Comments

by Faith Chatham at EPA Public Hearing- September

29, 2011 Adoption

of Air Pollution Standards for Oil and Natural Gas Production Arlington, Texas I am Faith Chatham,
one of the co-founders

of DEW Regional Concerned Citizens.

I reside

at 803 N. Mesquite

St. in Arlington, Texas. Thank you for being here today.

I personally appreciate those who are in the audience,
and those who are making public comments

or submitting written statements.

We appreciate

the EPA staff members who are present, and your many colleagues who “back

in the office” working diligently

on this issue. Thank you for careful deliberation

of New Natural Gas Air Quality Standards— for your evaluation

of sound science” and some “not so sound”, and your careful consideration

of the myriad impacts

of existing and proposed policy and for listening

to thousands

of opinions during this long process. With escalation

of natural gas production

in our region,
for the past

8 years

at least 60% of our time, attention and resources

at DFWRCC
has been devoted

to studying, evaluating
and commenting

on Natural Gas Production
and Transportation issues

in this region. DEW Regional Concerned Citizens

is an “independent” “Think Tank” which focuses on public policy

in the 16 county North Central Texas Council

of Government Region.

All of our study area

is in the Barnett Shale. The North Central Texas COG Region comprises

16 or the 18 counties

of the Barnett Share. In disclosure, DFWRCC does not accept financial contributions
from industry

or government except
for the occasional utilization

of meeting space.
All DFWRCC researchers

and analysts underwrite

our own expenses. Most
of us have been trained

at the University

of Texas Institute

of Urban Affairs and have earned multiple degrees

at UTA, however none
of us are currently employed

by UTA. Furthermore,

in the spirit of full disclosure,

I must add that all of us own
at least

a small interest

in some parcel

of property

in Texas which

is currently leased for natural gas production. That being said,
of this multi-year journey

of examining

NG production
and public policy from multiple directions
and examining research studies coming from all kinds
of sources,

I will share some
of our conclusions. • In this endeavor

of how
to produce and regulate

(or not regulate) Natural Gas, there

is much more than merely the billions

of dollars

of industry investment

and energy sector profit on the table. • How we develop Natural Gas as
a “bridge fuel” impacts our National Defense. Failing

to implement green completion
and industry best practices nationwide,

or deterring
the implementation

of appropriate

Air Quality Standards
will result

in lost profit for investors
and the industry and will result

in higher health care expenditure

and time lost from school, work and community service

by citizens. • We believe that adoption and implementation

of these rules

is an important step

in sensibly developing Natural Gas as
a bridge fuel for current consumption. • Current economic gains must be balanced with long-term economic sustainability. • These proposed

air quality standards impact not only NG industry, royalty owners and investors,

but they directly impact the lives of American families, especially

of children,
old people, and the medically vulnerable,

and those who work and play out-of-doors. • Decisions

to implement

or delays

in implementation

or non-compliance

will literally move
or deter the movement

of healthy individuals
into those who are medically “vulnerable”

or disabled. The standards Comments

to EPA on Proposed

NG Air Quality Standards

by Faith Chatham (DFWRCC)— Arlington, Texas- Sept. 29, 2011

Page

1 of
4you adopt and when you require their implementation

will impact the lung development

and neurological (lQ) development

of children. While there

is some short-term economic benefit from lax air quality standards, delay
of adoption

of these proposed

air quality standards
will have dire long-term consequences

both economically

and environmentally.

The proposed standards

are all based
on implementation

of practices which have been accepted by the industry

in various states and proven

to work. These technologies

are not cost prohibitive. They will not drain profits from the investors

or operators. Most have been proven

to capture

by products, turning
air pollution into PRODUCT which the operators/investors

sell for profit. Despite the “win!win”

of adopting these standards, voluntary implementation

has failed. Many

in the industry who advocate

for self-regulating

and voluntary implementation

of industry best practices
and proven cost effective technology continue

to refuse

to them
to voluntarily! In the NCTCOG region we saw some improvement

in Air Quality

a few years ago following
the close
of some cement plants. Since then thousands

of natural gas wells, hundreds

of miles
of pipeline and numerous new compression stations have gone on-line

in our region. There

is a direct co-relation between
the escalation

of natural gas drilling per county and decline

in air quality. Development began

in Parker and Wise County, western Tarrant County first. Air quality declined first
in those counties and Fort Worth. Development
then moved

to Arlington
and far eastern Dallas County.
As the number

of wells has increased

in Arlington,

the air quality has declined. Dallas county continues

to have better air quality than Tarrant even though Dallas has more cars on the road and more population.
The major difference

is that Tarrant has many more natural gas wells than Dallas— at least thus far. According

to the National Center for Prevention
and Disease Control, there has been an unusual increase

in incidents

of breast cancer

in six counties

in Texas. The counties with the most breast cancers

in Texas are Tarrant, Denton, Wise, Parker, Hood and Johnson
are all located

in the Barnett Shale, “where emissions from the exploitation

of shale gas are highest, according

to 2010 records from the Texas Commission

on Environmental Quality (TCEQ). Even though the O&G industry

is contributing

to the local economy, many feel that NG industry still does not pay its fair share for exploiting

the resources

in the region because
too many operators expose our communities

to unnecessary ambient

air pollution

by refusing

to use green completion, proper valve maintenance

and replacement

of faulty valves and couplings with better technology,

and investment

in vapor recovery systems. Seeing the gains

in air quality improvement erode despite removing older automobiles
from the highways
and higher automobile standards,
and successes

in closing down some
of the worst polluting cement plants in the region, many citizens are angry because they believe “bone-headed” practices

by some NG operators
has contributed

to the erosion

of gains

in Air Quality. Knowing that billions

of dollars

of profit

is on the table for each well, resistance

by producers

to implement relatively low-cost improvements which can capture product,
cut emissions,
and promote neighborhood health and safety

is viewed

by many citizens

as the industry profiteering

at community expense and the industry
not paying

its fair share

in protecting

the community from unnecessary

air pollution. As gas production moves closer

to homes and schools, traditional “environmental protection” issues are overshadowed

by child endangerment issues. As wells and pipelines
are permitted closer and closer

to day care centers, playgrounds,

and children’s bedrooms
and school rooms, citizens realize that there are insufficient safety nets for citizens who are harmed

by adjacent construction

or production activity. OSHA protects workers and promotes jobsite safety for employees

but implementation/enforcement

of similar rules
to protect citizens who are harmed

by production practices

or NG drill site or pipeline construction projects near homes, schools, daycares
and playgrounds

is non-existent

or ineffectively enforced. Comments

to EPA on Proposed

NG Air Quality Standards

by Faith Chatham (DFWRCC)— Arlington, Texas- Sept. 29, 2011

Page

2 of 4In the past decade
we have witnessed

an escalation

of movement from special interests and industries merely lobbying government

to special interests establishing non-profit “educational”

501 C3s which soliciting local, state and federal officials and governmental agencies and universities

as members,
and then use public money (collected from taxes and paid as membership dues)

to help finance the lobbying

& PR expenses

to protect industry interest rather than the public good. We view these trends

as evidence that necessary change will be less likely
to come from the bottom

up than even

in previous decades. Like the Voting Rights Act and the Civil Rights Act, effective improvement in adopting sensible, cost-effective natural gas standards which protect the health and safety

of people and the environment must come from the Federal Level. There continues

to be more “industry”

lip service about voluntary compliance

and implementation

of industry best practices than actual “boots
on the ground” self-implementation. There

is little or no will and br power
by most state and local governments

set standards
and effectively promote compliance

by the NG industry. Based
on scientific evidence and the impact

of “health and economic trends”
we conclude that failure

to adopt these proposed

Air Quality Standards

for Natural Gas will result
in: more days lost from work which

= lower GNP more absences from school for pupils and teachers

= less effective education higher health care expenditures

for families higher insurance premium costs for businesses unless capped

by governmental action larger public health expenditures

by county, state and Federal government— with budgetary

/ taxation consequences. Adoption

of these air quality standards

will help protect children from exposure

to VOCs and other ambient

air toxins which have been proven

to impact lung development

and neurological development

in children. Adoption

of these rules can literally help protect this nation’s children

by removing UNNECESSARY EXPOSURE

by air borne by products

of the Natural Gas industry. This can preserve and promote
the ability children

to be able
to absorb and process information.
Our national security and nation’s economic future

is dependent upon the ability
of American

to assimilate
and process information

and to be healthy enough

to work and study and serve our nation

in various ways. • The economic survival

of communities

is at stake. • These standards impact our nation’s vital natural resources
and have immediate
and long-term consequences

on health, safety ,the environment, food-chain, national defense and our nation’s economic sustainability. • Breathable

air and water and soil which sustains vegetation
has always been, and will always
be, basic requirements

for human
life and economic development. • Our research does not support the claims

by industry that adoption

of these rules will adversely impact the economies

of the communities where natural gas

is being developed

or where new permits are being considered. • Adoption

of the proposed

Air Quality Natural Gas standards

will not have

a significant negative impact
on jobs

is the conclusion

of an Economic Policy Institute 2011 Study.
“A series
of air pollution rules from the Obama administration provide major public health benefits with dollar values far greater than their compliance costs, according

to
a new report
by

a think tank affiliated with organized labor.”- By Ken Ward Jr.- The Charleston Gazette— September

21, 2011 (Charleston, WVa) •
In examining

the Economic Policy Institute’s report and weighing

it with other evidence
and reports, FWRCC’s concurs with the Economic Policy Institute analysts

in their 2011 report: “Fears that these rules together will deter economic progress
are unjustified.”... “The dollar value
of the benefits

of the major rules finalized or proposed

by the EPA so far during the Obama administration exceeds
the rules’ costs
by an exceptionally
wide margin. Health benefits

in terms
of lives saved and illnesses avoided will be enormous.”•... “Further,.. estimated costs
of these regulations.. to the size of the economy,

as well as the extended period over which they will take effect, indicate that they would not be
a major impediment

to economic

or job growth

in the near-term

or in the future.” • “The regulations finalized and proposed

by the Obama administration

are likely
to be of tremendous value

to the nation, producing

a wide range
of significant health benefits,”
the Economic Institute report said. Comments

to EPA on Proposed

NG Air Quality Standards

by Faith Chatham (DFWRCC)— Arlington, Texas- Sept. 29, 2011

Page

3 of4* Setting aside the Cross-State

Air Pollution rule, the combined annual benefits from all final major rules by the Obama EPA exceed their costs
by $10 billion

to $95 billion

a year. The benefit-to-cost

ratio ranges from 2-to-i

to 20-to-i. In conclusion, despite

a recent disappointing

vote by Congress

to delay new standards,

we wish
to point out that

a recent national survey

of 2400 likely voters between June 4-12, 2011 by the Greenberg Quinland Rosner Group shows that

a significantly higher number

of American voters overwhelming support tougher smog pollution standards
and reject Congressional action

to impede the EPA from updating these standards. Although there

is a difference

by political party, this study showed that 64 % surveyed strongly opposed Congressional action

to deter implementation

of stronger smog control standards. When asked about favoring

or opposing
the Clean Air Act, Congress,

the Environmental Protection Agency

or President, Congress was significantly most unpopular. There was less opposition

to the Clean Air Act than
to White House

or Congress. 75% of all voters surveyed soundly reject the argument that stricter smog standards

will hurt the economy
and cost American jobs. When asked

if they favor
or oppose EPA’s proposing

to update
air pollution standards

by placing stricter limits on the amount

of smog that power plants,

oil refineries
and other industrial facilities can release, 75% of all voters surveyed strongly favor stronger EPA standards. Voters surveyed trust the EPA more than Congress

to set clean air standards. There

is a +1- 3.7 margin

of error. Voters were surveyed

in Florida, Ohio/Michigan, Minnesota/Wisconsin

and North Carolina and Virginia. Researchers conclude that this study shows that there

is strong support among voters for the EPA in all regions

of the country. Thank you. Comments

to EPA on Proposed

NG Air Q.uality Standards

by Faith Chatham (DFWRCC)— Arlington, Texas- Sept. 29, 2011

Page

4 of 4My name

is Jane Lynn from Arlington,
TX.

I am

a conservative
wife and

a mother who has lived
in the same community

for 25 years. There are at least

a half dozen drill pad sites within two miles of my home, some of them having
up to 20 wells. The drilling for natural gas less than 2,000 feet from our home has dramatically impacted
my family’s quality
of life and consequently

has propelled

me into

a fight
to protect our lives and the environment. Since the onset of drilling operations

I have been experiencing negative health effects,

so

I personally began logging these symptoms

in October

of 2010. The most prevalent symptom
has been long-term headaches lasting
up to ten days, and

a neighbor reported having severe headaches lasting three weeks. I am also experiencing

a lot of fatigue, another symptom neighbors

are testifying

to. Other symptoms are nosebleeds, burning eyes, sore throat, slurred speech, weak extremities, dizziness
and blurred vision. We hear strange noises and smell strange odors. The fear of the unknown with lack of regulation
has had

a real physical

as well as emotional impact upon us. One day,

I decided

to call our Chesapeake neighborhood representative

to share with her these negative health effects

I had been experiencing which

I believed was

a direct result of the toxins being emitted into our air. She said, “PROVE IT!” At that moment

I realized

I was up
a creek without

a paddle. And speaking

of water,

I would like to mention that just last month Chesapeake

was found

in another violation

at our well pad site— this time for illegally trucking water across the city line to frac

a well in a city that had water restrictions

in place due to the drought. Although
our city knew what they were doing, they didn’t cite them until the media exposed their actions. Yet the maximum
fine of $2,000 will be considered just

a mere cost of doing business. And this brings
up another important issue— what will be the long-term ramifications

of the billions and trillions

of gallons
of water that are now being removed from the water cycle forever? Mankind
has survived thousands

of years without natural gas but has always required water
to sustain life. Now

I want
to tell you what happened

on April 11, 2011
at around 2:30 a.m.
A storm had blown through
the area knocking
out power which

in turn had thrown

a compressor station offline which then caused two separate malfunctions

to occur

at our drill pad site. Anyhow, since the storm blew
in a cool front, we opened the windows
and went back
to sleep. Later,

a terrifying sound like loud jetengines woke
us up.
It would not stop. We called 911, but the operator was unable

to provide

us with clear direction

on what
to do since our City did not have emergency protocols

in place for this type of situation. Simultaneously,

a similar incident was occurring

on the other side of town which had probably confused
the 911 operator. Our entire home was quickly filling with

a filthy smelling stench of chemical odors and gases. My husband and

I stepped outside

to see what was happening
and we could feel the weight like

a heavy blanket
of fumes covering
the neighborhood.

The whole experience was surreal. We quickly went back inside and scrambled

to shut all the windows

of our home.

I was feeling utterly helpless seeing my
11 year old daughter lying
in bed getting

a chemical exposure

in her sleep. After some time, my husband proceeded

to start his truck and drive
to the Fulson pad site to see what was going on or if emergency crew was there— totally unaware

at the time that his vehicle could have exploded from the gases which had settled over the neighborhood. There was no one at that site, but the well was still venting gases.

It vented for approximately

1 V 2 hours. Meanwhile, back
at the house,

I reported
the incident

to TCEQ. TCEQ’s report which came out

4 months later, stated that no violations were found. Mind you, they did not arrive on the scene until approximately

8 hours later to investigate

but by that time reported

‘no odors detected’. How much longer will this powerful, unregulated industry

be permitted

to legally poison us?

I am weary
of living this nightmare.Allwewantistobeabletolivepeacefullyonourproperty.AsAmericancitizensweareaskingtheEPAtoonceandforallputanendtothisself-regulatingofaverydangerousindustryrightnextdoortoourhomes,ourschools,ourchurches,andourparks.Humanlifemusttrumpcorporateprofits.Statement

by Gas Processors Association (GPA)

at Public Hearings

in Pittsburg.

PA (9/27/Il), Denver, CO (9/28/Il),
and Arlington,

TX (9/29/Il) regarding

the EPA proposed rule, ‘Oil and Natural Gas Sector: New Source Perfomiance Standards and National Emission Standards

for Hazardous

Air Pollutants Reviews” published

in the Federal Register

on August
23. 2011. Good morning,
my name

is Jeff Applekamp
with the Gas Processors Association.

On behalf
of the Gas Processors Association (GPA),

I appreciate
this opportunity

to speak

to you regarding

the Proposed Rulemaking entitled “Oil and Natural Gas Sector. New Source Performance Standards
and National Emission Standards

for Hazardous

Air Pollutants Reviews,” published

at 76 FR page 52738
on August 23, 2011. GPA

is a non-profit trade organization made up of approximately

130 corporate members,

all of whom are engaged

in the processing

of natural gas, or in the manufacture, transportation,

or further processing

of natural gas liquids. GPA’s membership accounts
for approximately

92% of all natural gas liquids produced

by the midstream energy sector

in the United States. Our members also produce, gather, transmit,
and market natural gas and natural gas liquids. Safely bringing clean burning natural gas from producers

to U.S. consumers

has always been one of the highest priorities

of GPA member companies.
The vast supply
of natural gas and natural gas liquids

is one of our country’s greatest assets. increased production and use of natural gas will help reduce our country’s dependence

on foreign
oil and keep billions

of dollars each year
at home

in the United States. Therefore,

we urge EPA
to be thoughtful
and use caution

in this rulemaking, ensuring
the rules are streamlined, reasonable

and do not impede the production, processing

and transportation

of natural gas to U.S. consumers. In that regard we have only

a few short comments

to make

at this time.1. We commend

the EPA for the hard work that has led to the proposed NSPS Subpart 0000. Our members
feel that the proposed new NSPS

is a reasonable start from which we can build

a final rule that meets the EPA’s objectives and, provided adequate time, would not unnecessarily burden the industry. 2. GPA respectfully requests

an extension

of the comment period

to December

30, 2011
to allow adequate time for

a thorough review
of the multiple changes contained

in the Proposed Rulemaking.
GPA feels that an extension

of time

is justified based
on the significant expansion

of the regulatory requirements

in the Proposed Rulemaking

that would cover

a variety
of emission units that have not previously been addressed

by these standards.

In order

to provide meaningful comments, GPA and other stakeholders
need

a reasonable amount

of time
to review and verify EPA’s data
as well
as to collect information
that could prove useful

in the rulemaking process. Given the scope and complexity

of the Proposed Rulemaking

and the anticipated burdens

it will place on the oil and gas sector, particularly small operators, GPA submits that an additional

60 days for this comment period

is reasonable
and appropriate. 3. GPA also requests that that EPA seek an extension

of the February

28, 2012 Consent Decree deadline
for finalization

of the rule.

It seems unlikely that EPA can complete

a thoughtful review and response

to comments before the current Consent Decree deadline.
For example,

if the 0MB interagency process requires 90 days for review, which would have
to start December

1 St assuming

a February 28, 2012 deadline, then EPA would have about one month from the current October 29th comment submittal deadline

in which

to review, analyze, and give thoughtful consideration

to the anticipated high number

of comments. GPA 7suggests that EPA seek

a full year extension,

to February

28, 2013, for finalization of the rule. 4. GPA members also have specific concerns relative

to the copious number

of requirements

for notifications, monitoring, recordkeeping,

and reporting that will apply

to thousands

of small and insignificant sources under the new rule. We do not believe that EPA has adequately considered

the substantial effort and expenditure required

to meet the ongoing paperwork requirements

of the new rule. In that regard, GPA asks for EPA’s consideration

and help
in rectifying specific concerns that, left unresolved,
will place substantial burdens

on our industry without

an associated
and justifiable environmental benefit. GPA has established

a workgroup under
its Environmental Committee
that

is reviewing the Proposed Rulemaking

and developing specific and detailed written comments
that we will submit

to the EPA. Our comments
can be more meaningful

to the rulemaking process

if EPA provides
the comment deadline extension requested. GPA appreciates your consideration

of our concerns
and we look forward

to working with EPA
to address these

in future comments
and discussions. Thank you. 3TESTIMONY

OF HARRIET IRBY
at the SEPTEMBER 29, 2011 EPA HEARING

at ARLINGTON TEXAS The recent exploitation

of the Barnett Shale gas play in populated North Texas areas has contributed

to the already unacceptable levels
of air pollution

in the Metroplex.For example, peak ozone
on September

27 in the zip code 76013 was 127 and ozone peak level
in the San Francisco
Bay area was
31 for zip code 94116. Over time the California ozone levels held fairly steady at about 25% of the Texas region. We are out of compliance period and that has economic
and health consequences. Texas air pollution laws and agencies have failed
to protect

us and our environment.
This summer

a high pressure system has sealed

in the pollutants
and inflicted both searing heat and

a devastating drought. We have been hit with

a triple whammey.We
need help. Your name says

it all: ENVIRONMENTAL PROTECTION AGENCY. State and local governments

do NOT protect
us. The The complaint process takes months.TCEQ
uses outdated summa canisters that let them ignore emissions peaks.When

a complaint finally

is sent to
acomplainant,

it only offers excuses and cover-ups.l am certain people have died waiting

on
a TCEQ answer. As individuals, we face forces that we can not fight alone.We need your knowledge,persistence,

and good will to help us in our battle for breathable

air, and drinkable abundant water. We are glad you have come
to Texas. Specifically, we want vapor recovery systems

on all wells and compressor stations.Drillers should execute “green completions”. On September 3,2011 my friends and

I outlined our struggle with Dalworthington Gardens Gathering Station Number One
in a Star-Telegram article.lt was titled “WOMEN ARE SURE SOMETHING SMELLS
AT COMPRESSOR STATION” TCEQ has had

8 citizen complaints

on this site since June 2011. Open valves were found

in June.

A sickening sweet smell was noted
by citizens and station employees.On August 18,2011

a TCEQ employee experienced health effects while inspecting the station. VOC levels were high but citizens still waiting

on results.August 22,2011 more odor and citizen health complaints

led to another inspection.Police

said leak was not harmful becausestation employees
said

it was rot.The substance
was not identified.TCEQ

later said that they found storage tank emissions that ceased after yet another valve adjustment. Our pet cats and chickens have suddenly died during these episodes.
We have experienced shortness

of breath,rapid heart rates and itchy eyes and throats.

