas of the United States.
To giv you an idea, the nearest Starbuck’s

is over an hour away! Wildlifeabounds. People stop and talk
to each other. There are no traffic

li There

is no need

to lock your house

or car. We have no Walmart,

n PetSmart,

no Officemax,

no Old Navy,
no Sports Authority,

no Tar What we do have

is a real main street with real mom and pop shops great library, good school, and

a lovely park.

I have heard

it descril as “Colorado

like

it used

to be!” We have gorgeous scenery,
and

ti’ ability

to be self-sufficient

if we want to. Our air is sweet and pure, we can see the stars- lots of stars- at night from anywhere

in town People come from other places

to get away

to here, for example

fro Texas

to escape the air pollution problems experienced
from frackir and drilling there. We do not want

to lose the beauty that we have. do not need
to be dependent upon oil and gas. We want the opportui to pursue our own local riewable energy sources en-a ssnRllI .:.icto grow our own healthy, local foods— I am here representing Citizens

for Huerfano Count

a non-profit

ti formed

in response

to the threa yfl Ofl recently propo drilling and fracking

in our area. The unique geology

of our area
(r dykes) suggests hydraulic fracturing

in this area may be especially dangerous,

or at least worthy

of further study. The permitting proce for Shell’s first exploratory
well, 14,500

ft deep Klikus 2-19, occurr May/June under the radar, without public knowledge

or input. We are currently

in litigation with the COGCC, Neslin, and Shell ii claimrights

to public input and hearing and demand’f?] our very real environmental,
health and safety concerns satisfactoril’ iehavebeeduti:thbllSo,onespecificcommentIhaveisthatIbelievethatthegreencompletionrequirementsshouldalsoapplytoexploratorywells,i.e.factsheetsays:“Thegreencompletionrequirementswouldnotappexploratorywellsordel,inetionwells...,becausetheyarenotnearsalesline.“,t1€/*-oIdhw,Andgoingforward,Iwouldaskyouto1jdtoeliminatetheHalliburtonLoopholewhich,IL-tLrpJ..-,effectivelystripstheEnvironmentalProtectionAgencyofauthoritytoregulatefracking,processinventedbyHalliburton.YouachievedyourdreamofacareerattheEPAbecauseyouhadti’capabilitiesandtheheart.Thosecapabilitiesarewhatwillallowynavigatethecomplexitiesandchallengesinfrontyou.Butloveisvwillmakeyouultimatelyact.Iaskyoutoreconnectwiththatidealiinsideyouwhichbroughtyoutowhereyouarerightnow.Thiscouneedsthatspiritmorethanevernowineachandeveryperson.Pleaserestoreintegritybyfullyregulatingfrackin.Thankyou.DianeSchrackSeptember28,201110170CharissglenLaneHighlandsRanch,CO80216Dueto1)thelackofgovernmentoversight,2)the2004EPAdeclarationthatcoalbedmethanewellsposelittleornothreattodrinkingwater,3)the2005Halliburtonloophole,and4)technologicaladvances--hydraulicfracturinghasrapidlyexpandedwithouthavingtoanswerforitsdamagingenvironmentalconsequences.Thepublicisnowfacedwith:•Highergreenhousegasemissions,smog-inducingcompounds,andreleasesofneurotoxinsandcarcinogens.•Considerablyhigherlevelsofozoneandmethaneinourairandwater.•Increasedairbornepollutantssuchasmethanol,formaldehyde,carbondisulfide,tolueneandbenzene.•Spills,leaksandaccidentswhichpolluteourwaterwaysandcanleachintoourdrinkingwatersupplieswithcontaminantsthathaveincludeddieselfuel,chloride,sodium,barium,strontiumandhydrochloricacid.•Frackingwastewaterwithradioactiveelementsthatendupinourriversduetoinadequatemunicipalwastewatertreatment.•Shorttermeconomicgainsforcommunitiesthatultimatelyturnintolowerpropertyvalues,heavytrucktrafficwithcostlyroadrepairs,safetyhazardsfrompossiblepipelineexplosions;harmtolocaltourismandrecreationindustries;andscenicviewsreplacedwithdrillingrigs.•Farmerandrancherlivelihoodsatriskbecauseofozoneandfrackingchemicalsthatpollutetheircropsandlivestock.•Theuseofenormousamountsofpreciouswaterinthefrackingprocess.•And,apossibleincreaseinearthquakesduetofracking.Thepublicisconcernedabouttheseissues.Oilandgascompaniestookunethicaladvantageofthelackoffederalandstateoversightoftheirindustry.NowtheEPAseemstobetryingtoputtheirfingerinthediketospaleakwithoutaddressingtherealissue--whichisthefactthathydraulicfracturingisnotsafetobeginwith.Therearenumerousvalidstudiesandinvestigationsthathavedemonstratedthehazardsoffracking.Thisevidencecannotbeconvenientlyignored.Frackingisanunacceptablerisktopublichealthandourenvironment.Ourcommunitiesarebeingsurrounded.IntheDenvermetroareaalone,drillingisactiveorproposedinWeld,Douglas,Arapahoeandothercounties.Partofyourproposalevenappearstoincludestepstoreducecomplianceburdensforindustry,state,localandtribalagencies.Reductionsincompliancedon’tsoundgoodtothepublicwhohastolivewiththenegativeconsequencesoffracking.Yourproposaltocutsmog-inducingVOCemissionsisadmirablebutitdoesnotgofarenoughforthepeoplewhobreathetheair,drinkthewaterandeatthefoodfromourfarmsandranches.Andwiththerecentexpansionofshalegasrigsacrossthecountry,productionwill--withinafewyears,probablyexceedUSdemand.Yourjobisnottoplacateandenablefutureprofitsfortheoilandgasindustry.ThepublicdemandsanddeservesmorefromourEnvironmentalProtectionAgency.Wethepeopledon’thavethemoneyandpowerthattheoilandgasindustryhas.Wedon’thavetheresourcestomakeslick,disingenuousadsliketheydo.Wehaveyou--theEPAtoprotectus.That’showimportantyouare.Wearesickandtiredoftheoilandgasindustryviolatingandprofitingfromourpublicrighttoahealthyenvironment.TheEPAneedstobanfrackingbecauseitpresentsariskofsignificantcontamination.Therearebetteroptionsoutthereincludingseriousresourceconservationandsubstantialsupportfordevelopmentofrenewablealternativeenergysources.Youaretheagencythathasenvironmentalprotectionasyourmandate.Youholdourhealthandenvironmentwithinyourhands.Pleasedotherightthing.enerus U.S. Operations— Eastern Business
Unit Appalachian District 1700 Lincoln Street, Suite 1300 Denver,

CO 80203 (720) 279-5500

Public Hearing: United States Environmental Protection Agency Docket

ID Number,
EPA -HQ-OAR-2010-0505 Federal Register 52738, Vol. 76, No. 163; Tuesday, August 23, 2011;
40 CFR Parts
60 and 63 Hearing Location: Colorado Convention Center 700 l4 Street, Room 207 Denver,

CO Prepared

by: HRL Compliance Solutions,

Inc. do Jason Rauen 744 Horizon Court, Suite 140 Grand Junction,

CO 81506 970/243-3271

/ 970/270-8733 jrauen@hrlcomp.com Date: September

28, 2011Docket

ID Number: EPA-HQ-OAR-2010-0505

September

28, 2011 EPA

is
6 months

to one year. Our estimates predict

a range more

in the area of one to five years depending upon the technological/operational

changes made. This could place

a significant financial burden

on industry which contrasts with the goals
of the current administration

that advocates

for energy security, energy independence

and affordable energy. The regulatory proposals made
by the EPA which were published

on August
23, 2011,

in the 76 th volume

of the Federal Register (FR) number 163, are for the most part fair initiatives

to perpetuate

the EPA’s and nation’s dedication

not only
to energy independence

but also
to the environment

that supports
our society and life. However,

I do urge the agency (EPA)

to consider all proposed regulation with extreme care and sensitivity

to ensure the assumed environmental benefits

do not come

at too grave

a cost- economically

and socially. Energy sustainability

is three pronged.
Not all harm that befalls

us is generated from the direct impact

on the environment; secondary

and tertiary effects can do as much

or more harm from those excessive actions which were intended

to prevent harm. One example

of this would

be the reckless implementation

of regulation which would hinder

an industry which energizes

the nation

in
a time of economic hardship;
nay

I say recession

or identify
the social

or additional economic implications

of such. Enerplus believes some assumptions made

in the proposed rules have led to higher emission rates and lower emission thresholds which unnecessarily triggered NSPS

or NESHAP compliance requirements

for equipment

and operations. Even

in cases where additional compliance requirements

do not occur there

is
a significant
cost
to industry

to implement meters and monitoring programs

to demonstrate non-applicability

to the proposed regulations.

An example

of such can be reviewed when looking

at the proposed regulations

for condensate

and crude storage vessels (i.e. throughput volumes
and emission factors). Another, upon reassessment

of the MACT standard imposed

on storage vessels may reveal the unnecessary regulation

of numerous appurtenances when the data set is examined

and emissions calculated

as two independent

data sets;
as defined by the physical
and functional characteristic differences between tanks with versus those without the Potential

for Flash Emissions (PFE). Enerplus appreciates
EPA intent
of the proposed
and subject regulations

and urges the EPA

to sincerely consider

the comments- good and bad -which have been made
by myself,

all other oral presenters

and those providing comment

in written

or electronic form. Thank you for your time and thank you for giving me time
to express Enerplus’s concerns about the proposed rules. Enerplus Resources
USA Corporation Robert Bleil, Regulatory Coordinator,

US Operations

Page

2 of
2Docket

ID Number: EPA-HQ-QAR-2010-0505

September

28, 2011 My name

is Jason Rauen.

I am

a Colorado native and

I have worked

in the environmental

field both for industry
and as
a consultant

to industry.

I am here today
on behalf

of Enerplus Resources USA Corporation.

I have

a B.S. degree

in Environmental Science and Technology

and a Master

of Applied Science

in Environmental Policy and Management

with

a specialty

in Energy and Sustainability.

I have worked with and for the natural gas industry now for more than seven (7) years and in that time

I have become very knowledgeable
about the regulations

that govern
the oil and gas industry

on the federal level, several states

in the southwestern

and northeastern United States and numerous counties within those States. I am

a proponent

of responsible energy development, efficient
and sustainable

use of natural resources,

and diligent environmental stewardship

of those entities which are developing

the resources
that are fueling our nation’s economy
and energy demand. Enerplus

is steadfast
and dedicated

to environmental stewardship

and comprehensive regulatory compliance.
With that being said,

I am also

a proponent

of effective
and efficient policy which facilitates

the responsible development

of our energy resources. Policy needs

to guide, not hinder

or confuse, the people who are on the ground carrying
out the day-to-day tasks which support
the nation and drive
us towards achieving

our national energy goals. And that policy needs

to be founded upon logical and scientific principle. There

is
a significant amount

of benefit and sustainability which can come out of these proposed regulations

if the language
can be modified

to better align some of the values stated for emission factors

or thresholds

and the monitoring, metering, recordkeeping. reporting,

and notification burden can be lessened

to

a level that

is practically achievable. To caveat,

I am sensitive

to the fact that superfluous regulation

can stifle
or all out suppress
not only the health and vitality

of the economy

but also threaten
the security

of our nation with regard

to domestic energy supply, employment sourcing
and the intended environmental benefits the regulation

set out to facilitate.

A prime example

of this was demonstrated
when the Colorado Oil and Gas Conservation Commission (COGCC) rules and regulations- governing

oil and gas exploration

and production

in Colorado -were given

a complete overhaul

in 2009 just
as the Environmental Protection Agency (EPA)

is doing now with Parts
60 and 63 of the Title 40 Code of Federal regulations

as pertaining

to New Source Performance Standards

and Air Toxics Standards

(i.e. NESHAP). Burdensome regulation which creates permitting gauntlets.
and daunting recordkeeping, monitoring, reporting, metering, notification hurdles,

do little

to improve

the quality

of life and protect
the environment;

they create undue burden

on the American people and American government.

This perversely

hits the pockets

of the American public

as much

as it does the pockets

of the oil and gas industry creating

an innocent casualty

for little

to no gain. While Enerplus

is not opposed

to increased capital expenditure

to be environmentally responsible

and regulatory compliant when reasonable

and practical,

the magnitude

of capital costs which the proposed regulations brings

all at once

is quite staggering. As the EPA has stated, the annual capital cost of complying
with the proposed requirements would

be $754 million annually

in 2015 dollars. The expected payback period, according

to the Enerplus Resources
USA Corporation Robert Bleil, Regulatory Coordinator,

US Operations

Page

1 of
2EPA Hearing September

28, 2011, Denver,

CO Jan Bennett 2991E

W 81st Aye, Westminster,

CO 80031 I’ve lived

in Colorado

for more than 60 years. Colorado
was once

a place where people came for recovery from lung diseases, asthma and TB. Now

it is the last place you would want

to go. People
are leaving the rural areas like Rifle and Silt because
the emissions from the natural gas industry

are harming their health and killing their animals.

It is unfortunate

that environmental control over the oil and gas industry
has dissolved under the lobbying efforts

of this special interest group that cares nothing
for the health

of citizens affected

by the current energy craze. During
my life in Denver there was one brief patch
of blue sky that broke through
the brown cloud.

I live
in Westminster

and look down
on the city from 84 th Avenue

& Federal Boulevard. From there you see the sludge
we call air fired by plumes

of smoke arising from the Conoco refinery. Why

is there

a refinery

in the middle

of our city?

I volunteer

at St. Anthony North where
we can watch the clouds blow downtown from the cafeteria.
One morning while driving

to my job
at the capitol

in the early ‘80s the ground beneath

my tires literally shook.

A disgruntled employee blew up the Conoco plant. Turned out to be

a breath

of fresh air. For the two years

it took
to rebuild,

we again saw the pristine blue skies

I remembered

as

a child. What regulations
were placed

on the rebuilt plant?

I’ not sure, but

I read that they were slim to none. I am not an expert

so

I do not have

a lot of statistics

to burn. You have probably heard most
of them already. How much the citizens

of Colorado

are being affected

by the current plethora

of oil and gas wells, the chemicals such
as Hydrogen Sulfide, Benzene, Toluene
and other carcinogens being released into the air, the destruction

of the ozone. We have become used
to caving into industry

on every level. Corporations— oil and gas and banks— have become
the darlings

of government, promising

us pampered lifestyles
and jobs.
At what cost? Why must we sacrifice
our health and see destruction

of our natural resources because

of
a corporate culture cult?

I take the bus, and

it adds
an hour and

a half to my workday.

I work

in the Golden Triangle
and every day

I see

it coming closer

to

a town

in Belgium where bikes are the primary choice

of transportation.

I cheer

all those who make choices that may include sacrifices
but include

all others
on the planet

in their decisions.

