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 ofthe 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=apilication°’2 lpdi&blob kev=id&hlohtahlevIungoBlohs&hlohwhere=l 251 736903762&sshinarv=rtrue These
find them in any search of the law review literature. The website of the Science and

Environmental Health Network is a good place to start. www.selm.orgAnd sixth, please consider the effect, on the biosphere and the climate, of unearthing a living

ecosystem that exists but has not been studied. Dr. Sandra Steingraber, on September 15 in a

forum on New York’s Finger Lakes, commented that some biologists are beginning to study

the effect of strange creatures in the shale whose behavior is thought to have a role in

stabilizing climate. Please consider the consequences of large-scale tinkering with something

we do not understand at all because we have never had to study it.

http://wwv.voutube.com/wach?v=eu1u3h Uhk Our past ignorance has gotten us in a

whole heap of trouble already, but it is too late in the game to wink or look aside as if we are

not the responsible ones!

So to sum up my six points:

1. Use unbiased scientific data, highlighting independent scientists.

2. Be sober in the cost-benefit analysis: Don’t weight the industry side for national

security.

3. The real urgency is climate change, and the real cost is lost R&I) opportunity.

Refocus industry resources on ramping up renewables.

4. Update the numbers.

5. Cumulative impact.6. Don’t mess with Mother Nature until we really know what we are doing!

I thank you for trying. Thank you for claiming responsibility for one of the soaring

environmental and public health issues of our decade., And thank you for helping us to make

this public record. 4L /

Good luck! God bless your work!

a4

Elizabeth A Comeaux, Colorado Attorney #8674

Former Chief Administrative Law Judge 01’ State Personnel Board, retired from Colorado Dept of labor

Former Program Administrator. Center for Earth Jurisprudence

Co—Coordinator. Loretto Earth Network Member. Healthy (3ulfKrewe. (jull Restoration NetworL

Residence 221 South Osceola St. Denver, CO 80219 720-379-7864libhvcomeau\i eniuileom
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 airstandards 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 standardshave 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
EOF supports ElA’s proposal and recommends it be strengthenedEPA’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 processingplants 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.
g

ector. 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.

I0

0

Efl1’ o-1 — LA 0\

1*

F.
J9)

L

0

---t

OLJ

(‘ c_,

c.

F- —- -L

> —

-

gc

-

C.

_

r

I

ir

3 c

?

,cC-. _)

C

c-i.
Q-y, ± 4rk \1-C) -i-. ‘)) c’

‘

L

/

c2 J1 2 (Q

\1 LA

\

7

4 cri

C24 -i
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 ofthis 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.

Soall 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 ofthe least populated areas ofthe United States. To giv

you an idea, the nearest Starbuck’s is over an hour away! Wildlife
we can see the stars - lots ofstars - 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 Oflrecently 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 claimrightsto public input and hearing and demand’f?]

our very real environmental, health and safety concerns satisfactoril’

iehavebeeduti:thbll
p

, 

p

, 

y 

p

Environmental Protection Agency of authority to regulate fracking,

process invented by Halliburton.You achieved your dream of a career at the EPA because you had ti’

capabilities and the heart. Those capabilities are what will allow y

navigate the complexities and challenges in front you. But love is v

will make you ultimately act. I ask you to reconnect with that ideali

inside you which brought you to where you are right now. This cou

needs that spirit more than ever now in each and every person.

Please restore integrity by fully regulating frackin.

Thank you.
• Considerably higher levels of ozone and methane in our air and water.• Increased airborne pollutants such as methanol, formaldehyde, carbon disulfide, toluene and benzene.• Spills, leaks and accidents which pollute our waterways and can leach into our drinking water supplies with

contaminants that have included diesel fuel, chloride, sodium, barium, strontium and hydrochloric acid.

• Fracking wastewater with radioactive elements that end up in our rivers due to inadequate municipal

wastewater treatment.

• Short term economic gains for communities that ultimately turn into lower property values, heavy truck traffic

with costly road repairs, safety hazards from possible pipeline explosions; harm to local tourism and recreation

industries; and scenic views replaced with drilling rigs.

• Farmer and rancher livelihoods at risk because of ozone and fracking chemicals that pollute their crops and

livestock.

• The use of enormous amounts of precious water in the fracking process.• And, a possible increase in earthquakes due to fracking.

The public is concerned about these issues. Oil and gas companies took unethical advantage of the lack of federal and

state oversight of their industry. Now the EPA seems to be trying to put their finger in the dike to sp a leak withoutaddressing the real issue-- which is the fact that hydraulic fracturing is not safe to begin with. There are numerous validstudies and investigations that have demonstrated the hazards of fracking. This evidence cannot be conveniently

ignored. Fracking is an unacceptable risk to public health and our environment.

Our communities are being surrounded. In the Denver metro area alone, drilling is active or proposed in Weld, Douglas,

Arapahoe and other counties. Part of your proposal even appears to include steps to reduce compliance burdens for

industry, state, local and tribal agencies. Reductions in compliance don’t sound good to the public who has to live with

the negative consequences of fracking. Your proposal to cut smog-inducing VOC emissions is admirable but it does notgo far enough for the people who breathe the air, drink the water and eat the food from our farms and ranches. Andwith the recent expansion of shale gas rigs across the country, production will --within a few years, probably exceed US

demand. Your job is not to placate and enable future profits for the oil and gas industry.

The public demands and deserves more from our Environmental Protection Agency. We the people don’t have the

money and power that the oil and gas industry has. We don’t have the resources to make slick, disingenuous ads like

they do. We have you-- the EPA to protect us. That’s how important you are.We are sick and tired of the oil and gas industry violating and profiting from our public right to a healthy environment.

The EPA needs to ban fracking because it presents a risk of significant contamination. There are better options out there

including serious resource conservation and substantial support for development of renewable alternative energy

sources.

You are the agency that has environmental protection as your mandate. You hold our health and environment withinyour hands. Please do the right thing.
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, 2011

p

ves 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 ofsuch. 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 2
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 ofthose 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 withregard 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 theAmerican 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 2
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 84th 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

1
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 survivalstrategy: “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/heafth-safety/

2
y 

to 

y

p

g 

p

, c

d

s

terms. An industry whose corporate giants each year post record profitswould like us all to believe that we have to choose between clean air and

having a strong economy. They would like to offer the option of jobs orsafe drinking water. They spend millions to convince our representatives

of these assertions without hard evidence to support them.