It is sometimes difficult

to remain outside. lrby,FeiI and Clark are still waiting

on the August

18 and 20 th TCEQ reports.We know the VOCs have been too high there, but once again TCEQ has kept the public

in the dark. We have asked that Midstream install vapor recovery systems

at that site.They have refused

to do this and

I am submitting their September 26,2011 e-mail containing
that refusal. In this e-mail there are several statements

I do not either comprehend

nor accept. First: they self report 1.76 tons of VOC emissions

a year.ls this by estimate

or actual air test?? How can these figures

be verified? Second: regular TCEQ inspections have got to be very rare.Each inspector covers thousands

of wells and other industrial sites.Third:Gasproductionsiteshavehugeinventoriesofheavyequipmentandproducedwatermustberegularilyhauledoff.Thisrequireslotsofdieselburningtrucksandconstructionequipment.Fourth:Midstreamdoesn’ttestforemissionsduringblowdowneventsbytheirownadmission.Howcantheyreporttheseemissionsiftheydon’tknowwhattheyare?

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Address: 1301 Constitution Ave, NW Room 3334 Washington, DC 20004 Telephone: 202-566-1744
Email: docket-customerservice@epa.gov1id5frcrr 1 s E-1I -C-o

i\ DWG Questions Thank you for your inquiry. Summit Midstream takes all resident complaints seriously
and continuously strives

to improve our operations
and our responsibilities

to the community

in which we operate. We are committed

to the safety of our pipeline and compressor station sites and we maintain
the highest operational standards, often exceeding state regulations

to ensure the communities

we operate

in are safe. Below we have listed answers

to the inquiries you made via our website

at www.summitmidstream.com

and info@summitmidstream.com. 1. When will the vapor recovery system
be installed? Where will they be installed? What pieces
of equipment
are? Summit Midstream

did not install

a VRU

at the DWG station because there

is not enough vapor emissions

for the unit to operate properly.

In order
to run

a vapor recovery unit (VRU) properly, there needs

to be
a constant vapor emission from the station.
At this time, the DWG station currently emits approximately

115 th of the level of Volatile Organic Compounds (“VOC”s)

as an average size gas station. The station

is currently 93% below
its permitted level of VOC emissions
and 98.4% below
its permit level for Hazardous

Air Pollutants. This

is not enough emission

to warrant

a VRU installation. Below

is the DWG station comparison

of VOC’s
vs. other local industrial sites. 50 45 40— 35 30 l 25 20 15 10 DV•S Sratn 2. When will DFW install charcoal filters

at DWG? Charcoal filtration
has been installed

at DWG and
is currently working.
We continuously work towards minimizing

any odor from the station and monitor our station
24 hours

a day, seven days

a week. City ofArThton

4vg. OS Gac SrarIo Daiaa avaJA.ir

GM Facia Lanñ1’l

Stato 3. Please
let me know

a time frame on this “leak” getting fixed.DWG employs very sensitive
gas detection devices that will shut down the facility

in the case of potential
gas leaks from the compression. Currently, DWG does not have any leaks. In order

to best serve our communities

and residents, Summit has purchased

a forward looking infrared (FLIR) camera,

an imaging tecimology
that senses infrared radiation,

to detect any gas emissions from the station and allows our operating team
to address any potential situations immediately.

The FUR camera

is used daily and
is the same device used by the TCEQ when they perfomi reg1ar checks

to the stations. 4. Question...what

is that material...what

is that chemical being used
to burn off the gas? Do you use diesel fuel? We do not burn off any gas at the DWG station. We do not use any diesel fuel at the station.

d I

a cc
c c L.L) o(f rectà dsej 5. Please
let me know what and when this foul odor and frequent releases will be fixed? The charcoal filtration should help with any odor from the station. We do not have frequent releases

of gas from the station. 6. How often do you do your blowdowns

and have you tested the air during that time? \Ve do not have
or perform station blow downs
on
a regularly scheduled basis. Venting

of the station, known

as Maintenance,
Start Up and Shut Down (MSS) emissions, occur only when compressor units are started/ stopped

or for

a variety
of safety reasons including
gas leak detection,
fire detection

or loss of power. We do not test the air during these events. However. ibeeinissions

are included

in our agencies. u C \SS(SAugust

8, 2011 Via Facsimile (512) 239-4808 and U.S. Mail First Class Charlotte Horn MC 205 Office
of Legal Services Texas Commission

on Environmental Quality P.O. Box 13087 Austin, Texas 78711-3087 Re: Chapter
115 Volatile Organic Compounds Storage Rule Revisions, Rule Project No. 2010-025-115-EN Dear Ms. Horn: The Barnett Shale Energy Education Council (“BSEEC”) appreciates

the opportunity

to submit comments

on TCEQ’s proposed revisions

to the Chapter

115 Volatile Organic Compounds (VOC) storage rules. BSEEC

is a non-profit educational organization
with member companies
that account
for approximately

85% of Barnett Shale natural gas production

in the nine-county non-attainment

area. BSEEC members include Chesapeake Energy, Dale Resources, Devon Energy, EOG Resources, Encana Natural Gas, XTO Energy, Newark Energy/Beacon
E&P, Pioneer Resources, Quicksilver Resources, Titan Operating, Western Production
and Vantage Resources. Our expanded comments

are attached and summarized below. The proposed rulemaking results from EPA’s January 2011 decision

to reclassify

the nine- county’ Dallas-Fort Worth (DFW) area as
a “serious” nonattainment

area under the eight-hour ozone National Ambient
Air Quality Standard (NAAQS). That reclassification triggers
the need for TCEQ

to submit

a state implementation

plan (SIP) revision

to EPA by January 2012 that incorporates

all reasonably available control measures, including

all reasonably available control technology (RACT),

for sources

of relevant pollutants.
The current rulemaking addresses RACT for oil and condensate storage tanks and proposes controls that,
in TCEQ’s view, would result

in VOC reductions
that would
be used
to demonstrate reasonable further progress toward
the attainment

of the 1997 eight-hour ozone NAAQS

in the DFW area. BSEEC members operate condensate storage tanks

in the DFW area (although only

a limited number

in the dry gas production areas— TCEQ should have an exact count from the Barnett Shale Special Inventory) and thus would
be directly affected

by the proposals here under consideration. It is apparent that the basis for the current proposal

is TCEQ’s belief that substantial amounts of VOC emissions

are emitted from condensate storage tanks

in the DFW NAA. TCEQ has Those counties
are Collin. Dallas. Denton, Ellis, Johnson, Kaufiiian, Parker, Rockwall,
and Tarrant.2 cited certain studies and findings

as support
for its assumption

as to the level of VOC emissions form condensate storage tanks, both
in the context

of this rulemaking

and in other contexts.

As explained

in the attached comments, TCEQ’s basis for this assumption
rests solely
on the ‘HARC
H5 1C” voc flash emissions factor
of 33 lb/bbl. This factor

is based
on faulty data and is being applied

by TCEQ for all condensate production regardless

of the separator letdown pressure

at the site or whether
the flash emissions

are being controlled. This
in turn has led to an unrealistic
and substantial increase

in TCEQ’s statewide voc emissions inventory from the oil and gas sector. TCEQ now has much more accurate data from the l3amett Shale Special Inventory which should demonstrate
that,
in reality, voc emissions from condensate storage tanks

in the Barnett Shale production
area are much less than previous “top..down” desktop studies have suggested.
The recent City of Ft. Worth ERG Study provides additional evidence that prior studies, such
as the present TCEQ inventory and,
in particular,

the January
26, 2009 Armendariz report “Emissions from Natural Gas Production

in the Bamett Shale Area and Opportunities

for Cost Effective improvements”,

have overestimated
VOC emissions from condensate storage tanks
by multiple factors. Unfortunately, emissions estimates from these desktop studies have been taken

as gospel
by some groups, which has led to public calls for additional VOC controls

at small oil and gas production facilities where only small amounts

of VOC are presently being emitted. In short, BSEEC urges TCEQ

to ensure that there

is a sound basis for any new controls that are imposed,
and to ensure that any new controls
are truly needed. Please
let me know

if you have any questions

on the attached comments. Sincerely, Ed Ireland. Ph.D. Executive Director Attachments:

(1) BSEEC Comments

on Proposed Rulemaking
Rule Project No. 2010-025-115- EN; (2) Environ ‘Review
and Analysis

of HARC Condensate Production VOC Emissions Factor” with (3) “Attachment

A: HARC H5IC Report Site Data”BSEEC Comments

on Proposed Rulemaking Rule Project No. 2010-025-115-EN I. The November 2010 ERG study for estimating emissions from oil and gas production equipment

is the basis for TCEQ proposing additional controls

on oil and gas condensate storage tanks. This study overstates statewide emissions

of VOC from oil and gas production sources. Emissions

of VOC are grossly overstated

for those oil and gas operations located

in counties within the DFW NAA where natural gas with little or no VOC content

is mostly produced. A. Table 3-1

1 of the proposed rulemaking
lists VOC emissions

for the 2006 base year
as 72.1 tpd with 40.6 tpd as VOC emissions from condensate tanks. Projected 2012 total VOC emissions

are 113 tpy in 2012. The 40.6 tpd 2006 estimate

of VOC emissions from condensate storage tanks

is demonstratively wrong. On page 4-28 of the 2010 ERG report,

it states that “Emissions from oil and condensate storage tanks were calculated using the methodology

and emission factor developed

in the 2009 TERC study “VOC Emissions From Oil and Condensate Storage Tanks” (TERC, 2009). These emission factors were multiplied

by county-specific

oil and gas production
data obtained from the TRC. The calculations assume that venting emissions are uncontrolled

by flares
or vapor recovery units.” (Emphasis added). Table 4-15 on page 4-29 lists the VOC emission factor

as 33 lb/bbl. This emissions factor has come

to be known

as the “HARC
H5

1 C emissions factor” and has been used
in multiple places
by TCEQ despite the fact that

it is based
on

a faulty study. Please see Appendix

A, which was part of earlier comments made

to TCEQ regarding

the proposed VOC Flash Emissions Guidance document. Appendix

A is a general technical critique

of the HARC study. Also, please see the attached May 16, 2011 Environ memorandum “Review
and Analysis

of HARC H5IC Condensate Production VOC Emission Factor.” This memorandum

is
a review
of the HARC study results based
on statistical analysis

of the data. It is worth noting here that the January
26, 2009 report “Emissions from Natural Gas Production

in the Bamett Shale Area and Opportunities

for Cost Effective Improvements”, prepared

by Dr. Al Armendariz

for Ramon Alvarez with the Environmental Defense Fund, also relied
on the HARC study for estimating VOC flash emissions from oil and gas activities

in
a 21-county Barnett Shale area. To calculate VOC emissions from condensate production during the summer months,
Dr. Armendariz relied on

a VOC emissions factor
of 48 lb/bbl of condensate throughput
that was derived from the north Texas well site data in the 2009 HARC study. Use of this erroneous emissions factor resulted

in
a projected 2009 estimate

of VOC emissions from condensate storage of 146 tpd for the peak summer months. This was an increase

of 116 tpd or almost 400% over the projected 2009 annual VOC emissions

of 30 tpd calculated

as an annual average. This result made no sense from

a technical standpoint

as the higher storage temperature of condensate during summer months significantly affects only the working
and breathing emissions from condensate storage tanks, which are typically insignificant compared

to VOC flash emissions from condensate
(the amount

of VOC flash emissionsPage

2 is mostly dependent

on the API gravity
of the condensate

and the separator pressure that the condensate

is being let down from). Nonetheless,

the oil and gas industry was falsely accused

of projected VOC emissions

of 146 tpd (53,290 tpy) of VOC emissions, just from condensate storage. Other errors

in the Armendariz report led to
a total projected 2009 VOC emissions estimate

of 255 Jpc! (93,000 tpy), which most everyone now understands

is an absurd numbei Unfortunately,

this faulty emissions factor has now also been used by the EPA

in proposed NSPS rulemaking

to suggest that

1 BOPD
of condensate production, regardless of the separator pressure that the condensate

is let down

to atmospheric storage from, emits over

5 TPY of VOC and should require controls. B. The 21.5 tpd estimate

of VOC emissions from pneumatic devices

is demonstratively wrong. The 2010 ERG report (page 4-43
to 45) relies
on the methodology
used
in the 2008 CENRAP study (Bar-Ilan,

et al., 2008)

to estimate VOC emissions from pneumatic devices. The CENRAP study assumes

all sites had pneumatics with high bleed rates and based those rates on Natural Gas STAR data (13.6— 31 scf/hr). The Barnett Shale production facilities

are relatively new and low bleed pneumatics

are the norm.

In addition, many companies

are using best management practice (BMP) and replacing existing high bleed pneumatics
with low bleed
or no bleed devices. Also, the 2008 CENRAP study assumed

a VOC content

of 10 wt%

to 15 wt% for onshore
gas production.
This high VOC content

is not representative

of gas production

in the core area of the Barnett Shale, especially

in the dry gas production areas of the counties

in the DFW NAA. To their credit, TCEQ seems

to have recognized
that the VOC emissions inventory

for pneumatic devices

is much too high for counties

in the DFW NAA and
is seeking additional information from operators
via

a supplemental Barnett Shale Special Inventory request. C. While not directly relative

to the proposed ozone SIP revision,

we note that estimated statewide inventory

of n-hexane, benzene, toluene, ethylbenzene

and xylene (BTEX) emissions

are also overestimated
since they are based
on the erroneous VOC emissions estimates
and

a possible error on the speciated HAP content

of vapor emitted during loading

of condensate. 1. In the 2009 ERG report, Table 4-15 on page 4-29 lists the HAP emission factors for condensate storage. These are based
on the VOC emissions factor
of 33 lb/bbl and storage tank vapor sampling data from the 2009 TERC (HARC) study. The vapor analysis

of vapors from storage tanks appear

to be reasonable other than the one noted exception
(see Appendix

A). However,

the faulty VOC EF of 33 lb/bbl should not be used for HAP emissions inventory.Page

3 2. The methodology
used
in the 2009 ERG report for estimating HAP emissions from oil and condensate loading

is described

on pages 4-30
to 4-35. The study uses the AP 42 Chapter
5.2 methodology which

is widely accepted

by industry and agencies. However,

a possible error was made

in determining

the speciated HAP content

of vapor emitted during truck loading. The study uses an analysis

of vapor from storage tanks from the 2009 TERC (HARC) study

to speciate
the VOC emissions estimated from use of the AP-42 loading loss equation. This supposedly gives the mass HAP/VOC ratio factors shown

in Table 4-17 on page 4-34 of the 2009 ERG report: 0.28 for benzene, 0.48 for toluene, 0.027 for ethylbenzene,

and 0.21 for xylenes. These ratios appear

to be in error
as they should most likely
be percentages;

i.e., mass HAP/VOC ratios for vapors emitted during the loading

of condensate would typically be no more than 0.04 for n-hexane (which should

be listed

as

a HAP

in the inventory), 0.002 for benzene, 0.003 for toluene, 0.0002 for ethylbenzene

and 0.002 for xylenes.

It is not known

if the actual emissions inventory
was based on the ratios as shown

in Table 4-17 or on correct values. D. TCEQ has accurate VOC emissions data from the Barnett Shale Special Inventory which should demonstrate
how much the November 2010 ERG study overestimates
VOC emissions from counties

in the DFW NAA. Data collected from seven
of the largest independent producers

in the Bamett Shale (Chesapeake Energy, Devon Energy, EOG Resources, Encana Natural Gas, Quicksilver Resources, XTO Energy and Pioneer Resources) indicates that emissions

of VOC from oil and gas production equipment within the 9-county DFW NAA average
0.7 tpy per well. (Note that many well pad sites contain multiple wells; therefore, VOC emissions from

a single well pad site could
be multiples

of 0.7 tpy). Extrapolating

this average value

to all 10,700 wells

in the DFW NAA gives

a total VOC inventory

of approximately 7,500 tpy or 21 tpd. This

is less than one-third

of the 2006 base year inventory. The recently released ERG study of emissions from oil and gas activities

in the City of Ft. Worth verifies these low VOC emissions numbers.

In that study, total VOC emissions were estimated

to be 929 tpy from 388 sites with

a total of 1,140 wells. That

is an average of 2.4 tpy per site and 0.8 tpy per well. The average VOC emissions from

a well pad with no compressor engine located

on site was estimated

to be 0.07 tpy. Average VOC emissions from

a well pad with

a compressor engine(s) (usually

a small 175 to 215 Hp rich-burn engine) were estimated

to be

2 tpy. E. Part of the reason that the present VOC inventory

for oil and gas production equipment

in the DFW NAA

is overestimated

is that the substantial

use of best management practices (BMPs)

by most operators

is not considered. Operators

in the Barnett Shale typically practice BMPs, such
as low or no bleed pneumatics, vapor recovery units where teclmologically

and economically feasible, flares. etc to control VOC emissions. These may not be considered

in some top down emissions inventory estimates,

but can achieve substantial VOC emissions reductions

of 90%
to 99%. These types
of controls

are required

to keep large sites below the 25 tpy threshold

if an operator chooses

to permit the site under the TCEQ Permit
by Rule, which

is typically
the case for well pad sites.
InPage

4 addition,

a 3-way NSCR catalyst

is typically used on rich-burn engines operated

in the DFW NAA

to control emissions

of NO and an oxidation catalyst

is often used on the large lean-burn engines

to control emissions

of formaldehyde

(to stay below major source thresholds

for HAP emissions). These engine catalytic controls also reduce VOC emissions

by 50%
to 90% depending

on the specific application. II. TCEQ should update the VOC emissions inventory

for oil and gas production equipment

in the 9-county DFW NAA before even considering additional mandatory controls

on operators. Based
on the emissions estimates given above, there

is little VOC reduction
that can be obtained from mandatory controls

on VOC emissions from condensate storage tanks located in the 9-county DFW NAA. This

is because
the vast majority

of production

in this area
is dry natural gas with little
to no VOC content. Therefore, there

is little condensate storage

in the area. In fact, the vast majority

of storage tanks present

on well pads
in this area are produced water storage tanks, which emit very little
to no VOC. Note that the Texas Railroad Commission
may show some condensate production from gas wells

in the area that does not really exist. This

is because
the TRC allocates condensate recovered

by salt water injection operators back
to the wells where the produced water was generated. Since salt water injection operators have no way to determine which
of the many wells that they service produced

the “skim” condensate,

it is often allocated

to all wells contracted

for water disposal

by

a salt water disposal operator.
For dry gas wells with little or no VOC, this produced water does not contain any significant amount

of condensate. There can be some ‘skim” condensate

in the water produced

at a wet gas well such
as those in Wise, western Denton and Parker Counties. III. In any ozone SIP rulemaking, TCEQ should include

a section
on the reactivity

of the VOC species typically emitted

by the various sectors. The public should

be informed that not all VOCs are equal when ozone formation

is the central theme.

A December 2004 paper by TCEQ highlights

the reactivity

of different VOC species: 1 Looking

at the VOC part of the Iozonej equation,
not all VOcc are created equal some VOC’s make ozone much more eJjctively than others.
We can define reactivity

as the potential

of a given compound

to make ozone. This paper cites the Maximum Incremental Reactivity (MIR) scale which measures

the maximum amount

of ozone that can formed
by adding

a particular VOC into NOx-laden

air. The vast majority

of VOC emissions from oil and gas production equipment

are propane butanes and pentanes, which have lower reactivity.

In the MTR scale,

it is notable that propane

is at the bottom and that some VOC species
are more than 20 times more effective than propane

at forming ozone.

In contrast, VOC emissions from on-road vehicles contain multiple compounds
with

a high reactivity index. Emissions Modeling o/5pecic High/v Reactive ?‘httile Organic Compounds (HRI MC’)
in the Houston-Ga/veston-Brazoria

Ozone bonattainment

Irea.

R. Thomas

et ci!. ([‘(TO), December 2004Page

15 IV. The EPA just released proposed NSPS revisions

for the oil and gas production sector. The proposed rules contain standards

for VOC emissions from oil and condensate storage tanks. Although

the proposed standards

are subject

to change after public comments

are received, TCEQ should consider
the proposed new standards
and evaluate

if a new NSPS standard would make adoption

of new SIP requirements

on condensate storage tanks

in the DFW NAA area

a moot point.ENVIRON May 16, 2011 Mr. Grover Campbell Manager Regulatory Affairs— Air Regulations Chesapeake Energy Corporation Oklahoma City, OK 73154-0496 Re: Review and Analysis

of HARC H5IC Condensate Production VOC Emission Factor Dear Mr. Campbell: As requested

by Chesapeake Energy Corporation (Chesapeake”), ENVIRON
has performed

a technical review

of the October
31, 2006, report prepared

by URS Corporation (“URS”) entitled “VOC Emissions From Oil and Condensate Storage Tanks” (hereafter referred

to as the “HARC H51C Report”). 1 Following

is a summary

of ENVIRON’s review specifically related

to the derivation

of the 33.3

lb VOC/bbl emission factor. As presented within the HARC H51
C Report, average VOC emission factors were derived from emission tests conducted

on 21 tank batteries. 2 Figure

1 shows the relationship between
the estimated VOC emission factor and production
rate for these
22 sites. 3 As shown,

9 test sites had condensate production

of less than

5 bbl/day. 4 Derived tank battery-specific
VOC emission factors ranged from 0.7 lb/bbl

to 215.1 lbJbbl. Figure

1 presents
the relationship between condensate production
and estimated VOC emission factor for the 21 condensate storage tank batteries used by URS

in the derivation

of the VOC emissions

as
a function

of condensate production emission factor. For this data set, the mean VOC emission factor was 33.3 lb/bbl with

a standard deviation

of 53.3 Ib/bbl. 5
As can be seen from Figure

1, there are two sites with much higher VOC emission factors compared

to the other sites. These two sites are denoted with red diamonds.
The emission factors and condensate production rates for these two sites are: • 215.1 lb/bbl

at a production
rate of

1 bbl/day, and • 145.1 Ib/bbl

at a production
rate of 2 bbl/day. I httr://files.harc.edu/Proiects/AirQuality/Proiects/H051

C/H051 CFinalReport.pdf 2 Results from testing conducted

at a 22 ,d site, Tank Battery

26 with

a derived emission factor
of 1,218 lb/bbl, was discarded from the analysis with the reason given that the vent gas flow rate measurement was taken during non- representative conditions.

Per the HARC H-51C Report,
for Tank Battery
26, 97 percent

of the measured vent gas was released during the first

8 hours
of the 24-hour sampling period. The report attributed
this condition

to fracking

at an adjacent well. Detailed HARC H-51C data

is presented

in Attachment

A of this review. “Based

on our review

of the report,

it is our understanding

that production rates were not measured during testing. Rather, URS requested
and obtained production estimates from operators

at a later date. The standard deviation, which

is the variation around the mean,

is approximately

1 .6 times the mean for this data set, indicating high variability

in the data. When the standard deviation exceeds
the mean,

it can imply that the data set
is either too small
to accurately determine

the true mean value and/or there may not be

a strong relationship between
the two variables considered. Caution should
be exercised when using

a mean value derived from this data set.Mr. Grover Campbell

-2-

May 16, 2011 Chesapeake Energy 300

= Condensate Production,

5 bbl/day

I 250 ___________________________________ Emission Factor, 215.1

lb VOC/bbl

I 200- o

Emsson Factor, 145.1

lb VOC/bbl U- 150 C 0 100- 50. >

0—. 0

20

40

60

80 100
120 140 160 Condensate Production (bbl/day) Figure

1. VOC Emission Factor

as
a Function

of Condensate Production, Excluding Tank Battery

26 (Derived from HARC H5IC Report) To put these values into context: • Condensate production

of

1 bbl/day

is equal

to approximately

22.4 teaspoons

per minute of condensate production.