I love the free bikes Denver provides
and see them zooming

up and down the Platte which now resembles Boulder Canyon. There are alternatives

to destroying

our mountains,

our cities and the health

of our children

in
a mad pursuit

of more and more energy.
We need greener forms

of energy.
We need sustainable houses and electric cars.

In the future this will be our only choice,

as the oil and gas are finite sources

of energy. Why not make the leap now and realize these dinosaur mega-companies

are

a thing
of the past, draining
our economy with their government bailouts
and handouts.

We need
to take responsibility and limit our intake first of all. Second

of all we need
to make the decision makers aware that human health and prosperity

far outweigh

the profits

of greedy corporations

or the need for another bad behaving CEO for another golden parachute. I am adopted
and met my birthmother

in 1975,

a Hispanic woman from New Mexico. Investigating

on the web

I recently found 342 ancestors from Spain, the Zuni and Taos Pueblos along with plains Indians

1who were captured

as children then given their own town
of Abiquiu.

My sister and

I had our mtDNA tested. Mitochondrial

DNA reveals who your mothers’ mothers were almost

ad infinitum.

We belong to the” Cl” haplogroup,

one of the five—and probably oldest—of Native Americans. Generations

of our mothers roamed hereabouts, building Pueblos, Chaco canyon, Mesa Verde and before that pithouses, fighting wooly mammoths

in the Pleistocene.

I feel

I owe

it to them

to take this brief digression. Among
the books

I read about these hardy survivors
was one explaining

the Pueblos who have made

it through three regime changes: New Spain, Mexico, then the US.
In Anasazi America’ David

E. Stuart explains
the anomaly

of the Pueblo Indians being able
to maintain themselves continuously

in their original habitats. When we visited the Taos Pueblo they explained their survival strategy: “We care about corn stalks, not the stock market.” The same solutions they have found are sadly missing

in what will likely prove

to be our lack of survival.
The Pueblos
see themselves

as fragile. We deny any such weakness.
The Pueblos saw their strength

in their community; sharing wealth, lending

a helping hand, feeding and clothing each other and realizing

we are all in this together.
Not so US.

It takes 400 of the richest

to equal 150 million

of the rest of US and our “representative” government continues

to be bought
off by the spoiled demands

of the wealthy

at

a rate that

is bankrupting

US. This continues exponentially
from the corruption
that alarmed
the outspoken Maria Amparo Ruiz de Burton. “God
of Justice,

is this right, that so many should

be sacrificed because

a few men want more millions?”

She wrote this
in the 1880’s and further provided

a solution:

“It seems now that unless the people

of California
take the law into their own hands and seize the property

of those men, and confiscate

it to reimburse

the money due to the people,
the arrogant corporations

will never pay. They are so accustomed

to appropriate

to themselves what rightfully belongs

to others, and have
so long stood before the world

in defiant attitude, that they have become utterly insensible

to those sentiments

of fairness animating law-abiding
men of probUy and sense ofjustice.

“i” Denver

is 20% higher

in pollution than the average

US city’. Just
as the people

of Bolivia had to resort to revolutionary tactics when
US companies bought their water and made them pay to stay alive we must realize that our Colorado

air sustains

us and

is being appropriated

for short-sighted,

low yield, highly destructive energy production
that makes

a few rich while destroying

our natural resources
and leaving

a barren planet for our children.
We don’t need thousands

of more
oil and gas permits issued. The damage done from the last 23,000

is obvious. Groundwater
from the time of Christ

is being contaminated. Energy

is to be used by people; people
are not to be sacrificed

for energy.
We must limit exploitation when human health

is endangered

and realize
we are fragile people and our resources

are finite. The environment
must be protected

and

it will protect

us. ‘Anasazi America, David

E. Stuart, University

of New Mexico Press, Albuquerque,
2000, pp. 187 ff. The Squatter and the Don, Maria Amparo Ruiz de Burton, Arte Publico Press,

H ouston, 1977,

p. 335. Ibid.,

p. 338. 1 http://www.areavbes.com/denver-co/hea

fth-safety/

2Thankyoufortheopportunitytohavemyconcernsaboutthisvitalissueheard.Thenameofyouragencyincludesawordthatverysimplyaddressesaneedthatwe,asbothcitizensandhumanbeings,have.Thatwordis“protection”andyouhavetheauthoritytomakedecisionsthatensurethatyouindeedprotectourairandourwater.Theenergyindustrylikestoframetheissueofyourprotectingusinsimple,childishterms.Anindustrywhosecorporategiantseachyearpostrecordprofitswouldlikeusalltobelievethatwehavetochoosebetweencleanairandhavingastrongeconomy.Theywouldliketooffertheoptionofjobsorsafedrinkingwater.Theyspendmillionstoconvinceourrepresentativesoftheseassertionswithouthardevidencetosupportthem.SincetheEnergyBillof2005,craftedbyanoil-soakedadministrationwithnotableconflictofinterestsinthissensitivearea,recordprofitshaveaccompaniedreducedenvironmentalsafeguards.Thisraisesamostobviousquestion.Iftheoilandgasindustryiscapableofeffectiveselfregulationintheinterestofpublichealthandsafety,thenwhywasthereaneedtograntthemexemptionstoTheCleanAirandWaterActsthathavestoodsincethe1970’s?IrememberthegreatsatisfactionofwatchingPresidentNixonsignthesebillsintolaw.Thefeelingthenwasthatwehadputthisissuetorestforourlifetimes.Nowwewitness,somethirtyyearslater,afreshandvigorousassaultonourpreciousnaturalresources.Fuelingthisattackistheenergyindustry’shugeoutpouringofmoneyspenttolobbyfordegradationofprotectiveregulations.Ourairandwaterarenotcommoditieswhicharetobemanipulatedorsacrificedforcorporateprofits.Theyarevitalpublicresources,birthrightsofusall,asintrinsicallyprotectedbyintentionofourfoundersasourrightstofreespeechandredressofgrievances.Thehealthofourpeople,youngandold,presentandfuture,willdeterminethehealthofournation.Withoutaccesstocleanairandwater,ourfutureisbleak.Healthymenandwomengenerateideas,effectgrowtharidchange,anddiscovernewwaystodothingsbetter.Healthypeopleautomaticallyreducetheburdenonourmedicalcaresystem,whichhasbeenuniversallyidentifiedasabarometerofournation’smoralaswellasfiscalsoundness.CEOsandstockholdersofgasandoilcorporationsneedtobreathecleanairanddrinkpurewaterasmuchasanyofusdo.Ifwearecorrectinourdemandstohaveyouragencybolsterthedefenseagainstpollutingourresources,thentheoutcomebenefitsallpeople,notjustenvironmentalactivists.Iftheindustryiswrongabouttheirabilitytoself-governtheiractivities,thenallofussufferpermanently.Thereisnotapricethatcanadequatelydescribethevalueofourwaterandair.Themoneythatoilandgasindustryspendsonpoliticalpersuasionalonewouldgoalongwaytowardimplementingrestrictionsandregulationstowhichwe,ascitizens,areentitled.OurdomesticresourcesareincreasinglybeingtargetedforexportinpursuitofnewmarketsandincreasedprofitswhileoilandgascompaniesgiveslipservicetoU.S.energyindependence.Pleasedonotcompromisethehealthofourownpeoplebyallowingtheeagernessofaboomingindustrytoexclusivelydictatethetermsoftheirownoperations.Pleaserememberthenameofyouragencywhenyouareconsideringyouractions.Youareapartofathinlineofdefensewhichcanofferprotectionfortheoverallintegrityofourenvironment.Yourfailuretoactaccordinglywillhaveirretrievableconsequencesforallofus.Pleaseseizetheopportunitytoelevatethenation’shealthtoitsrightfulplaceabovethebottomline.KennethSajdakP.O.Box1084LaVeta,Colorado81055)EPAl-leanng,Denver,ColoradoSeptember28,2011PowerPoint#1.ThankyoufortheopportunitytocommenttodayregardingchangestoEPAairqualityperformancestandardsforhazardousairpollutantsgeneratedduringoilandgasoperations.Requiringoilandgascorporationstocapture95%ofvolatileorganiccompoundemissionsusingproventechnologywillhelpreducemethaneandothernoxiousgasreleasesthatalsocontributetogreenhousegassescreatingclimatechange.ThiswillalsobeapositivestarttowardsprotectingthewelfareofColoradocommunitiesfacingserioushealthrisksassociatedwithoilandgasextraction.Iftheoilandgasindustrycapturedescapinggasses,itcouldbenefitfrommillionsofdollarsannuallyduringthelifecycleofoperations.Increasingairqualityregulationsfornaturalgastransmissionandstorageisanimportantproactivemeasure.PowerPoint#2Coloradohasexperiencedarapidincreaseofoilandgaswellpermittingduring2011.Withapproximately35,000activewellsstatewidethereareotherseriousissuesfacingColoradoresidentsconcerningairqualityimpacts.Manydrillingandhydraulicfracturingoperationsareliterallyinhomeowner’sbackyardsorclosetoschools.Manyresidentscomplainofhealthimpactslivingincloseproximityordownwindfromwastewaterevaporativedrillingpits.Coloradoresidentshavereportednosebleeds,headaches,nausea,brainlesions,eyeinflammation,asthmaorrespiratoryproblemsandotherheathrelatedissueswhenlivingnearopenoilandgaspits.PowerPoint#3and#4Thepracticeofwatertrucksspreadingproductionwastewateronruralroadspresentsseriousconcernsforcommunitymemberswhereoilandgasdevelopmentisoccurring.Thousandsofgallonsofuntreatedwaterisusedto“suppressdust”onbackroadsthroughoutColorado.Usuallythewaterevaporatesafteramatteroftwohoursandresidentscomplainthatthedustcloudthenseemstoincrease.Whatparticulatesbondtothefinesilicaondirtroads?Whatthenarelocalpeoplebreathingwhenlivingneartheseroadsortravelingalongthem?PowerPoint#5RecentlyShellOildisclosedtheirintentiontoflareanexploratorywelloperationfor45-60daysjust2.5mileswestofthetownofLaVetalocatedinSouthernColorado.TheprevailingwindblowsinthedirectionofLaVetafromthewest,whichwouldexposeresidentstotoxicemissions(suchasBenzene,Ethylbenzene,TolueneandXylenes),whichareknownorsuspectedofcausingcancerandotherserioushealtheffects.LaVeta’seconomicwellbeingisdependentonseasonaltourismfromneighboringstatesandlocaltrainrideadventurers.DegradationofsouthernColorado’slandscapeandairqualitywouldseriouslyreducetheeconomicstabilityintheregion.WecalluponourelectedrepresentativestoprovideadequateappropriationstofacilitatetheEPA’seffortsprotectingpublichealthandtheenvironmentforthewelfareofColorado’scommunities,ourchildren,andfuturegenerations.FundingmustbeadequateforcomprehensivemonitoringandregulationtoguaranteecleanairandprotecttheconstitutionalandhumanrightsofallofourColoradocitizens.Iknowthepersonalsufferingofhomeownersandranchersimpactedbygasandoiloperations,firsthand.Isufferedfromnosebleeds,headaches,andinflamedupperpalletforthreeyears.IhadtobreathethebluehazecontaminationduringhydraulicfracturingandthetoxicfumesfromfoursurroundingpitsforthreeyearsuntilIreceivedasettlementfordamagesonmyranchfromdrillingandlaterfromwhatIbelievewasfromhydraulicfracturing.Ilivedinthetackroomofmybarnwithoutwaterorfacilitiesandlostmylifesavingsasateacherduetogasextractionimpacts.UptonSinclaironcesaid:“liisdfflculitogetamantounderstandsomethingwhenhissalarydependsuponhisnotunderstandingit”.GopaRossSiraClubThe Hydrology Company for a Gas CorporationStated That The Water Used in “Dust Mitigation” onCounty Roads was “Proprietary” Information.What Are The Members of This Community Breathing?What’s Wrong With This Picture?EPA HEARING COMMENTS DENVER SEPTEMBER

28, 2011 Who am

I Hello, my name

is Dave Devanney. Where

I am from I come

to you today from Battlement Mesa, CO- a community

with

a current population of about 4400 residents,

in unincorporated Garfield County

in western Colorado. Who

I represent I am speaking

to you on behalf

of the members

of Battlement Concerned Citizens- a grass-roots group

of BM residents who have for the past 2+ years been advocating

for responsible

NG drilling practices
and health and safety based regulation

of the energy development industry. This action was taken after

a NG operator announced plans

to develop

up to 200 wells
on 10 well-pads within our PUD boundary. Some

of those well- pads will be as close
as 450’
to residences

and two of them will be located

on our golf course (...talk about

a hazard...). For the past two years some

of our residents have experienced

the negative impacts from NG drilling operations

in the area just outside
the PUD boundaries. Many significant impacts were experienced

in July of 2010 due
to odors from the fracking flow-back

at
a well-pad just outside
our PUD. More recently another well-pad

in the Town

of Parachute

and near some BM homes has caused particulate pollution
due not only
to dust from traffic and site-prep work but also from the handling

of the sand used in the fracking process. With

a large retiree population, many residents already complain

of respiratory problems

of unknown origins. Additionally,

I know
of one person, who

I have lived with for over 43 years, but cannot identify due
to HIPPA regulations,

that has recently found that she has higher than normal levels

of mercury, barium and lead

in her blood.

Of course
we don’t know the cause

at this time, and will probably never know, but can only speculate about the increasing exposures

to
a more toxic environment. Why

I am here I’m here
to say that while these new regs. are necessary

and long over-due, more could and should

be done. First,

I recommend

that Hydrogen Sulfide

be more carefully regulated.
H2S has recently been acknowledged

to be found

at well-pads

in Garfield County. Whether biogenic

or thermogenic,

the presence

of potentially lethal H2S

is a major health concern- for the public and particularly industry workers. Also,

I have personally observed
and been exposed

to H2S
at the private water well of a residence

in Garfield County
but not
in BM. Shortly after NG drilling began near thishome, the water became foul and contaminated

and ultimately came

to smell like rotten eggs. As

a member

of the BM Bucket Brigade,

I was able
to collect

an air sample, outside
the home next
to
a running water faucet and sent
to
a lab for analysis.
The results showed an H2S level
of 370 ug/m 3- a level that

is 185 times the long-term level set by the EPA. Second,

I would recommend
more strict controls

of particulates
such
as road dust and the dust from tracking sand be considered.

The health effects may not be clearly known at this time but certainly warrant further study and potential regulation. And finally,

I would like to see the EPA recognize
and support
the use of citizen initiated and cost effective

air monitoring methods such
as the “Bucket Brigade”

as developed

by an org. called the Global Community Monitor. Their recently released report highlights the air pollution hazards from NG drilling that are currently present

in Colorado
and New Mexico, using citizen volunteers

and low-cost sampling equipment.

I understand

that the staff
at EPA Region

9 has reviewed
and tested the methods used by the “Bucket Brigade”
and found them satisfactory.

The data collected

by

a “Bucket Brigade” would be used
as

a screening
tool and

a supplement

to more standard methods that may not be available

at the time
of an odor event. Thank you and acknowledge I want

to thank the EPA first of all for taking the necessary steps

to develop new, more stringent
AQ regulations

to help protect public health and also for the opportunity

to present public comment here today.