Since the Energy Bill of 2005, crafted by an oil-soaked administration

with notable conflict of interests in this sensitive area, record profits have

accompanied reduced environmental safeguards. This raises a mostobvious question. If the oil and gas industry is capable of effective selfregulation in the interest of public health and safety, then why was therea need to grant them exemptions to The Clean Air and Water Acts that

have stood since the 1970’s? I remember the great satisfaction of

watching President Nixon sign these bills into law. The feeling then was

that we had put this issue to rest for our lifetimes. Now we witness, somethirty years later, a fresh and vigorous assault on our precious naturalresources. Fueling this attack is the energy industry’s huge outpouring of

money spent to lobby for degradation of protective regulations. Our airand water are not commodities which are to be manipulated or sacrificed

for corporate profits. They are vital public resources, birthrights of us all,

as intrinsically protected by intention of our founders as our rights to free

speech and redress of grievances.

The health of our people, young and old, present and future, willdetermine the health of our nation. Without access to clean air and

water, our future is bleak. Healthy men and women generate ideas, effect

growth arid change, and discover new ways to do things better. Healthy

people automatically reduce the burden on our medical care system,

which has been universally identified as a barometer of our nation’s

moral as well as fiscal soundness.
activists. If the 

dust

y 

g about 

y 

g

activities, then all of us suffer permanently. There is not a price that canadequately describe the value of our water and air. The money that oiland gas industry spends on political persuasion alone would go a long

way toward implementing restrictions and regulations to which we, as

citizens, are entitled. Our domestic resources are increasingly being

targeted for export in pursuit of new markets and increased profits while

oil and gas companies gives lip service to U.S. energy independence.

Please do not compromise the health of our own people by allowing theeagerness of a booming industry to exclusively dictate the terms of their

own operations. Please remember the name of your agency when you are

considering your actions. You are a part of a thin line of defense which

can offer protection for the overall integrity of our environment. Your

failure to act accordingly will have irretrievable consequences for all of

us. Please seize the opportunity to elevate the nation’s health to its

rightful place above the bottom line.

Kenneth Sajdak

P.O. Box 1084La Veta, Colorado 81055
industry captured escaping gasses, it could benefit from millions of dollars annually during the life cycle of operations.

Increasing air quality regulations for natural gas transmission and storage is an important proactive measure.Power Point #2Colorado has experienced a rapid increase of oil and gas well permitting during 2011. With approximately 35,000 activewells statewide there are other serious issues facing Colorado residents concerning air quality impacts. Many drilling andhydraulic fracturing operations are literally in homeowner’s back yards or close to schools. Many residents complain ofhealth impacts living in close proximity or downwind from wastewater evaporative drilling pits. Colorado residents havereported nose bleeds, headaches, nausea, brain lesions, eye inflammation, asthma or respiratory problems and other heathrelated issues when living near open oil and gas pits.Power Point # 3and #4The practice of water trucks spreading production waste water on rural roads presents serious concerns for communitymembers where oil and gas development is occurring. Thousands of gallons of untreated water is used to “suppress dust”on back roads throughout Colorado. Usually the water evaporates after a matter oftwo hours and residents complain thatthe dust cloud then seems to increase. What particulates bond to the fine silica on dirt roads? What then are local people

breathing when living near these roads or traveling along them?

Power Point # 5Recently Shell Oil disclosed their intention to flare an exploratory well operation for 45-60 days just 2.5 miles west ofthe

town of La Veta located in Southern Colorado. The prevailing wind blows in the direction of La Veta from the west,

which would expose residents to toxic emissions (such as Benzene, Ethylbenzene, Toluene and Xylenes), which areknown or suspected of causing cancer and other serious health effects. La Veta’s economic well being is dependent on

seasonal tourism from neighboring states and local train ride adventurers. Degradation ofsouthern Colorado’s landscape

and air quality would seriously reduce the economic stability in the region.We call upon our elected representatives to provide adequate appropriations to facilitate the EPA’s efforts protecting

public health and the environment for the welfare of Colorado’s communities, our children, and future generations.

Funding must be adequate for comprehensive monitoring and regulation to guarantee clean air and protect theconstitutional and human rights of all of our Colorado citizens.

I know the personal suffering of homeowners and ranchers impacted by gas and oil operations, first hand. I suffered fromnose bleeds, headaches, and inflamed upper pallet for three years. I had to breathe the blue haze contamination during

hydraulic fracturing and the toxic fumes from four surrounding pits for three years until I received a settlementfor damages on my ranch from drilling and later from what I believe was from hydraulic fracturing. I lived in the tack

room of my barn without water or facilities and lost my life savings as a teacher due to gas extraction impacts.Upton Sinclair once said: “li is dfflculi to get a man to understand something when his salary depends upon his not

understanding it”.

Gopa Ross

Sira Club


The Hydrology Company for a Gas Corporation 

Stated That The Water Used in “Dust Mitigation” on County Roads was “Proprietary” Information.
What Are The Members of This Community Breathing
What’s Wrong With This Picture?
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 this
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 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 Assessilent used information from a variety of sources to conclude thatnatural 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.
Si

c

‘

1-

S.P0

r:L3

-i

1’

:‘

:‘ ,_

‘-

-..2

JjF

N

.. IC

[

0

g

g

gens 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 fromtheir 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

ofthe 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 80218
Thank yov for your interest in taking part w;Lh the EPA hearing err air po:lutinn 1mm nit and eati,rat gas drilling en Wednesday,September 26e, 2011 at the Ceterado Canoenbae Center in Denver (700 14t’i Street Room 207 Denvnr)

Signing Up

It you nave nor already, please canhrm whh me that you haun signed up tsr a 5 minute testimony spat if not, pieaov contact Ms

Joan Poyerr at the EPA at yqLeEp.launyanrtov or )j9jj41-44eJ to reserve a time The snoner you do this, the mare tauoruble a

time uvil be available

It you are unable to attend! please see belew,

PreparingI’ve attached three documents for your convenience: - How to Prepare My Public Comment - General Talking Paints

• Sackprovnd

We nail also be avuilable across the hallway in Roam 206 whore you may prepare, praDico and base retreshments,Letterte the EditorI’ve also attactied a Leant to the Editor Template pea can personalice and submit ta your local paper! Thin is important to gain public

support aod I highly encourage you to spend a tew minutes creating and submitdng one.Unable te AHeed

It is best tor yau to physicatly attend and testity, but it circamstances prevent you from being present you can submit ycur comments

(labeled under Decket ID Namber ePA-t-tQ-0AR-2010-oSgg) to the Environmental Protection Agency through one ut the followingmethods

1202! 56e-744

Bryan Carter

Associate Drganizing Representative

Sierra Club Beyeod Coat, Colorado

1536 fflinkesp Street, Suite 46-6

Denver, CD g0202

I4133S (office)ZD143A.S02 bell)

—Attachments -.