In other words,

a fast drip. • A production
rate of
5 bbl/day

is equal

to about 18.7 fluid ounces per minute.

At that rate, on average,

it would take about
39 seconds

to fill
a 12 ounce soft drink can. • A typical condensate storage tank

is 12 feet
in diameter with

a cross-sectional

area of approximately

113 ft 2 . Adding

5 barrels

to a tank of this size will raise the liquid level

in the tank approximately

3 inches. • Assuming

a condensate specific gravity

of 0.70,

a barrel
of condensate weighs approximately

245 lbs. An emission rate of 215.1 lb/bbl means that, on
a mass basis, nearly
as much VOC

is being emitted

as is being collected and recovered. Note that VOC already excludes emissions

of methane and ethane. Based
on ENVIRON’s experiences

in managing tank testing programs

as well as observations provided

by natural gas liquids producers, making accurate measurements

of condensate production

at very low production levels

is problematic. Presented

as Figure

2 is a “box-and-whisker”

plot of the 21 data points used

in deriving
the 33.3 lb/bbl VOC emission factor. The box-and-whisker

plot
is a useful way of depicting observations graphically
and also
to identify outliers. The lower and upper limits
of the central gray box represent

the 25 1h and 75 th percentiles,
also known

as the lower and upper quartiles

of the data. The thin white band within the gray box

is the median

of the data. The red diamond

is the mean of the data. The whiskers’ (short horizontal
end cap lines) represents

the lower and the upper extreme quartiles. The red circles represent data points that are at least

3 times the difference between
the upper and lower quartiles (also called the intra-quartile range) above (or below) the median. Statistically, these red circles are “outside outliers.” “Inside outliers are data points thatMr. Grover Campbell- 3-

May 16, 2011 Chesapeake Energy are more than 1.5 times but less than 3.0 times the inter-quartile range above (or below) the median.

250 2001
Outliers 150 100 :1_ Figure

2. Box-and-Whisker

Plot for All Data Points Used

in Deriving 333 Ib/bbl Emission Factor (Derived from HARC H5IC Report) The two red circles

in Figure

2 representing 215.1

lb VOC/bbl and 145.1

lb VOC/bbl emission factors
for Tank Batteries

25 and 17, respectively,

are outside outliers and, most likely, should be excluded from the analysis. If the outside outliers identified

in Figure

2 are excluded from the data set, the average VOC emission factor

is 17.9 lb/bbl with

a standard deviation

of 19.5
lb /bbi. By excluding these two outliers, the standard deviation becomes smaller relative

to the mean:

1.1 times the mean versus
1.6 times the mean when these two data points are not excluded. Therefore,

the data shows better agreement when these two data points are excluded. As noted,

it is difficult

to obtain accurate measurements

of condensate production

at low levels. If 5 bbl/day

is used as the threshold

for making reasonably accurate measurements

of condensate production, then eight
of the sites used

in deriving
the 33.3 lb/bbl emission factor should
be excluded from the analysis. Figure

3 presents
the relationship between VOC emission factor and condensate production

for the 13 sites with measured production rates greater than or equal

to
5 bbl/day. The mean VOC emission factor for this data set is 13.8
lb VOC/bbl with

a standard deviation

of 18.3
lb VOC/bbl (1.3 times the mean). While showing less variability than the data set presented

in Figure

1, the data shown

in Figure

3 does demonstrate variability
due to the three points shown

as red diamonds.Mr. Grover Campbell Chesapeake Energy -o .0 .0 1 0 1.) 0 in E c) 0 >

50 04-’ U C 0 in in E U-I c-I 0 >

-4-

May 16, 2011 S

‘p—

. 70 60 50 40 30 20- 10- 0
0

20

40

60

80 100 120
140 160 Condensate Production (bbl/day) Figure

3. VOC Emission Factor

as
a Function

of Condensate Production, Tank Batteries with Production

? 5 bbllday (Derived from HARC H5IC Report) Figure

4 is a box-and-whisker

plot for derived VOC emission factors
for 13 tank battery sites with condensate production greater than or equal

to
5 bbl/day.

As explained earlier

in this summary,

the box-and-whisker

plot
is a useful way of identifying outliers. The red circle

in Figure

4 is an outside outlier. This represents

the derived VOC emission factor for Tank Battery 32. The red stars

in Figure

4 are inside outliers. The two stars represent

the derived VOC emission factors
for Tank Batteries

20 and 29. 70 60 40 30 20 10 0 Figure

4. Box-and-Whisker

Plot for Derived VOC Emission Factors, Tank Batteries with Production

5 bbllday (Derived from HARC H51C Report)Mr. Grover Campbell

-5-

May 16, 2011 Chesapeake Energy If the one site identified

as an outside outlier

in Figure

4 is excluded from the data set, the average VOC emission factor

is 9.6 lb/bbl with

a standard deviation

of 11.0
lb /bbl. By excluding this one data point, the standard deviation becomes smaller relative

to the mean:

1.1 times the mean versus

1 .3 times the mean when this data point

is not excluded. Therefore,

the data shows better agreement when this data point

is excluded. If, in addition

to the one outside outlier, the two inside outliers are excluded from the analysis, the average VOC emission factor

is 5.1 lb/bbl with

a standard deviation

of 3.5 lb /bbl. By excluding these three points, the standard deviation becomes smaller relative

to the mean: 0.7 times the mean versus

1.1 times the mean when just the outside outlier

is excluded. Note that,

in this statistical analysis,
the lowest derived emission factors— Tank Batteries

4 and 5 at 0.78 and 0.67
lb VOC/bbl, respectively— are not outliers. Thus,

it is would not be appropriate

to exclude them from the analysis. A standard deviation lower than the mean indicates that the data are closely grouped around the mean. Assuming

a “normal” distribution,
68% of the tank battery sites would have

a VOC emission factor within one standard deviation

of the mean and 95% of the tank battery sites would have

a VOC emission factor within two standard deviations

of the mean. Only the last data set considered exhibits

a “normal” distribution. 6 Table

1 presents

a statistical analysis

of various datasets presented

in this review. Condensate

Mean VOC Standard Dataset Number

of Tank. Production Emission Factor Deviation No. Battery Sites (bbllday)

(lb VOCIbbI)

(lb VOCIbbI) Iba

21

All

33.3

53.3 lcb

19

All

17.9

19.5 3a

13

5

13.8

18.3 3bc

12

5

9.6

11.0 3bd

10

5

5.1

3.5 “Original HARC H51C data set.b Original data set excluding

the two outside outliers.C Condensate production

5 bbl/day, excluding

the one outside outlier.d Condensate production

5 bbl/day, excluding

the one outside and two inside outliers. For comparative purposes,

the Colorado Department

of Public Health and Environment (CDPHE”) recommends
VOC emission factors that range from 3.0 lb VOC!bbl

to 13.7
lb VOC/bbl,

for condensate storage tanks, depending

on the location

of the facility. 786 This data set consists

of 10 tank batteries:

2, 3, 4, 5, 6, 15, 18, 23, 28 and 30. http://www.cdphe.state.co.us/ap/sbap/SBAPoilgastankguidance.pdf CDPHE recommends

that these emissions factors should only be used

if the total uncontrolled VOC emissions
due to condensate tanks

at the site are less than 80 tons per year. CDPHE recommends

site- specific sampling
and analysis

to estimate emissions

for sites having uncontrolled VOC emissions greater than 80 tons per year. Table

I. VOC Emission Factors— Statistical AnalysisMr.GroverCampbell-6-May16,2011ChesapeakeEnergyItshouldbenotedthatofthe21tankbatteriesusedinderivingthe33.3lbVOC/bblemissionfactor,10ofthesiteswereoperatingataseparatordischargepressureofapproximately200poundspersquareinch(‘psi”),onewasoperatingatadischargepressureofapproximately121psi,andtheremaining10siteswerealloperatingatpressuresoflessthan50psi.Insteadofderivingasingleemissionfactor,inENVIRON’sopinion,itmayhavebeenmoreappropriatetoderivetwoemissionfactors:onefor“highpressure”separationandonefor“lowpressure”separation.Usingthe3bdataset(condensateproduction5bbl/day,excludingtheoneoutsideandtwoinsideoutliers),derivedemissionfactorsfor“highpressure”separators(operatingatapproximately200psiorgreater)and“lowpressure”separators(operatingatlessthan50psi)areasfollows.•“HighPressure”Separators:-Datapoints=3-MeanVOCEmissionFactor=16.6lb/bbl—StandardDeviation=12.2lb/bbl•“LowPressure”Separators:-Datapoints=7-MeanVOCEmissionFactor=4.0lb/bbl—StandardDeviation=2.5lb/bblWhilethesedatasubsetsmostlikelyhaveaninsufficientnumberoftestdatapointstoaccuratelyderiveemissionfactors(especiallyforthehighpressureseparatorsubset),itisinterestingtonotethatthesesubsetsshowbetterdatacorrelationthandoanyofthelargerdatasets.Forthelowpressureseparatordatasubset,thestandarddeviationis0.6timesthemean.Aspreviouslynoted,forthe3bdatasetasawhole,thestandarddeviationis0.7timesthemean.Pleaseletusknowifyouhaveanyquestions.BestRegards,StevenH.Ramsey,P.E.,BCEEShagunBhat,PhDPrincipalConsultantSeniorAssociateAttachmentA:HARCH5ICReportSiteData

# Attachment A (Derived from HARC H-51C Report)

Tank Battery Sites

Separator Condensate Derived VOC Tank Discharge API Production Emission Factor Battery County Area Pressure (psi) Gravity (bbllday) (IbIbbi) 2 Montgomery Houston-Galveston-Brazoria 41 42 105 3.65 3 Montgomery Houston-Galveston-Brazoria 38 41 87 7.92 4 Montgomery Houston-Galveston-Brazoria 34 40 120 0.78 5 Montgomery Houston-Galveston-Brazoria 46 43 100 0.67 6 Montgomery Houston-Galveston-Brazoria 33 39 130 2.96 13 Denton Dallas-Fort Worth —200 61 2 39.23 14 Denton Dallas-Fort Worth —200 59 4 29.51 15 Denton Dallas-Fort Worth —200 61 5 11.99 16 Denton Dallas-Fort Worth —200 61 2 60.58 17 Denton Dallas-Fort Worth —200 58 2 145.11 18 Denton Dallas-Fort Worth —200 58 10 7.34 19 Denton Dallas-Fort Worth —200 58 2 13.16 20 Denton Dallas-Fort Worth —200 59 10 30.43 23 Parker Dallas-Fort Worth 39 48 27 5.56 24 Parker Dallas-Fort Worth 36 41 1 4.22 25 Denton Dallas-Fort Worth —200 58 1 215.08 27 Denton Dallas-Fort Worth —200 59 2 14.39 28 Brazoria Houston-Galveston-Brazoria 38 46 30 4.17 29 Brazoria Houston-Galveston-Brazoria 41 42 61 33.68 30 Brazoria Houston-Galveston-Brazoria 36 42 15 6.11 32 Galveston Houston-Galveston-Brazoria 121 48 142 63.49Appendix

A Evaluation

of “VOC Emissions from Oil and Condensate Storage Tanks- Final Report” (2006 HARC Report) The 2006 HARC Report has been cited by TCEQ

in the context

of under reporting

of VOC emissions from storage tanks
by the oil and gas industry. The report used an average VOC emissions factor

of 33 lb/bbl

of condensate

to calculate

an estimate

of total VOC emissions from storage tanks for the East Texas Region. For Denton County only the results from the report give

a VOC emissions factor
of 48 lb/bbl. We believe that the methodology
used

in the report

to arrive

at these two emission factors

is flawed. We are also concerned
that these inaccurate numbers may be used

in VOC emissions inventory estimates

for future nonattainment areas. Therefore,

we offer the following analysis

to demonstrate
why the results from the 2006 HARC Report for VOC emissions from condensate storage
are unreliable
and should
be revised

or discarded.

We would welcome
the opportunity

to discuss this analysis with TCEQ, especially since

a second VOC emissions report

is already

in the works for release

in 2009. A.

It is obvious from looking

at the reported measurements

for tank battery #25 that gross errors

in measurements occurred. Both the reported vent gas MW of 89 and the VOC fraction

of 0.99 are impossible values for gas flashed from condensate

at a natural gas production
site. The calculated VOC flash emissions factor
of 215 Ibfbbl would require that 82%
of the condensate flashed when reduced

in pressure from 200 psig. This

is simply not possible

at this separator pressure.

At
a minimum,

the TCEQ should reject this data point and recalculate

the average VOC flash emissions factor from the remaining

20 tank batteries. Recalculation would give

a factor
of 24.2 lb/bbl,

a reduction

of 27% from the one reported. B. For tank battery #17, the calculated VOC flash emissions factor

of 145 lb/bbl would require that 55% of the condensate flashed when reduced

in pressure from 200 psig. This

is simply not possible

at this separator pressure. Since the other measured data for the vented gas (MW
of 36.6 and VOC fraction

of 0.65) are reasonable numbers, the error

is most likely due to the low condensate production
rate of 2 BOPD used

in the calculations.

The TCEQ should reject this data point and recalculate

the average VOC flash emissions factor from the remaining

19 tank batteries. Recalculation would give

a factor
of 17.8 lb/bbl,

a reduction

of 53% from the one reported. C. The report lists data for 10 condensate
tank batteries

(in Montgomery, Parker, and Brazoria Counties) with

a range

of separator pressures from 33 to 46 psig and with

a range

of API gravity from 39° to 48°. The test results
for tank battery #29 (33.7 lb/bbl), tank battery
#4 (0.78 lb/bbl), and tank battery
#5 (0.67 lb/bbl) appear

to be statistical “outliers.” Since there are no obvious data errors and the condensate
flow rates are high,

a statistical analysis

of the data would have

to be conducted

to determine

if any of these three test results are “outliers” that should
be discarded. We have no specific recommendation

on that point.D.Ingeneral,theresearchersdidnotfollowtheirownExperimentalDesign,whichwassomewhatdeficienttobeginwith.Onpage2ofSectionBi(ExperimentalDesign),itisstatedthat“VOCemissionrateswillbemeasuredbysamplingthetankventgasforcompositionalanalysisandmeasuringtheventgasflowrate.Measurementsofseparatorgasventedtotheatmospherewillalsobemade.TheconcentrationofeachC1-C6gascomponentinthesample,plusbenzene,toluene,ethylbenzene,xylene(BTEX)andotherC6+VOCwillbemultipliedbytheflowrate(averagedover24-hours)toproducemeasurementsofmassemissionratesforeachofthereportedgasconstituentsandotherC6+VOCinunitsofpoundsperhour.Themassemissionrateswillthenbedividedbythenumberofbarrelsproducedduringthe24-hourflowmeasurementperiodtoproduceemissionfactorsinunitsofpoundsperbarrel.Criticalmeasurementsforthisapproachincludethefollowing:•Ventgascomposition;•Ventgasflowrate;and•Oilorcondensateproductionrate”Furtherdownonthesamepage,whendiscussingselectionofwellsitestobetested,oneofthestatedcriteriaisthat“Theoilorcondensateproductionrateisatleast2barrelsperday.”Lastly,SectionB5(QualityControl)states“Thegreatestsourceofuncertaintyinthecalculatedemissionfactorsislikelytobetheestimationofoilorcondensateproducedoverthesamplingperiod.Theaccuracyoftheemissionfactorsderivedfromthesetestswillbelimitedtohowaccuratelytheproductionvolumescanbedeterminedduringthesamplingepisode.WhilesuchproductioninformationisreadilyavailableonamonthlyorannualbasisfromtheTexasRailroadCommission,accurateproductiondataovera24-hourperiodisgenerallynotavailable(emphasisadded),andwillhavetobeestimatedfromreadingthetanklevelgauges(ifpresent),manuallygaugingthetanklevel,orfromproductionmetersatthesiteifavailable.Thespecificmethodsandinstrumentsusedtoestimatedailythroughputwillberecordedinthefieldsamplinglog;however,thesensitivitiesofthesedevicestooilorcondensatethroughputover24-hoursisunknown.”1.Weagreethatthecriticalmeasurementsforthisstudyweretheventgascomposition,ventgasflowrate,andoilorcondensateproductionrate.2.Wedonotagreethatobtainingdatafromawellsitethatisonlyproducing2barrelsofcondensateperdayisappropriatewhenthegoalistocalculateaVOCemissionsnumberinlb/bblbasedona24-hrtestperiod.Usingemissionsdatabasedonthislowamountofproductionlendsitselftolargesamplingerrorsthatcanresultinlargevariabilityinreportednumbers(whichisexactlywhatoccurred).Inaddition,onpage1ofSectionB2(SamplingandMeasurementMethods),itisstatedthat“Theliquidproductionrateswillbedeterminedduringthetestperiodeitherbyreadingthelevelgageonthetanks(ifpresentatthesite),orbymanuallygaugingthetanks.Themanualtankreadingswillbeadjustedtoaccountforanyunloadingofthetanksintotanktrucksduringthetest.”Thesmallestcapacitystoragetankfoundinthereportwas300barrels.Evenifoneassumesatankheightof20feet(mostlikelytheheightwouldbe12feet),thestoragecapacityofthetankwouldbearound15bblperfoot.Togaugea24-hrproductionrateof2barrelswouldmeantakingtwomeasurementstoobtainadifferenceofabout14inches.Foratankheightof12feet,measurementofadifferenceof1inchwouldbenecessary.Inaddition,allofthesiteshadatleasttwotanks.Therefore,tomeasure2barrelsofproductionwouldtaketwomeasurementstoobtainadifferenceof1/2to3/4ofaninch.Itiseasytoseethatthistechniquewouldleadtolargeerrorsincondensateproductionrate,andinfact,itappearsthattheresearchersabandonedthisconceptatsomepoint(seeItem5).3.Webelievethattheresearchersusedpropertechniquesforobtainingventgascompositionsandhavenoreasontoquestionthatdata,otherthantheobviouserrorsfortankbattery#25previouslymentioned.4.Webelievethattheresearchersusedpropertechniquesformeasuringventgasflowrate,usingaFoxModel1OAFlowMeter,althoughsomeofthosemeasurementsmaybequestionableduetothelowratesattemptedtobemeasuredfromtestsiteswithlowcondensateproduction.5.Ourgreatestconcerniswiththemethodologyusedtocomeupwithcondensateproductionratesforthe24-hrtestperiods.Evidently,theresearchersrightlydeterminedthatanaccuratemeasurementofcondensateproductionduringthetestperiodsfromtankgaugingwasnotpossiblebasedontheconcernsexpressedinItem2.Itappearsthatinplaceofmeasuredcondensateproduction,theresearcherssubstituted2005dailyaveragecondensateproductionnumbersforeachtestedsiteobtainedfromtheRRCdatabase(footnote“f’forTable3-3onpage3-4“Dailyaveragecondensateproductionfor2005fromwww.rrc.state.tx.us/interactivedata.html”).Usingdailyaveragecondensateproductionnumbersfromahistoricaldatabase,forwhichonlymonthlyandyearlytotalsarereported,tocalculateaVOCemissionsfactorfromactual24-hrtestdataforaspecifictankbatterycanintroducelargeerrorsinthecalculationoftheflashVOCemissionsfactorasevidencedbytheresultsfromtankbattery#17.E.WebelievethisflawedmethodologyrenderstheresultsofthereportmeaninglessandurgeTCEQnottorelyonthemforanyinventoryanalysisorasthebasisagainstuseoftheVBEmethodforestimatingflashVOCemissions.IfanaverageflashVOCemissionsfactormustbeusedbyTCEQuntilamorerigorousstudycanbemade,thenthatfactorshouldbe17.8lb/bblasdiscussedinItemBabove.Anotheroptionwould
be to exclude any tank battery that used

a BOPD

of 2 or less. This would give an average VOC flash emissions factor
of 14.9 lb/bbl. Either
of these factors

is more in line with the results from the CDPHE study (page 1-2 of the 2006 HARC Report), which gave

a range
of 10.0 to 13.7 lb/bbl for different condensate producing regions. In addition, TCEQ must keep

in mind that this factor represents “uncontrolled storage tank emissions because

no account was made
of vent controls that exist
at an unknown number

of tank batteries

in East Texas”. (Page ES-2
of 2006 HARC Report). F. We urge TCEQ

to check the results

of the 2006 HARC Report
for condensate
tank batteries against data provided from industry

for actual sites that used process simulator programs, E&P Tanks,

or the GOR method with

a flash gas analysis and condensate analysis. TCEQ should have access

to site specific data with

a wide variety

of separator pressures
and API gravities.
We believe such

a comparison

will show that the reported average VOC flash emissions factor

of 56.6 (lb/bbl)
for Denton County
are out of line with values calculated from actual site data using methodologies

that are known

to be fairly accurate. When added

to the two battery sites for Parker County, the report gives an erroneous average VOC flash emissions factor
of 48.0 lb/bbl for counties

in the DFW nonattainment
area. Unfortunately,

this factor has already been used

in another draft report dealing with VOC emissions

in the DFW nonattainment

area (see Emissions from Natural Gas Production

in the Barnett Shale Area and Opportunities

for Cost Effective Improvements, Peer-Review Draft September

30, 2008,
by Dr. Al Armendariz, Ph.D.) G. We gather from the language

at the top of page

8 that TCEQ has commissioned

or will commission another study
on VOC flash emissions from
oil and condensate storage tanks that

is scheduled

for completion

in 2009. We request that TCEQ allow industry and/or

a third party consultant

to review the proposed testing procedures and proposed procedure

for obtaining accurate condensate production rates for the sites
to be tested. Otherwise,

it is likely that the same errors produced

by the 2006 HARC Report will be repeated. The most critical issue

is the method used
to measure actual condensate production during

a test period. We believe that to calculate

an accurate VOC flash emissions factor

in lb/bbl requires total condensate production

of at least
10 barrels during the test period. Therefore,
any test site should
be one with either

a high condensate production
rate
(>

10 BOPD)

or the test period must be extended

to 48-hr
or longer to obtain data from
at least
10 barrels

of production.
The condensate production should either
be measured directly with the use of a liquid meter

or from

a minimum tank gauging measurement

of
4 inches. This

is needed

to give

a reasonably accurate condensate production number. TCEQ may want

to consider whether

a testing program that proposes

to provide actual VOC emissions from multiple test sites (i.e., tries
to measure
the condensate rate or uses

a historical condensate production rate)

is really necessary
and worththe expense.