In these difficult financial times, some are calling for less bureaucratic red-tape that can hamper industry and job creation. While

I can support more health and safety-based regulations,

I also would advocate

for more jobs in the monitoring

and enforcement

side of energy development. I understand

the need for NG
in the short-term

and less fossil fuels

in the long run.

A cleaner burning fuel can only help
to bridge the gap between
our current energy crisis and

a more energy independent nation

in the future. But let’s not mortgage

our energy independence

with the health

of our nations citizens.The HIA One of the more significant achievements

of our group was
to convince

the county commissioners

to initiate and fund

a Health Impact Assessment

or HIA. This HIA was

a relatively new process used

to assist decision-makers

in making health-based choices when industry comes into

a community.

The Colorado School

of Public Health

at the Univ.
of Colorado produced

a draft report that included
the following statements: The principal findings

of the HIA are that health

of Battlement Mesa residents
will niost likely be affected

by chemical exposures. accidents emergencies resulting from industry operation.;. and stre;srelated conununitv changes.

To address these potential health impacts.

we provide The Human Health Risk Asses silent used information
from

a variety

of sources

to conclude
that natural
gas processes release chemicals
that are known

to impact health: chemicals emitted into the air from natural
gas processes

are more likely

to impact health than chemicals released
into the water

or the soil: exposures from
air emission;

are likely

to be highest during well completion activities:

and residents living near

a well pad ,defined

as within mile are more likely

to experience health effects than residents living farther away from

a well pad ‘:defined

as greater than mile). For decision makers.
the prima.rv value
of

a risk assessment

is in its capacity

to rank the re1ativ inagiinude

of exposures

and prioritize actions.
The Battlement Mesa Human Health Risk Assessment identifies which airborne chemicals most likely

to impact health. This infonnatior ran help guide decisions about where

to focus pollution prevention efforts. Since the risk assessment indicate;
that
in Battlement Mesa exposure

to chemicals

in the air
is more likely

tc occur than exposure

to chemicals

in the water

or soil, method;

to reduce

air pollution

anc monitor

the air hiniild
he the foni;
of current and fliflire nohlution nrevention Obviously

the researchers

and academics

at the CSPH knew
all to well the risks

to human health posed

by current
NG industry practices. Many

of the more than 70 recommendations

that were made were

to minimize

air pollution. Unfortunately,

the HIA project was terminated before

it was completed.

It has been stated that the claims

of bias, resistance

and threats

of legal actions

by the O&G industry caused the county

to pull the plug on the project. Subsequent efforts

to obtain EPA grant funds

to further study
air pollution

in the Battlement Mesa area have been thwarted.

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# NHello, my name

is Lisa Willis.
I’m

a Denver resident,
and

a cancer survivor.
The doctors couldn’t
tell me why

I contracted renal cell carcinoma.

I had

a kidney removed, which did the trick— but

I know firsthand that cancer

is very painful
for

a person and her family.

I don’t want anyone else to get it, especially

if it can be prevented

by taking extra care
to stop deadly chemicals from being

in our drinking water! I’ve read some articles about fracking. There

is a danger

of carcinogens ending

up in drinking water.
I’m old enough

to remember congressional hearings where the big tobacco executives stood and swore that smoking

did not cause cancer.

It was later proven that they clearly knew otherwise. Things are different today— we know that chemicals

in cigarettes cause cancer. We’ve identified

a lot of chemicals
that cause cancer. Some
of these chemicals

are used
in fracking.
I’ve noticed

an energy company’s

TV ads lately about fracking. They’re great commercials,

very reassuring.

To hear them tell it, fracking

is the safest thing ever. But they don’t tell you that there are already documented examples

of contaminated drinking water near fracking locations.

So you’ll forgive
me for doubting their good intentions.

It’s an historical
fact that corporations aren’t

as keen on protecting the public

as they are of making profits. There

is a danger

of these chemicals being spread into drinking water

in the fracking process. From what

I understand, when the fracking

is complete
and the pipe

is pulled out of the ground,
the toxic chemicals they injected down there are leaked into the ground

as wastewater.

This wastewater

can leak into wells and other drinking water and

is very hard to get rid of. You can’t just clean

it up. Methane

gas can also be brought

up and actually leaked into wells! This could make homes explode.

It doesn’t
get much more dangerous than that.

I think we’ve
all seen the TV footage

of people setting their drinking water from their faucet
on fire after fracking

in their area. That paints

a more vivid picture than the illustrations

in the gas company commercials. I know that natural
gas is
a big part of our future,

as we move away from coal. But these dangers haven’t been studied enough. Fracking isn’t well-regulated

or even understood

by local governments. That’s the purpose

of the EPA— to protect
the public against health and environmental threats. You do

a good job. The United States

is a much safer place because of the EPA. It’s your job to investigate

this method

of getting
gas out of the ground and just make sure it’s safe. It’s your job to make sure that energy companies follow the strictest safety regulations

as possible.

I believe

it’s your duty
to protect

us against
the threat

of dangerous chemicals

in our drinking water and our lands.

By doing
so, you might well prevent other people from having

to learn what it’s like to have cancer. Thank you for your consideration. Lisa Willis— (303) 830-2209- P0 Box 181057, Denver,

CD 80218FordjSpasniiEPAHearingni..—ninafl_____________0EPAHearingInformationv4FRD’1:CGite,SryDe9CC:vnii:.vDenh,cherr.rr,o,innrcmHellotdernd,-.--Thankyovforyourinterestintakingpartw;LhtheEPAhearingerrairpo:lutinn1mmnitandeati,ratgasdrillingenWednesday,September26e,2011attheCeteradoCanoenbaeCenterinDenver(70014t’iStreetRoom207Denvnr)SigningUpItyounavenoralready,pleasecanhrmwhhmethatyouhaunsigneduptsra5minutetestimonyspatifnot,pieaovcontactMsJoanPoyerrattheEPAatyqLeEp.launyanrtovor)j9jj41-44eJtoreserveatimeThesnoneryoudothis,themaretauorubleatimeuvilbeavailableItyouareunabletoattend!pleaseseebelew,PreparingI’veattachedthreedocumentsforyourconvenience:-HowtoPrepareMyPublicComment-GeneralTalkingPaints•SackprovndWenailalsobeavuilableacrossthehallwayinRoam206whoreyoumayprepare,praDicoandbaseretreshments,LettertetheEditorI’vealsoattactiedaLeanttotheEditorTemplatepeacanpersonaliceandsubmittayourlocalpaper!ThinisimportanttogainpublicsupportaodIhighlyencourageyoutospendatewminutescreatingandsubmitdngone.UnableteAHeedItisbesttoryautophysicatlyattendandtestity,butitcircamstancespreventyoufrombeingpresentyoucansubmitycurcomments(labeledunderDecketIDNamberePA-t-tQ-0AR-2010-oSgg)totheEnvironmentalProtectionAgencythroughoneutthefollowingmethods1202!56e-744BryanCarterAssociateDrganizingRepresentativeSierraClubBeyeodCoat,Colorado1536fflinkespStreet,Suite46-6Denver,CDg0202I4133S(office)ZD143A.S02bell)—Attachments-.Page1of1SipsGutDytionsHelpUpgraaeteSuterlbsrcri-Moil)td7!Yahoo!H4vDetutlbWndveoday.Suycnnour21,2bttIt3PMtebeuII1°Drabs4SentSpam06CTrash40FetdnrsApptieetiensA:!MyPurchasesAcacnLargePilesAutomahcDrganicerCalendarEditPhotosEvitePlickrMyCoalPostsMyDoveNotepadStationeryUnsubscnberWake--upyourskin!:J,z4nDoline’•PederaleRulamakingPapal.hde’lywwwregulationsgay•FollowinstructionsfarsubmitbngcommentsAgenojWebsite:htle’l)cogoovioartdooket,hlmt•PotlauninstmctionstarsabmifflngcommentsentheAirandRad:atianDocketWeesite•E-mail.avundvcvocbobWa5agCe•tnclude‘DocketIDNumberBPA-HD-DAR-2g10-gSgdinsubloctlinerayMa:lAttonhonDocketIDNumberEPA-HD-DAR-2glg-gSgb1200PennsylvaniaAvenue,NWWashington,DC20460PleaseiocludeTWDcopiesandinaddition,pleasemailacopyofyourcommentsontheinformationcollectionprovisionstn:•DificeatlotonnrationendRegulatoryAtfaits,DtticeatManagementandBudgetAgo:DeskDfficerfortheEPA72517thStreet,NW,,Washington,DC.gggoDaestiaes?Ifyoubaneanyquesticns,pleasedun’IhesitatetocantactmeatBmce.cartertfflsierraclub.oroor303.4543364ThankyoufortakingaleadaothisimportantopportunityIlookforwardtomeetingyouthen!Sincerely,SryceCarterEPAGasAi..bPADesyj,,EPAGaset..bPADasdj.,9/28/2011Good Afternoon.

My name

is Anna Florey and

I live here

in Denver. I own oil and gas stocks.

In fact

a large percentage

of my portfolio

is energy stocks.

I have

a vested interest

in the profits

of the companies

I’ve invested

in because high profits mean money

in my pocket. To add more regulations

to the energy extraction process
will affect the amount

of money

I receive

as dividends. More importantly,

I am

a human.

I breathe

air and

I drink water. Extracting energy, especially

in the form
of fracturing
rock with high powered sand, water, and chemicals

to get to the gas inside the rock, is
a dirty process— a process that pollutes
the air with
all kinds
of noxious chemicals

like methane, benzene
and sulfur dioxide.

It pollutes

my drinking water and

it toxifies the air that

I breathe. Over time, that pollution
will cause me and my family

to be sick and possibly

die premature deaths. The oil and gas industry would have you believe that safeguards

and regulations

on their standard business process, that

is creating ever larger amounts

of pollution,

will impose

an undue financial hardship

on them. That’s just hogwash.

Oil and gas companies
have plenty

of money. They already receive unbelievable government subsidies.

In other words, the taxpayers currently
pay them

to pollute our basic resources
that we need
to live and stay healthy. The oil and gas companies
have very smart people working

for them. They can figure out how
to efficiently clean up their act, but they won’t
do
it without

a fight. And they won’t
do
it without strict regulations

and true government oversight
and enforcement.

Do not let them get away with raping our environment

any more than they’ve already done. They must be forced

to find

a cleaner way to do their business. It’s time for these dirty industries

to clean
up after themselves.

It’s time for them
to change business

as usual and standard industry practice. There

is no excuse
for the pollution
and resulting sickness that this industry forces
on us. Specifically, what can be done?
To begin with: • Any rule or regulation must require direct methane reductions

and controls. • Hydrogen sulfide

is a dangerous

air pollutant that

is currently ignored and not regulated.
This oversight must be addressed immediately. • The oil and gas industry must not be allowed

to “flare”

or burn-off un-captured

gas— that just creates more pollution. Even

if it means that

I as an investor must sacrifice money

in my pocket.

I as

a human will be forever grateful
for clean air to breathe.

I implore you to regulate
this industry

in the strictest manner possible. Thank you. Anna Florey annaflorey@gmail.com 619.929.4396Ke..i-t)’3V4dl1I(0II\(UI\SI.SLIII2710I))cviR.(:00264I’Iiiic303i(hI.IJ.2CoLORADO()I1.&GAS3X(1),SsucIAItoEPAPublicHearingOilandNaturalGasSector:NewSourcePerformanceStandardsandNationalEmissionStandardsforHazardousAirPollutantsReviewsSeptember28,20119:00am—8:00pmColoradoConventionCenter70014thStreet,Room207Denver,Colorado80202VerbalStatementColoradoOil&GasAssociationSubmittedbyAndrewCasper,RegulatoryCounselHello,IamAndrewCasper,RegulatoryCounselwiththeColoradoOilandGasAssociation(COGA).COGAisanationallyrecognizedtradeassociationwhosepurposeistofosterandpromotethebeneficial,efficient,responsibleandenvironmentallysounddevelopment,productionanduseofColoradooilandnaturalgas.Everyoneusesoilandgasonadailybasis.Consumptionofoilandgasisanessentialpartourlives.InrecentyearsColoradohasproventohaveasignificantamountofoilandgasresources.Recoveringtheseresourceswillbebeneficialbotheconomicallyandenvironmentallycomparedtoimportingthesegoods.TheproposedoilandgasregulationsareextensiveandcomplexamendingtwoexistingNewSourcePerformanceStandards(NSPS),twoexistingNationalEmissionStandardsforHazardousAirPollutants(NESHAPs),andintroducinganewNSPS.TheseproposedruleswillhaveadirectimpactonColoradooilandnaturalgasproductionandprocessing.COGAandourmembercompanieshavebeenreviewingthisproposedactionandhavethefollowinggeneralcomments.1)Becauseofthelargeamountofinformationpresentedintheseproposedrules,COGArequestsanadditional60daystoreviewtheseregulations.ThecurrentcommentperiodissettoexpireonOctober24,2011.COGAbelievesthata120daycommentperiodwouldbemoreappropriatetothoroughlyevaluatetheproposedregulationssincethereare5regulationsbeingamendedinthissingleproposedaction.2) COGA also requests

a

1 year extension

on the final issuance deadline. Issuing these rules
by February

28, 2012

is very ambitious.

A large number

of comments

will likely
be received

by the EPA. The EPA should seek

to extend the timeframe

in the consent decree
for final action

on these rules

to allow the EPA time

to thoroughly address comments

and avoid several costly iterations
and reissuances

of the rule. 3) The EPA states that there will be significant
cost savings

for the industry associated
with these new rules and has also estimated

the cost
of control equipment.

It is COGA’s opinion that the EPA has overstated these cost savings and underestimated

the cost
of the required control equipment.

We believe that more time
to validate these costs

is needed.

By having

a more accurate estimate

of costs and savings,

the EPA should

be in
a better position

to determine

the appropriate
level
of controls. 4) The State

of Colorado currently
has very stringent emission control guidelines

for the 8-hour Ozone non-attainment

area. These rules,

as proposed,

will have even more stringent requirements.

For example, controls
will be required

for any condensate
tank with

1 bbl/day

or more

of production.
More sensibly,

the State of Colorado today requires controls based

on predicted emissions, which are required

if the tank exceeds

1 ton/yr VOC emissions.