Fetdnrs

ApptieetiensA:! My Purchases

Acacn Large PilesAutomahc DrganicerCalendarEdit Photos

Evite

Plickr

My Coal PostsMy Dove

NotepadStationeryUnsubscnber

Wake - - up

yourskin! :J,z 4

n Doline’

• Pederal eRulamaking Papal. hde’lywww regulations gay

• Follow instructions far submitbng comments

Agenoj Website: htle’l) cog oovioartdooket,hlmt

• Potlaun instmctions tar sabmifflng comments en the Air and Rad:atian Docket Wee site

• E-mail. avundvcvocbobWa5agCe

• tnclude ‘Docket ID Number BPA-HD-DAR-2g10-gSgd in subloct line

ray

Ma:l

Attonhon Docket ID Number EPA-HD-DAR-2glg-gSgb

1200 Pennsylvania Avenue, NW Washington, DC 20460

Please ioclude TWD copies and in addition, please mail a copy of your comments on the

information collection provisions tn:

• Difice at lotonnration end Regulatory Atfaits, Dttice at Management and Budget

Ago: Desk Dfficer for the EPA

725 17th Street, NW,, Washington, DC. gggo

Daestiaes?

If you bane any questicns, please dun’I hesitate to cantact me at Bmce.cartertfflsierraclub.oro or 303.454 3364

Thank you for taking a lead ao this important opportunity I look forward to meeting you then!Sincerely,Sryce Carter

EPAGasAi.. bPADesyj,, EPAGaset.. bPADasdj.,

9/28/20 1 1
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

619.929.4396
EPA Public Hearing

Oil and Natural Gas Sector: New Source Performance Standards and National Emission

Standards for Hazardous Air Pollutants Reviews

September 28, 2011

9:00am — 8:00pm

Colorado Convention Center

700 14th Street, Room 207

Denver, Colorado 80202

Verbal Statement

Colorado Oil & Gas Association

Submitted by

Andrew Casper, Regulatory Counsel

Hello, I am Andrew Casper, Regulatory Counsel with the Colorado Oil and Gas

Association (COGA). COGA is a nationally recognized trade association whose purpose

is to foster and promote the beneficial, efficient, responsible and environmentally sound

development, production and use of Colorado oil and natural gas.

Everyone uses oil and gas on a daily basis. Consumption of oil and gas is an essentialpart our lives. In recent years Colorado has proven to have a significant amount of oil

and gas resources. Recovering these resources will be beneficial both economicallyand environmentally compared to importing these goods.

The proposed oil and gas regulations are extensive and complex amending two existing

New Source Performance Standards (NSPS), two existing National Emission Standards

for Hazardous Air Pollutants (NESHAPs), and introducing a new NSPS. These

proposed rules will have a direct impact on Colorado oil and natural gas production andprocessing. COGA and our member companies have been reviewing this proposed

action and have the following general comments.

1) Because of the large amount of information presented in these proposed rules,

COGA requests an additional 60 days to review these regulations. The current

comment period is set to expire on October 24, 2011. COGA believes that a 120

day comment period would be more appropriate to thoroughly evaluate the

proposed regulations since there are 5 regulations being amended in this single

proposed action.
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 savingsand 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 properlimitations 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 SO2emissions.

However, much of the proposed Quad 0 rule seems to take aim at green house

gas emission reductions and not VOC and SO2emissions. 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

2
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.

3
Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPS) at

least every eight years. But EPA has not promulgated NSPS for the oil and gas sector for over25 years. Existing standards only cover emissions of VOCs and sulfur dioxide from natural gas

processing plants, neglecting to control a vast portion of the industry. EPA last promulgated

NESHAPS for this sector over ten years ago. Not until Earthjustice brought suit against the

agency did EPA agree to fulfill its nondiscretionary duty to review the NSPS and NESHAPS.Even still; the rulemaking has been further delayed. We therefore strongly urge EPA to delay no

more and implement this rule, necessary to protect public health and welfare.

Second, the oil and gas sector is booming. Shale gas production in the United States

increased fourteen-fold in the last ten years. 1 In 2008 alone, the oil and gas production sectoremitted over 6.5 million tons of criteria and hazardous air pollutants nationwide. 2The ColoradoDepartment of Public Health and Environment recently concluded that the smog-forming

emissions from Colorado’s oil and gas operations exceed vehicle emissions for the entire state. 3

And for the first time in its state’s history, Wyoming failed to meet federal health-based

standards for air pollution primarily due to emissions from the state’s oil and gas sector. 4 The

U.S. Energy Information Administration projects a nearly fourfold growth in shale gasproduction alone from 2009 to 2035. These facts demand immediate action to protect the public

from pollutants that will not only cause and exacerbate respiratory diseases, asthma attacks,cancer, and neurological issues, but will also significantly contribute to the accelerating climatecrisis.

This brings me to my third and final point. EPA must directly control emission of

methane in the final rule. Methane is a potent greenhouse gas that is over twenty times more

‘U.S. ENERGY INFORMATION ADMINISTRATION (ETA), OUTLOOK FOR NATURAL GAS, at 14

(2010), http://205 .254.135 .24/neic/speeches/newell 10111 0.ppt.

2EPA, THE NAT’L EMISSIONS INVENTORY,

http ://www.epa. gov/ttn/chief/net/2008inventory.html (last visited Sept. 27, 2011).