An option would
be to test

a large number

of productions
sites by (1) collecting applicable

site data such as separator temperature

and pressure, storage tank temperature, condensate

API gravity, etc, (2) obtain

a sample
(or multiple samples over

a set time period)

of the low pressure

oil (condensate)
prior
to flashing for

a GOR analysis with an extended
gas analysis

of the flash gas. This data can then be used
to obtain

a VOC flash factor

in lb/bbl for each tested site. The most critical item would
be proper collection

of the condensate sample. Historical production numbers
can then be used

to generate

a VOC flash emissions
rate for the site

if that information

is needed. This method does away with the potential

for large errors due to measurement

of low condensate production rates
or the use of historical information

for calculating

a VOC flash emissions factor.

It should also be much less costly than

a project that requires actual measurement

of flash gas and condensate
flow rates.Americ&s Natural Gas Alliance Good morning,

my name

is Craig Brown and

I rk for QEP Resources. Today

I am offering comments

on behalf

of America’sNatural GasAlliance,

a trade organization dedicated

to increasing understanding

of the environmental, economic
and national security benefits

of clean, abundant, dependable

and efficient North American natural gas. ANGA’s31 memoers include North America’s largest independent natural gas exploration

and production companies —the leading developers

of theshale plays that aretransforming

the clean energy landscape and allowing communities across the country

to advance economically, create sustainable joos, stay competitive globally, and embrace

a cleaner environment. We need reliable energy

to meet our growing needs. We need clean energy

to protect our environment. Natural gas bridges both of those needs vkile also providing energy security and domestic jobs. Discovery ofU.S. shaleplayscombined

with advancesin drillingtechnology have resulted

in game-changing projections

of our supply

of affordable domestic natural gas. Respected academics, gornment agencies,
and expert bodies —from the Energy Information Association

to MIT to the National Petroleum Council--
are all coming

to the same conclusion. We ha abundant, domestic supplies

of economically recoverable natural gas to power our nation for generations

to come. We see

a growing role for natural gas in the nation’s energy mix,
in particular because

of the environmental advantages

of its use as
a power generation

and transportation

fuel. When used
to generate electricity, natural gas burns cleaner than many other fuel sources, virtually eliminating S02, particulate,

and mercu

ry emissions
and significantly reducing NOx emissions. Vehicles running

on natural gas also emit significantly

less NOx, VOCs and particulate matter than vehicles running

on gasoline

or diesel. The natural gas community

is keenlyaware
that with the opportunities presented

by North Americas vast supplies

of naturalgas comes the responsibility

to be dedicated environmental stewards.
We firmly believe that people
do not have
to choose between
pro tecting their natural resources
and reaping the benefitsof
this abundant energy source.

To that end, we hope
to work with EPA to ensure these regulations protect the environment

in
a manner that

is consistent with our commitment

to safe and responsible development without adding unnecessary burdens that would impede our Nation’s ability

to take full advantage

of the tremendous potential

of American natural gas. ANGA intends

to submit detailed written comments

to the Agency,and

v nope to have

a continued dialogue with the Agency

as it develops
the final rulemaking.

In the meantime,

v. offer the following thoughts

on the proposed requirements. In the natural gas production process, there are already significant incentis

in place for operators

to reduce
air emissions.
Lost emissions equate

to lost renues, aswe strive
to cost-eff ectively capture

as much salablegas

as possible.

It is important that the new standards recognize these existing incentives.

To that end, ve encourage

the Agency

to ensure the standards continue

to allow appropriate consideration

of safetyas well as engineering judgment, particularly
with respect

to reduced emission completions. Where requirements

are prescriptive,
such as those that require installation

of
a particular piece
of equipment

or maintenance

on

a particular timeframe,

we encourage

the agency

to ensure that compliant technologies

or equipment exist and that operators

are gin flexibility with respect

to prescribed schedules

if there isno need from an emissionsstandpoint

to undertake

an actvty at
a particular time.

In the instances where
ve believe the requirements

are largely capturing existing good operating practices because

of the incentives mentioned above, we encourage the agency

to recognize that and to aid creating unnecessary

and orIy-burdensome recordkeeping

and reporting requirements. Finally,
we look forward

to discussing further the agency’s regulatory impact analysis.
We believe

a better understanding

of existing operating practices
will help the agency produce

a more accurate cost-benefit estimate associated with the rulemaking. Again, ANGA and its member companies appreciate

the opoortunity

to comment here today. We look forward

to rking with the agency

to ensure the dual goals
of resource development and environmental protection

are met so that Americans

can continue

to benefit from the development

of our vast domestic natural gas resource.EdIreland’sRemarkstoEPAArlington,TexasSeptember29,2011Goodmorning.IamEdIreland,executivedirectoroftheBarnettShaleEnergyEducationCouncil,anon-profiteducationalorganizationthatfocusesonenergyeducationasrelatedtotheBarnettShaleregioninNorthTexas.BSEECmembersarecommittedtoresponsibleprinciplesandoperationsinthedevelopmentoftheclean-burningnaturalgasintheBarnettShale.IwouldliketofocusontwopointsregardingtheproposedNewSourcePerformanceStandardsorNSPSrules.First,a“one-sizefitsall”approachtoregulatingVOCemissionsfromnaturalgaswellsisnotappropriatebecauseVOCemissionsvarywidelyduetogeologicfactorsandoperatingconditions.Forexample,thedrygasareasoftheBarnettShalehaveverylowVOCemissions.ThisalsosuggeststhatitisnotappropriatefortheEPAtousenaturalgasemissionsasasurrogateforVOCemissions(NSPSProposedRules,FederalRegister,page52760).Second,theproposednewNSPSrulesfortheoilandnaturalgassectoraresoextensiveandcomplexandthecommentperiodsoshortthattheEPAshouldextendthecommentperiodanddelayimplementationoftherulesuntilsufficientreviewisperformedandcommentscanbemade.RegardingVOCemissionsfromBarnettShalenaturalgaswells,theTCEQrecentlyreleasedthedatacollectedfromtheirPhase2SpecialInventoryinwhichoperatorswererequiredtoreporttheactualVOC,NOxandHAPemissionsfromall49,021piecesofequipmentlistedinthePhase1inventory.ThosedatarevealedthattheTCEQsignificantlyoverestimatedVOCemissionsfromBarnettShalenaturalgaswellsinitsStateImplementationPlan(SIP)forthe9-countyDEWnon-attainmentarea.TCEQ’sPhase2emissionsdatashowedthatVOCemissionsinthe9-countyEPAnon-attainmentareaoftheBarnettShalewereactually23.2tonsperday(TPD)in2009.ThiscomparestoTCEQ’sSIPestimateof101.8TPDfor2010(afterbackingoutthe10%growthratethatTCEQassumedfrom2010to2012—seepage3-28of“RevisionstotheStateofTexasAirQualityImplementationPlanfortheControlofOzoneAirPollution,”Proposal,June8,2011).Evenallowingforthemodestgrowthinthenumberofwellsinoperationbetween2009and2010,itisobviousthattheTCEQhasbeenover-estimatingtheVOCemissionsfromBarnettShalenaturalgaswellsbymanyordersofmagnitude.Onebasisfortheover-estimationofVOCappearstobeTCEQ’sassumptionthatsubstantialamountsofVOCemissionsareemittedfromcondensatestoragetanks.TCEQhascitedcertainstudiesandfindingsassupportforitsassumptionastothelevelofVOCemissionsfromcondensatestoragetanks,Asexplainedintheattachedcomments,TCEQ’sbasisforthisassumptionrestssolelyonthe‘HARCH5IC”VOCflashemissionsfactorof33Ibs./bbl.Asdetailedintheattachedwrittencomments,this33lbs./bbl.emissionfactorisbasedonfaultydataandwasappliedbyTCEQforitsSIPrulemakingforallcondensateproductionregardlessofthesubstantialdifferencesinVOCcontentoftheflashgasandoperatingconditions.ThisinturnhasledtoanunrealisticandsubstantialincreaseinTCEQ’sstatewideVOCemissionsinventoryfromtheoilandgassector(seeattached:EdIreland’sAugust8,2011writtencommentsonTCEQ’sproposedrevisionstotheChapter115VolatileOrganicCompoundsstoragerules).TherecentCityofFortWorthERGStudyprovidesadditionalevidencethatpriorestimates,suchasinthecurrentTCEQSIP(citedabove)andtheJanuary26,2009Armendarizreport“EmissionsfromNaturalGasProductionintheBarnettShaleAreaandOpportunitiesforCostEffectiveImprovements”,haveoverestimatedVOCemissionsfromtheoilandgassector.Unfortunately,thefaulty33Ibs./bbl.emissionfactorfromthesestudieshasreappearedinthisEPArulemakingandappearstounderlietheEPA’sVOCcalculationsonwhichsubpart0000isbased.Insummary,theEPAshouldrecognizethata“one-sizefitsall”regulatoryapproachtoregulatingVOCfromnaturalgaswellsisnotappropriatebecausesuchemissionsvarywidelydependingongeologicfactorsandoperatingconditions.ThisalsosuggeststhatitisnotappropriatefortheEPAtousenaturalgasemissionsasasurrogateforVOCemissions.SincebothTCEQandEPAhaveoverestimatedVOCemissions,thecostsoftheseproposedNSPSrulesmaybeunderestimatedandthebenefitsoverestimated.TheEPAneedstobeencouraging,notdiscouraging,thedevelopmentofclean-burningnaturalgas.Thiswashighlightedinastudyreleasedthisweekbywell-knowneconomistDr.RayPerrymanthatnotedthehugeeconomicbenefitsandjobsthatBarnettShaleactivityisprovidingtonorthTexasandtheentirestateofTexas.TheEPAshouldproceedwithcautionsoasnottodamagethispowerfuleconomicengineunnecessarily.Finally,theEPAneedstoprovidemoretimeforaffectedcompaniestoreviewtherulesandpreparecomments.Theremustbeareasonabletimeperiodforcompaniestoavoidnon-compliancebybeingabletoproperlyprepareforimplementationofthesenewregulations.Thankyou.&k.LtL-€IL-J‘-CJpr-(.Tp’i-it)Firstly,IwanttothanktheEPAforthissteptowardssomesortofregulationofthefrackingprocess.IVTO’4.’L.IliveinEastFortWorth.Withinamileortwoinanydirectionofmyhouse....thereareallsortsofnaturalgasoperationsunderway,Bythedogpark.AlongtheRiver.Behindthe7-11.NexttotheWaffleHouse.Besidethehighschoolsportsfield.Practicallyinpeople’sfrontyards.Ialsocan’thelpbutnoticehowconcentratedtheoperationsareinthelessaffluentsectionsoftown.Unsurprisingly.ItscaresmesomuchthatIdomybesttoavoidBerryStreetandBeachStreetandLancasterAve.Iknowthatpowerfulpeoplewithdeeppocketshavetriedtohidethisindustrytechniquefromanyandallregulation.Iknowthatacademicsandscientistswhohavespokenoutagainstthedangersoffracking(nottomentionURBANfracking)havebeensystematicallysilencedorundermined.AsfarasIcantell,theNatiaIGasindustryandourQuoteUnQuoteRepresentativesandSo-calledLeadershavedecidedtogambleonthehealthandsafetyofmyself,myfamily,andmyfellowcitizens.Why?IguessbecausetheyhadBigMoneytomake.Icanthink4tnootherplausiblereason.ThequestionIaskmyself—thatIdon’twanttoaskmyself,butIcan’thelpit—is“AmIambylivinghere?inanurbantrackingfield?HowmuchamIincreasingmyIriskofcancer?houldIgrabmyfamilyandrunawayfrommymortgagetosomeplace‘1else.Wherewouldthatevenbe?”-‘IknowthatsincecomingherelastyearIhaveheadaches.everydayandaweirdfluttere,tsois?1wPassingaLancasterAvençhesapeakeoperationonedaythesmellwassointensethatitgavemeaninstanCheadacheandleftanacridtasteinmymouthforaday.TheTCEQseemsremarkablytoothless.Iamnotevensurethatmycallgeneratedanactualreport.ThisisalltosaythatIcallupontheEPAtoregulatethisindustryastheywouldanyotherwithstrong,healthandscience-basedrules.Thiscountrycanillaffordtocleanupthemessthattheindustrywillcertainlyleavebehind.Thiscountrycanillaffordtheresultanthealthcoststhatwillsadlycomeinourfuture.Andplease,d9-P1eletexistingfrackingoperationsoffthehook.Thatwouldmerithatyouarewritingmeoff.Writingoffmn9nighborhood,andmycommunity.Becausetherearealreadyhundreds,ifnotthousandsofwellshere.ThankyouTestimony

on Proposed
Air Pollution Standards

for Oil & Gas Sector David Weinberg Executive Director, Texas League

of Conservation Voters EPA Hearing+ Arlington, Texas+ Sept. 29, 2011 The Environmental Protection Agency’s proposals

to address
air pollution standards should
do much

to provide clarity

to industry and stakeholders

and reduce
air pollution from oil and natural gas operations. It’s

a worthy effort, and one that despite some state leaders’ long-running
feud with EPA

is welcomed here by many

in the public, community leaders, conservationists

and environmental organizations

like mine. Balancing market needs and demands with public health and safety concerns

is an essential role of government. The National Petroleum Council’s (NPC) recently released report, Prudent Development (Sept. 2011, www.npc.org), suggests that
if natural gas development

is done right, our state and our nation’s vast natural gas reserves could be— in the words
of the NPC itself— “transformative

for the American economy, energy sector and environment.” The pivotal point
in this
is that we doit right. Doing

it right means leveraging reasonable regulations

and effective available technologies

to reduce emissions. Doing

so means

a truly win-win-win situation
for the environment, consumers
and industry. Texas has been

a leader

in improving drilling practices from hydraulically fractured wells, passing the nation’s first mandatory disclosure
law for hydraulic fracking fluids this year. Improving

air quality controls
for gas and oil drilling

is a necessary next step
in advancing drilling practices.

1Compared

to coal, natural gas, delivers significant benefits
for air quality, emitting

far less nitrogen oxides, little sulfur dioxide and no mercury per unit of electricity produced.
The cleaner-burning benefits

of natural gas in particular
also improve

as we cut down on fugitive emissions from natural gas production, namely methane emissions.

For these reasons, TLCV strongly supports proposed EPA regulations

on improvements

for natural gas compressors, pneumatic devices, and storage tanks. TLCV feels strongly that the EPA’s proposal significantly improves
the New Source Performance Standards (NSPS) under the Clean Air Act. By requiring
the use of reduced emission completions,

for example,

we would
be working

to reduce the emissions

of volatile organic compounds, though further clarity
of the specific terminology

and applicability

of the rule to “workover” wells and liquid unloading would
do much

to help address the environmental community’s concerns and, no doubt, provide

a level of clarity to benefit both public and industry alike. Regardless

of the EPA regulations ultimately adopted, TLCV strongly believes that Texas
on the whole must do

a better job of policing drilling— which means better funding

of the Texas Railroad Commission— and establishing clarity between
the Railroad Commission and the Texas Commission

on Environmental Quality. Improved stakeholder

and constituent input and response
are also needed. And, it’s

a resource with such an abundant supply here
in Texas that
if it is safely produced and properly regulated, that it’s production could stand
to generate significant severance tax revenue—supplying

much needed general revenue during very difficult economic times and providing potentially more revenue
for the critical state regulatory needs. TLCV

is confident
this can be accomplished

in
a way that benefits and addresses

the environmental

and public health concerns, while providing reasonable regulatory measures
and considerable savings

to the industry. Thank you for the opportunity

to testify today.

2CLEAN WATER ACTION TEXAS September

29, 2011 To: US Environmental Protection Agency From: Clean Water Action Re: Docket EPA-HQ-OAR-2olo-o5o5,

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

for Hazardous

Air Pollutants Reviews On behalf
of Clean Water Action’s 35,000 Texas members
and our one million across the country,

I want
to thank EPA for coming

to Arlington
and for their strong proposal

to restrict
air emissions from oil and gas extraction operations. EPA regulations

of these large pollution sources are urgently needed here
in Texas and in many other communities across the country. State governments including Texas have
so far done little
to manage
gas drilling, and we need the federal government

to step in and play

a strong role here
in protecting public health and the environment.

It is important

for EPA to understand
that fracking operations

in Texas and elsewhere

are frequently occurring quite literally

in people’s backyards.

We have over 1,000 gas facilities within the city limits
of Ft Worth alone,

a city of more than half

a million residents. Any rules on air emissions must take into account that people are living extremely close
to these pollution sources. We should not he protecting people
‘on average’.
We need
to protect everyone living near gas drilling. Another important point for EPA to consider

is that these rules are urgently needed and should
be implemented

as soon
as possible. EPA should not delay
or extend the comment period or the effective date of any of these new rules. Many
of Texas’ major metropolitan areas, including the DFW metropolitan
area, are already

in non-attainment tinder the federal Clean Air Act. New air pollution rules can take

a long time
to be enacted, and we need these rules
in place
as soon
as possible. There

is no moratorium

at the state level on permits
for new frack wells here
in Texas. Thousands

of wells have already been drilled here, and many more thousands

are planned
for the IflI() \iiiii \riii \\\.,,iiI

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# CLEAN WATER ACTION TEXAS near for the near future. Any delay
in putting restrictions

in place means allowing thousands

of new pollution sources

in Texas that will have

a significant impact
on our health. Finally,
we urge EPA to ensure that these rules are as strong

as they can be. Best available control technology should
be

a standard requirement

for all oil and gas operations.

All significant sources

of air emissions must be included

in the rules, such
as the thousands

of open air frac pits that accompany drilling sites. Remember
that these pits can also be only

a couple hundred feet from where people live. All relevant pollutants should
be directly controlled including methane and hydrogen sulfide. Finally, flaring should
be completely prohibited.

It is simply irresponsible to allow the gas industry

to start production

at
a well, before they have

a way to safely control the flow of hazardous emissions. In closing,

I would like to again thank EPA for coming

to Texas and for issuing these important rules, and

I urge you to implement them without delay. We are looking towards federal agencies such
as EPA
to step up to the plate and provide the protect
we all deserve. Respectfully, David Foster Texas Program Director IOI() \(iiiIIIII \(I)IH 

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# Leaking Money

Potential Revenues from Reduction of Natural Gas and Condensate Emissions in North Central Texas
Melanie Sattler, Ph.D., P.E. May 2011

Downwinders at Risk Education Fund

# About the Author - Dr. Melanie Sattler has over 15 years of professional experience with air quality issues, including experience in consulting, academia, and government. She has published 50 peer-reviewed conference proceeding papers and journal articles related to air quality and other aspects of environmental engineering. Dr. Sattler earned her Ph.D. in environmental engineering, with a focus on air quality, from the University of Texas at Austin. She is a registered professional engineer in the State of Texas.

Founded in 1995, the Downwinders at Risk Education Fund is dedicated to research and public outreach on issues of public health, air pollution and the environment.

PO Box 763844 Dallas TX 75376 972-230-3185 info@downwindersatrisk.org

# SUMMARY The objective of this study was to estimate the amount of money that the natural gas industry in the Dallas-Fort Worth 9-county ozone non-attainment area could earn by reducing emissions of natural gas and condensate that currently escape into the atmosphere. Natural gas prevented from leaking could be sold as fuel. Recovered condensate can be used as a chemical feedstock or refined into gasoline and other products. Reducing such emissions would be a win-win: increased revenues for the natural gas industry, and lower ozone-forming volatile organic compound (VOC) emissions for the citizens of North Central Texas. This study considered emissions from the following natural gas
sources:

• Gas fugitives
• Gas well completions
• Gas well blowdowns
• Pneumatic devices
• Condensate tanks
• Condensate loading.
VOC emission estimates for each of the above categories for 2012 were provided by the Texas Commission on Environmental Quality (TCEQ). Methane and ethane emissions, which also have commercial value, were estimated by multiplying the VOC emission estimates by the ratio of the weight percent of methane or ethane in natural gas or condensate to the weight percent of VOCs.

Significant conclusions include the following:

• By installing equipment to recover natural gas and condensate emissions in North Central Texas, natural gas companies could earn up to $51.9 million a year in new revenues, and at the same time reduce VOC emissions.

• Emissions from pneumatic devices account for the largest percent of emissions with economic value (70%), and thus should be targeted first. Addressing the “low-hanging fruit” of pneumatic devices could save up to $35 million in the current 9-county non-attainment region plus Wise County, and reduce VOC emissions by 71 tons per year (tpy).

• Technology for reducing emissions from pneumatic devices has already been successfully demonstrated by many companies in the field. Most retrofit investments pay for themselves in little over a year, and replacements in as little as 6 months. An image captured from a Texas Commission on Environmental Quality film using an infrared cam era. The black plumes are Volatile Organic Com pounds escaping from a Barnett Shale gas field tank battery. These plumes are normally invisible to the naked eye. Capturing this pollution instead of allowing its release into the atmosphere could bring millions in new profits to gas field owners, shareholders and mineral rights property owners. Leaking Money page 1

# 1. Study Objective The objective of this project was to estimate the amount of money that the natural gas industry in the Dallas-Fort Worth 9-county ozone non-attainment area could earn by reducing emissions of natural gas and condensate that currently escape into the atmosphere. Although some initial investment in replacing or retrofitting equipment would be required, much of this investment would pay for itself in 6 months to a year. Natural gas prevented from leaking could be sold as fuel. Recovered condensate can be used as a chemical feedstock or refined into gasoline and other products. Reducing such emissions would be a win-win: increased revenues for the natural gas industry, and lower emissions of ozone-forming volatile organic compounds (VOCs) for the citizens of North Central Texas. Wise County emissions were also included because of the concentration of gas industry VOCs there and the probability that a new federal ozone standard is likely to draw that County into the designated DFW non-attainment area in the near future. 2. Study Scope VOC emission reductions of 140 tpy are required as part of the region’s rate-of-progress State Implementation Plan (SIP). According to TCEQ (Boyer, 2010), oil and gas drilling and production togetherwill release 103 tons per day (tpd) of (VOC) emissions in the 9-county Dallas Fort Worth (DFW) nonattainment area in 2012 (see Figure 1). Figure. 1 DFW 9-County Non-Attainment Region Oil & Gas Production and Drilling VOC Emissions, 2010 (TCEQ, 2010) Leaking Money page 2



# Although oil drilling and production releases VOCs, this study limits itself to natural gas drilling and production. Of the 103 tpd of VOC emissions due to oil and gas facilities, only 0.7 tpd (0.7%) is attributable to oil drilling and production (well blowdowns, oil well completions, oil load

ing, crude tanks, and oil fugitives).