The proposed control standard based solely
on

a very low level
of production

will not be cost effective and will have little additional environmental benefit

on smaller sources. More time should

be spent investigating these requirements

and evaluating proper limitations
that will be environmentally beneficial
and cost effective

so as not to further drive
up consumer costs. 5) There will likely
be

a shortage

on much

of the required control equipment

(i.e. vapor combustors, green completion equipment,
etc.) since these rules will be requiring controls

for many sources which have yet to be regulated.
The EPA should reevaluate

the timing

of these requirements

so that manufacturer’s

of this equipment

will be able
to meet the demand. 6) NSPS 0000 (Quad

0) as described

in the BID and preamble

is
a rule for the purpose

of setting new standards

for control

of VOC and SO 2 emissions. However, much

of the proposed Quad

0 rule seems

to take aim
at green house gas emission reductions

and not VOC and SO 2 emissions. There are already several new greenhouse

gas reporting rules which require

a significant amount

of new monitoring equipment

and tracking

of emissions through

40 CFR Part 98. The oil and gas industry

is in the midst

of installing

all of this tracking equipment 2and getting

a more detailed estimate

of these emissions

and their sources. Quad o should

be amended

to only focus
on VOC laden sources

of emissions

and greenhouse

gas reductions should

be addressed

at
a later time once the data from the reporting
rule

is gathered. 7) Quad

0 and the revised NESHAP

HH set the definition

of
a leak
at 500 ppm. The current leak definition under NSPS KKK

is 10,000 ppm. The proposed
limit of 500 ppm

is a dramatic drop. The EPA should reevaluate

the leak definition level
or perhaps
add

a few step downs before 500 ppm needs

to be achieved. 8) Under Quad

0, several changes could
be made

to reporting requirements

to streamline

the submittals

to the EPA. Much

of the reporting seems rather burdensome

and will require

a significant
time commitment

by both industry and EPA

to prepare and review the required reports. Some

of the recordkeeping

such as the 30 day notice
for frac flowback

is unnecessary

and duplicative. Recordkeeping

and reporting requirements should

be reevaluated

and streamlined where possible. 9) The applicability dates

of these rules vary

in several instances; some predating the issuance

of the final rule. These applicability dates should

be reevaluated based

on the comments received
and no date should

be before the issuance

of the final rule. The comments which

I have just stated are very general

in nature but highlight some

of the main issues that must be addressed before making these rules final. COGA

is in the process

of working with our member companies

to identify
the main issues and generate specific comments

so that these proposed rules can be amended

to reflect actual and achievable compliance goals. Thank you for the opportunity

to speak today. We look forward

to working with the EPA

to help develop

a quality final product. 3EPRI—ILiSrICEALASKACALIFORNIAFLORIDAMID-PACIFICNORTHEASTNORTHERNROCKIES_______________________________________NORTHWESTROCKYMOUNTAINWASHINGTON,DCINTERNATIONALBecausetheearthneedsagoodIavqerI’mBenTettlebaum,hereonbehalfofEarthjustice,anationalnonprofitpublicinterestlawfirmdedicatedtodefendingtherightofallpeopletoahealthyenvironment.First,thankyoutoEPAforundertakingthislong-overduerulemaking.Section111oftheCleanAirActmandatesthatEPAreviewand,ifnecessary,reviseNewSourcePerformanceStandards(NSPS)andNationalEmissionStandardsforHazardousAirPollutants(NESHAPS)atleasteveryeightyears.ButEPAhasnotpromulgatedNSPSfortheoilandgassectorforover25years.ExistingstandardsonlycoveremissionsofVOCsandsulfurdioxidefromnaturalgasprocessingplants,neglectingtocontrolavastportionoftheindustry.EPAlastpromulgatedNESHAPSforthissectorovertenyearsago.NotuntilEarthjusticebroughtsuitagainsttheagencydidEPAagreetofulfillitsnondiscretionarydutytoreviewtheNSPSandNESHAPS.Evenstill;therulemakinghasbeenfurtherdelayed.WethereforestronglyurgeEPAtodelaynomoreandimplementthisrule,necessarytoprotectpublichealthandwelfare.Second,theoilandgassectorisbooming.ShalegasproductionintheUnitedStatesincreasedfourteen-foldinthelasttenyears.1In2008alone,theoilandgasproductionsectoremittedover6.5milliontonsofcriteriaandhazardousairpollutantsnationwide.2TheColoradoDepartmentofPublicHealthandEnvironmentrecentlyconcludedthatthesmog-formingemissionsfromColorado’soilandgasoperationsexceedvehicleemissionsfortheentirestate.3Andforthefirsttimeinitsstate’shistory,Wyomingfailedtomeetfederalhealth-basedstandardsforairpollutionprimarilyduetoemissionsfromthestate’soilandgassector.4TheU.S.EnergyInformationAdministrationprojectsanearlyfourfoldgrowthinshalegasproductionalonefrom2009to2035.Thesefactsdemandimmediateactiontoprotectthepublicfrompollutantsthatwillnotonlycauseandexacerbaterespiratorydiseases,asthmaattacks,cancer,andneurologicalissues,butwillalsosignificantlycontributetotheacceleratingclimatecrisis.Thisbringsmetomythirdandfinalpoint.EPAmustdirectlycontrolemissionofmethaneinthefinalrule.Methaneisapotentgreenhousegasthatisovertwentytimesmore‘U.S.ENERGYINFORMATIONADMINISTRATION(ETA),OUTLOOKFORNATURALGAS,at14(2010),http://205.254.135.24/neic/speeches/newell101110.ppt.2EPA,THENAT’LEMISSIONSINVENTORY,http://www.epa.gov/ttn/chief/net/2008inventory.html(lastvisitedSept.27,2011).ColoradoDept.ofPublicHealth&Environment,AirPollutionControlDivision,OilandGasEmissionSources,PresentationfortheAirQualityControlCommissionRetreat(May15,2008),atpages3-4.“WYDEQ,TechnicalSupportDocumentIforRecommended8-HourOzoneDesignationFortheUpperGreenRiverBasin,WY,p.viii(Mar.26,2009),availableathttp://deg.state.wy.us/out/downloads/Ozone%2OTSDfinalrev%203-30-09jI.pdf.U.S.ENERGYINFORMATIONADMINISTRATION(EIA),ANNUALENERGYOUTLOOK2011:WITHPROJECTIONSTO2035,at2(2011),http://www.eia.gov/forecasts/aeo/pdf/0383(2011).pdf.1400GLENARMPLACE,SUITE300DENVER,CO80202-5050T:303.623.9466F:303.623.8083E:rmoffice@earthjustice.orgW:www.earthjustice.orgeffectivethancarbondioxideattrappingheatintheatmosphere.6In2009,methaneemissionsfromPetroleumandNaturalGasSystems,adjustedfortightsandplaysandtheMarcellusShaleplay,constitutedover328millionmetrictonsofC02equivalents.7Theproposedrulewouldcapturelessthan20%ofmethaneemissionsbyregulatingVOCsasasurrogateformethane.TouseEPA’sowncomparison,thatwouldbetheclimateequivalentofleavingover45milliontypicalpassengercarsontheroad.EPAhasmadeanEndangermentFindingthatmethaneisanairpollutantthat“cause[SI,orcontribute[s]to,airpollutionwhichmayreasonablybeanticipatedtoendangerpublichealthorwelfare.”8Andintheproposedrule,EPAadmitsthatmethaneemissionsremain“significant.”9Consequently,undertheCleanAirAct,EPAmustimplementcontrolstoregulatedirectlymethaneemissions.Insum,westronglyurgeEPAtoimplementafinalrulewithoutdelaythatadequatelyprotectsthepublichealthandwelfare.Thankyou.BenTettlebaumEarthjustice1400GlenarmPlace,Suite300Denver,CO802026EPA,INVENTORYOFU.S.GREENHOUSEGASEMISSIONSANDSINKS:1990—2009,at9(2011),http://epa.gov/climatechange/emissions/downlaods11/US-GHG-Inventory-2011-CompleteReportpdf.76Fed.Reg.52,792(Aug.23,2011).874Fed.Reg.66,496,66,497—99(Dec.15,2009).976FedReg.52,756.NataliaSwalnickDirectorofEnvironmentalHealthAmericanLungAssociationinColorado5600GreenwoodPlazaBlvd,Suite100GreenwoodVillage,CO80111nswalnick@lungcolorado.org303-847-0271IntroductionDirectorofEnvironmentalHealthfortheAmericanLungAssociationinColoradoLunghealthimpactsIamheretodaytosupporttheEPA’sproposaltoimplementnewstandardstoreducedangerousandharmfulairpollutionfromtheoilandnaturalgasindustries.ThesestandardswillprotectAmericansfromharmfulairpollutants,includingvolatileorganiccompounds,toxicairpollutants,ozoneandparticulatematteracrossthecountry.AccordingtotheEPA,thesenewstandardswillresultinan25%industry-widereductionofVOCs.VOCsareoneofthekeyprecursorstoozonepollution,andweareexceedingthefederalstandardforozonepollutionhereintheDenverMetroArea.Ozoneinflamesourlungsandairwaysandcancausechestpainandcough,aggravateasthma,reducelungfunction,andincreasehospitalandemergencyroomvisitsforrespiratoryproblems.Ozonecanevenresultinprematuredeath.Particulatematter(PM25)aremicroscopicaerosolsformedbythereactionofsulfurdioxideintheair.Theybypassthebody’snaturaldefensesandlodgedeepwithinthelungs.PM25cantriggerasthmaattacksandheartattacks,andincreasehospitalandemergencyroomvisits.PM25can shorten
life.WhatALACRequirecleanupofbothnewandexistingsources,notjustnewones—recommendsespeciallycompressorsandgas-drivencontrollersandvalves;andSetstandardsforthereductionofmethane.Inadditiontobeingapotentgreenhousegas,methaneisanairpollutantthatimpairslocalairquality,itshouldbedirectlyregulatedandnotjustabyproductofthereductionsofVOCs.ConclusionTheproposedstandardsontheoilandgasindustryareagoodsteptowardsprotectingthehealthofAmericans.Thestandardswillhelpreduceozoneandparticulatematterlevelsinareaswhereoilandgasproductionoccurs.TheDenverMetroAreaespeciallymustfindnewwaystocomplywiththe2008ozonestandardifthatiswhatislikelytobeenforced.TO: FROM: Randee Webb, 12854

E Villanova

Dr, Aurora,
CO 80014-1916,

USA DATE: September

28, 2011 RE: Air pollution

as
it relates

to fracking 7c 325ObD My name

is Rand Webb and i’m from Aurora,

a long, h1ypopuate4—eiic-- residential suburb’ between Denver and the prairie. Welcome

to Colorful Colorado,

or as you may have heard

it more recently called, Fraca-rado. Today
it’s your job to hear from The People, albeit mainly repetitious

at this hour; and it’s my duty
to “stand

up and be counted”
and to apprise you of some

of my thoughts. The EPA exists because
We The People have

a RIGHT

to LIFE. And

in order

to live: we need

to breathe clean air in this

1 1 th windiest state— necessitating monitoring

air pollution;

we need

to be exposed

to the right amount and type
of sunshine

in this 2 nd sunniest state— necessitating monitoring

of ozone; and we need

to drink plenty

of clean water and other things we usually take for granted.

So to sustain ourselves,

we must sustain our

f:. planet and its environment-- which generally comes down to having Rules. And as

I understand

it, the EPA

is in Denver today

to get feedback about the Rules, particularly relating

to Gas

& Oil Industry’s continual
and heinous polluting

of the Air and destruction

of the Ozone

in order

to accomplish extraction

of those resources from our Earth. We all know we can’t breathe “natural gas” and we can’t drink
oil and we’ll burn up without

a certain amount

of protection from the sun. So Rules must apply

to everyone, including

the Oil

& Gas Industry. Obvousty

the HALLIBURTON LOOPHOLE must
be closed! You individually,

the EPA, our elected officials,

all of us must turn

a deaf ear to the whining

of an under-regulated industry.

Oil
& Gas Industry, including the newest process

of horizontal hydraulic fracturing,

or fracking, must once again
he accountable

to the Clean Air Act and all the environmental protection Acts. As the richest industr,

in the world,

it should actually

be easy

to hold them accountable retroactively

and to require

Oil
& Gas
to foot the bill for all clean-up,

like every other ndustrv

or company,

and without subsidies. Back

in 1987,
an EPA Report showed fracking

as

a hazard

to humans. Come
on, it’s just Ioca and sensible that fracking

is responsib

for its neighbors

and their neurological illnesses, cancer, and more. PROOF

IS ALL OVER THE NTERNET.

The many, many hazards

of fracking, WITH FACTUAL PROOF,
can be found

on 1-acebook,

for example

at FrackingCo!orado,

which

I administer.

You must be aware

of the many public Petitions about tracking,
and I’m submitting herewith
one initiated

in Arapahoe County, Colorado,
that includes some specc regulations necessary

for ‘a
0 king.Minimally,

to protect public health and public environmental
rights, the EPA must Require
use of currently-available technologies

to reduce toxic emissions related

to the oil and gas extraction process. The EPA’s proposed regulations regarding

air pollution are better than what we had, but we MUST HAVE MUCH GREATER REDUCTIONS

IN METHANE EMISSIONS, SMOG-FORMING COMPOUNDS,
VOCs, HYDROGEN SULFIDE. Even
as

:

& Oil
is frenzied

in its obtaining about 30,000 new drilling permits each year

in the United States, We The People— and only with the help of the EPA, including your attention today— musr URGENTLY

put Life itself before the lifestyle

of the Industral Age. You yourselves,

that

is the EPA, have researched

and stated that following better environmental
Rules will actually CREATE JOBS. We have only crawled toward

a Rwah Energy Age, but it’s time we must run forward, before time runs out on health and our lives While change

is difficult, this

is already
the 21 st Century.PETITION REGARDING PROPOSED HYDRAULIC FRACTURING

FOR OIL AT THE FORMER LOWRY BOMBING RANGE LANDS

IN ARAPAHOE COUNT’i ON LAND OWNED
BY THE COLORADO STATE LAND BOARD Whereas

the Colorado State Land Board

is currently considering leasing half or all of its 26000 acres of land
at the Former Lowry Bombing Range lands

in Arapahoe County

to the oil and gas industries

for the purpose

of horizontal hydraulic fracturing

of the Niobrara shale beneath

it for oil production, and whereas
the Colorado State Land Board intends

to act as
a responsible trustee
for the education

of the children

of Colorado

by procuring royalties there from, and as
a wise, long-term steward

of the land which

it holds, and whereas
the use of current hydraulic fracturing technology

to produce

oil in deep shale beds

is known

to pose numerous serious risks
to public health, water and air quality, and water security,
we,
as residents

of Arapahoe

and Elbert Counties
and Denver, Colorado, residing

in areas surrounding

the former Lowry Bombing Range land,
or potentially impacted

by aquifer impact, reasonably insist that the Colorado State Land. Board uisure the responsible mitigation

of th risks by ensuring that the following stipulations

are included in any such lease:_ 1) Requirmentof
using gren completion technology

to the uIntçpcurrently_4yailable,

and improved asimprovements ccpdeyd,nIy- a. Prohibiting

the storage

of fracking wastewater (so-called “produced water”

in any lined
or unlined open air pits (thus reducing airborne exposure

to toxic volatile fracking chemicals

and associated threats

to air quality and the purity
of open water such
as the Aurora reservoir) b) Prohibiting

the venting

of any codnateheating

tanks (for the same reason) c) Requirirg capture

of any secondarily released

not preyi.o ljeiçacd)_biqgppic

or thermogenic jnethane gas (since

it is known

to seriously edlitaminate groundwater,

kill plants and animals, poseuiintis human health ñsks, and to be many times more impactfiul

to global warming than burning coal),

in addition

to applying available technology

to prevent such release d) Centralizing

well pads
so as todecresefrack-fluid-spilLrisk e) Any fracking wastewater

not left in a well and capped

to be removed

to
a fitcility certified capable

of safely removing hazardous chemicals

and radionucleides
prior
to using the water for any purpose f) Ensuring that all wells are sç ened

in concrete
and steel, with certified secure bonding,

the length
of the well g) Application

of current and evolving technology

for imaging, assessment

and modeling

of existent natural fissures near aquifers, reservoirs

or creeks,

to avoid inadvertent exacerbation

of such fissures and possible release

of thermogenic
gases into the aquifers, current

or planned water reservoirs,

or other groundwater. 2) Requirement

of full disclosure

of all hazardous chemicals used and nature
of usage
on site to the Tn-County Health Service and the Colorado Department

of Public Health,

6 months

in advance

of operations initiation,

to allow these public health entities adequate time
to organize emergency preparation procedures

to address spills, fires, explosions, fracking fluid
or methane

or radionucleide release into groundwater

or reservoir

or aquifer. Full cooperation
with these entities

in developing adequate emergency protocols
and fill financial coverage

of the cost of emergency response plan development

and materials cost, cost of emergency response,
and the cost of any treatment plans and treatment

for affected individuals,

as well
as full cost of remediation

of land, aior water contamination
there from. Similarly, provision

of any additional information (acquired

in other drilling operations

in Colorado

or other states) regarding common health complaints noted by workers

or residents

in the area of such drilling operations, to Tn-County Health and Colorado Department

of Public Health, such that this information

can be disseminated to physicians

in the area,

in order

to develop medical awareness

for appropriate treatment, report

to State of Colorado,

and state collection
and assessment

of associated epidemiological

data.PETITIONREGARDINGPROPOSEDHYDRAULICFRACTURINGFOROILATTUEFORMERLOWRYBOMBINGRANGELANDSONLANDOWNEDBYTHECOSTATHLANDBOARDI3)PaymentforstateofColoradogeologistandwaterspecialistpre-drillsamplingofthe4underlyingwateraquifersandtheAuroraReservoir,andanycreeksorgroundwaterwithin5milesofeachfrackingarnttotestformethaneandradionucleidesknowntobereleasedmthefrackingprocess,chemicalscontainedmthefrackingfluluL1iirotherundergroundproceduresinvolvedinfrackingandextractionofoil,aswellascontinuousmonitoringofsame,toallowforimmediatedetectionofcontaminationandlocationandmitigationofcontaminantsource,aswellasimprovedprotocolstopreventsuchreleasesinfutureoperations.4)PaymentforstateofColoradoinstallationofaiqalijysensorsonandnearwellsites,(testingforsimilarchemicalsandgasesaslistedin13),inordertocontinuouslyassessairqualitypriortoandduringallphasesofdrillingoperations,suchthatanycontaminantcanbetimelynoted,remediated,andavoidedinthefuturebyimprovedperformanceprotocols5)FulldisclosuretostateofColoradoregardingtheestimatedvolumeofwaterusedperfrackateachwellsite,priortoleaseagreementandstipulatedinleaseagreementterms,andtheactualvolumeofwaterusedperfrackuponcompletionofeachfracktoberecordedandyearlyreported,topermitthestatetoactasresponsiblestewardofColorado’sincreasinglyscarcewatersupply6)FulldisclosuretostateofColoradoregardingthenumberoftankertrucksandotherheavymachinerytripsperfrack,inorderthatthestatecanactasresponsiblestewardofColoradotransportationandroadsandlevycostofneededimprovementsorrepairassociatedwithsuchlogarithmicallyincreasedheavytraflictotheoilandgascompanies,onaproratabasis7)Intheeventofaseriousspillormethanecontaminationofaquifer,fire,explosion,orothersuchseriousthreattopubliciiealth_andwelfärealldnllmgoperationsshallceaseuntilthecauseisdeterminedbybothindustryandstatespecialists,andaplanofremediationandfuturepreventioncanbeagreeduponbysamepartiesandinitiatedbyresponsiblepartiesinindustry,paidforbyresponsiblepartiesinindustry,andoverseenbythestateofColorado.8)NoindividualresidinginArapahoeorElbertCountyortheCityofDenvershallforfeitorhaveabridgedanylegalrights,includingrightofcivilsuitforlawfuldamages,relatedtoStateLandBoardapprovedoildrillingontheformerLowryBombingRangelands.9)InitialleasesonofferonlytothosecompaniesthathavearecordofaveragetoaboveaverageperformanceinthetndinotPcgárdirijâc&clentsoranykiiidandeachadditionalwelldevelopmentcontingentuponsuccessfulachievementofgreencompletionandabsenceofanyseriousincident;allleaseproductionrightstoceaseintheeventofmajorincidentlaccident,untilsuchtimeasincident/accidentisfullyinvestigated,remediationeffortsproceedtostatesatisfaction,andperformanceprotocolsareimprovedtopreventthelikelihoodoffuturesuchincidents.10)Initialleasebatchesbelimitedtounder10intotoforthefirstyearofsuchoperations,toallowforstatewater,andhealthspecialiststopresentperformanceassessmentstotheStateLandBoardattheendoftheyear,suchthattheStateLandBoarddecisionregardinganyadditionalleasescanbebaseduponreviewofperformanceoftheabovestipulations.Subsequentadditionalleasebatches,ifany,tobeinmultiplesof10peryear,topermittheStateLandBoardtofuffillitslongrangelandstewardshipobligationstothefullestcapacity.Leasetermsshouldcontainstipulationsthatcontinuingleasebesubjecttoperformancereviewoutcome.Copiesofthispetitionarealsobeingsubmittedtoourlocalcity/towngovernment,countygovernment,andtheTnCountyHealthservice,aswellastheColoradoDepartmentofPublicHealth.WerequestthattheseentitiessubmitformalwrittenstatementstotheStateLandBoard,insupportofourstipulationrequestsaslistedabove,forthepreservationofpublichealthandsafety.To: The EPA From: Rick Blotter 23011 County
Rd. 150 Agate, CO 80101 Date:

28 September
2011 Subject: Clean Air Regulations Nine months ago my wife and

I received

a letter from

a landman asking

us to lease our mineral rights,

if we owned them,

to Conoco-Phillips.

Since then I’ve tried
to learn

as much

as

I can about hydraulic fracturing.

I am not

a petroleum engineer

or

a geologist

or an attorney (I’m

a retired public school teacher who can’t afford

an attorney).

I have gone to many Colorado

Oil and Gas Conservation Committee meetings;

it’s the regulatory agency

in Colorado.

I have watched numerous

on line videos, and have read
as much

as

I can.

I have watched

the documentaries ‘Gasland’
and ‘Split Estate’. I’ve read ‘Collateral Damage’

by Tara Meixsell.
I’ve talked

to geologists

and people who work for Encana, Chesapeake,

and Anadarko.

I’ve driven through Garfield
and Weld counties

to try to understand what ‘fracking’

is. One doesn’t have
to look too hard

to find numerous incidences

of the consequences

of living

in an industrial
site. My wife and

I have worked and lived

in Elbert County,

in eastern Colorado,

for 30 years and have looked forward

to retiring

on our ranch where we grow organic vegetables, raise dairy goats, chickens
and

a few steers. We consider ourselves lucky

to watch the constellations
move through
the night sky. We can hear the coyotes call, the songbirds sing and the wind blow through
the Ponderosa Pines. Our well water

is ample and good. We know that when the ten story, 150’, oilrigs move

in with generators running 24/7, lights lighting

up the sky at night, non stop truck traffic and the smell
of spent diesel fuel and open hydraulic fracking fluid pits, that will all change. With the mortgage debacle, our property

is now worth less than what we owe on it; to make matters even more dismal, property values around

oil fields typically depreciate
25%

to 75%. And, because of President Lincoln’s 1862, grant of mineral rights

to the railroad (and subsequent purchase

by them by Anadarko) we’ll get nothing

in royalties. I will not accept ground level ozone pollution,
dust from more than 4000 truck trips per frack on our dirt roads, Volatile Organic Compounds
from condensate tanks

as Dr. Theo Colburn
has validated

at the Endocrine Disruption Exchange

in Paonia, CO. and as the ‘Colorado Congress Clarion’,

a paper

in Grand Junction,

has recently published, toxic and carcinogenic chemicals

in our air. The citizens cannot rely on large corporations

to regulate themselves.

The recent banking industry debacle,

the mortgage industry collapse
and the New Horizon,
BP, spill
in the Gulf have confirmed
that big industry

is in it for the money;

if they don’t make money, they don’t survive, regardless

of the consequences

to the people.

It is not unreasonable

toask companies

that make billions

of dollars each quarter

to initiate changes

in their business that would protect people that they impact. It is obvious that the Colorado

Oil and Gas Conservation Commission doesn’t care about the results

of hydraulic fracturing

on the public.

It is fruitless

to talk
to them. We have petitioned

our county commissioners

to install regulations

to protect
the county but apparently

the State regulations preempt

the counties’.
The Colorado Supreme Court has given the oil companies

the right

to drill on anyone’s land
to get to their minerals. Surface owners have no rights. The oil and gas industry uses eminent domain
for their private gain. The Federal Government needs

to help protect landowners.

The Federal Government needs

to protect
the planet from being raped.

I don’t think anyone

is asking that oil companies don’t drill; people
are asking that drilling

be done safely and that,
if a person’s property

is violated, compensation

is quickly provided.
Use closed loop systems,
use afterburners

on wells, mitigate dust on dirt roads, use mufflers
and cleaners

on mufflers, and keep wells

a reasonable distance from residences.

The EPA’s proposed rules take

a big step forward

in addressing

the cumulative impacts

of hydraulic fracturing.My name

is Sandy Toland and I’d like
to thank you for letting me speak. I am concerned about the oil and gas boom that

is headed our way and the adverse environmental impacts

it will have on our State and the nation. As

a member

of

a group trying

to raise awareness about fracking’s dangers,

we have submitted petitions

to our public officials

to let them know that fracking needs more stringent regulations,

to reduce risk to our health and the environment. One day, while collecting petition signatures,

a couple approached

me, wanting

to know what the petition was about, and when

I told them, they were anxious

to sign. They said they owned

a house

in Denver and one in Nebraska,

and that fracking was happening
near their Nebraska home. The woman, who was clearly distressed,
said the fracking was driving her crazy. The man said that he was always glad
to come

to Denver because

he can breathe here. Apparently, fracking
has made parts of Nebraska

a bad place

to live,
if you like
to breathe. So

I am here today

to speak for this couple, and anyone who likes breathing clean air. We have

a right

to clean air, and this right must be protected. The Halliburton loophole must
be closed,

so that the oil and gas industry isn’t exempt from several important regulatory
Acts that protect
the environment

and our health. And the EPA’s new proposed fracking regulations must be stringent enough

to prevent VOCs, methane,
and other toxic gases, from polluting

our air and contributing

to climate change. If you do anything less, our government

will have fallen short of its most important role:

to represent
and protect
the people. Clean air, land, and water are real wealth.

If we continue

to base our economy

on plundering

the earth and polluting
our environment,

we will eventually destroy our wealth and ourselves. Author Kurt Vonnegut wrote: We probably could have saved ourselves,

but we were too damned lazy
to try very hard, and too damned cheap.” I hope you prove this statement wrong, and implement

the strongest

air regulations possible

for oil and gas fracking.1 came here
to comment today because

as
a resident

of Colorado,

air quality

is particularly important

to me. My husband
and

I returned

to Colorado, after living

in Boston
for 10 years because

we missed
the natural beauty. Now that we’ve returned

I can say, the natural beauty

is more stunning

on some days than on others, depending

on the level of smog and haze. In light of world events

in the last ten years,

I understand

the push for more domestic sources

of energy. However, increased drilling must
be done responsibly.

By that

I mean EPA shouldSet limits for all toxic emissions from individual
sites and should also consider

the cumulative impact

of all oil and gas drilling. What matters

to me
is if

I can see the vistas,

if my children will grow
up healthy, and
if we are generally being responsible

as
a society. Achieving those goals requires regulation

of the cumulative impacts from oil and gas drilling. The current proposed
rule moves

in the right direction

by reducing

the allowable emissions thereby reducing both the smog and the number

of cancer causing agents

in our environment. I am also impressed
that the regulation indirectly regulates methane.

It does not make sense

to continue using outdated techniques

that emit large quantities

of methane when methane

is such

a potent greenhouse

gas, 20 times more potent than carbon dioxide. Instead that methane
can and should

be captured
and used productively

as natural gas. Given the amount

of energy that the government

and individuals

are putting into reducing greenhouse

gas emissions from vehicles
and industry,

it does not make sense

to be lax in the regulation

of methane which has

a larger detrimental effect. This regulation could
be better. Ideally

it would

1) reduce
air emissions more
by requiring

the use of upto-date currently available technologies,

2) regulate

all toxic emissions including hydrogen sulfide,

3) directly regulate methane thereby creating much greater reductions

in methane pollution
and increasing the amount

of natural
gas produced,

and 3) not include
the malfunction defense, allowing companies

to emit higher levels
of pollution. However,

as written,
the regulations

are

a step
in the right direction. I, like many people. choose

to live
in Colorado because

it is beautiful
and pristine.

I breath the air while hiking

up mountains

and admiring

the views.

To the extent we allow the degradation

of Colorado’s

air, we threaten
the whole economy

of this state. That

is why

I support
the facilitation

of
a modern

oil and gas industry that uses up-to-date technology

in order

to produce domestic energy while protecting Colorado’s
land and air.

# Copyrighted page(s) removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder. Removed pages can be viewed at the USEPA Docket Center, Public Reading Room.

Address: 1301 Constitution Ave, NW Room 3334 Washington, DC 20004 Telephone: 202-566-1744

Email: docket-customerservice@epa.govNatural resources, Politics, Europe, USA, Gas The French government

may institute

a nationwide

ban on fracking;

a controversial practice used

to extract natural gas from the earth, due
to US based disasters. Recent reports indicate fracking may indeed

be more dangerous

for the environment

and lead to global warming

at rates much higher than previously thought.

In addition,

a number

of reports show the proactive pollutes water supplies,
kills wildlife and destroys

the quality

of life
in the communities where

it takes place. Citing US fracking catastrophes, French officials
are edging towards banning
the practice outright. Across America however fracking continues amid rising disasters. Kate Sinding,

a senior attorney with the Natural Resources Defense Council explained
that France

is the start
of
a trend where nations
are recognizing

the risks involved with fracking.