Colorado Dept. of Public Health & Environment, Air Pollution Control Division, Oil and

Gas Emission Sources, Presentation for the Air Quality Control Commission Retreat (May 15,2008), at pages 3-4.

“WYDEQ, Technical Support Document Ifor Recommended 8-Hour Ozone Designation

For the Upper Green River Basin, WY, p. viii (Mar. 26, 2009), available athttp ://deg .state.wy.us/out/downloads/Ozone%2OTSD final rev%203 -30-09 jI .pdf.

U.S. ENERGY INFORMATION ADMINISTRATION (EIA), ANNUAL ENERGY OUTLOOK 2011:

WITH PROJECTIONS TO 2035, at 2 (2011), http://www.eia.gov/forecasts/aeo/pdf/0383(201 1).pdf.

1400 GLENARM PLACE, SUITE 300 DENVER, CO 80202-5050

T: 303.623.9466 F: 303.623.8083 E: rmoffice@earthjustice.org W: www.earthjustice.org
EPA has made an Endangerment Finding that methane is an air pollutant that 

cause [SI,

or contribute[s] to, air pollution which may reasonably be anticipated to endanger public healthor welfare.” 8And in the proposed rule, EPA admits that methane emissions remain“significant.” 9Consequently, under the Clean Air Act, EPA must implement controls to regulatedirectly methane emissions.

In sum, we strongly urge EPA to implement a final rule without delay that adequately

protects the public health and welfare.

Thank you.

Ben TettlebaumEarthjustice

1400 Glenarm Place, Suite 300

Denver, CO 80202

6EPA, INVENTORY OF U.S. GREENHOUSE GAS EMISSIONS AND SINKS: 1990—2009, at 9

(2011), http://epa.gov/climatechange/emissions/downlaods 11 /US-GHG-Inventory-20 11-Complete Reportpdf.

76 Fed. Reg. 52,792 (Aug. 23, 2011).

8 74 Fed. Reg. 66,496, 66,497—99 (Dec. 15, 2009).

976 Fed Reg. 52,756.
Colorado

Lung health

impacts

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 andparticulate matter across the country.

According to the EPA, these new standards will result in an 25% industry-wide

reduction of VOCs. VOCs are one of the key precursors to ozone pollution, and

we are exceeding the federal standard for ozone pollution here in the Denver

Metro Area.

Ozone inflames our lungs and airways and can cause chest pain and cough,

aggravate asthma, reduce lung function, and increase hospital and emergency

room visits for respiratory problems. Ozone can even result in premature

death.

Particulate matter (PM25)are microscopic aerosols formed by the reaction of

sulfur dioxide in the air. They bypass the body’s natural defenses and lodge

deep within the lungs. PM25can trigger asthma attacks and heart attacks, and

increase hospital and emergency room visits. PM25can shorten life.

What ALAC Require cleanup of both new and existing sources, not just new ones—

recommends 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.

Conclusion The proposed standards on the oil and gas industry are a good step towards

protecting the health of Americans. The standards will help reduce ozone

and particulate matter levels in areas where oil and gas production occurs.

The Denver Metro Area especially must find new ways to comply with the

2008 ozone standard if that is what is likely to be enforced.
p

, 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 1th windiest state

— necessitating monitoring air pollution; we need to be exposed to the right amount and type of sunshine in this

2nd

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.
y

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 21stCentury.
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 ofthrisks by ensuring that the following stipulations are included in any suchlease:

_

1) Requirmentof using gren completion technology to the uIntçpcurrently_4yailable, and improved asimprovements ccpdeyd,nIy

-

a. Prohibiting the storage offracking 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 ofsafely removing hazardous chemicals and radionucleides priorto 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 ofsuch fissures and possible release ofthermogenic gases into the aquifers, current or planned water reservoirs, or other groundwater.

2) Requirement offull 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 ofremediation 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 ofsuch 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.
4) Payment for state of Colorado installation of aiqalijy sensors on and near well sites, (testing for similarchemicals and gases as listed in 13), in order to continuously assess air quality prior to and during all phases of

drilling operations, such that any contaminant can be timely noted, remediated, and avoided in the future byimproved performance protocols

5) Full disclosure to state ofColorado regarding the estimated volume ofwater used per frack at each well site,

prior to lease agreement and stipulated in lease agreement terms, and the actual volume of water used per frack

upon completion of each frack to be recorded and yearly reported, to permit the state to act as responsible

steward of Colorado’s increasingly scarce water supply

6) Full disclosure to state of Colorado regarding the number oftanker trucks and other heavy machinery trips per

frack, in order that the state can act as responsible steward of Colorado transportation and roads and levy cost of

needed improvements or repair associated with such logarithmically increased heavy traflic to the oil and gas

companies, on a pro rata basis

7) In the event of a serious spill or methane contamination of aquifer, fire, explosion, or other such serious threat

to publiciiealth_andwelfäre all dnllmg operations shall cease until the cause is determined by both industry and

state specialists, and a plan ofremediation and future prevention can be agreed upon by same parties andinitiated by responsible parties in industry, paid for by responsible parties in industry, and overseen by the state

of Colorado.

8) No individual residing in Arapahoe or Elbert County or the City of Denver shall forfeit or have abridged any

legal rights, including right of civil suit for lawful damages, related to State Land Board approved oil drilling on

the former Lowry Bombing Range lands.

9) Initial leases on offer only to those companies that have a record of average to above average performance in

thetndin ot Pcgárdirijâc&clents or any kiiid and each additional well development contingent

upon successful achievement of green completion and absence of any serious incident; all lease production

rights to cease in the event of major incidentlaccident, until such time as incident/accident is fully investigated,

remediation efforts proceed to state satisfaction, and performance protocols are improved to prevent the

likelihood offuture such incidents.

10) Initial lease batches be limited to under 10 in toto for the first year ofsuch operations, to allow for state

water,andhealth specialists to present performance assessments to the State Land Board at the end oftheyear, such that the State Land Board decision regarding any additional leases can be based upon reviewof performance ofthe above stipulations. Subsequent additional lease batches, if any, to be in multiples of 10per year, to permit the State Land Board to fuffill its long range land stewardship obligations to the fullest

capacity. Lease terms should contain stipulations that continuing lease be subject to performance reviewoutcome.