# Of the categories of natural gas drilling and production emissions identified by TCEQ, this study consid

ers only the following:

• Gas fugitives • Pneumatic devices
• Gas well completions • Condensate tanks
• Gas well blowdowns • Condensate loading. For explanations of the processes, the reader is referred to Bar-Ilan et al. (2008).The categories listed above account for 87% of oil and gas VOC emissions in the DFW 9-county nonattainment area, according to the TCEQ data. Emissions from pumpjacks, dehydrators, gas heaters, compressor engines, drill rigs, and produced water are not considered. Emissions from most of these pieces of equipment are post-combustion (ERG, 2010), and would have little commercial value, since organics have been largely converted to carbon dioxide and water. The TCEQ definition of volatile organic compound (VOC) excludes methane and ethane, which are less reactive than other organics in forming ground-level ozone. These compounds, however, still have commercial value and are, in fact, the primary constituents of natural gas. This study thus includes emissions of VOCs, methane, and ethane. Natural gas and condensate emissions also contain a small fraction of carbon dioxide (2-3% by weight). Although carbon dioxide has commercial value in the food, oil, and chemical industries, its value is not considered here. 3. Regional Emissions of Compounds with Commercial Value Table 1 shows emissions from natural gas drilling and production facilities with a commercial value. Emission estimates are given for VOCs, methane, and ethane, as discussed above. Emission estimates are provided for the 9-county DFW non-attainment area, as well as for Wise County, which equals over half the VOCs of the 9-county total.

Table 1. Emissions with Potential Commercial Value from Natural Gas Facilities in North Central Texas



# In Table 1, emissions from gas fugitives, gas well completions, gas well blowdowns, and pneumatic devices are lumped into the general category of “produced gas” emissions. According to a report prepared by Eastern Research Group for TCEQ (2010), emissions from these categories are assumed to have the same species composition as produced natural gas. Emissions from condensate tanks and loading, which have a different species composition, are lumped into the general category “condensate”. Leaking Money page 3

# The data in Table 1 are summarized in Figures 2-4 below. As shown in Figures 2-4, reducing emissions from pneumatic devices would recover the greatest amount of compounds with commercial value: 73%, 62%, and 70% for the 9-county non-attainment area, Wise County, and the combined 10-county region, respectively. Capturing emissions from condensate tanks would recover the second largest amount of compounds with commercial value: 12%, 28%, and 17% for the 9-county non-attainment area, Wise County, and the com

bined 10-county region, respectively. VOC emissions could be reduced by up to 52 tons per day by addressing pneumatic devices in the 9-county non-attainment area alone.

Figure 2. Sources of Natural Gas Emissions with Potential Commercial Value – 9-County DFW Non-Attainment Area

Figure 3. Sources of Natural Gas Emissions with Potential Commercial Value – Wise County Leaking Money page 4

# Figure 4. Sources of Natural Gas Emissions with Potential Commercial Value – 9-County Non-Attainment Area and Wise County Combined

VOC emissions in Table 1 were taken directly from TCEQ estimates for 2012 (Boyer, 2010; Maldonado, 2011). Methane and ethane emissions were estimated by multiplying the VOC emission estimates by the ratio of the weight percent of methane or ethane in natural gas or condensate to the weight percent of VOCs, as shown in Table 2.

Table 2. Weight Percents of Components of Natural Gas and Condensate in North Central Texas Leaking Money page 5

# The weight percent of methane and ethane in natural gas in Table 2 were taken from a permit application for the Havener well site. This was the only complete natural gas speciation data specific to the North Central Texas Barnett Shale that the author could find. According to Armendariz (2009), natural gas producers in the North Central Texas region reported unprocessed natural gas composition to be 8.2% VOCs and 74% methane on a mass % basis. Using these alternative numbers would actually increase the estimate of revenue-producing emissions, because the ratio of the weight percent of methane to the weight percent of VOCs would increase. Condensate weight percents in Table 2 were taken from Hendler et al. (2009). Average weight percents for North Central Texas were used. T-tests showed that methane, ethane, and VOC weight percents for condensate tanks in DFW differed from other parts of the state, to 95%, 85%, and 98% levels of confi

dence, respectively. These t-test results are included in the appendix. Species with weight percents <1% were not included. Table 2 also shows incremental reactivities (moles of ozone formed per mole of carbon added to the VOC mix in an air mass) for some of the compounds (Carter, 1991; Russell et al, 1995). For comparison, an urban mix has an average reactivity of 0.28 mol ozone/mol C (Carter, 1991). Although the VOCs listed in Table 2 are alkanes, and not highly reactive VOCs (HRVOCs), they still contribute to ozone formation. Released in large quantities, the amount of ozone that they form would be significant on a regional basis
4. Potential Revenues from Reduced Emissions As discussed above, the emissions in the category “produced gas” have a composition like that of natural gas. If these emissions were captured, it is assumed that they could be sold as natural gas. According to the U.S. Energy Information Administration, the average commercial price of natural gas in Texas was $7.24 per thousand cubic feet for February 2011, the latest month for which information is available. The commercial price is the price of gas used by nonmanufacturing establishments or agencies primarily engaged in the sale of goods or services such as hotels, restaurants, wholesale and retail stores and other service enterprises; and gas used by local, State and Federal agencies engaged in nonmanufacturing activities. The commercial price is higher than the industrial price, but lower than the residential price, so represents an intermediate sales price. A price of $7.24 per thousand cubic feet was accordingly used in Table 3 to calculate potential revenues from capture of produced gas, based on the emission values from Table 1. Natural gas condensate is a mixture of hydrocarbon liquids that are present as gaseous components in the raw natural gas. At temperatures below the hydrocarbon dew point of the raw gas, they condense out of the raw gas. Natural gas condensate can be used as a chemical feedstock for production of ethylene and propylene. It can also be refined into gasoline and other products. According to the Energy Information Administration (EIA), in 2006 refineries in the USA used 5563 million barrels of crude oil (15.24 million barrels per day) and 180 million barrels of natural gas liquids, or around 3% of the crude oil input volume. The price of condensate fluctuates with the prices of natural gas and crude oil. Devon Energy reported in May 2011 that their average realized natural gas liquids price for the first part of 2011 was $37.39 per barrel. This number, along with a mid-range condensate density of 0.65 g/cm3, was used to compute the potential revenues from condensate shown in Table 3. As shown in Table 3, potential revenues from capture of natural gas and condensate emissions in North Central Texas exceed $51 million per year for the 9-county non-attainment area and Wise County. Potential revenues from the combined 10-county region are summarized in Figure 5. Leaking Money page 6

# Table 3. Potential Revenues from Capture of Natural Gas and Condensate Emissions in North Central Texas

Figure 5. Potential Annual Revenues from Capture of Natural Gas and Condensate Emissions in the 9-County Non-Attainment Area and Wise County



# 5. Methods of Reducing Emissions Pneumatic devices and condensate tanks should be targeted first for emission reductions, since they represent 70% and 17% of emissions, respectively, for the 10-county region including Wise County.
5.1 Pneumatic Devices Pneumatic devices, used for various natural gas processes, are powered mechanically by high-pressure produced gas as the working fluid. Pneumatic devices include control devices that automatically operate values and control pressure, flow, temperature or liquid levels (EPA, 2006). As part of normal operation, these devices leak the working fluid, which is produced gas (Bar-Ilan, 2008). In the U.S. natural gas production sector, it is estimated that 400,000 pneumatic devices are used to control and monitor gas and liquid flows and levels in dehydrators and separators, temperature in dehydrator regenerators, and pressure in flash tanks (EPA, 2006). In the U.S. natural gas transmission sector, around 85,000 pneumatic devices actuate isolation valves and regulate gas flow and pressure at compression stations, pipelines, and storag e facilities. Leaking Money page 7

# Pneumatically-operated devices became the standard in the oil and gas industry since electricity was not available at remote production sites (EPA, 1996); this, however, is not the case with drilling and production in urban areas. Emissions could be reduced, and valuable natural gas saved, by (EPA, 2006; Armendariz, 2009): 1. Replacing high-bleed devices with low-bleed devices, 2. Installing low-bleed retrofit kits on high-bleed devices, 3. Improving maintenance practices, 4. Ensuring that all natural gas actuated devices discharge into sales lines or closed, loops, instead of venting to the atmosphere; 5. Convert gas pneumatic devices to instrument air (see EPA’s document, “Lessons Learned: Convert Gas Pneumatic Controls to Instrument Air” available at http://www.epa.gov/gasstar/docu ments/ll_instrument_air.pdf), or replace them with non-pneumatic devices (electric). Options for reducing gas-bleed emissions by controller type are shown in Table 4. Enhanced maintenance can include repairing/replacing leaking gaskets, tubing fittings, and seals, as well as cleaning and tuning; such measures can save 5-10 standard cubic feet of gas per hour (scfh) per device (EPA, 2006). Eliminatingunnecessary valve positioners can save up to 18 scfh per device. Pressure control valves with a selfcontained spring/diaphragm can be used; such controls discharge to the downstream gas line, resulting in no bleeding of gas to the atmosphere (EPA, 1996).

Table 4. Options for Reducing Gas-Bleed Emissions by Controller Type (EPA, 2006)



# Natural Gas STAR partners are natural gas companies who voluntarily partner with EPA to adopt costeffective technologies and practices that improve operational efficiency and reduce emissions of methane. According to EPA (2006): Natural Gas STAR partners have achieved significant savings and methane emission reductions through replace

ment, retrofit, and maintenance of high-bleed pneumatics. Partners have found that most retrofit investments pay for themselves in little over a year, and replacements in as little as 6 months. To date, Natural Gas STAR partners have saved 36.4 Bcf by retrofitting or replacing high-bleed with low-bleed pneumatic devices, representing a sav

ings of $254.8 million worth of gas. Individual savings will vary depending on the design, condition and specific operating conditions of the controller. Payback times for replacement, retrofit, and maintenance of pneumatic devices are shown in Table 5, and range from immediate to 13 months. Leaking Money page 8

# Table 5. Payback Times for Options for Reducing Natural Gas Emissions from Pneumatic Devices (EPA, 2006)



# Savings from reduced emissions can range from $315 to $1820 per year per device, based on a natural gas price of $7 per thousand cubic feet (EPA, 2006). EPA’s field experience with Natural Gas STAR partners has shown that up to 80% of all high-bleed devices can be replaced with low-bleed equipment or retrofitted. Union Pacific Resources provides one example of successful retrofit and replacement of high-bleed pneu

matic devices. Union Pacific replaced 70 high-bleed pneumatic devices with low-bleed devices and retrofitted 330 high-bleed devices. The retrofits and replacements cost $166,300, but will save $347,200 annually (at $7 per Mcf natural gas prices), resulting in a payback of less than one year. In addition to saving money and reducing emissions of ozone-forming VOCs, the retrofit or replacement of worn high-bleed pneumatic devices can improve system-wide performance and reliability, and provide better monitoring of gas flow, pressure, liquid level, and other parameters. The EPA brochure “Lessons Learned from Natural Gas STAR Partners: Options for Reducing Methane Emissions from Pneumatic Devices in the Natural Gas Industry,” available online at http://www.epa.gov/ gasstar/documents/ll_pneumatics.pdf, provides additional information about replacing, retrofitting, and maintaining pneumatic devices.
5.2 Condensate Tanks Vapor recovery units (VRU) are estimated to capture over 98% of emissions from condensate tanks (Hendler, 2009). Gases and vapors from the tanks are directed to the inlet side of a compressor, which increases the gas pressure so that many of the moderate and high molecular weight compounds con

dense back into liquid form. Methane and other light gases are directed to the inlet (suction) side of the compressors to join the main flow of natural gas. In this way, VRUs increase the total production of gas at the well. In addition, liquids produced by the VRU are directed back into the condensate tank, increasing condensate production and potential revenue (Armendariz, 2009). Leaking Money page 9

# 5.3 Other Processes Enhanced leak detection and repair can be used to reduce fugitive emissions, which represent 8% of emissions with commercial value in the 10-county region. “Green completions” to capture methane and VOC compounds during well completions, which represent 3% of emissions with commercial value in the 10-county region. For additional discussion of enhanced leak detection and repair, and green comple

tions, see Armendariz (2009).
6. Conclusions

• By installing equipment to recover natural gas and condensate emissions in North Central Texas, natural gas companies could save up to $51.9 million a year, and at the same time reduce VOC emissions that contribute to ground-level ozone formation.

• Emissions from pneumatic devices account for the largest percent of emissions with economic value (70%), and thus should be targeted first. Addressing the “low-hanging fruit” of pneumatic devices could save up to $35 million in the current 9-county non-attainment region plus Wise County, and reduce VOC emissions by 71 tpy.

• Technology for reducing emissions from pneumatic devices has already been successfully demonstrated by many companies in the field. Most retrofit investments pay for themselves in little over a year, and replacements in as little as 6 months.

7. References Armendariz, Al. “Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost-Effective Im

provements.” Report for Environmental Defense Fund, January 2009. Available online at http://www.edf.org/documents/9235_ Barnett_Shale_Report.pdf . Bar-Ilan, Amnon; Parikh, Rajashi; Grant, John; Shah, Tejas; Pollack, Alison K. “Recommendations for Improvements to the CENRAP States’ Oil and Gas Emissions Inventories.” Report prepared by ENVIRON International Corporation for the Central States Regional Air Partnership. November 13, 2008. Available online at http://www.wrapair.org/forums/ogwg/docu

ments/2008-11_CENRAP_O&G_Report_11-13.pdf Boyer, Doug. “2006/2012 DFW Modeling Update.” Presentation prepared by Texas Commission on Environmental Quality for the DFW Photochemical Modeling Technical Committee, November 5, 2010. Carter, William P. L. “Development of the SAPRC-09 Chemical Mechanism and Updated Ozone Reactivity Scales.” Report to the California Air Resources Board, Contracts No. 03-318, 06-408, and 07-730, Revised January 27, 2010. Hendler, Albert; Nunn, Jim; and Lundeen, Joe. “VOC Emissions from Oil and Condensate Storage Tanks.” Final Report pre

pared for the Texas Environmental Research Consortium, April 2, 2009. Available online at http://files.harc.edu/Projects/ AirQuality/Projects/H051C/H051CFinalReport.pdf . “Permit by Rule for the Havener Tank Battery” located in Tarrant County, Texas. Attachment #7. Submitted by XTO Energy, Inc. to the TCEQ on May 24, 2010. Pring, Mike; Hudson, Daryl; Renzaglia, Jason; Smith, Brandon; and Treimel, Stephen. “Characterization of Oil and Gas Produc

tion Equipment and Develop a Methodology to Estimate Statewide Emissions.” Final Report prepared by Eastern Research Group for Martha Maldonado of the Texas Commission on Environmental Quality, Air Quality Division, November 24, 2010. Texas Commission on Environmental Quality. Texas Air Emissions Repository (TexAER), http://www.tceq.texas.gov/airquality/ areasource/TexAER.html, accessed May 2011. Leaking Money page 10

# U.S. Energy Information Administration. “Natural Gas Prices.” Independent Statistics and Analysis, Texas, http://www.eia.doe. gov/dnav/ng/ng_pri_sum_dcu_STX_m.htm, accessed 5/11. U.S. Environmental Protection Agency. “Lessons Learned from Natural Gas STAR Partners: Options for Reducing Methane Emissions from Pneumatic Devices in the Natural Gas Industry.” http://www.epa.gov/gasstar/documents/ll_pneumatics.pdf, October 2006. U.S. Environmental Protection Agency. “Methane Emissions from the Natural Gas Industry: Volume 12: Pneumatic Devices.” National Risk Management Laboratory, EPA-600/R-96-0801, June 1996.



# APPENDIX A Table A1. Weight Percents for Condensate Tank Emissions in North Central Texas vs. Other Parts of the State Leaking Money page 11SenatorJaneNelsonP.O.Box12068CapitolStationAustin,Texas78711ClaudetteFette2708GlenwoodLnDenton,TX76209HonorableSenatorNelson,Iamwritingwithconcernsregardingtheneedforstrongerlawsandoversighttoprotectthepublichealthrelatedtothepracticeofhorizontaldrilling.First,knowthatIamnotunilaterallyagainstoilandgasdrillingandthatIunderstandthebenefitofincreasingdomesticenergyproductionandofthepotentialforgastobeacleanerfuelthansaycoal.Iliketurningonmylightswitchandhavingreliablepower.However,Ialsobelievethatwemustassurethattheextractionofthatgasisnotplacingundueburdenonthoseofuslivingontopofit.MyfamilyhasasmallfarminthefarsouthwesterncornerofCookeCountywithahundredsof-year-oldliveoaktreewhosebranchesarcgracefullytothegroundbeforerisingagain,somewherebetween100and150oldgrowthnativepecantrees,morethanadozengrandfatherblackwalnuttrees,ahandfulofwillowtrees,andmanypersimmon,postoak,burroakandredoaktreesamongothers.It’snortheasternboundarybordersonClearCreek(whicheventuallyfindsit’swaytothemunicipalwatersupplyviaLakeLewisville)andithasalargepondandwaterwayclosetothefrontofthepropertythatcollectsrunofffromseveralnearbyfarmsduringheavyrainfall.ItisamultigenerationalventurestartedwhenmyfatherdecidedhecouldnotkeepupwithhisfarmincentralTexasandmyyoungestsonapproachedhimaskingifhecouldhelphimfarmit.Insteaddaddecidedtosellthatfarmandbuyoneuphere,essentiallygainingtwoextrafarmhandsinmyhusbandandI.Wehavebeensteadilyimprovingthefarm,drillingawell,buildingabarnandtendingtopastureandwoodlandalike.Itiscurrentlypredominantlyproducinghaybutweareclearingtheunderbrushfromthepecantreesandhavebuiltthefirstphaseofanirrigationsystemandplantedourfirst38chestnuttrees.Therehavebeenafewoilandgaswellsevidenthereandtherebutthisyeartheyhavebeenincreasingexponentially.ImagineourshockwhenourneighborfoundoutontheRailroadCommission(RRC)websitethattherewereseven(7)horizontalfracturingwellstobecompletedunderourfarm.IinitiallyhadsomedifficultynavigatingtheRRCwebsitebutwhenIinquired,foundtheirstafftobeveryhelpful.Theybegantoeducatemenotonlyonthewebsitebutalsoontheprocessesinvolvedin“fracking”.Sureenough,thereare7wellsunderourproperty.Theyhelpedmefigureoutwheretheyareinrelationtoourwaterwell.Theyalsohelpedmefigureoutthatthelarge“socks”thatsuddenlyappearedinClearCreekat8/28/2011CFette,Page1thebackofourpropertyweretheresultofa5barrelspillthathadoccurredatanotherEOGwellupstream(SpillNo.2011-09-0587).IreallycannotsayenoughtocommendtheRRCinspectorsandtheirpatiencewithmyquestionsandtheenormouslearningcurveinvolvedineducatingahealthcareprofessionalongeologyworkings.IhavecontinuedmystudyoftheseprocessesthroughwebsitesthatthegoodinspectorsreferredmetoaswellasthroughreportssuchastheAugust11,2011SEABShaleGasSubcommittee90dayreportandbetweenwhatIhavelearnedandmyexperiencestodateasastakeholder,Ihaveseveralrecommendationstoputforth:1.Theremustbebetterpublicinformationmadeavailabletoinclude:a.Theupcomingdisclosureofinformationregardingchemicalsusedtomakethewater“slick”forfrackingisagoodfirststepbutIamnervousaboutwaitinguntilnextsummertoknowwhatIhavepotentiallybeenexposedto.Iwouldliketoseethattimelineshortened.b.Informationneedstobereadilyavailableregardingspills—especiallytothoselandowners,residencesandbusinesseswithin5milesofthespillorwhoborderaffectedwaterways.c.Thereshouldbeaccuratepublicaccountingforeachoftheoilcompaniesinagivenoilfieldorplaythatreportsonallincidentsincludingspills,leaks,substitutionsofexpectedchemicalconstituents,issueswithseals,failedinspections,faultyworkmanship,inferiorconcreteworketc.d.Thereshouldbeeasyaccesstopubliceducationsitesthatteachaboutbasicgeologysuchaswhatthelayersingivenregionsconsistofandthedepthofvariouslayersaswellashowfluidstravelthroughthem(directionandrate)sothatinformedinferencescanbemadetoassessriskbythoseofusforwhomgeologyisnotourfieldofexpertise.e.AstheindustrydevelopsBestAvailableTechnology(BAT)standards(Iamshockedthatthisisonlynowbeingdiscussed),thisshouldbepartoftheaboveeducationsiteaswellaspartofwellbywellandcompanybycompanyinformationtrackedandpublicallydisclosed.2.Wemustimmediatelyincreasestaffingattheagencieschargedwithoversightofdrillingandwelloperations.a.Iunderstandthatmuchofwhatneedstobeinspectedintermsofcriticalprocessesoccursatnightandfromallpublishedreportswebarelyhaveenoughinspectorstocoverthedayshift.PolicyforinspectionsneedstoincludecriticalactivitiestoassurethatverticalboresareappropriatelycompletedusingBATandthatallfrackingandcleanupactivitiesrendernorisktotheenvironmentCFette,Page2byfollowingbestpractices.Therearewellover50horizontalwells,another70+verticalwells,andoneinjectiondisposalwellwithinatwo(2)milesofmyfarm;whichmeanswecannotaffordlessthan100%compliance.Iwanteachandeveryoneofthosewellsinspectedwellandregularly.b.Inadditionwellsandgas/water/oiltanks/pipelinesneedtoberandomlyinspectednolessthanannuallytoassurethattherearenoleaksandthatpublicsafetyisadequatelyprotected.Ididnotsignawaymyrighttocleanwaterandtheoilandgasindustrydoesnothavetherighttojeopardizemywater,treesorlivestockevenalittlebit.c.Firsttheplanshouldbewrittentodeterminewhatmonitoringneedstooccurtokeepmyfarmandothersurfaceownerspropertyandhealthsafe—thenfigureoutwhatstaffingneedstooccurforthattobeassuredandhireasmanyqualifiedpersonsasneeded.Itisacostofdoingbusinessiftheywanttobemyneighbor.d.Waterandairqualitymustbemonitored.Currentlythisoccursatthesurfaceland-owner’sexpensewhichisinappropriate.IdidnotcreatethethreattowaterandairqualityandIshouldnotbepayingformonitoring.Oilandgasindustryentitiesshouldsetasideresourcesintoafundtopayformonitoringthatlandownerscanaccessforroutinemonitoringandlabfees.e.Increasedstaffingandmonitoringshouldbefundedwithincreasedfeeschargedtothecompaniesbenefitingfromoilandgasproduction.ftisacostofdoingbusiness.3.Surfacelandownersrightsneedtobeincreasedtoallowussomesayinwhatoccursonourlandandwhere.Itisnolongerpossibletopurchaselandwithmineralrightswhichwasnotonourlistofconcernsbecausewewantedtofarmtheland.Butregardlessofmineralrights,weboughtournearly100acrefarmwithrealmoneyandhavecontinuedtoinvestrealmoneyandsweatintoit.OilcompaniesmayhavemoremoneythanIbuttheydidnotchoosetospendtheirmoneybuyingthatpieceoflandwhenitcameupforsale.Wedidandtherearerightsthatcommonsensedictatesshouldcomewithourhavingmadethatchoicewhentheydidnot.ItisnotOKtobullylandownersanddisregardourhealth,safetyandrighttothepursuitofhappiness.Theycouldhaveboughtthatlandiftheywantedtoruinit.ButIshouldbeabletoprotecttheacreagethatIpaidfor.Thelawmustbechangedtoreflectincreasedrespectforsurfacerights.4.Attendtoairquality:a.TheSEABreportrecommendsdevelopingcapacitytomeasuremethaneandtotrackthereleaseofairpollutantsasaresultofshalegasoperations.CFette,Page3b.Developrequirementsthatexpanduseofproventechnologies/practicestoreduceairemissionsfromallsourcessurroundingoilandgasproductionandtransport.5.Attendtowaterquality:a.TheSEABreportrecommendspublicreportingofthecompositionofwaterstocksandflowthroughoutthefracturingandcleanupprocess.b.Iamconcernedthatweareremovingbillionsofgallonsofwaterfromthewatercycleentirely.ItiseitherpumpedfromtheTrinityAquiferorissurfacewaterwhethertheybuyitfromtheCityofDenton,FTWorthorwherever.Theyputwhatevertoxicsubstancesthattheyaddalongwiththepropellant(tokeepthefracturesopen)thenonceitisusedforfrackingtheyaregenerallydisposingofitindeepinjectionwells(thereisonejusttothenortheastofourfarm)thatgobelowthewatertableintoasaltwaterlayerthattheycall“theocean”thatismeanttonotreturntothewatertable.Attheleast,theyshouldbereusingthedirtywaterthattheyrecovertofrackanotherwellinsteadofpullingmorefromthewatertableandincreasingdeeppressurethatisbeingconsideredasaprimesuspectintheincreasedearthquakeactivityarounddrillingplays.ThereisacompanyinRoanoakeTXwhohasfiguredouthowtoreusefrackingwaterbuttheirprocessisonlybeingusedoutsideofTexasbecauseourregulationsaresolaxandcompaniesdoingbusinessheredonothavetoconsiderwaterconservation.c.Thentherearethelargeevaporationpoolsthattherearedocumentedincidencesofleakagefrom(theyareclearingaspaceacrossFM922frommyfarmthatlooksfrighteninglylikethisistheirintention,butwhoknowsbecausetheytellusNOTHING).d.Forbothairandwaterquality,therehavetobebestpracticesdevelopedandastheyimprove,wellsandequipmentmustberetrofitted.SeetheSEABreportrecommendationsathttp://thehilI.cornjjmagejstories/bIogJçpergy/subcornrnrpt.pdfThissummerIcompletedmydissertationontheuseofstudentstrengthsforsuccessfultransitionfromelementarytomiddleschoolandthisyearhasbeenabusyonebetweenthatworkandmydaytodayworkwithchildreninschools.Iwatchedthispastlegislativesession,largelyfromthesidelines,notingtheeffectsofourbudgetcutsonTexaschildrenandtellingmyselfthatthemostproductivethingthatIcoulddoforthekidsrightnowistosustainmyresearchontheirbehalfandfocusoneachchildinfrontofme.Thisfarmwastobearespiteratherthananothercrusade.MyhusbandandIhopetobuildthehouseonthisfarmthatwelostwhenweweredesperatelytryingtosavethechildthatledmeintochildadvocacy.HisyoungestbrotherwhosestrengthsarealsonotthosetypicaltohiscohortbutareCFette,Page4idealtofarmingisturningwhatwasanovergrazedandvinechoked,neglectedoldfarmwiththebonesofbothcattleandoldtruckschokingitswaterwaysintowelltendedpastureandgracefulfruitandnutgroves.Iwillgrowoldthereassuringthatotherchildrenhavehisopportunitiesandprotectingthegracefuloldoakasanotherlegacy.IamfinewithcoexistingwiththeoilandgasindustrybutIneedyourhelptoassurethatthetreeandIsurvivethem.Sincerely,ClaudetteFette940-367-6937cc:SenatorEstesRepresentativeCrownoverRepresentativeBurgessSenatorCornynDentonRecordChronicleCFette,Page5September