As more and more comes

to light about the practice fewer people
are willing

to allow

it to enter their communities. A number

of US states have begun

to improve regulations

on fracking.

but

it has not prevented disasters. More regulations

are needed, argued Sinding. Many regulators

are weary

of halting the practice because
the economic gains for communities

can be iery high. ‘A lot of where shale gas
is developed

in this country

is in economically depressed places and there

is a lot of political pressure from the other side
to get
in and develop

as much gas as possible,”

she explained. The economic potential often trumps public safety. Hydraulic fracking,

the process

by which natural gas

is extracted from the earth, could create

as much

as twice the amount

of greenhouse

gas pollution

as coal, according

to
a recent study

at Cornell University.Prior

to the study the general consensus

was that fracking was safer and more environmentally friendly than coal. Even US President Barack Obama applauded natural gas as

a true clean energy standard. But, that view may have changed. Cornell Prof. Robert Howarth argued

in
a new study that the process which makes natural gas available actually contributes more

to global warming than conventional

coal. The gas may burn clean, but the process

of obtaining

ti is dangerous

to the environment. “Natural
gas

is composed largely

of methane,
and 3.6 percent

to 7.9 percent

of the methane from shale-gas production escapes

to the atmosphere

in venting and leaks over the life-time

of a well,” the study said. “These methane emissions

are at least 30 percent more than and perhaps more than twice
as great
as those from conventional

gas. The higher emissions from shale gas occur

at the time wells are hydraulically fractured

— as methane escapes from flowback return fluids

— and during drill out following

the fracturing.” The study further added, ‘The footprint

for shale gas

is greater than that for conventional

gas or oil when viewed

on any time horizon,
but particularly

so over 20 years. Compared

to coal, the footprint

of shale gas

is at least 20% greater and perhaps more than twice
as great
on the 20- year horizon and

is comparable when compared over 100 years.” Natural gas produced

via fracking

is poised

to become

45 percent

of total production

by 2035, according

to the US Department

of Energy. Obama and

a number

of industry insiders have continued

to praise gas production. “Recent innovations
have given
us the opportunity

to tap large reserves— perhaps

a century’s worth
of rese,’ves,

a hundred years worth
of reserves—

in the shale under our feet,” Obama said during

a recent speech. Many who support tracking
and natural gas have come out to oppose
the recent study. “It needs

to be understood

as

a study that has several key assumptions

that are highly uncertain or based

on limited data points,” Christopher

Van Atten, Vice President

of M.J. Bradley

& Associates energy consulting
firm, told The Hill. “They focus some
of their results

on

a 20 year period which

is not particularly relevant

in terms

of climate change. Methane only lasts

in theatmosphere

for about

a decade,
co2 remains

in the atmosphere

for about

a century.

By focusing on the shorter time frame, they show

a greater impactfrom the shorter lived chemical.’ However,

the new study

is the second study this year which argued fracking
and natural gas are not as clean

as once thought. Natural gas industry officials and environmentalists

in the US are at loggerheads

over the safety of
a controversial drilling technique. Some groups claim that “fracking”, which involves injecting millions

of gallons

of water and chemicals deep underground

to force out gas, threatens supplies

of drinking water. Lori “The Resident” Harfenist finds out

if people

on the streets

of New York think

it is just

a lot of hot air. In rural Pennsylvania,

a process

for extracting

gas from shale known

as fracking
has released dangerous gases into

a community’s drinking water. On

a quiet street, tucked
off the main road

in Dimock, Pennsylvania,

live people who once dreamed

of spending their lives

in this close-knit community.
Now most residents

say they want to move, but have
no chance

of being able
to sell their homes

or property. The people

of Dimock
live above the Marcellus Shale,

an abundant source

of natural gas and one of the best energy alternatives

to oil in the United States. Most residents

in Dimock signed leases with the Cabot
Oil and Gas company
that allowed
the company

to drill into their property and set up pads

to manufacture

gas.

In exchange

for the rights

to invade the earth under the surface,
the residents would receive royalties from the sale of the gas. But something went wrong. ‘Tm paying

a mortgage

on

a house that

is completely worthless,”
said Craig Sautner. Julie and Craig Sautner planned

on retiring here

in Dimock.
But the swingset

in the yard for their grandchildren

sits empty and unused. Julie Sautner says her children don’t feel safe bringing their kids
to the house since their water supply has become contaminated. When Cabot
Oil started drilling
for gas, something

got into the Sautner’s
well water. And theirhouse has had an extreme makeover.

It now sports two pumps,

a carbon filter,

a second filter,

a gas separator,

an air pump and

a tower

to vent methane gas,
so

it doesn’t collect

in the house and explode.

U Cabot
Oil retrieves
gas from the area by

a process called hydraulic fracturing,

or fracking.

In this process,

a mixture

of water, sand and chemicals

are pumped underground

at high pressure.

It causes fissures

in the shale

to force the natural gas
to the surface. According

to the Pennsylvania Department

of Environmental Protection,

the Marcellus Shale

is 8,000 feet beneath
the surface,
but Cabot
Oil struck gas from

a shallower s,ource, called the Devonian Shale. “As they went down

to the Marcel/us
gas, they failed

to isolate the shallower

gas deposits and

it was those shallower
gas deposits that migrated,” explained John Hanger from the Pennsylvania Department

of Environmental Protection. The gas migrated
into the water

of the local families. “My kids started getting very sick early
on in the drilling process

/ think.

/ think they started throwing

up and having,

it’s sort of/ike

a very bad intestinal bug,’ said Pat Farne!li. Her neighbor’s

well blew up from the concentration

of gas. Cabot
Oil has refused

to comment

on the situation, although

it does provide drinking water for local families. In rural Pennsylvania,

a process

for extracting

gas from shale known

as tracking
has released dangerous gases into

a community’s drinking water, forcing families

to leave their native places. For the Ely family, their problems

run deep, underneath

the soil,

in their roots. Scott Ely grew up on this land, but things have changed since
he was

a child. For the last year and four months, he and his family have been unable

to drink their water. The problems began when
he agreed

to allow Cabot
Oil and Gas
to drill on his property.
The Elys are one of more than

a dozen families in Dimock, Pennsylvania

who have water that

is full of methane gas. Families
like the Elys live out of tanks that hold 250 gallons

of water. The water

is delivered once

a day. Ely says that he and his wife signed

on to the Cabot plan only after they were assured
the gas extraction would
be

a quick, safe process. The reality

is quite different. ScottElyandhiscousinwereevenabletolighttheirwateronfire.ForJimGrimsleyandhiswifeAnnVanLenten,however,Dimockiswheretheycametoretire.Drillingjustbeganontheirproperty,buttheyarehopeful..“Wedidsignonandwe’renotsorthatwedid,”saidAnn.“SusquehannaCountyisapoorcounty,soalotofpeopledidgetworkandtheygotjobsandthey’remakingmoney,sotomethat’saplus,“saidJim.ButsomeofthosewhogotjobscomplainedaboutCabotOilandGasandwerepunishedorputonleave.MostoftheemployeesarefromTexasandstayinrentedhousesorlocalhotels.ThePennsylvaniaDepartmentofEnvironmentalProtectionhasbeenoutseveraltimestolookatthesituationinDimock,butonlyrecentlydecidedtotakeaction.TheDEPhashowissuedordersforCabottoplugthreewellstheyhavealreadydrilled,whichcouldcostmillionsofdollars.Cabotalsohas30daystoinstallpermanentwatersuppliesforfamilies,includingtheElys,whohavewaterdelivered.“IfCabotdoesn’tagreetothesetermsandgetitdone,we’llbeincourtandseekingacourtordertoenforcewhatI’vejustlaidout,“saidScottEly.ForJimGrimsley,whathashappenedissimplyaroughpatch.“It’sjustlikeanything.WhentheywerediggingsubwaysinNewYorkCityahundredyearsago,eve,ybodyprobablyhatedthem.Today,theymoveacouplemillionpeople,aday.Withoutthem,NewYorkCitywouldn’tbethere,“Grimsleysaid.ButforEly,itisaloomingquestionofwhethertouproothisfamilyfromtheonlyplacehehaseverknownortokeeptheminDimockwiththehopethatthingswillchange.America’slargestshalegasreserveisinthenorth-eastofthecountryandasthefrackingindustrydevelops,eventhewaterinNewYorkmaybeunderthreat.EnvironmentalreporterAllisonSicklesaidthattherehavebeennostudiesintowhetherfrackingisasafetechnique.“There

is no guarantee
that hydraulic fracturing canl7ot contaminate surroundmg wells’ waters and streams. “she said Sickle pointed
out that New York City has an unfiltered water supply.

If it were

to be contaminated

by

a hydraulic fracturing accident, then there would
be

a massive impact

on

a huge number

of residents. EPA’S LIST OF FRACIçING FLUIDSCharncoIConipirr.dirrc-lr.jectio.irFC_,2.crMISS’Lintirialoarturndoriir.tiaria5ivarvvVirtamdiriI.,iccc’ni.airtlitfIuir,brir:rir.a313.2C55)ioIi.±r,522CC‘JC’DC)atIara522C’C7C3D)lara•52,OCra.ri-h&aiar.ri4O94.C’O1-rrnapthaI,ria1,.3OOC2O/6C2anapthalariridinr.apthcJar.ar270,570.OGiramatilrthalarao1E2,O6OQOiraEjorrir,t:1.aQ2C3)pr,ar:hrer.a3O.OD&r,,aictWatarGallinggirnr.tlrrAgtrrtprotar4ll3,04S.50irafurroricacid132357.37na.linearOn)furn.iricacid529,351.4llnra..Polyivrnradjoinacid365.25743nraCerrg4vrtabar..oern5.2)1LIILts)Ibcr.onrrn7Ci.D]nirathyltare-t.athcr2.5±phalarnp.olyrijclnoraroma.tkIeydrcrorb.,nrnaJt)ira.policvalirior;orriemuttnt(tram)iratodknorhirdrooidanra.tominrinaC,00).IS)xvlrir.t1C.OC’3.3OCrosommkarhoririacidj.7O9?6.OCnratth1airtgIcoI3S2S8L273.)C3r)r,-cnictthanrc’la.rnirtrroira.Cro,snlin,karairdiurativb.irrae‘aCroirnlunucetommoaingnrrckrlorida-iraIaLMLbta)potonicncirhrelroxidrairD,njurrrnitrattin.:jrcrirrijni_r,tftttfoAatin.opropa.nol234,945.16cia.taitofa1klainrirra:rio00d,tth.a.rrola.rairtrcairaFaucüncgAa.tethanol233,091.75ira.2-btiririthanol250,641.09ira.anterta.ltrcairapoljlyn.n.leihrnoira.watt,Irafounrirr(9J.J0)IircIathnrerionraAddTreatmanthdruchleririacidrrarcaAridT,aatin,arrtiorrnmriiouira73SC)2)llnaakartkuiddjac,rnirrcnj,,rriraroxdituIfataIraira.llraakarikjidria.zrrtnconuinoirieroculfatacia.(IU.lilirtir)aznnrcrrianrr,oulfotaIraccciparcompoczrrdn..±f)C’)ethIenirt1-nc.lIra tuna-Iatharn.no5diarbiaaiih2-rra-2rritroI.3-rrropacrcdicliraShnaidri2,ibmaao-3-propioaaraideira.2--3-ninilovropiarca.rchidcnrallitnriaidtirpirlynyriuiriorganicrriaer(pain)irapolyrcucleoramrroriuichydrocorbor.sIPaKtcia.AddCarraahnrirra.etharrci936O7ç0OO.D01450)23ldr9,itiirpropargiolri&ioI±7.425,009.00iraAddCnranionciyridircium,Ihaniytcarth1).,oehninartiryldth.noiraIrdrttaritilounea210750,000.92irapir9LI020l39275,000CCiranolv{oxy-1.2hanediyl>r.onvlpnranvl-3,vdroranaIra.-ccedtreuIatoryn.tirrdardSOCL=*t.a,aim-.,monrtarrrina.nctLevel-Thrihightkvelofacontaminantthatioalawndjrdr,rrbnirr.atnr.£E=AORiok9aoadCoocentraonTable.4iretp:/i’=.aaçovIg3hmd!rikfandnnirnIdvclopadbyRagior.3,tervir.g:Dala’.-ara,DuiotricrofColumbia,ll4rrlnnrd,Pcniniry4vvik,Wginia,WeotWginio)4P=t4arachurettn.ContingencyPlvr-Ritk-batadgroundirn-ateratanthrdtFardrinking“nattrprotection-.chotrirrbecaciteMantacbrzn.ett.shairdmelopcdotandardoformarryconrtituorctniiid,nrn&friel.Tvonumbernarcgiven(thefiretitdniirkinrgwatern.tindord,thetecorirdatzrxfardforgroundwaterdinc*rargingtotwfa.cawater).ProdcCriarnintalCompoiritsonofExiirtcnirgPrdjctsConcentrationvlrtarest4q(UMyth: Hydraulic fracturing fluids and products pose no real risk to our water supplies

or public health. Fact: Hydraulic fracturing fluids contain toxic chemicals

and are being injected into and near drinking water supplies. According

to the EPA, toxic chemicals

in fracturing fluids include substances
such
as polycyclic aromatic hydrocarbons; methanol; formaldehyde; ethylene glycol; glycol ethers; hydrochloric
acid; sodium hydroxide;

and diesel fuel, which contains benzene, ethylbenzene, toluene, xylene, naphthalene

and other chemicals. These chemicals have known negative health effects such
as respiratory, neurological

and reproductive impacts, impacts

on the central nervous system, and cancer. The Endocrine Disruption Exchange,
Inc., (TEDX) has also recently documented health effects of chemicals used

in 435 fracturing products. According

to TEDX, the top four health effects
for chemicals

in these products include: skin, eye and sensory organ effects, respiratory effects, gastrointestinal effects, and brain and nervous system effects.

In addition

to being injected into and near water resources, these chemicals

are also being trucked through
our communities and can spill and leak from trucks, pits, disposal wells, and flowlines. Aside from water contamination, communities

are faced with public health threats from chemicals evaporating

off drilling sites and residual chemicals
that can spill or leak onto our soils. Myth: There are no ocumentëd
cases

of fracturing fluids migrating intodrinking water wells. Fact: The oil and gas industry

is splitting hairs with this claim. Complaints
have been documented

in Alabama, Colorado, New Mexico, Ohio, Texas, Virginia, West Virginia and Wyoming

in which residents have reported changes

in water quality

or quantity following fracturing operations

of gas wells near their homes.

In mitigating

and documenting
these instances, industry and state regulators have cited casing failures, impacts from other mining operations, methane migration
and other explanations

for water contamination. Regulators

and the public have had to accept these explanations,

in part, because industry refuses

to disclose the make-up

of fracturing chemicals,

and regulators

do not know what specific chemicals they are looking
for following fracturing complaints.

The fact remains that landowners

and communities

are experiencing changes

in water quality and quantity that occur during and after fracturing. Myth: Our drinking water

is not at risk from hydraulic fracturing because industry

is fracturing at depths below the aquifers from which our communities

are locating water wells. Fact: There are number

of ways

in which hydraulic fracturing threatens

our drinking water. Where drilling companies

are developing fairly shallow

oil or gas resources,
such
as some coalbed methane formations, drilling may take place directly

in the aquifers from which we draw our drinking water.