Copies ofthis petition are also being submitted to our local city/town government, county government, and the

Tn County Health service, as well as the Colorado Department of Public Health. We request that these entities

submit formal written statements to the State Land Board, in support of our stipulation requests as listed above,

for the preservation ofpublic health and safety.
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; ifthey don’t make money, they don’t survive, regardless ofthe consequences to the people. It is not unreasonable to
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.
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.
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 therebyreducing 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 whilehiking 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.gov
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.
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 the
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 signedleases 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 thesurface, 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 their
p

p

g

g

p

e. 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. Scott
g

,

“Susquehanna County is a poor county, so a lot of people did get work and they gotjobs and

they’re making money, so to me that’s a plus, “said Jim.

But some of those who got jobs complained about Cabot Oil and Gas and were punished or put

on leave. Most of the employees are from Texas and stay in rented houses or local hotels.

The Pennsylvania Department of Environmental Protection has been out several times to look

at the situation in Dimock, but only recently decided to take action. The DEP has how issued

orders for Cabot to plug three wells they have already drilled, which could cost millions of

dollars. Cabot also has 30 days to install permanent water supplies for families, including the

Elys, who have water delivered.

“If Cabot doesn’t agree to these terms and get it done, we’ll be in court and seeking a court

order to enforce what I’ve just laid out, “ said Scott Ely.For Jim Grimsley, what has happened is simply a rough patch.

“It’s just like anything. When they were digging subways in New York City a hundred years ago,

eve,ybody probably hated them. Today, they move a couple million people ,a day. Without them,

New York City wouldn’t be there, “Grimsley said.

But for Ely, it is a looming question of whether to uproot his family from the only place he has

ever known or to keep them in Dimock with the hope that things will change.

America’s largest shale gas reserve is in the north-east of the country and as the fracking

industry develops, even the water in New York may be under threat.

Environmental reporter Allison Sickle said that there have been no studies into whether frackingis a safe technique.
g

EPA’S LIST OF FRACIçING FLUIDS

CharncoIConipirr.d irrc-lr.jectio.ir FC_,2.cr MISS’

Linti rial oar t urn doriir.tiari

a5ivarv vVirtam diriI.,ic cc’ni.air tlit fIuir,

brir:rir.a 313.2C 55)

ioIi.±r, 522CC ‘JC’DC)

atIara 522C’C 7C3D)

lara •52,OC

ra.ri-h&aiar.ri 4O94.C’O

1-rrnapthaI,ria 1,.3OOC 2O/6C

2anapthalariri

dinr.apthcJar.ar 270,570.OG ira

matilrthalarao 1E2,O6OQO ira

Ejorrir,t :1.aQ 2C3) pr,ar:hrer.a 3O.OD

&r,,aict

Watar Galling girnr .tlrr

Agtrrt protar 4ll3,04S.50 ira

furroric acid 132357.37 na.

linear On) furn.iric acid 529,351 .4ll nra. . Polyivrnr adjoin acid 365.25743 nra

Cerrg 4vrta bar..oern 5.2)1LII Lts) Ibcr.onrrn 7Ci.D]

nirathyl tare- t. athcr 2.5±

phalarn p.olyrijclnor aroma.tk Ieydrcrorb.,nrn aJt) ira.

policvaliri or;orrie muttnt (tram) ira

todknor hirdrooida nra.

tominrina C,00).IS)

xvlrir.t 1C.OC’3.3O

Crosommkar horiri acid j.7O9?6.OC nra

tth1airt gIcoI 3S2S8L2 73.)C3 r)

r,-cnictthanrc’la.rnirt rro ira.

Cro,snlin,kar airdiura t ivb.irrae ‘aCroirnlunucet ommoaingnrr ckrlorida -ira IaLM Lbta) potonicncir hrelroxid ra

irD,njurrr nitratt in.

:jrcrirrijni_r,tfttt

foAat in.opropa.nol 234,945.16 cia.

tait of a1kl ainrirra: rio 00

d,tth.a.rrola.rairt rca ira

FaucüncgAa.t ethanol 233,091.75 ira.

2-btiririthanol 250,641.09 ira.

anter ta.lt rca ira

poljlyn.n.l eihr no ira.

watt, Ira

founrirr(9J.J0) IircI athnre rio nra

Add Treatmant hdruchleriri acid rra rca

Arid T,aatin,arrt iorrnmri iou ira 73 SC) 2) llnaakartkuid djac,rnirrcnj,,rr iraroxdituIfata Ira ira.

llraakar ikjidri a.zrrtnconuinoi rieroculfata cia. (IU.l ilirtir) aznnrcrrianrr, oulfota Ira

ccciparcompoczrrdn. .±f) C’)

ethIenir

t1-nc.l Ira

tuna-I atharn. no

5diarbiaaiih 2-rra-2rritroI.3-rrropacrcdicl ira

Shnaidri 2,ibmaao-3-propioaaraide ira. 2- -3-ni nilovropiarca.rchidc nra

llitnriaidtir pirlynyriuiri organic rriaer (pain) ira polyrcucleor amrroriuic hydrocorbor.s IPaKt cia.

Add Carraahnri rra.etharrci 936O7ç0OO.D0 1450) 23 ldr9,itiir propargi olri&ioI ±7.425,009.00 ira Add Cnranion ciyridircium, I haniytcarth1).,oehni nartiryl dth. no ira Irdrttar itilounea 210750,000.92 ira

pir9LI020l 39275,000CC ira

nolv{oxy-1 .2hanediyl>r.onvlpnranvl-3,vdrora na Ira

.-ccedt reuIatory n.tirrdard

SOCL = *t.a,aim-.,m onrtarrrina.nct Level - Thri hight kvel of a contaminant that io alawnd jr dr,rrbnir r.atnr.

£E= AO Riok 9aoad Coocentraon Table. 4iretp:/i’ =.aa çovIg3hmd!rikfandnni rnI dvclopad by Ragior. 3, tervir.g: Dala’.-ara, Duiotricr of Columbia, ll4rrlnnrd, Pcniniry4vvik, Wginia, Weot Wginio)

4P= t4arachurettn. Contingency Plvr -Ritk-batad ground irn-ater atanthrdt Far drinking “nattr protection-. chotrirr becacite Mantacbrzn.ett.s hair dmelopcd otandardo for marry conrtituorctn iii d,nrn& friel. Tvo numbern arc given (the firet it dniirkinrg

water n.tindord, the tecorird at zrxfard for groundwater dinc*rarging to twfa.ca water).