29, 2011 EPA Hearing, Arlington, Texas Proposed

Air Pollution Rules for Natural Gas Drilling Comments

by: Julia Burgen, 2312 Winewood Lane, Arlington,

TX 76013 Thank you very much for this opportunity

to comment

on this major air quality/health issue which personally impacts
me and so many others.

I also spoke
as an advocate

for breathable, healthy
air at EPA hearings

on March

16 and August

2, of 2010. The August one was specifically related

to air issues and the oil and gas industry. Similarly

I have commented

at TCEQ hearings

on air issues June 24, 2010 and July 14,2011. I am

a native Texan

of 7-plus decades, residing

in the Metroplex since 1949.

If you want someone who knows the history

of environmental efforts— you are looking

at one. My history with air issues began

in Dallas.
My earliest clipped cartoon

on air quality

is dated 1971. 1973

is the earliest letter

in my files addressed

to the EPA.

I moved

to Arlington
and by the late 1980’s began attending meetings

at the North Central Texas Council

of Governments

on Air Quality and other environmental issues. That was almost
25 years ago. Why

is it taking
so long
to get breathable, healthy air? The latest hurdle has been thrown

by the gas industry with its emissions virtually unabated.

In fact they were specifically exempted from all the federal environmental

laws for their horizontal fracking

in the 2005 Energy Bill,
in a section commonly known

as the Halliburton Loophole. That marked the beginning

of the recent phenomenal growth

in the gas industry. Yet, as
a Nov.

3, 2009 New York Times editorial said: “But

if hydraulic fracturing

is as safe as the industry says

it is, why should

it fear regulation?”

Or is this all just about turf wars and not public health? I have four gas well complexes within 3/8 to

1 2/3 miles
of my home— with probably 2 dozen

+ wells, plus

a compressor complex

% mile away. Two more gas well complexes

are just

2 miles away. My personal costs for medications

due to asthma are currently $1,827

a year.

I use Singulair, ProAir and Advair. None are generic. Please note that “AIR”

is in each
of these drugs

to help me breathe. That $1,827

is money which

I don’t have
to spend in our local economy— the money ends up in companies

in Kansas

or California.

I’m not even figuring the cost of Dr. visits

in insurance
and co-pays.

If you start quantifying

the costs

to society/citizens- paid by themselves,

or partly through drug plans that they pay for, or partly through donations made

to the many social serviceagencies

to assist those with no insurance
and little income,

or property taxes

to support county public health

— the costs become more than just significant.

It is no wonder that medical services and drugs are

a growth industry. Surely that isn’t the rationale

for allowing
the gas industry

to continue polluting. I fear we are approaching

the same scenario that we have had with the cement kilns ever since they started burning hazardous waste

in 1987. Health issues

in neighboring communities were problems with the burning

of dangerous chemicals.

I too have been downwind

of that problem
for 24 years.

I have attended meetings along with hundreds

of other breathers, written

so many letters, made lots of phone calls over the years

to get relief for North Texans from air pollution,
not just from the cement kilns but from all the other sources.

So now how long will

it take
to get meaningful regulation

of the newest polluter

- gas wells? Another

25 years?

I hope not.

I won’t be here and

I don’t want
to leave

a damaged planet behind

as my legacy. Any business plan has two paramount themes: Maximize profits and minimize costs.

It is imperative under such

a system that there be
a government agency charged with acting

in the interest

of the public

to see that the industries play fair. YOU ARE THE PEOPLE’S ENVIRONMENTAL PROTECTION AGENCY. I am eternally grateful that your agency was created

in December, 1970

— the Year of the First Earth Day. I NEED YOU. WE ALL NEED YOU! Thank you for this hearing. Respectfully submitted, :yJulia Burgen, 2312 Winewood Lane, Arlington,

TX 76013 BA, SMU, 1956, Magna cum laude, Phi Beta Kappa; MS, UTA, Interdisciplinary Studies, 1986, emphasis

on science and education. President

of Arlington Conservation Council, 1993— 1997; Member

of Arlington
City Council, 1997— 2003;
40 year member

of national Sierra Club and Audubon Society; recipient

of three statewide awards and one national award for conservation activities.COMMENTS
FOR THE ENVIRONMENTAL PROTECTION AGENCY ARLINGTON, TEXAS PUBLIC HEARING FOR THE OIL AND GAS SECTOR September

29, 2011 1. Gas Treating Facilities: Sulfur dioxide will be regulated

by 40 CFR Part 60 Subpart
LLL for Facilities with

a sulfur feed rate of at least five long tons per day. What

is the 502 preferred control method?

In Freestone COUfltVf Texas. we have permits
for facilities that burn the hydrogen sulfide via flaring. The resultant sulfur dioxide

is uncontrolled

and not measured. Flaring

of H2S

is not acceptable

for control

of the sulfur. 2. Natural Gas Compressor Stations: Compliance
with New Source Performance Standards, Page 52751, Paragraph
E.2; Title

V permits are not required
for gas compressor stations, only

a permit
by rule

is required

in Texas. However, with

a significant number

of compressor stations in one county, the air emissions allowed can exceed those
of
a large coal fired electric power plant. There are 130 compressor stations

in Freestone County, Texas alone that are allowed

to emit 32,500 tons per year of nitrogen oxides and 3,250 tons per year of sulfur dioxide. How can we address this issue? Maybe

a corporation having enough aggregate facilities

in
a given county that exceed the NSPS standards should
be required

to obtain

a Title

V permit for the aggregate

of facilities 3. NAAQS Compliance:

A county’s NAAQS compliance

is undeterminable without

air monitors. There are few air monitors

in central Texas and most
all areas with less than 100,000 population

do not have an air monitor. Rural towns and counties need protection

of our air quality also. We believe that air monitoring must not depend

on population,

but by existence of major sources

of air pollution

in an area. Air monitoring

is a must
to insure compliance
with the NAAQS. a. In Freestone County,
we have two large coal fired electric power plants, one large gas fired power plant, 130 natural gas compressor stations, several gas treating facilities not to mention numerous industrial facilities having
air emissions.
Just south
of us are two more large coal fired electric power plants with another one approved.
Our county

is classified

as Attainment/Unclassified. Therefore,

the uncontrolled issuance

of air permits continues

for any facility that may want
to locate

in our area. We are in
a continuous battle trying
to protect our air. Air monitors must be installed within
40 miles
of any major source

of air pollution. 4. A major area not addressed

in any EPA rules

is the Noise issue. Noise from gas compressor stations

is causing havoc
all across the country. People are dying, being run out of their homes, suffering body damage such
as brain damage, ruptured
ear drums, and heart damage, restless leg syndrome, vertigo and other symptoms.
This

is named Vibro-Acoustic Disease

by the Portuguese
who have studied this whole body pathology

for 25 years. The EPA delegated authority

to state and local governments

in 1982
as
a cost cutting measure. However, only sixstates have picked
up that authority. Those
of us in the forty four other states are just unprotected.

The EPA must take back its authority under the 1972 Noise Control and Abatement

Act and protect our people. Millions more people will be affected before that happens. Submitted

by: Charles

E. Morgan, P.E., Inactive Executive Director, Citizens
for Environmental Clean-Up (CEC) P.O. Box 1534 Fairfield, Texas 75840 (903)389-5616RetiredEngineerFindsNewDiseaseCausedbyNaturalGasCompressorStationNoise(Ri)AfterbeingtorturedbyintenseLowFrequencyNoise(LFN)forthreedaysthatwasbeingemittedfromalargenaturalgascompressorstation0.9milesfromhishome,CharlesMorgan,P.E.,Inactivehadtogotothehospitalemergencyroom.Whattheyfoundcouldnotbeexplained,braindamageduetoseverelackofbloodflowtothebrain.Why?MorganhadlivedonhiscattlerancheastofDew,Texasfor21yearsinnearperfecthealth.Thencameanaturalgascompressorstationthatgraduallybuiltuptoeleven1,340horsepowercompressorswithnonoiseabatementinstalled.Aseriesofvisitstodoctorspecialistsincludingneurologist,heartandpulmonaryspecialist,foundbrainandheartdamage,buttheycouldnotexplainthecause.MorganbelievedthedamagewascausedbytheLowFrequencyNoise(LFN)andbeganresearchingthisissuetryingtofindtherelationshipbetweenbodydamageandLFN.Morganfollowedupontwomajorsourcesofresearch,CanadaandPortugal.AsubsequentreviewofpaperspresentedbyLisbon,Portugal’sHumanDevelopmentCenterrevealedthatenvironmentalLFNcanindeedcausenumeroussymptomsjustwhilesittinginoneshome.TheLisbonCenternamedthedisease,Vibro-AcousticDisease(VAD).AnotherInternetsource,HealthEffectsofNoise,revealedthebasicrelationshipofLENtobodydamage.TheLFNcausestheadrenalineglandstosecreteadrenalinethroughoutthehumanbody.Theadrenalineinturncausesthebloodvesselstoconstrict(vasoconstriction).FromMorgan’sexperiences,thebody’sextremitiesareusuallyaffectedfirstwithnumbnessinanklesandhands.Thenthegenitalareabeginstohurtandthenthetopofoneshead.Beforeonesheadstartstohurt,theneckveinsusuallyfeelliketheyareburning.Morganhassufferedarupturedeardrumtwiceashavechildrenintheneighborhood.Thehearinglosshasbeensubstantial.Otherneighborshavereportedseveredizziness.Thisisvertigo.Onemannowhasrestlesslegsyndromeandmustwearsockstobedtokeepthesheetsfromwearingtheskinoffhistoesbecausehislegsjerksomuchwhentryingtosleep.TheycouldnotheartheLFN,butcalledMr.Morganaftertheirweirdsymptoms.Hehadpreviouslyrecorded102.5decibelsof25cyclespersecondnoiseatthecouple’sdrivewayusingarentednoisemeter.At70dBAhearingprotectionisrequiredaccordingtoEPArules.OnlyfivepercentofthepopulationcanheartheLENsinceitsfrequency(25to500cps)isbelownormalhumanhearing.Mr.MorganandpersonslivingintheLanelyCommunityfivemileseastofDewarebeingtortureddailybyveryloudLFNintheirhomes.Vasoconstrictioniscausinghighbloodpressureashighas214/113.WhenoutoftheLFN,Mr.Morgan’sbloodpressureisaround127/70.WhatcanbedoneabouttheVADandwhatcanbedoneaboutthecause?AsfortheVAD,takeanti-adrenalinetabletsandgetoutoftheLFNifpossible.SincetheLFN:;...4.........L..+;.i..L.a-....-..—.-.,-LIdVCIliveLUCIlILIIiiIe,ILUCJtlIUUIIIIUWiiidIL..UIiipiCUILdLIUIlcitiiiciL.UUIILdLUhowfaronemusttraveltogetoutofitsrangeofinfluence.InMr.Morgan’ssituation,thereare130compressorstationsthroughoutFreestoneCounty,Texas.OnemustleavethecountytotrytogetoutoftheLFN.InTexas,thereissomuchnaturalgasproductionthatfewcountiesaresafe.Mr.Morganhastraveled150milessouthpastHoustontoFriendswood,easttoNacogdoches(twohoursdrivefromhishome),northtoDallasandwesttoWaco.TheLFNwasstillpresent.Adjacentstateshavesimilarnaturalgasdevelopment.Hehasreceivede-mails,L..;4v-...I,••,I..,.,I,1,..iivflit.S.I,iiiO,VCILCrnrtnii\iiIciiliddiIUidtVVIUII\IIILdIiiiiVVIIcILL.diIUtUVIeLUalleviatethesituation.Thisisanationalissue.Thereisafederallawconcerningnoise,the1972NoiseControlandAbatementActthatisstillineffect.TheEPAwastaskedtodevelopguidelinesfornoiselimits.LowFrequencyNoisewas.,..#-I..,..-.,..1...-...;..ICV7Ai..1flo+1..,..EflAIIULpti..Ilii..ciIIyIIUUIttU.I.JIIlyciUIItJdCUIUtIIlItVVcI.1iUUUL.tUIII.LJIt.Ill.LOL,LiltL?inoisecontrolofficewasclosedandauthoritytoregulatenoisewasdelegatedtostateandlocalgovernments.Thelocallevelwillnotdoanythingwithoutastatelaw.Onlysixstatesoutof50haveastatelawonnoisecontrol.TheyareCalifornia,Illinois,NewYork,Maine,MassachusettsandjustrecentlyColorado.Apersoncaninitiatealegalsuiteinfederaldistrictcourtatacostofabout$50,000.Mr.Morganhascontactedandprovideddatato26largelawfirmswhowillnottakehiscaseonacontingencybasis.Theystatethattoomuchmoneyisrequiredupfrontorstatutesoflimitationsareaquestion.Nooneenforcesthefederallawandfewstateshavenoiselaws,somostofusarejustoutofluckandmustputupwiththetortureandwillprobablydieanearlydeath.••inecompressorstationcanoeixeuwanatemenoise.riowever,tnegaspruouctioncompaniesdonotwanttospendadime.Theymustbeforcedtocleanuptheirproblem.Meanwhile,ourchildrenarefacedwithlearningandreadingproblemsduetolackofconcentration,hearingloss,bodydamageandevendeath.NumerouschildrenhavediedofheartattacksinFt.Worth,Texasbutnooneknowswhy.Channel8NEWSinFt.WorthinterviewedadoctorthereinDecember2008.Hestatedtheyweredoingelectro-cardiogramsonareachildren.Thisisthewrongtoolandwillnotdetecttheproblem.Anecho-cardiogramisrequiredandadoctorwhoknowswhattolookfor.Asstatedabove,theyarescarce.Recently,twopersonsdiedofbrainaneurismsandathird,ayounglady,almostdiedoftwobrainaneurisms.TheyalllivedinFreestoneCounty,Texas.Mr.MorganwrotelettersconcerningtheLFNissuetohisfederallegislatorsandeveryTexaslegislatoraswellasPresidentObama.HemetwithEPA’srecentlyappointedRegion6A;+..-.#...ri..AlA---.II1.l...,-?iUItIlIIlLIdLUI,U.lui’.iIllellucliIL.l’IUIlClJIIUILilLUIiIlII.Weneedyourhelpbywritinglettersinsuchquantitythattheymustact.WeneedtoinundatetheWhiteHouseandourlegislators’officeswithlettersaskingthattheEPAbecomereinvolvedbytakingbackthedelegatedauthorityinthosestateswithoutnoiselawsorhavether..J...Ic...........n.-....Ii-..-..Ircori.-.l.,..-..+L......:#...........I:......I.....i.I.;-i-.-.#,reueiciiciieiyneulaLuIyLUIIIIIIIIUIIrLiw...)LdledULlIUIILUVCIICUldLIUllUIUJULIIIIILldLdLCnaturalgasfacilitiesaswellasinterstategasfacilities.TheFERCregulatesonlyinterstategasfacilitiesatpresent.WecanexpectcatastrophicdamagetoanddeathsofourcitizensandnoonewillknowthecauseduetoignoranceoftheLFNproblem.PresidentObama’saddress:PresidentBarackH.Obama,UnitedStatesofAmericaTheWhiteHouse1600PennsylvaniaAvenueNWWashington,DistrictofColumbia20500Best4egarJs,-.c_!(-L.CharlesE.Morgan,P.E.,InactiveMajor,USAF,RetiredExecutiveDirector,CitizensforEnvironmentalClean—Up(CEC)e-mail:cemorgan75831@yahoo.com

# 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.govSome symptoms of Vibro-Acoustic Disease (VAD), due to exposure to Low Frequency Noise include: head hurting, numbness in fingers and toes, back pain deep inside the back, enlarged aorta of the heart, brain damage, fibrosis of the lungs, sharp pain n various parts of the body, restless leg syndrome, incontinence (regardless of age). ruptured ear drums, ear ringing, nervousness & nausea. The LFN causes adrenaline to be released that in turn causes blood veins to constrict, thus causing most of the above symptoms. More symptoms of this disease are, (but not limited

to), mood swings, indigestion & heartburn, mouth/throat infections & bronchitis. In later stages, the individual tends to recognize the existence of memoiy lapses. Neurological disorders include epilepsy, balance disorders and a marked increase in cognitive impairment.

Studies show only about 5 percent of people can actually hear the LFN, but it still causes bodily damage. Since the LFN can travel at least 5 miles (in all directions) from these 130 compressor stations in Freestone County, more people than ever before are being exposed to the dangers of the LFN. We and our children deserve a safe,

Low Frequency Noise free environment.

Most industrialized countries of the world, such as the United Kingdom, Canada, The Netherlands, Australia, Japan, New Zealand, Germany, France and many others, recognize the effects of Low Frequency Noise. Most have rules governing LFN to control its effect on people.

The EPA developed some noise rules, but did not include LFN controls. Authority given EPA by the 1972 Noise Control Act has been delegated by the EPA to state & local governments. However, only six states have implemented their own laws and rules based on the EPA guidelines. Texas did not! We Texans are in dire need of a state law on noise control, especially LFN. People all over central and north Texas where gas drilling and compressor stations exist are exposed to this new danger to our health. You can write Senator Steven Ogden at Capitol Building, P.O. Box 12068, Capitol St., Austin, Texas 78711-2068 and/or Congressman Byron Cook at Capitol Building, P.O. Box 2910, Austin, Texas 78768 -2910 and attach this document. This document is provided by Citizens for Environmental Clean - Up (CEC), P.O. Box 1534, Fairfield, Texas 75840. Please help us spread the word about this insidious disease. All donations are appreciated & may be mailed to the above address with checks made out to CEC. Charles E. Morgan, P.E., Inactive, Executive Director Citizens for Environmental Clean-Up (CEC)

VAD Vibroacoustic Disease ibroacoustic Disease (VAD) Low Frequency Noise (LFN) A

Is caused by It Lc a whole-body noise-induced pathology, that is not particularly related to the ear.