In that case, contamination

may result from the fracturing fluids that are stranded underground,

as the few studies that are available have shown that
at least 20- 30%
of fracturing fluids may remain trapped underground. Where drilling companies

are developing deeper

oil or gas resources,
such
as shale gas resources, there are

a number

of issues and concerns. Hydraulic fracturing

can leave fluidsstrandedatthesedepths,and,throughthehighpressuresused,canopenuppathwaysforfluidsorgasesfromothergeologiclayerstoflowwheretheyarenotintended.Thismayimpactdeepergroundwaterresourcesthatmaybeconsideredfordrinkingwatersuppliesinthefuture.Iffracturingwastewaterdisposalisconductedthroughundergroundinjectionwells,thereisanadditionalriskforgroundwatercontamination.Ifwastewaterdisposaloccursinstreams,thechemicalmake-uportemperatureofthewastewatermayaffectaquaticorganisms,andthesheervolumeofwaterbeingdisposedmaydamagesensitiveaquaticecosystems.Additionally,fracturingfluidchemicalsandwastewatercanleakorspillfrominjectionwells,flowlines,trucks,tanks,orpits.Thiscontaminationcanbemovedoff-sitethroughstormwaterrun-off.Finally,faultycasing,weakcementing,humanerrorandgeologicalunknownscancontributetocontaminationfromfracturingandotherdrillingpractices.Myth:All,ornearlyall,hydraulicfracturingfluidsarerecoveredduringthefracturingprocess.Fact:Factorsaffectingfracturingfluidrecoveryincludeflowbackprocedure,jobdesign,specificreservoirconditionsandothercomplexities.Withmultiplefactorsaffectingfracturingfluidrecovery,itisreasonabletoassumethattherewillbeawiderangeinfluidrecoveryefficiencies.Infact,literaturecitedbyEPAintheir2002draftversionofthehydraulicfracturingreportconfirmedthisassumption.EPAcitedordiscussedfourdifferentstudies.Thesestudies,conductedinnon-coalbedmethanebasins,foundthatbetween25%and61%ofcertainhydraulicfracturingfluidsflowedbacktothewell(thatis,between39%to75%wasleftstrandedinsomeinstances).Oneparticularlycompellingstudyshowedthatonly35-45%ofthefracturefluidswererecovered.ThisstudywaswithdrawnfromtheEPA’sfinaldiscussionofflowbackandwasnotlistedontheirmasterreferencelistforthefinalreport4.Citizensandgroupsworkingonthisissuehaveoftenusedtherangeof20%-30%offracturingfluidsremaininginthegroundwithoutobjectionbyindustry.WhenconsideringtheEPA’sliteraturecitations,thisisaconservativeestimatethatgenerouslygrantsarangeofrecoveryefficienciestotheindustry.Myth:Thepracticeofhydraulicfracturingandcreatingundergroundfracturesiswell-tested,controllableandsafe.Fact:Itiscriticalforcommunitiesanddecisionmakerstounderstandthathydraulicfracturingfluidsnotonlycontaintoxicchemicals,butthisoperationutilizeshighvolumesoffluidsandhighpressurestointentionallyopenupundergroundpathwaysforgasoroiltoflow.Injectedfluidshavebeenknowntotravelasfaras3,000feetfromawell,andfracturingfluidsmayremaintrappedunderground.Whileindustryclaimsthatfracturingisawell-testedandcontrollabletechnology,computermodelshaveshownthatfracturescanbehavedifferentlythanpredicted,anddiagnostictechniquesillustratingfracturehistoryarerarelyused.Itisimportantforcommunitiesanddecisionmakerstogathermoreinformationaboutfracturebehavior,andtoensurethatanystrandedfluidsdonotremaininormoveintoourdrinkingwaterresources.Myth:Stateregulationsaddressingcasingandotheraspectsofdrillingprocesssuchasspillsandleaksadequatelyregulatefracturingproductsandpractices.Fact:Moststates’policiesregardinghydraulicfracturingamountto“don’taskanddon’ttell.”Atthestatelevel,mostoilandgasagenciesdonotrequirecompaniestoreportthevolumesornamesofchemicalsbeinginjectedduringhydraulicfracturing,andtheyhaveneverconductedanysamplingtodeterminetheundergroundorsurfacefateofhydraulicfracturingchemicals.Withoutthatinformation,neitherstatesnorthepubliccanbegintoeliminatetheuseoftoxicmaterials,noradequatelyevaluateordevelopmonitoringprogramstoassesstherisksposedbyinjectingthesefluidsunderground.Myth:Non-toxicandlesstoxicfracturingalternativesareintheirinfancyandnotavailableforindustryuse.Fact:Oilandgasoperatorsareroutinelyusinglesstoxicfracturingfluidsinoff-shoreenvironmentsinordertomeetfederalrequirementsundertheCleanWaterAct,andsomeoperatorshavetestedandstudiednon-toxicfracturingfluidsastheyproblem-solvesitespecificissuesintheBlackWarriorandSanJuanBasins.Thus,thedevelopmentofnon-toxicorgreenfracturingfluidsisnotinitsinfancy.Theoffshoreoilandgasindustry,forexample,hashadtodevelopfluidsthatarenon-toxictomarineorganismsinordertobeallowedtodischargethefluidsintotheocean.AccordingtotheSchlumbergerwebsite:“MeetingstringentenvironmentalguidelinesinboththeU.K.NorthSeaandtheGulfofMexico(GOM),thenewSchlumbergerGreenSlurrysystemdeliversconsistent,earth-friendlyperformance.Thisslurrysystem,developedforuseinalltypesoffracturingandgravel-packingoperationsinenvironmentallysensitiveregions,featuresauniquecarrierfluid.Thenewcarrierfluidcanbeeasilymeteredusingallexistingequipment.”ThepublicanddecisionmakersmustassumethatSchlumbergerandmanyothercompaniesformulatethesetypesoffluidsbecausestandardfracturingfluidsaretoxictomarineorganismsandwillnotmeetoff-shoreregulations.Becausewedon’thavefulldisclosureoffracturingfluids,itremainsvagueastohowtoxicorlesstoxicproductsdesignedforanoffshoreenvironmentaretohumans.However,industrystudiesanddemonstrationshaveshowthatwaterwithoutanyadditivesisaneffectivefracturingfluidthatismoreeconomicincertainenvironments,andcansolveproductionproblemssuchaschemicalgels(cross-linkergels)damagingcoalpermeabilityZ.Myth:LiftingtheexemptionforhydraulicfracturingundertheSafeDrinkingWaterActwouldbeundulyburdensomeforStates.Fact:CongressionalRepresentativesDeGette(CO),Salazar(CD)andHinchey(NY)introducedabillin2OO8thatwouldreversespecialtreatmentofHalliburtonandotherhydraulicfracturingcompaniesbyrequiringregulationofhydraulicfracturingundertheSafeDrinkingWaterAct(HR7231).Thiseffortestablishesaminimumfederalfloorforprotectingdrinkingwaterfromhydraulicfracturing.AccordingtotheEPA,theregulationofundergroundinjectiondoesnotrequireanewpermittingprocess.Astatecouldbeginthespecificregulationofhydraulicfracturing

by issuing

a general rule for hydraulic fracturing
with safety standards. States already have permit processes

for oil and gas wells and they could simply include hydraulic fracturing. Protect Our Drinking Water Join us and support efforts

to: End the Safe Drinking Water Act exemption

for hydraulic fracturing. Require
full chemical disclosure

and monitoring

of hydraulic fracturing products. Require non-toxic fracturing

and drilling products. Visit www.ogap.org

to learn more, receive action alerts and stay involved.1.U.S.EnvironmentalProtectionAgency.August,2002.DRAFTEvaluationofImpactstoUndergroundSourcesofDrinkingWaterbyHydraulicFracturingofCoalbedMethaneReservoirs.EPA816-D-02-006.2.TheEndocrineDisruptionExchange,Inc.February2009.ProductsandChemicalsusedinFracturing.http://www.endocrinedisruption.com/chemicals.ftacturing.php3.U.S.EnvironmentalProtectionAgency.August,2002.DRAFTEvaluationofImpactstoundergroundSourcesofDrinkingWaterbyHydraulicFracturingofCoalbedMethaneReservoirs.EPA816-D-02-006.Thisdraftcitesordiscusses:Mukhergee,etal(1995),Palmerandothers(1991a),Samueletal.(1997),Willbergetal(1997).4.Mukhergee,HI,Paoli,B.F.,McDonald,T.andCartayaH.1995Successfulcontroloffractureheightgrowthbyplacementofanartificialbarrier.SPEProductionandFacilities,10(2);89-95.(citedonpageA-18ofthedraftEPAReport)5.INThESUPREMECOURTOFTEXAS,No.05-0466,CoastalOil&GasCorp.andCoastalOil&GasUSA,L.P.,Petitioners,v.GarzaEnergyTrustetal.,Respondents,OnPetitionforReviewfromtheCourtofAppealsfortheThirteenthDistrictofTexas,ArguedSeptember28,2006.6.(Schlumberger.Greenchemistry:Earth-friendlyGreenSlurry systemforuniformmarineperformance.)http://www.slb.com/content/services/stimulation/execution/greenslurry.asp7.SeeL.Sumi’sdiscussioninOurDrinkingWateratRisk(2005).Tworeleventindustrystudiesonnon-toxicfracturingfluidsinclude:(i)T.L.Logan.1994.‘PreliminaryresultsofcooperativeresearcheffortswithPhillipsPetroleumCompanyandAmaxOilandGasInc.,SanJuanBasin.”QuarterlyReviewofMethanefromCoalSeamsTechnology.April199411(3&4):39-49.(ii)Purl,R.,King,G.E.,Palmer,I.D.AmocoProductionCo.1991.‘DamagetoCoalPermeabilityDuringHydraulicFracturing.’PaperpresentedattheRockyMountainRegionalMeetingandLow-PermeabilityReservoirsSymposium,Denver,CO,April15-17,1991. releasing
gas, along with radioactive

and other carcinogenic

and highly toxic substances from deep within the earth. These carcinogens, along with radioactive materials
and the toxic sludge known

as frack fluid, can contaminate aquifers
and spoil water supplies. Gas/and tells the gripping
and awful story of how fracking became
the dominant technology

in US gas production.

As Eisenberg explained, Halliburton

and Dick Cheney

are prime actors

in the fracking drama. The Energy Policy Act of 2005, developed behind closed doors with Cheney’s oversight, allowed energy companies

to conceal

as trade secrets
the chemicals they use to help the drilling liquid reach and fracture
the shale. But reports

by whistle-blowers,

and industry documents have revealed that the“trade secrets” clause

is being used
to cover the fact that dangerous compounds

like butoxyethanol, formaldehyde, ethylene glycol, glycol ethers, hydrocholoric

acid, sodium hydroxide

and benzene

are posing

a major health risk to increasing numbers

of Americans. Filmmaker

Fox traveled across

32 states

to meet rural residents

on the front lines of fracking
and investigate

the concrete consequences

of the practice

on the ground.

He discovered toxic streams, ruined aquifers, dying livestock, brutal illnesses,
and kitchen sinks that burst into flame. What

to do?
A good first step

is to implore your reps
to support
the Fracturing Responsibility

and Awareness

of Chemicals (FRAC) Act. The legislation
aims

to repeal the exemption

for hydraulic fracturing

in the Safe Drinking Water Act.

It would require
the energy industry

to disclose
the chemicals

it pumps underground

in the hydraulic fracturing process, information

that has been protected

as trade secrets. Supporting United
for Action,

an organization

of “volunteers
who shape public policy decisions

by organizing

and mobilizing groups

of like minded citizens,”

is another good way
to help halt the practice

of hydraulic fracturing. Check out the groups’ website
for more background

info and details

on how you can get involved

in the fight against fracking. Related Topics: ActivismH:1•1.&tCONDENSATE •1 AND: I j9A!Lj Condensate to an oil refinery NGL RECOVERY ‘Turbo-expander and

_____ I dernethanizer.. oo(ln older pnts) FRACTIONA11ON TRJN • De-ethanzer : Deropnzer

1 1 Rawgas + pipeline Waste water

ACID GAS REMOVAL • Amine treating ‘enfleId prccess •PSAunit: Sulfinol process • Others

Tail TAIL GAS TREA]1NG gas *ScotproceS$:. C[auspol process Off gas to incinerator Elemental sulfur —JRAT1ON 1 • Gtycolunft LAun[t.:. To sales gas pipeline

F NITROGEN REJECTiON: I • Cryogenic process

j Sbsorption processes L ‘Adsorption processes Nitrogen-rich gas

MERCURY REMOVAL ‘Mol sieves • Activated carbon SWEETENING UNITS Merox process ‘Suifrexprocess • Mol sIeves

-

Ethane Propane Butane PentaneS++ Rules need to require “Top to Bottom” cementing to prevent seepage into upper formations and intersected faults. This reduces water and air contamination. Prolongs pipe life and reduces corrosion/damage. Enhanced closure at end of production life. + Piping arrangements should be welded as opposed to screw fit in all but absolutely needed make/break situations. + Normally closed valves should be used in material handling operations, such that positive attention is used for open status. + If electric power not available, use “dual” fuel engines, with natural gas being the alternate.+ H2S removal equipment required if any H2S over 10 ppm is encountered regardless of initial cause. •. No open dumping of down hole gases in any non-production operations and/or rework. •• Tank all produced water with capture requirements on vent systems. Negative pressure environment in tanks would further reduce fugitive emission. + Flaring devices should be on an emission program of improvement from 95% efficiency to 99% in 5 years. Catalytic converters should be mandatory, as a minimum, if they work in this application. + Valves on well pipe and tree must be above ground surface and maintained properly at all times.•• Welded or soldered piping for pneumatic systems to reduce emissions. No open to air exhaust dumping without going through reclassifiers, filters, etc. + Flaring operations on same 5 year improvement program and requirements as outlined in ON THE PAD.+ Pigging operations are remote operators sensitive. Failsafe communications and procedures must be required to prevent pressurized opening of pipelines. High maintenance is required to keep seals leak tight. Pipeline vulnerability exists at these stations and redesign should be explored. + Induced power currents can be created by overhead power transmission lines can create corrosion problems and leaks. Layout routes must be carefully planned or proper cathodic protection required.+ SOx and NOx emissions are occurring at every level of operation with engine and process venting. Flaring operations must be improved and engine idle times reduced. Programs like Energy Star could be applied. + Particulate handling of tracking sand is inadequate and subject to easy failures. Material transfer filters for these operations must not allow this type of release. See:

httD :/!viv’w.yo utu be. cc rn/dcdsva n ni + Pad construction must be done with proper dust controls such as water wet down.New York Times: In North Dakota, Flames of Wasted Natural Gas Light the Prairie Jim Wilson/The New York Times Thirty percent of the natural gas extracted in North Dakota is flared off, like this gas near Ray. By OLFFCDJSS Published: September 26, 2011 NEW TOWN, N.D. — Across western North Dakota, hundreds of fires rise above fields of wheat and sunflowers and bales of hay. At night, they illuminate the prairie skies like giant fireflies. They are not wildfires caused by lightning strikes or other acts of nature, but the deliberate burning of natural gas by oil companies rushing to extract oil from the Bakken shale field and take advantage of the high price of crude. The gas bubbles up alongside the far more valuable oil, and with less economic incentive to capture it, the drillers treat the gas as waste and simply burn it.