Prodc Criarnintal Compoiritson of Exiirtcnirg Prdjcts Concentration

v lrtarest 4q (U
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 fluids
ecosystems.

Additionally, fracturing fluid chemicals and wastewater can leak or spill from injection wells,flowlines, trucks, tanks, or pits. This contamination can be moved off-site through stormwater

run-off. Finally, faulty casing, weak cementing, human error and geological unknowns can

contribute to contamination from fracturing and other drilling practices.Myth: All, or nearly all, hydraulic fracturing fluids are recovered during the fracturing process.

Fact: Factors affecting fracturing fluid recovery include flowback procedure, job design, specific

reservoir conditions and other complexities. With multiple factors affecting fracturing fluidrecovery, it is reasonable to assume that there will be a wide range in fluid recovery

efficiencies. In fact, literature cited by EPA in their 2002 draft version of the hydraulic fracturing

report confirmed this assumption. EPA cited or discussed four different studies. These studies,

conducted in non-coalbed methane basins, found that between 25% and 61% of certain

hydraulic fracturing fluids flowed back to the well (that is, between 39% to 75 % was left

stranded in some instances). One particularly compelling study showed that only 35-45% of the

fracture fluids were recovered. This study was withdrawn from the EPA’s final discussion offlowback and was not listed on their master reference list for the final report 4.Citizens andgroups working on this issue have often used the range of 20%-30% of fracturing fluids

remaining in the ground without objection by industry. When considering the EPA’s literature

citations, this is a conservative estimate that generously grants a range of recovery efficiencies

to the industry.

Myth: The practice of hydraulic fracturing and creating underground fractures is well-tested,

controllable and safe.Fact: It is critical for communities and decision makers to understand that hydraulic fracturing

fluids not only contain toxic chemicals, but this operation utilizes high volumes of fluids and

high pressures to intentionally open up underground pathways for gas or oil to flow. Injected

fluids have been known to travel as far as 3,000 feet from a well, and fracturing fluids may

remain trapped underground. While industry claims that fracturing is a well-tested and

controllable technology, computer models have shown that fractures can behave differently

than predicted, and diagnostic techniques illustrating fracture history are rarely used. It is

important for communities and decision makers to gather more information about fracture

behavior, and to ensure that any stranded fluids do not remain in or move into our drinking

water resources.
Without that information, neither states nor the public can begin to eliminate the use of toxic

materials, nor adequately evaluate or develop monitoring programs to assess the risks posed by

injecting these fluids underground.Myth: Non-toxic and less toxic fracturing alternatives are in their infancy and not available for

industry use.

Fact: Oil and gas operators are routinely using less toxic fracturing fluids in off-shore

environments in order to meet federal requirements under the Clean Water Act, and some

operators have tested and studied non-toxic fracturing fluids as they problem-solve site specificissues in the Black Warrior and San Juan Basins. Thus, the development of non-toxic or green

fracturing fluids is not in its infancy.

The offshore oil and gas industry, for example, has had to develop fluids that are non-toxic to

marine organisms in order to be allowed to discharge the fluids into the ocean. According to the

Schlumberger web site: “Meeting stringent environmental guidelines in both the U.K. North Sea

and the Gulf of Mexico (GOM), the new Schlumberger GreenSlurry system delivers consistent,

earth-friendly performance. This slurry system, developed for use in all types of fracturing and

gravel-packing operations in environmentally sensitive regions, features a unique carrier fluid.

The new carrier fluid can be easily metered using all existing equipment.” The public and

decision makers must assume that Schlumberger and many other companies formulate these

types of fluids because standard fracturing fluids are toxic to marine organisms and will not

meet off-shore regulations. Because we don’t have full disclosure of fracturing fluids, it remains

vague as to how toxic or less toxic products designed for an offshore environment are to

humans. However, industry studies and demonstrations have show that water without any

additives is an effective fracturing fluid that is more economic in certain environments, and can

solve production problems such as chemical gels (cross-linker gels) damaging coal

permeabilityZ.

Myth: Lifting the exemption for hydraulic fracturing under the Safe Drinking Water Act would

be unduly burdensome for States.

Fact: Congressional Representatives DeGette (CO), Salazar (CD) and Hinchey (NY) introduced

a billin2OO8 that would reverse special treatment of Halliburton and other hydraulic fracturing

companies by requiring regulation of hydraulic fracturing under the Safe Drinking Water Act (HR7231). This effort establishes a minimum federal floor for protecting drinking water fromhydraulic fracturing. According to the EPA, the regulation of underground injection does not

require a new permitting process. A state could begin the specific regulation of hydraulic
Require non-toxic fracturing and drilling products.

Visit www.ogap.org to learn more, receive action alerts and stay involved.1. U.S. Environmental Protection Agency. August, 2002. DRAFT Evaluation of Impacts to Underground Sources of Drinking Water by

Hydraulic Fracturing of Coalbed Methane Reservoirs. EPA 816-D-02-006.

2. The Endocrine Disruption Exchange, Inc. February 2009. Products and Chemicals used in Fracturing.

http://www.endocrinedisruption.com/chemicals.ftacturing.php

3. U.S. Environmental Protection Agency. August, 2002. DRAFT Evaluation of Impacts to underground Sources of Drinking Water byHydraulic Fracturing of Coalbed Methane Reservoirs. EPA 816-D-02-006. This draft cites or discusses: Mukhergee, et al (1995), Palmer and

others (1991a), Samuel et al. (1997), Willberg et al (1997).

4. Mukhergee, HI, Paoli, B.F., McDonald, T. and Cartaya H. 1995 Successful control of fracture height growth by placement of an artificial

barrier. SPE Production and Facilities, 10(2); 89-95. (cited on page A-18 of the draft EPA Report)

5. IN ThE SUPREME COURT OF TEXAS, No. 05-0466, Coastal Oil & Gas Corp. and Coastal Oil & Gas USA, L.P., Petitioners, v. Garza Energy

Trust et al., Respondents, On Petition for Review from the Court of Appeals for the Thirteenth District of Texas, Argued September 28, 2006.