# I’’ibro—.’I eous’tic 

# Disease (F ID) is a

i 

# i’Ii ole—body I)(11h o/ogr cu u.s ed hr
e.VeL’ssi) ‘e 

# expos tire to L o,i’ 

# Freq ueii c .‘s’oise (LFN).

Vibro-Acoustic Disease (VAD) is a whole-body pathology caused by excessive exposure to Low Frequency Noise (LFN).

It was initially identified among aeronautical technicians. VAD has also been observed in military and commercial pilots and aircrew. Now millions of people world wide are suffering from VAD.

Noises with a dominant content of frequencies in the range of 20 to 500 hertz (Hz) (low frequency noise) are emitted by a large range of sources in our society.

With the natural gas drilling boom in Texas

we have an ever increasing source of low frequency noise from GAS COMPRESSORS 

# STAT! \ ‘. 

# There are 130 such stations in Freestone County that are causing this insidious VAD. This disease has been studied and recognized in other countries

more than the U.S.. Very few doctors in the U.S. are knowledgeable about it.. When driving around on the country roads, you might notice the large structures that have large fans on the ends. You can hear the low pitch, but loud and annoying hum of these stations.

Many of these large Compressor Stations are built on property set back off the road, so people

can not see them. However, the LFN can travel
at least five miles from the stations in all directions and penetrates all structures. People can get VAD by just being in their homes.

Not everyone can hear the LFN at their residence. One member of a household may hear it and another may not. The noise has its affect on all persons, only to varying degrees. The ill health affects can be immediate, but

can also accumulate with time, depending on the person and the intensity of the noise. The longer one is exposed, the more damage it can cause.
Many people have health problems and dont realize they are due to this exposure. Some people are more susceptible to have problems than others. Pregnant women and children are especially susceptible. Learning ability in children is affected. Some local children, who live near a compressor station, are having headaches and others ruptured ear drums. One local lady suffered vertigo for two weeks so bad she could not get out of bed and stand up.

One gentleman in Freestone County has a host of severe health problems due to the compressor station 0.9 miles of his property after living here for 21 years in near perfect health: heart damage, brain damage, constriction of blood vessels, ruptured ear drum (twice) and now permanent hearing loss. When his head hurts too much, he is regularly forced to leave his home in an effort to escape the ill effects of the LFN. When he gets out of range of the LFN, about five miles, his head stops hurting and burning blood vessels ceases. He has been diagnosed with VAD. IJ



# Photo of a gas compressor station. (Some are larger.)LEAGUE

OF WOMEN VOTERS OF TEXAS September

29, 2011 Attention Docket
ID No. EPA-HQ-OAR-2010-0505 1200 Pennsylvania Avenue, N.W. Washington
D.C. 20503 Comments

of the League
of Women Voters
of Texas On New Source Performance Standards
and National Emissions Standards

for Hazardous

Air Pollutants Reviews For the Oil and Natural Gas Sector The League
of Women Voters
of Texas (LWV TX) applauds
the Environmental Protection Agency (EPA) for proposing national

air emission standards

for the oil and natural gas industry. We are particularly gratified that these proposed standards cover the process
of recovering natural gas through hydraulic fracturing, commonly known

as fracking. These proposed regulations

are in conformance
with LWVUS’s support for strengthening federal regulation

of gas drilling

in a manner consistent with the preservation

of a healthy environment. Obviously, the oil and gas industry has

a huge economic
and environmental impact
on Texas, and we are pleased that the EPA chose Texas

as the site of one of the three hearings

on these proposals. The standards listed below are especially important

to the League
of Women Voters
of Texas. We strongly endorse their adoption: • Source performance standards

for volatile organic compounds (VOC5), which would cut VOCs by nearly one-fourth across the oil and gas industry, including

a nearly
95 per cent reduction

in VOCs emitted from new and modified hydraulically fractured
gas wells. The process

to meet the new standard captures natural gas, thus saving the industry nearly $30 million annually. • Source performance standards

for sulfur dioxide. • Air toxics standards

for oil and natural gas production, which includes reducing

air toxics from all large dehydrators

by 95 per cent and requiring crude oil and condensate tanks

at major sources

to control

95 percent
of their air toxics emissions. • Air toxics standards

for natural gas transmission

and storage that are estimated

to reduce the maximum
risk level for cancer from 90 per million

to 20 per million. • Elimination

of exceptions

for startup, shutdown,
and malfunction events since many of the highest levels of hazardous emissions occur

at these times.These rules are important

for health and environmental quality

in the 16-county Barnett Shale region
of Texas and the over

3 million people who inhabit this region.
As gas drilling moves into Dallas County,
the population impacted

by gas drilling will increase

by nearly 2.4 million. The City of Fort Worth’s Air Quality Study, dated July 13, 2011, recommended

that “all reasonable precautions

to reduce emissions from the well pads and compressor stations should
be made. This

is particularly important

for tanks and line compressor engines, because these two sources accounted

for the greatest portion

of the risks observed
for the pollutants selected
for further evaluation.” These proposed regulations
will reduce toxic air emissions, provided
the regulations

are adequately enforced. Thank you,

,?L’A ) /-Karen Nicholson, President - League
of Women Voters
of Texas 1212 Guadalupe

St.. Suite 107

* Austin, Texas 78701

* 512-472-1100

* 512- 472-4144

fax

* lwvtexasal%’,texa5.

ore

* wwwlwvtexas.ora 10 ‘0 co o cif— 0 °ai 0 I <OtCN d

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1 v’ C 2

3 cj d ç\J > z)THE AMERICAN

OIL &GAS REP@fER The “Better Business” Publication Serving
the Exploration

/ Drilling

/ Production Industry Data Confirm Safety
Of Well Fracturing By Kevin Fisher HOUSTON—North American

oil and gas companies

and energy services providers

are following with

a keen and vested interest
the news coming
out of Washington regarding

the “Frac Act,”

a congressional proposal

to amend the Safe Drinking Water Act
to remove

a 2005 Energy Policy Act exemption

on hydraulic fracturing
and effectively
give the U.S. Environmental Protection Agency
the au thority

to regulate fracturing operations. A year or two ago, no one outside

of the upstream

oil and gas industry even knew what

a hydraulic fracture was. FIGURE

1

Today, senators, congressmen

and jour nalists arc discussing fracturing

as if they were career frac engineers. A number

of key questions

are central to the debate over the Frac Act.
Ts there

a cleaner fossil fuel available than natural gas?

Is natural gas abundant

in North America
and many other parts
of the world? Has the growth

of unconventional gas in the past decade, primarily ftom shale, materially added

to the recoverable gas (and sometimes

oil) reserves

in North America, eliminating

the need for natural gas imports? Does this improve our energy security? Does incremental production create new sources

of tax revenues
and local jobs?

Is there

a more impacting service

in low-pcnncahility reservoirs than hydraulic fracturing? Does hydraulic fracturing imperil groundwater supply? Whoa, let’s park the pump trucks here for

a moment. On March
17, 1949,

a team comprised of Stanolind

Oil Company
and Halliburton personnel converged

on

a well about

12 miles east of Duncan, Ok.,
to perform the first commercial application

of hy draulic fracturing. Later the same day, Hallihurton fractured another well near Holliday,

Tx. The technique
had been developed
and patented

by Stanolind
and an exclusive license was issued

to HalBarnett Shale Mapped Fracture Treatments (TVD) Reproduced

for Halliburton Pinnacle with permission from The American

Oil
& Gas Reporter ±

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# 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.govEndofEntranceRoadCarlDimon97226418489t79It79L6UOW!QIJBD‘-3UEne-o&9anGe-Road S C

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A 3H 15,2011 Carl

A

• Jan (—) Carl Dimon 972 264 1848tndr:ffah.CocI)“.3.’-‘3rn5Cs’“30CarlDimon9722641848Comments

by the Oklahoma Independent Petroleum Association EPA’s Oil and Gas NSPS/NESIIAP Proposed Rule Public Meeting— Arlington, Texas September

29, 2011 My name

is Angie Burckhalter.

I represent

the Oklahoma Independent Petroleum Association (OIPA). OIPA has approximately 2,100 small
to large independent crude oil and natural gas producers
that operate

in Oklahoma
that will he significantly impacted

by EPA’s
oil and gas NSPS and NESIIAP rule. • Nationwide, independent

oil and gas operators drill approximately

95 percent

of the oil and gas wells

in the U.S., and produce

85 percent

of U.S. natural gas and 56 percent

of U.S. crude oil. • We appreciate

the opportunity

to provide input into EPA’s proposed

oil and gas NSPS and NESHAP rules, and we submit the following comments

for your consideration. • Many
oil and gas operators

in Oklahoma

are small businesses (similar

to small family farms). These small independent

oil and gas companies

are ill-equipped

to bear the costly burdens

of more and more air requirements.
Over the past

3 years, EPA alone has come out with significant rules that impact our members.
For example, EPA’s engine rules i.e. Part 60 Subpart J.TJJ, Part 63 Subpart ZZZZ, and the GHG Reporting Rule, Subparts

C and W. • Many small operators/businesses

of production facilities have limited staff. Forty-six percent

of OIPA’s members have less than
19 employees. Their tolerance

for more complex and costly regulations

is significantly different,
and significantly
less,
as compared

to larger companies. These truly are small businesses
that are struggling

to stay in business. • Oil and gas facilities vary significantly across the country.
For example. there are drastic differences

in the characteristics

of the fluids and gases produced,

the volumes initially produced,

the production volume drop-off rates, the economics

of each well, the locations

of wells (most are typically located

in rural areas- miles from cities and towns),
the availability

of infrastructure,

the availability

of consultants

and equipment

to support compliance efforts, and other like issues. The proposed regulation does not provide
the tiexibility
that the different

oil and gas sectors and facilities need nor does

it address costly and burdensome issues for small business.• For example, EPA proposes

an overwhelming

and unnecessary amount

of information

to be submitted such
as initial and subsequent notices, monitoring

and testing data, recordkeeping

and various reports. These types of requirements

will be onerous
for large companies,

but especially on the smaller companies. Most small companies don’t have an Environmental, 1Iealth and Safety data management systems

in place
or the staff
to address these issues. EPA proposes

to reduce the burden
by the use of an electronic database and/or third-party compliance verification. Instead,
we request EPA re-evaluate

the need for this information, greatly simplify and streamline

the various notices. recordkeeping, monitoring, annual reports, and other various submittals,

and utilize

a general duty clause that would allow operators

of production
sites
to keep records without
the data submittals.

If EPA
or the states want
to check compliance
they can with

a site inspection

or
a specific data request. • Another area problematic

for small operators would
be the compliance deadlines. Small businesses/operators

won’t
be able
to meet the immediate Federal Register publication compliance date. They need time
to fully understand

the final rule, determine applicability

to their operations, program funding. train staff or hire consultants, establish procedures

and protocols

to comply, and purchase/rent control equipment.
Our members

are greatly concerned with access

to available consultants

and control equipment

as they will have
to compete with larger companies. Once the proposed rule
is final, the demand
for these resources
and equipment
will be great, the supply will be low, and the costs will quickly increase which will negatively impact

all operators, especially

the smaller ones. We request

an

I 8-month delay

to comply with the requirements applicable

to production sites. • EPA’s NESHAP requirements
have become

so technical that only

a person with significant knowledge

and experience with those rules are able to evaluate and understand them. Even the most sophisticated

air person struggles with the MACT requirements.

We are very concerned that most small businesses
that operate production facilities will struggle

to comply with the storage tank and dehydrator requirements which will lead
to costly violations.

We request EPA streamline
and simplify those requirements. • EPA proposes

to reduce the compliance burden

to industry, state and local governments

by proposing

to exempt certain sources from Title

V permitting requirements

that would
be triggered

by the proposed rule; however, EPA does not consider limiting minor source permits. Again the impacts

on smaller operators will be costly and burdensome,

not to mention
the

2requirements

on state air agency stall
to manage
the notices. monitoring data. reports, test data. and other various submittals proposed

in the rule. We request EPA address this issue. •
It is imperative
that EPA develop simplified, usable applicability

and compliance tools, fact sheets. tables, flow diagrams,
and other similar information

for the final NSPS

& NESHAP
rule that will help small oil and gas businesses
that operate production
sites easily determine applicability, know what data
to collect and report, easy understandable methodologies

to calculate emissions,
and the identification

of specific compliant control technologies

to be able to comply with the requirements.

In addition, EPA should conduct specific outreach and education efforts that walk small oil and gas operators through
the rule and how
to comply. • Finally,
we request

a 60-day extension

to the comment period

to allow smaller operators more time
to review, evaluate,
and comment

on EPA’s proposed requirements. • We appreciate

the opportunity

to provide input into the rulemaking process. Thank you.

3

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--4--Environmental Protection Agency Oil and Natural Gas Air Pollution Standards Public Meeting Arlington, Texas September

29, 2011 Comments from Larry Kitchens First, thank you for giving me the opportunity

to come before you today

to address this very important topic. And, second, thank for your time today and your willingness

to listen
to all of us and for what has to be

a very long day. For the sake of brevity and to, hopefully, avoid repetition

of comments made
by previous speakers, both for and against these new regulations,

I will offer only some general observations

and comments

as

a concerned citizen
on this issue. I have taken the time to read the basic information provided

by the EPA on its proposed suite of regulations
that would reduce the harmful

air pollution from oil and natural gas industry, while allowing continued, responsible growth

in U.S. oil and natural gas production.

The proposed updated rules,

as

I read them, would rely on proven technologies

and best practices that are in use today
to reduce emissions

of smog-forming volatile organic compounds
into our air. While

I am not

a scientist

or even an expert

in the oil and gas industry

I am concerned

on two levels about the quality

of the air that we breathe here
in the Dallas-Ft. Worth Metroplex
and why

I am supporting

the proposed EPA Oil and Natural Gas Pollution Standards

as proposed. One of my professional responsibilities,

and privilege,

is to serve
as
a council member

on the Hurst City Council, Place

2 for the past ten years.

In that capacity

it is my duty to become informed

on issues that come before our council for consideration. Obviously with the recent development

gas exploration

and production

in the Barnett Shale area this

is an issue

in which we have spent much time

in consideration. Consideration

of the economic benefits and the rights
of land owners

to have reasonable access

to their mineral rights and rights
of those who live in the immediate area of gas wells
to be protected from harmful pollutants. Recently our city council updated our city ordinance

as it relates

to gas drilling operations

in our city by strengthening

our testing requirements. These changes were reflective

of proven industry standards and of similar actions being taken
by other councils

on this issue. While

I am not speaking
for our council today,

I think

it safe to state that our council strongly believes that testing

is important

to the environment

and in the protection

of our citizens and

is allowed under state and federal law— and

is the right thing
to do. The best proof that

a company

is not harming the environment

is regular and systematic testing for pollutants

in the air, water and soil. We feel our testing requirements

are responsible

and reasonable

in meeting our obligations

to protect our citizens and at the same time provide companies
who wish to engage

in gas drilling

in neighborhoods

a way to reasonably accomplish their goal. This seems

to be the goal of the proposed

Oil and Natural Gas Pollution Standards.Second,

as
a citizen who lives within the footprint

of the Barnett Shale

I am personally concerned about the quality

of our air in the Dallas-Ft. Worth area. This

is not to say that the oil and gas industry

is the sole contributor

to the pollution problems

in our area but
it is clear that the industry

is one of the largest industrial sources

of emissions

of volatile organic compounds (VOC5),

a group
of chemicals that contribute

to the formation

of ground-level ozone (smog). Exposure

to ozone

is linked

to

a wide range of health effects, including aggravated asthma, increased emergency room visits and hospital admissions and premature death. This means increased costs

in health cared an issue not to be taken lightly. On

a more personal note,

it is an issue that directly touches
my family. My wife suffers from asthma. On Orange pollution days

it is not safe for her to venture outside. Her doctor has even suggested that one way to avoid the asthma attacks

is to move away from the Dallas-Ft. Worth area.

ln fact, when we go to our cabin on Lake Whitney which

is only 85 miles south
of here, within
an hour of arriving she

is able to breathe better and she can feel the relief of pressure

on her lungs when she tries to breath. My goal, my hope,

is that the EPA will stay the course with these proposed changes.

I am very much aware
of the pressures being made
by the oil and gas industry,

by lobbyists
for the industry, and by politicians who express fear this will be too expensive
and cost jobs.

In fact

it probably
will create more jobs and provide

a better environment

for all of us.

I would submit

to you that

it is in the best interests of all of us— the oil and gas industry and those who live in areas
of oil and gas production— that we protect the quality

of our air and ensure

a place safe to raise our families and

a place for our children’s children

to raise their families. I am not opposed

to oil and gas exploration

and drilling.

I would love to enjoy the economic benefits

of a monthly check from

a gas company. What

I am in favor of is a reasonable
and responsible
way of ensuring our future

in energy and at the same time

a safe place
to live to enjoy those benefits.

It is my belief that the proposed regulations proposed

by the EPA move
us in that direction.

I encourage

the EPA and our political leaders

to do the right thing and to stay the course

in protecting
our environment. Recently,

a top executive

of one of the companies involved

in the gas operations

in the Barnett Shale made

a statement

at
a conference
that critics
of shale drilling are fear mongering extremists who want Americans

to live in
a world where”
it’s cold, it’s dark, and we’re
all hungry.” May

I suggest that

if we have all the energy

in the world

at our disposal and live in an uninhabitable
place— we will find ourselves

in
a place that’s ‘cold, dark, and we will all be hungry.’ Thank you for your attention today and for what you are doing for all of us. Contact Information: Larry Kitchens 917 Henson Drive Hurst, Texas 76053 (817) 284-6353

H (817) 257-6123

0 (187) 308-6667

CTEXASHOUSEOFREPRESENTATIVESCAPITOLOFFICE:DISTRICTOFFICE:P.O.BOX29101067W.MAGNOLIA,SUITECAUSTIN,TEXAS78768-2910FORTWORTH,TEXAS76104512-463-0740817-924-1997EMAIL:LON.BURNAM@HOUSE.STATE.TX.USL0NBuRNAMDISTRICT90•FORTWORTHSeptember29,2011Rep.BurnamApplaudsEPA’sProposedRulestoReduceEmissionsfromOilandGasOperationsRecommendstherulesbestrengthenedandapplytoexistingfacilities(Arlington,Texas)—IapplaudtheEPAforproposingthesecommonsenserulestoreducedangerousemissionsfromproliferatingoilandgasfacilitiesaroundthecountry.TheselongoverdueimprovementstotheNewSourcePerformanceStandardswilldowhattheTexasLegislatureandstateagenciesthatoverseeoilandgasproductionhavefailedtodo:protectpublichealthbyplacingreasonablelimitsonairpollutionthatwillbothreduceemissionsandincreaseindustryrevenues.BelowaremycommentsregardingfourcomponentsoftherulethatwillhavethegreatestimpactonpublichealthinFortWorth.GreenCompletionsWhilegreencompletionsarealreadyrequiredunderFortWorth’sGasDrillingOrdinance,thisrulewillextendtherequirementtotheun-incorporatedareasandtothemunicipalitiesaroundtheBarnettShalelackingsucharequirement.RequiringgreencompletionstoincludeallgaswellsintheBamettShalewillsignificantlyreduceemissionsintheD-FWnon-attainmentarea.Irecommendthat:•regardlessofcommentsprovidedbyindustry,thegreencompletionrequirementnotbelimitedtoapplyonlytogaswellswithacertainVOCcontent,butrathertoallhydraulicallyfracturedwellcompletions;•withincreasingproductionofoilfromtheBarnettandothershaleformationsinTexas,therequirementbeextendedtoincludenewandexistingoilwellsthatco-producegas,insteadofonlyapplyingtogaswells.PneumaticControlDevicesRequiringthatneworreplacedpneumaticdevicesbe“no-bleed”or“low-bleed”isanimportantstep,buttheimprovedruleswouldhavenoimpactontheemissionsfromthethousandsofvalvesalreadyinoperationaroundtheBarnettShale.Committees:EnvironmentalRegulation--PublicSafetyIrecommendthattherequirementbeextendedtoapplytoallexistingpneumaticdevices,andnotjusttoneworreplacedones.gcJnLc<c(Ui1fingvaporrecoveryforhighpollutingoilandcondensatestoragetanksislongoverdueintheRarncttShale.StoragetanksarethesinglelargestsourceofVOCemissionsintheBarnettShale(57°/bo1otalVOCemissionsfromoilandgasproduction)andalmostone-thirdofsmogforming(NOxplus\/OC)emissions.ThethresholdatwhichrecoverywouldberequiredundertherulemirrorsexistingrequirementsinColoradoandWyoming.Asoflastyear,therewerealmost5,000oilandcondensatestoragetanksintheBarnettShaleandalmost15,000producedwaterstoragetanks.Withsomanypollutingtanksalreadyinexistence.IrCcOiTllflCfldthatthevaporrecoveryrequirementbeexpandedtoinclude:•producedwatertanks,inadditiontooilandcondensatetanks,and•existingoil,condensate,andproducedwaterstoragetanks,asopposedtojustnewtanks.LeakDetectionatGasProcessingPlants‘[heproposedrulesstrengthentheleakdetectionandrepairstandard(LDAR)byloweringthedetectionthresholdfrom10,000partspermillion(ppm)to500ppm.IstronglysupportthisprOViSion.Irecommend,though,thatthenewLDARrequirementbeextendedtoapplytoolder,existingprocessingplantsaswellastonewplants.Insummary,theproposedrulesareanextremelyimportantstepfonvard,andtheEP.4istoberoivnie;ided/orthesesignificantimprovementsthatwillprotectpublichealth.IencouragetheEPAtostrengthentherulesandimproveconsistencyaroundthecountrybyextendingthe:mad5rdstoesistingfacilitiesaswellasnewones.IftheEPAoptsnottoextendtherulestoallexistingfmcilitics,itcouldextendtherequirementstoexistingfacilitiesinareasthatareinoriearozonenon-attainment.Committees:Environrnen[aIRegulation——[‘ubikSafety815 Brazos, Suite 600 Austin, Texas 78701 www.EnvironmentTexas.org (512) 479-0388 Good morning,
my name

is Luke Metzger and

I am the Director

of Environment Texas,

a statewide, citizen-funded advocate
for clean air, clean water and open spaces. Today’s hearing

is especially timely. The DFW

is suffering from another orange ozone health warning, where electronic billboards

on the highways advise
us to limit our outdoor activities. Incredibly, those warnings

are all too common here and around Texas. Last year, there were 48 days when

at least part of Texas experienced smog levels exceeding

the national health standard. Children,

the elderly, and people with respiratory illnesses suffer the most on these days. Children who grow up in smoggy areas may develop diminished lung capacity, putting them

at greater risk of lung disease later
in life. And children exposed

to smog
in the womb can experience lower birth weight and growth retardation. Even for healthy adults, repeated exposure

to smog pollution damages lung tissues, decreases

the ability

to breathe, exacerbates chronic diseases like asthma, and can even cause premature death. Texas also recently finished
the hottest June-August summer

in recorded U.S. history, which the Texas State Climatologist— an appointee

of Gov. Perry, mind you— has attributed

in part to global warming pollution.