ij wwnvur’ies ccrr’2Di s’v.tr 2 rtner=rs2m=rssThankyouforprovidingthisopportunityforthepublictoweighinonthepubUcJieatlia-thiwirrmmeit.I’dliketomaketwomainpointstoday:Thefirstisthatthetimetoactisnow.And,thesecondisthatwhiletheserulesareabigstepforwar4,EPAhasalsomissedsomekeyopportunitiestotrulygetahandleonthepoll’4tioncausedbythisindustryI(1)Thetimetoactisnow:‘‘N-Existingrulesthatapplytotheoilandgasindustryarewoefullyinadequateandout-of-date.Asyouknow,EPAissupposedtoupdatethesestandardseveryeightThyears,buttheydidn’tdoit.Someofthesestandardshavebeenaroundfor20years,andthey’veneverbeenupdated.So,in2009,EarthjusticesuedEPA—onbehalfofWildearthGuardiansandSanJuanCitizens’Alliance—toforcethemtotakealookatthesestandardsandwhat’sbeengoingonintheindustryandwheretheholesare.-And,what’sbeengoingonisthattherehasbeenanoilandgasdrillingboomintheRockyMountainWestandotherpartsofthecountry.And,thedevelopmentof“fracking”technologyhasenabledtheindustrytodrillinplacesthathaveneverbeforebeendrilled.And,suddenlywehavecommunitiesthathaveneverhadtodealwiththistypeofpollutionsaying,waitaminutethetoxicchemicalsandsmogformingcompoundsassociatedwithoilandgasdevelopmentaremakingussick.-Forexample,someoftheworsesmogpollutionoccurringasaresultofoilandgasdevelopmentishappeninginruralWesternWyoming,wherelastwintertheyexperiencesozonelevelsthatareworsethantheworsesmogdaysinL.A.Onthosedays,Wyomingstateofficialshavewarnedelderlypeople,children,andpeoplewithasthmatoavoidoutdooractivityandtostayinside.-TheproblemsaregrowinginColoradoaswell.Therearenowmorethan45,000activeoilandgaswellsinthisstate.-PeopleinwesternCOhavebeencomplainingforyearsaboutthenoxiousfumesandheadaches,dizziness,andnosebleedscausedbyrampantoilandgasdevelopmentintheirbackyards.controltechnologiesavailableforcapturingthatgasandputtingittogooduse.-EPAalsoappearstohaveignoredcost-effectivecontrolsthataceavailabletopreventpollutionassociatedwuidsunloading.-And,EP*iiasleft—ttt-alot-ofsourcesofpollutionatthewellsite,suchasstoragetanks,pneumatics,andcompressors.-EPA-alsofailstpptoposethueHydrogensugtaiies-neuro1eg4calimpaeJt.ctc,LL(3)Existingsonrcs:Theproposedruleisfocusedoncleaningupnewandmodifiedsourcesandthat’sreallyimportant,butthere’salsoalotofreallydirty,outdatedinfrastructureouttherethatEPAhastheauthoritytoregulate.Itshouldtakeadvantageofitsauthorityunder111(d)oftheCleanAirActtoregulatethoseexistingsourcesandprovidegreaterprotectionforpublichealth.(4)And,finally,withrespecttohazardousairpollutants,EPAneedstoeliminatethesocalled“malfunctiondefense,”whichallowsindustrytoviolatestandardsdesignedtoprotectthepublichealthwithoutpayinganypenalty.Wewillprovidemoredetailregardingthesemissedopportunitiesinourwrittencommentsontheproposedrule.Insum,wethinkthatEPAisheadingintherightdirection,buttherearestillgapstobefilledinordertotrulyprotectourcommunities.Thankyouai-f..theSeptember

28, 2011 Presented

to: Environmental Protection Agency Subject: Public Hearing

on Air Pollution

by the Oil and Gas Industry By: Wayne

E. Grider, Chair
of the Advocacy Committee American Lung Association- Colorado I am here today

to support
the EPA’s proposal

to implement
new standards

to reduce dangerous

and harmful

air pollution from the oil and natural gas industries. These standards

will protect Americans from harmful

air pollutants, including volatile organic compounds,
toxic air pollutants, ozone and particulate matter across the country. The EPA’s-proposed
sulfur dioxide standard
will help reduce this harmful pollutant,
long recognized

for its harm

to health. What are the health impacts?

It has been clinically demonstrated

that breathing sulfur dioxide causes wheezing, coughing
and shortness

of breath. Sulfur dioxide can worsen asthma and increase
the need for hospital and emergency room treatment. Collectively,

the human clinical, epidemiologic,

and animal toxicological

data are sufficient

to conclude that there

is a causal relationship between respiratory morbidity
and short-term exposure

to 502. Present day concentrations

of 502 are also implicated

in increased emergency department
visits and hospitalizations

for respiratory causes among children
and older adults. The American Lung Association

of Colorado recommends
your agency require cleanup

of both new and existing sources,
not just new ones—especially compressors

and gas-driven controllers

and valves; and Set standards

for the reduction

of methane.

In addition

to being

a potent greenhouse

gas, methane

is an air pollutant that impairs local air quality,

it should

be directly regulated
and not just

a byproduct

of the reductions

of VOCs. The VOCs,
air toxics and sulfur dioxide reductions

in the proposed
rule are expected

to improve outdoor

air quality, reduce cancer risk from air toxics emissions
and reduce health effects associated with exposure

to ground-level
smog and fine particle pollution.
The VOC reductions

are estimated

to be 540,000 tons, for methane another

3.4 million tons and air toxics 38,000 tons. We believe those represent significant strides forward and worth the short term costs. Thank you for giving

us the opportunity

to testify this morning.

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# Limit VOC emissions from new fracking and refracked wells Question: If one option is to flare gas, where is this net savings coming from?
Question: If we are assuming this is a new well without infrastruct ure, where is this captured gas going to be sold to create this net savings? Are you going to truck it off?
Question: If we are assuming this is a new well w ithout infrastructure, will the producer need to obtain a separate permit to install a VRU compre ssor? Obtaining these permits could take up to 12 months. For smaller producers this could make many wells unviable with the requirement for additional costs and delays.
If a permit is not required, then controls will not be required, and how much additional emission will come from the uncontrolled VRU unit?
Where will the fuel gas come from to operate the VRU, since the quality of the gas coming off the well will likely not be of ade quate quality to run the VRU?
Has the return for New Net Savings included the cost to provide fuel gas or electricity at outlying areas?
Question: If the well is at the tail end of gathering system, wit hout electrical power for a VRU compression, will it be necessary for the producer to obtain a permit for a VRU compressor?
Question: How does this apply to oil wells with associated gas? Pneumatic Controllers, which regulate pr essure, flow and compressor stations
Question: Are older facilities grandfathered? If not, how will the pr oducer recover the new expense? The cost for some small compressor controllers can cost anywhere from $5,000 to $10,000 each.

Condensate and crude oil storage tanks

 Tanks with a throughput of at least 1 barrel p er day of condensate or 20 barrels per day of crude oil (equivalent to about 6 tons of VOC emissions per year) must reduce VOC emissions by 95 percent.
This WILL affect smaller producers substantially. This also may result in more combustion of fuel gas to supplement the tank vapors. Stock tanks may also require costly controls not currently required.

GCC believes the EPA has grossly underestimated the cost of these provisions and overstated the reduction in emissions.

For the large producers and Midstream companies these rules may be acceptable. For the smaller companies, the capitol cost, mainte nance costs and recoded keeping w ill force them from the market.ILLiHPUHA1LiLrs’EamprerirCnniiiItiintMynameisWayneSartori,andIamthepresidentofGasCompressorConsultantsInc.Ihaveover40yearsofexperiencewiththemaintenance,designandoperationofcompressors.MycompanyiscurrentlybuildingcompressorstationsandoptimizingcompressionandprocessfacilitiesinPennsylvania,WestVirginia,Mississippi,Louisiana,Colorado,Utah,WyomingandNorthDakota.Ourmissionstatement:“CCCisdedicatedtoimprovingtheeconomicperformanceofcompressionfacilitiesandgatheringsystemsbyapplyingnewandprovensolutionstooptimizenaturalgasdeliveryingathering,compressionandprocessing.”ThemajorityofourclientsaresmallproducersandmidstreamcompaniesseekingwaystoreducetheirLOEasapercentageofthroughput.“Theestimatedrevenuesfromsellingthegasthatcurrentlygoestowastearesignificant—somuchsothattoday’sproposedruleisanticipatedtoquicklyresultinanetsavingsofnearly$30millionannually,whilesignificantlyreducingpollutionfromthisexpandingindustry.”Sealreplacementrequiredat26000HrintervalsonreciprocatingandcentrifugalcompressorsTypicalsealswillhavesomeinitialleakageuponinstallation.Thisleakagewillremainfairlyconstantuntilthesealfails.Thesealfailurecouldoccurat20hrs,2000hrsor150,000hrs.Anyoperatorwillimmediatelyneedtoreplacethesesealsuponfailureastheircompressorwillnotoperateproperly.Aspecifiedtimeperiodisauselessandcostlyendeavortocontrolemissionreleasefromcompressorseals.Inallcases,sealreplacementwillresultinsubstantialdowntime.Insomecases,thesealreplacementmayrequirethedismantlingofthecompressorpiston,crosshead,pistonrodandpiping,andmayrequirerealignmentofthecompressoritself.Howisthiscostreimbursedbythenewregulations’?Isthereagrandfatherclauseforoldercompressors?Whatwouldbethebaselinepointfordeterminingruntime?howwouldthisbeenfhrced?Li?Ae6PerhapstheEPAshouldregulatehowoftenvalvesarechangedonacompressorpackage!ORRegulatehowoldacompressorpackagecanhe!ORRegulatewhatcompressormanufacturercanbeused!4725SouthMonacoSt.,Suite360**Denver,CO80237**(303)400-4300**303-400-4301FAXLimitVOCemissionsfromnewfrackingandrefrackedwells//Question:Ifoneoptionistoflaregas,whereisthisnetsavingscomingfrom?Question:Ifweareassumingthisisanewwellwithoutinfrastructure,whereisthiscapturedgasgoingtobesoldtocreatethisnetsavings?Areyougoingtotruckitoff?Question:Ifweareassumingthisisanewwellwithoutinfrastructure,willtheproducerneedtoobtainaseparatepermittoinstallaVRUcompressor?Obtainingthesepermitscouldtakeupto12months.Forsmallerproducersthiscouldmakemanywellsunviablewiththerequirementforadditionalcostsanddelays.Ifapermitisnotrequired,thencontrolswillnotberequired,andhowmuchadditionalemissionwillcomefromtheuncontrolledVRUunit?WherewillthefuelgascomefromtooperatetheVRU,sincethequalityofthegascomingoffthewellwilllikelynotbeofadequatequalitytoruntheVRU?I-lasthereturnforNewNetSavingsincludedthecosttoprovidefuelgasorelectricityatoutlyingareas?Question:Howdoesthisapplytooilwellswithassociatedgas?PneumaticControllers,whichregulatepressure,flowandcompressorstationsQuestion:Areolderfacilitiesgrandfathered?Ifnot,howwilltheproducerrecoverthenewexpense?Thecostforsomesmallcompressorcontrollerscancostanywherefrom$5,000to$10,000each.Condensateandcrudeoilstoragetanks•Tankswithathroughputofatleast1barrelper(layofcondensateor20barrelsperdayofcrudeoil(‘equi’alenttoabout6tonsofVOCemissionsperyear)niustreduceVOCemissionsby95percent.ThisWILLaffectsmallerproducerssubstantially.Thisalsomayresultinmorecombustionoffuelgastosupplementthetankvapors.Stocktanksmayalsorequirecostlycontrolsnotcurrentlyrequired.GCCbelievestheEPAhasgrosslyunderestimatedthecostoftheseprovisionsandoverstatedthereductioninemissions.ForthelargeproducersandMidstreamcompaniestheserulesmaybeacceptable.Forthesmallercompanies,thecapitolcost.maintenancecostsandrecodedkeepingwillforcethemfromthemarket.4725SouthMonacoSt.,Suite360**Denver,CO80237**(303)400-4300**303-400-4301FAXTestimony

of: William

P. Crossen Chairman

of the Board

of Directors American Lung Association

in Colorado At the:

EPA Public Hearings

on Air Pollution from the Oil and Natural Gas Sector September

28, 2011 Denver, Colorado Good morning.

My name

is Bill Crossen
and

I am the Chairman

of the Board

of the American Lung Association

in Colorado.

I am here today with my colleagues

to testify

in support

of the EPA’s proposal

to implement
new standards

to reduce dangerous

and harmful

air pollution from the oil and natural
gas industries. These standards

will protect Americans from harmful

air pollutants, including volatile organic compounds,
toxic air pollutants, ozone and particulate matter across the country. These EPA-proposed standards

will cut toxic air emissions, including

the carcinogen benzene

by 95%. The air toxics standards

will reduce hazardous

air pollutants arising from the oil and gas production process

as well
as from the transmission

and storage

of oil and gas products. Toxic air pollutants

can cause cancer, but they can also irritate the eyes, skin, and the respiratory tract, impair lung function,
and cause harmful affects

to other vital organs. People most

at risk of harm from breathing these hazardous

air pollutants include: infants, children
and teenagers, older adults, pregnant women, people with asthma and other lung diseases, people with cardiovascular disease, diabetics, people with low incomes,
and otherwise healthy adults who work
or exercise outdoors. In addition

to supporting

the proposed standards,

the American Lung Association

in Colorado
also encourages

the EPA to develop additional standards

to: • Require cleanup

of both new and existing sources,
not just new ones—especially compressors

and gas-driven controllers

and valves; and • Set standards

for the reduction

of methane.

In addition

to being

a potent greenhouse

gas, methane

is an air pollutant that impairs local air quality. Accordingly,

it should

be directly regulated

and not just
as

a byproduct

of efforts

to reduce volatile organic compounds. Emissions from
oil and gas production

not only harm human health, they waste money because, essentially,

gas products

are escaping
into the air. These proposed standards provide

a proven approach

to protect health and save money. The EPA has calculated
that these measures

will save the industry
$30 million annually. In summary,

we support
the proposed regulations because

we believe they will improve health, enhance efficiency
and save money.

In addition,

we encourage

the EPA to extend the proposed standards

to include existing sources,
not just new ones, and to establish standards

for the reduction

of methane. Thank you for the opportunity

to testify this morning.