6. (Schlumberger. Green chemistry: Earth-friendly GreenSlurry system for uniform marine performance.)

http://www.slb.com/content/services/stimulation/execution/greenslurry.asp

7. See L. Sumi’s discussion in Our Drinking Water at Risk (2005). Two relevent industry studies on non-toxic fracturing fluids include: (i) T.L.Logan. 1994. ‘Preliminary results of cooperative research efforts with Phillips Petroleum Company and Amax Oil and Gas Inc., San Juan

Basin.” Quarterly Review of Methane from Coal Seams Technology. April 1994 11(3&4):39-49. (ii) Purl, R., King, G.E., Palmer, I.D. Amoco

Production Co. 1991. ‘Damage to Coal Permeability During Hydraulic Fracturing.’ Paper presented at the Rocky Mountain Regional Meeting

and Low-Permeability Reservoirs Symposium, Denver, CO, April 15-17, 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
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: Activism

CONDENSATE •1

AND: I

j9A!Lj

o an oil refinery

NGL RECOVERY

‘Turbo-expander and

I dernethanizer..

oo(ln older pnts)

FRACTIONA11ON TRJN • De-ethanzer

: Deropnzer

1 1Rawgas

+ pipeline

Waste water

ACID GAS REMOVAL • Amine treating

‘enfleId prccess

•PSAunit:

Sulfinol process • Others

Tail TAIL GAS TREA]1NG

gas *ScotproceS$:.

C[auspol process

Offgas 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 -

PentaneS+

Butane

Propane

Ethane
ed to require “Top to Bottom” cementing to prevent

into upper formations and intersected faults.

s reduces water and air contamination.

longs pipe life and reduces corrosion/damage.

hanced closure at end of production life.

rrangements should be welded as opposed to screw fit in all

lutely needed make/break situations.

closed valves should be used in material handling

ns, such that positive attention is used for open status.

c power not available, use “dual” fuel engines, with natural

g the alternate.
moval equipment required if any H2S over 10 ppm is

ered regardless of initial cause.

dumping of down hole gases in any non-production

ns and/or rework.

produced water with capture requirements on vent systems.

e pressure environment in tanks would further reduce

emission.

devices should be on an emission program of improvement

% efficiency to 99% in 5 years. Catalytic converters should

datory, as a minimum, if they work in this application.

on well pipe and tree must be above ground surface and

ned properly at all times.
or soldered piping for pneumatic systems to reduce

ns. No open to air exhaust dumping without going through

iers, filters, etc.

operations on same 5 year improvement program and

ments as outlined in ON THE PAD.
operations are remote operators sensitive. Failsafe

ications and procedures must be required to prevent

ed opening of pipelines. High maintenance is required to

ls leak tight. Pipeline vulnerability exists at these stations

sign should be explored.

power currents can be created by overhead power

ion lines can create corrosion problems and leaks. Layout

ust be carefully planned or proper cathodic protection
NOx emissions are occurring at every level of operation

ine and process venting. Flaring operations must be

d and engine idle times reduced. Programs like Energy Star

applied.

te handling of tracking sand is inadequate and subject to

ures. Material transfer filters for these operations must not

s type of release. See:

iv’w.yo utu be. cc rn/dcdsva n ni

struction must be done with proper dust controls such as

et down.
Times:

Flames of Wasted Natural Gas Light the

ork Times

atural gas extracted in North Dakota is flared off, like this gas near Ray.

S

ember 26, 2011

D. — Across western North Dakota, hundreds of fires rise above fields of wheat and

and bales of hay. At night, they illuminate the prairie skies like giant fireflies. They are

caused by lightning strikes or other acts of nature, but the deliberate burning of natural

ompanies rushing to extract oil from the Bakken shale field and take advantage of the

f crude. The gas bubbles up alongside the far more valuable oil, and with less economic

capture it, the drillers treat the gas as waste and simply burn it.

rr’2Di

er=rs2m=rss
And, the second is that while these rules are a big step forwar4, EPA has alsomissed some key opportunities to truly get a handle on the poll’4tion caused by this

industry I

(1) The time to act is now:

‘‘N

-Existing rules that apply to the oil and gas industry are woefully inadequate andout-of-date. As you know, EPA is supposed to update these standards every eight Th

years, but they didn’t do it. Some of these standards have been around for 20

years, and they’ve never been updated. So, in 2009, Earthjustice sued EPA—on

behalf of Wildearth Guardians and San Juan Citizens’ Alliance—to force them totake a look at these standards and what’s been going on in the industry and where

the holes are.

-And, what’s been going on is that there has been an oil and gas drilling boom in

the Rocky Mountain West and other parts of the country. And, the development of

“fracking” technology has enabled the industry to drill in places that have never

before been drilled. And, suddenly we have communities that have never had todeal with this type of pollution saying, wait a minute the toxic chemicals and smog

forming compounds associated with oil and gas development are making us sick.

-For example, so me ofthe worse smog pollution occurring as a result of oil andgas development is happening in rural Western Wyoming, where last winter they

experiences ozone levels that are worse than the worse smog days in L.A. On

those days, Wyoming state officials have warned elderly people, children, and

people with asthma to avoid outdoor activity and to stay inside.

-The problems are growing in Colorado as well. There are now more than 45,000active oil and gas wells in this state.

-People in western CO have been complaining for years about the noxious fumes

and headaches, dizziness, and nose bleeds caused by rampant oil and gasdevelopment in their back yards.
-EPA-also fails tp

ptoposethueHydrogensugtaiies-neuro1eg4cal

impaeJt.

ctc,LL

(3) Existing son rcs: The proposed rule is focused on cleaning up new and

modified sources and that’s really important, but there’s also a lot of reallydirty, outdated infrastructure out there that EPA has the authority to regulate.It should take advantage of its authority under 111(d) ofthe Clean Air Act to

regulate those existing sources and provide greater protection for public

health.

(4)And, finally, with respect to hazardous air pollutants, EPA needs to

eliminate the so called “malfunction defense,” which allows industry to

violate standards designed to protect the public health without paying any

penalty.

We will provide more detail regarding these missed opportunities in our written

comments on the proposed rule.

In sum, we think that EPA is heading in the right direction, but there are still gaps

to be filled in order to truly protect our communities. Thank you ai-f..the
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 andparticulate 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 isan 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.
4725 So

My name

over 40 y

My comp

facilities 

North Da

Our miss

compress

natural g

The majo

reduce th

“The est

so much

nearly $3

industry

Seal repl

Typical s

constant 

operator 

operate p

release fr

In some c

head, pis

How is th

Is there a

What wo

How wou

Perhaps t

Regulate

Regulate

outh Monaco

e is Wayne S

years of expe

pany is curre

in Pennsylv

akota. 

sion statemen

sion facilitie

as delivery i

ority of our c

heir LOE as 

timated reve

 so that tod

30 million a

y.” 

lacement req

seals will hav

until the sea

will immedi

properly. A s

rom compres

cases, the se

ton rod and 

his cost reim

a grandfather

ould be the b

uld this be en

the EPA sho

 how old a c

 what compr

o St., Suite 36

Sartori, and I

erience with

ently buildin

vania, West V

nt: “GCC is

es and gather

in gathering,

clients are sm

a percentage

enues from 

ay’s propos

annually, wh

quired at 26

ve some init

al fails. The s

iately need t

specified tim

ssor seals. I

eal replaceme

piping, and 

mbursed by th

r clause for o

aseline poin

nforced? 

ould regulate

compressor p

ressor manu

0  **  Denver

I am the pres

 the mainten

ng compresso

Virginia, Mi

 dedicated to

ring systems

, compressio

mall produce

e of throughp

selling the g

sed rule is a

hile significa

6000 Hr inte

tial leakage u

seal failure c

o replace the

me period is a

In all cases, s

ent may requ

may require

he new regu

older compre

nt for determ

e how often v

package can 

facturer can 

r, CO 80237  *

sident of Ga

nance, design

or stations an

ssissippi, Lo

o improving

 by applying

on and proce

ers and mids

put. 

gas that cur

nticipated t

antly reduc

rvals on rec

upon installa

could occur 

ese seals upo

a useless and

seal replacem

uire the dism

e realignmen

lations? 

essors? 

mining runtim

valves are ch

OR 

be! 

OR 

be used! 

**  (303) 400

as Compresso

n and operat

nd optimizin

ouisiana, Co

g the econom

g new and pr

essing.” 

stream comp

rrently goes

to quickly r

cing pollutio

ciprocating a

ation. This le

at 20 hrs, 20

on failure as

d costly ende

ment will res

mantling of th

nt of the com

me? 

hanged on a 

0‐4300  **  30

or Consultan

tion of comp

ng compress

lorado, Utah

mic performa

roven solutio

panies seekin

s to waste ar

esult in a ne

on from this

and centrifu

eakage will r

000 hrs or 15

s their compr

eavor to con

sult in substa

he compress

mpressor itsel

compressor

03‐400‐4301 F

nts Inc. I hav

pressors. 

sion and proc

h, Wyoming

ance of 

ons to optim

ng ways to 

re significan

et savings o

s expanding

ugal compres

remain fairly

50,000 hrs. A

ressor will n

ntrol emissio

antial down 

sor piston, cr

lf. 

r package! 

FAX

ve 

cess 

 and 

mize 

nt – 

f 

g

ssors 

y

Any 

not 

n 

time. 

ross 
4725 South Monaco St., Suite 360  **  Denver, CO 80237  **  (303) 400‐4300  **  303‐400‐4301 FAX

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 infrastructure, 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 without infrastructure, will the producer need to 

obtain a separate permit to install a VRU compressor? 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 adequate 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, without 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 pressure, flow and compressor stations 

Question: Are older facilities grandfathered? If not, how will the producer 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 per 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, maintenance costs and recoded keeping will force them from the market. 
Our mission statement: “CCC is dedicated to improving the economic performance ofcompression facilities and gathering systems by applying new and proven solutions to optimizenatural gas delivery in gathering, compression and processing.”The majority of our clients are small producers and midstream companies seeking ways toreduce their LOE as a percentage of throughput.

“The estimated revenues from selling the gas that currently goes to waste are significant — so much so that today’s proposed rule is anticipated to quickly result in a net savings ofnearly $30 million annually, while significantly reducing pollution from this expanding

industry.”

Seal replacement required at 26000 Hr intervals on reciprocating and centrifugal compressors

Typical seals will have some initial leakage upon installation. This leakage will remain fairly

constant until the seal fails. The seal failure could occur at 20 hrs, 2000 hrs or 150,000 hrs. Anyoperator will immediately need to replace these seals upon failure as their compressor will notoperate properly. A specified time period is a useless and costly endeavor to control emission

release from compressor seals. In all cases, seal replacement will result in substantial down time.

In some cases, the seal replacement may require the dismantling of the compressor piston, cross

head, piston rod and piping, and may require realignment of the compressor itself.

How is this cost reimbursed by the new regulations’?Is there a grandfather clause for older compressors?

What would be the baseline point for determining runtime?

how would this be enfhrced? L

i? Ae6

Perhaps the EPA should regulate how often valves are changed on a compressor package!

OR

Regulate how old a compressor package can he!

OR

Regulate what compressor manufacturer can be used!

4725 South Monaco St., Suite 360 ** Denver, CO 80237 ** (303) 400-4300 ** 303-400-4301 FAX
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 adequate quality to run the VRU?

I-las the return for New Net Savings included the cost to provide fuel gas or electricity at outlyingareas?

Question: How does this apply to oil wells with associated gas?

Pneumatic Controllers, which regulate pressure,flow and compressor stations

Question: Are older facilities grandfathered? If not, how will the producer recover the new

expense? The cost for some small compressor controllers can cost anywhere from $5,000 to

$10,000 each.Condensate and crude oilstorage tanks

• Tanks with a throughput of at least 1 barrelper (lay of condensate or 20 barrels per day of

crude oil (‘equi’alent to about 6 tons of VOC emissions per year) niust reduce VOC emissionsby 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. maintenance costs and recoded keeping will force them from the market.

4725 South Monaco St., Suite 360 ** Denver, CO 80237 ** (303) 400-4300 ** 303-400-4301 FAX
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.