In addition,
our drought

- the worst oneyear dry spell
in recorded history— and the recent wildfires— also the worst

in Texas history— are consistent with scientific predictions about global warming. Texans deserve clean air. But on far too many days, children and seniors here
in Arlington
and across Texas are exposed

to dangerous smog and toxic air pollution
and are suffering
the impacts

of global warming.
For the sake of our children,

we must make every day

a safe day to breathe. I am here today

to commend EPA for taking steps
to reduce
air pollution coming from oil and gas drilling, which according

to the TCEQ, will soon surpass the emissions

of all the cars and trucks

in the DFW area.North Texas’ recent
oil and gas boom has made

it the leading shale gas-producing

gas area in the country, raising the number

of drilling permits issued

in the Barnett shale from 36 in 1993
to 4,145

in 2008. The Barnett shale now has over 15,000 wells. 1 Hydraulic fracturing
has also exponentially expanded drilling permits

in the Midland-Odessa

area and south Texas’ Eagle Ford region. This growth has put our citizens

at a serious health risk. Oil and gas wells, processing plants, compressor stations, pipelines
and storage tanks leak about 2.2 million tons of smog-causing
gases annually,

as well
as greenhouse gases such
as methane,
and countless toxic and carcinogenic gases like benzene.
All have serious effects
on the health
of Texans and their environment. 2 Natural gas and oil operations

in the Barnett Shale counties alone produce

as more harmful
gas emissions

as all of the cars, trucks and airplanes

in the DFW metro area, over 103 tons per day. 3 This massive

air contamination

has tangibly affected North Texans

in recent years.

A study of Dish, Texas

in Southern Denton County found that 61 % of its citizens suffered from health problems ranging from dizziness
and nasal irritation

to brain disorders, severe nervous system problems,
and cancerous lesions that the study linked to 16 harmful chemicals produced

by local oil and gas facilities. The chemicals were all found

in the communities’

air in unsafe levels,

as well
as urine and blood samples. A similar slew of health problems have been seen
in nearby Argyle and Bentonville. In these communities,

7 harmful gasses were found

in ambient
air before the oil and gas boom. Recent tests
at their high school’s band practice

lot found
65 of the 84 air contaminants tested for by the EPA. The rise in air pollution was accompanied

by health problems among schoolchildren, including severe asthma, dizzy spells, and chest pain. 4 Furthermore,

a study from The City of Fort Worth reported this year that metro-area

oil and gas exploration produces over 20,000 tons of gases annually, including dozens
of harmful pollutants, often due to faulty equipment such
as open hatch tops and corroded tanks. The study also found highly toxic henzene

in 94% of air samples. 5 Meanwhile, Texas-based

oil companies
that participate

in hydraulic fracturing

are among Fortune 500’s top earners, raking

in billions

of dollars
of profit per year
to shareholders, while leaking toxic and polluting chemicals
into Texas’ air. Company profits should
be based on hard work and smart management,

not irresponsible policies that put citizens and the environment

in peril. The oil and gas companies

are making

a killing with all this drilling. They can certainly afford

to install pollution controls. We Texans have
to pay to get emissions inspections

for our cars and pay to repair them
if they pollute. It’s only fair that the oil and gas industry

do their part to help reduce
air pollution. 1 http: //www.rrc.state.tx.us/barnettshale/drillingpermitsissuedl993-20

10.pdf 2 http://www.epa.gov/airquality/oilandgas/basic.html http://www.edf.org/sites/default/files/923 5_Barnett_Shale_Report.pdf 4 http ://www.earthworksaction.org/FLOWBACK-TXOGAP-HealthReport-lowres.pdf http://www.scribd.com/doc/600463 62/Air-Quality-Study-Finalt The new EPA rules are commendable.
They provide long-awaited standards that both increase profits

to the private sector by recovering
tons of lost natural gas, while reducing smog-forming pollutants

by 25%, cutting methane emissions

by 26%, and decreasing

air toxics
by nearly 30%. However,

the proposed rules can be improved.
For example,
the rules do not include

a standard
for emissions from liquids unloading activities, includes loopholes

for older compressors

and storage tanks, and does not hold up to the strict standards

of some states, such
as Wyoming. 6 These new standards represent

a significant
step in reducing

air pollutants from the oil gas industry,

a strong involvement

of the EPA
to create meaningful, broad regulations, and

a tangible reduction

of harmful

air pollutants. They show that environmental

and public health laws can also be cost-beneficial

for the private sector, and should
be used
as a standard
for even more stringent policies that significantly

cut air and water pollutants that put our health and environment

at risk. 6 Environmental Protection Agency: “EPA’s Proposed
Air Pollution Standards

for the Oil and Natural Gas Sector”. Preliminary Analysis. September 2011Good morning.

I’m Mike O’Connor with XTO,

a wholly owned subsidiary

of ExxonMobil Corporation.

I am appearing today on behalf

of the American Petroleum Institute.

I appreciate having the opportunity

to appear

at this hearing

on proposed regulation

of emissions associated
with the oil and natural gas industry. The proposed rules have

a very broad reach. My focus

is on those parts specifically directed

at emissions related to oil and gas development,

and especially operations employing hydraulic fracturing. This focus

is important because hydraulic fracturing operations

are critical

to U.S. energy development. Without this technology

— or without the ability

to employ

it cost- effectively

— natural gas and oil development could be discouraged, delayed

or reduced. Oil and gas are

a vital part of our nation’s energy landscape today and are expected

to continue

to be in our future. The EIA energy projections show that oil and natural gas are expected

to supply most
of our nation’s energy for decades. Unfortunately, unless properly crafted, these rules could hamper our ability

to supply the oil and natural gas that we know will be needed. And making the rules work could be difficult. The comment period for these extensive, detailed rules

is too short. Controls would be imposed

on the industry with inadequate
lead time. This would make

it difficult for operators

to prepare

to implement

the controls and would increase
the risk of unintended consequences. In the worst case, the result could be requirements

that would hinder hurt job creation, federal and state revenue generation,
and harm our nation’s energy future. We have prodigious reserves

of oil and natural gas here

in the United States.
Oil will continue

to be vital for supplying transportation fuels. And there are large and growing markets
for natural gas related

to electricity generation, manufacturing, transportation, and home consumption.

We need
to be able
to meet this demand. Natural gas

is more affordable today relative

to just

a few years ago, largely because

of the shale gas boom now underway. More domestic

oil and natural gas development

is crucial for job growth. The industry has

a strong track record

of creating jobs as evidenced

by what

is happening

in North Dakota, Texas, Pennsylvania

and many other states. The industry now supports
9.2 million jobs, and continues

to create them. More than 9,000
oil and gas related jobs were created this summer according

to BLS,
at a time when new job creation

in the economy was sorely needed. Perhaps

a million

or more new U.S. jobs could be created over the next seven years

if common sense changes

to energy policy were implemented, according

to recent research conducted

by the energy consulting
firm Wood Mackenzie, assuming new regulations

do not have unreasonable provisions.Finally, sound, common sense rules that do not impair development

are important because increased
use of natural gas could greatly benefit the environment, reducing air pollutant and carbon emissions. As for the specifics

in the proposed rules, we support reduced emission completions where the operators determine
the technology

to be safe, technically feasible and cost- effective. However,
the final rules should phase any reduced emission completion requirements

by including

a significant extension

of time for their full implementation. Specially designed equipment
that

is time consuming

to build

is required

to safely perform reduced emission completions. There

is insufficient emission control equipment currently available and

it cannot
be constructed before the expected second quarter 2012 compliance date. Furthermore,

the proposed regulations

do not account
for challenges relating

to several current completion technologies

and known reservoir properties.

For example, there are challenging technical issues regarding certain coal bed methane technologies,

low pressure reservoirs,
and reservoirs with very low volatile organic compound content. The final rules should also recognize that thousands

of “tank emission combustors”

will need
to be certified and manufactured

to reduce emissions. These combustors

will not be available early next year. The final rules should recognize that additional time

is necessary before this requirement

is imposed. Lastly, EPA should simplify the overly burdensome aspects

of the notification, recordkeeping, monitoring, reporting
and performance testing requirements

in the proposed rules
to reflect that many
of the industry’s sources
are at remote and unmanned facilities. In closing,
we believe the Agency should allow an additional

60 days for the public

to provide comment

on this important rulemaking

for the following reasons: • The proposed rules are expansive
and complex. This

is a set of five complex and interconnected
rules. Indeed, the proposal spans over 100 pages

in the Federal Register and the docket contains many times more pages

of supplemental analyses and materials. Preparing comments

on any one of these rules would be a challenge within
60 days. Preparing thorough
and meaningful comments

on all five within 60 days

is not reasonable

or practicable. • The proposed rules are not being implemented

in a vacuum— EPA has numerous other rules under development

that demand time and attention from this sector.• The proposed rules will have

a much greater economic impact than EPA predicts. Following

a preliminary review

of the regulatory impact analysis,

it already seems clear that EPA has significantly underestimated

the cost of implementing

the proposed rules. For such

a far-reaching

set of rules,

it is imperative

for affected companies

to have the time needed

to thoroughly assess the economic
and other analyses underpinning

the proposal. Again, we do not fundamentally oppose reduced emission completions where they make sense and the operators have sufficient time
to implement

the controls. However, given the complexity

of the issues, the many competing demands

on Agency resources, and the time that will be needed

to respond

to public comment
and complete interagency review

of the draft final rules, we also believe that

a one-year extension

of the final rule deadline
for completing these rules

is appropriate

and justified. API will be submitting detailed comments before the comment period closes and API looks forward

to working with the EPA on safe, achievable,

and cost-effective
final rules. That concludes

my comments. Thank you.F 7C?.\ ‘. LTYV’j By Jim Bradbury Special

to the Star-Telegram The length and complexity

of Fort Worth’s recent air quality study make

it difficult

to decipher and its infirmation
thus virtually unavailable

to most residents. While we now have information
that we did not have before,
we do not have the clear-eyed answers that we need. We must do far more.

I encourage

the mayor and City Council

to not place this report
on

a shelf
as
a question answered
but instead use
it as a foundation

to address emission controls for natural gas production activities over the long term. The value
of royalty income will prove fleeting

if we discover

all too late that the health
of our young and old was diminished because
we were unwilling

to press this issue. The Si million cost of the air quality study was enormous

for the results that were provided. The city staff failed

to take

a sufficiently aggressive approach

in managing

the work and the contractor
and allowed
the final cost to run significantly
over budget. Credibility
was key for this work. After the protocol was developed
and Eastern Research Group selected

to do the work, the city staff folded back into

a behind-the-scenes process

of developing

the contract. The process was not open
to the Air Quality Study Committee

or the public. Eastern Research was asked

to conduct
air quality sampling

to determine

the existence
and prevalence

of harmful emissions from natural gas operations citywide. The ambient
air monitoring report revealed relatively consistent signs of important

air quality issues. Benzene,
the contaminant
that has drawn much
of the current attention

on air quality, was detected

94 percent

of the time.

it is the best marker

of an emission problem. Seven other volatile organic compounds were detected

at rates higher than 90 percent. That these values were collected citywide underscores

the gravity

of the situation. The report identified seven key pollutants

for Fort Worth. Eastern Research’s analysis appears

to judge the presence

of the pollutants only by whether they produce

an “urgent health hazard.” That leaves open

a very important question about Fort Worth’s overall near- anti short-term

air quality. This may be too simplistic

for air scientists,
but if we find henzene

94 percent

of the time, we have

a problem.1 frJ The most important part of the study was to be point-source testing

at every natural gas site in the city. The air quality committee
was surprised
but also impressed that Eastern Research assured

us that so many sites would
be closely evaluated. The committee discussed

at length the use of testing and detected rates of emission instead of oil and gas “book estimates.” Unfortunately,

as the details
of the report make clear, the consultant utilized “surrogate emission profiles” and industry-estimated
values

in its analysis. Stunningly,

the report reflects raw averaging
and even wholesale assumptions
that nontested equipment
was not leaking. That

is not what the city asked
or paid for. NoPvithstanding

the consultant’s assurances,

the report acknowledges

that not all of the sites’ emissions were even tested. For example, certain parts of storage tanks, wastewater
and condensate loading equipment and flaring were not tested. The report highlights compressors

as well as gas treatment plants

as the greatest sources

of obvious emissions.
The reported values for the one gas treatment plant examined

are ç significant.
The city should inventory

all gas treatment plants that are just outside city ri

, A boundaries

and produce emissions that can or do (Irift into the city. \ C) Cettain emissions were &tected

b infraied camera

at
a well completion

site but weie not measured otherwise.
The evaporative units
at the city

s waste disposal pilot project were not tested for emissions. ( Despite requests, testing

in heavy condensate production areas outside

of Fort Worth was not done. We have no sense of the volume

of emissions that drift into our city from production areas that are known

to emit volatile organic compounds. The real question facing the city and its residents concerns Barnett Shale natural gas development’s cumulative effect on air quality and good health. The answer still eludes
us. .Jim Bradbury

is a Fort Worth attorney practicing environmental

law and

a member

of the city’s Air Quality Study Committee./cameheretoArlingtonin1983./cametoescapedtheenvironmentalproblemsinSouthernCalifornia/S.D..IservedasacorpsmanintheUS-navywiththemarinesatCamppendleton.Iwasproficientatmedicalcareformarinestrainedinmountain/jungleanddesertwarfare.WhenIwashonorablydischargedIbecameanOrderlyinthehospitalsandmyworkinalliedhealthcarespans14years.IleftCaliforniabecauseofthelackofnaturalwatersupply,andbadair.IrememberdrivingnorththroughtheSanBernadinoValleyandnotbeingabletoseetheriglinearoundthecity.TheHazeintheairwassothick.Icanremember[evenonthecleardays]itwasstillahazyyellow.Ivotedtoapprovetheperipheralcanal.ItwasameasurethatwassupposedtoimprovethevolumeofwatersuppliedtothemillionsandmillionsofpeopleinSouthernCalifornia.Itdidn’tpasssobetweenthatandthepoorairquality,lfelttrapped,soIleft.TherewasplentyofworkhereinTexasandMygrandparentshadahomeinFtWorthsoIstayedwiththemtillIgotonmyfeet.IguessaccordingtosocialstatisticsIwouldbeconsideredworkingclassoraworkingpoorperson.I’veearnedmyEMTtwiceandworkedinhospitalsinCaliforniaandTexas.AlongwiththemillionsofpeoplehereinnorthTexas2 I’ve had many jobs, hospital orderly, built bridges, cleared tree limbs from power lines for the electric company, driven wreckers, worked

in factories and warehouses.
Until lately

I never felt the need to become

a professional because there was always employment. As long as the rent was paid and food

in the refrigerator

I was happy. Like everyone else of my status I’ve paid thousands

of dollars

in sales taxes, purchasing
cars and light bulbs and brooms and books, shoes and furniture.

It’s

a long list. I’ve lived at my current location(1119 South Davis Drive]for

22 years.

I raised

a family here. Except for the extreme heat and the bugs
in the summer times, it’s been

a good experience.

I been noticing though over the last

6 years
or so, the air quality

is getting worse.

I started

to notice that drilling rigs were popping

up everywhere. Towers with lights
at night.

I thought they were cool looking. They have American flags on them.

I consider myself

a patriot. The lighted towers

at night had

a sparkle that made the landscape
less dull and dark.

It made me happy

to know that people were working. Then one day

I noticed exhaust coming from one of them/smoke.

As

I traveled over the Fielder bridge
on my way to work every morning

I would look to the west and some days

I couldn’t even see the buildings inft Wi’44’

D (CHwoFth.

It reminded

me of the skies

I had seen
in southern California.

I know the effects
of poor air quality because with the Marines, training,

in Bridgeport California,

I saw strong young men reduced

to puffing heaps

at high altitude. I’ve held the nebulizer
for

a COPD patients

in hospital.
I’ve seen people struggle

to get a breath. I’ve recently mentioning

to friends that the air is getting bad here, The kind of bad that I remembered when

I use to live in southern California.
The air in Southern California

is better now thanks to the EPA and courageous leaders

in the community
who fought against
big business and their lobby.

In southern California now

a days the brown skies have all but vanished.

I’m told there were mistakes when California and the EPA undertook

the tasks and procedures

to get good air quality. But Texas and the EPA can do this right, right from the beginning.

I live near

a busy Street and there is a private school

in my neighborhood. Although

at times

in the past

I did notice the faint smell of car exhaust

I never notice
an issue with my breathing before the gas wells came. Since the drilling began[within

the last

4 years] my breathing

is not as good. Sometimes when

I wake up in the early mornings

my chest hurts, way before the school

s’ are open or the daily commute.



# cp

E1c4-(

)Through-out

the day Ifeel some discomfort when

I breath. This was not the case prior
to the fracking. Fracking that continues

in my area! There

is a huge fracking complex

on the UTA campus, some

in Pantego,

at the south end of N Davis Drive, and numerous others,
all within

2 miles of where

I stay. I’m going

to see

a doctor next month

to ask about

it.

I do NOT believe that the reports on T orthatthe testing that was done

in Ft Worth
on air quality, was correct

or accurate.

I know that what the television weather people sometimes report

as “good” quality air,
is not true for me.

I am not

a smoker. The air that

I breath

is bad.

I know it’s true because

I can tell. As
a hobby

I like to sing. Lately my abilities

to sing long phrases have diminished.

In the last

2 years I’ve mourned

to myself and my friends that I’m not able to hold

a note for as long or with as much volume,

as

I used to.

I believe

it is due to the exhaust caused by drilling gas wells. Based
on what I’ve seen and felt here
in Arlington;

I’d like to charge these drilling companies, adhere

to the air-pollutants

& air quality rules!

If you lived here.

If you lived around these drilling sites, like me, you would want the highest quality
air to breath, for yourself and your children. Thanks for you time,

I hope and pray you will impose the strictest rules. Ed Eichinger tech support

11 years Arlington

TX 76013 () /q/A//-“What lies behind

us and what lies before

us are small matters compared

to what lies within us.” --Ralph Waldo EmersonI1l\\PhDGnuI11(11\‘““\LuL([xCirciaCnisin?iCinnsL(1,71,7siJI?MarkR.\iukei.PG.,LnvuLivcDirackv.TExAsCoiMIssIoNONENViRoNMENTALTOALITOJvtevtiy7’cxasbyRaciuciIG1,inCPreue.itiiuSeptember6,2011Ms.SandraDenbraber114RayStreetArlington,Texas76010-2724Re:ComplaintagainstCarrizoOil&Gas,Inc.DearMs.Denbraber:OnJuly27,2010andAugust2,2010,theTexasCommissiononEnvironmentalQualityconductedairqualityinvestigationsinresponsetocomplaintsthatodorsfromburningdieselfuelwerecreatinganuisanceconditionattheCarrizoUTAfacility.Afterthoroughlyreviewingallavailablesourcesofinformationincludingtheinvestigator’sreport,medicalrecords,affidavitsandmonitoringdata,ehavedecidedtocloseourfileonthismatterandwillnotbepursuingformalenforcementactionagainstCarrizoOil&Gas,Inc.Wewillhowever,continuetheagency’seffortstomonitorairqualityaspartoftheagency’sinitiativetocompleteanetworkofairmonitorsintheBarnettShaletobetterserveresidentsofNorthTexas.Wedothankyouforyourcourtesies.Sincerely,2/1BryanSinclairDirëctor,EnforcementDivisionTexasCommissiononEnvironmentalQualitycc:MarkVickery,ExecutiveDirectorRichardA.Hyde,P.E.,Deputy,OfficeofComplianceandEnforcementStephanieBergeronPerdue,Deputy,OfficeofLegalServicesP.U.Lu::•,\:s:1i..f.uusi-.::S7•512—2-UDO•w-vw.tceq.texas.govIL:visnujsIumvsmruvv.a.texa.ggotn’custornersurveySandraKDenBraberll4RayStreetArlington,Texas76010-2724September12,2011OfficeoftheAttorneyGeneralPublicInformation&AssistanceDivision,,MC-027P.O.Box12548Austin,TX78711-2548DearAttorneyGeneralGregAbbott,IamaskingthatyoupleasehavetheTCEQfollowthelawinenforcingthefollowing:TexasAdministrativeCodeTitle30Part1Chapter101SubchapterARule101.4States“Nopersonshalldischargefromanysourcewhatsoeveroneormoreaircontaminantsorcombinationsthereof,insuchconcentrationandofsuchdurationasareormaytendtobeinjurioustoortoadverselyaffecthumanhealthorwelfare,animallife,vegetation,orproperty,orastointerferewiththenormaluseandenjoymentofanimallife,vegetation,orproperty.”ThislawisveryclearitisnotbasedontheTCEQ’sairsamplebutuponwhatthecontaminantsdotomyhealth.TheTCEQ’sairsamplesshowthattherewasnoothersourceforthedrillingchemicalsinmyblood.TheTCEQ’sairsamplesarebasedona1hourexposurenotthealmost3yearsof24/7drilling,frackingandacompressorstationtheyhadinstalledandthenlaterremoved.TheTCEQfiledaviolationwithenforcementagainstCarrizoOilandgasusingthiscodethenBryonSinclairdecidedtoclosethiscaseandnotfollowthelawandtheintentofthelaA6Tncaselawthereare2casesthatareimportanttoTexasAdministrativeCodeTitle30Part1Chapter101SubchapterARule101.4andyouneedtoseehowthecourtshaveruled.Westlaw180S.W.2d959CityofTemplev.Mitchell1944andWestlaw781S.W.2d646ManchesterTerminalCorporation,appellant,v.TexasTXTXMarineTransportation1989bothcasesarebasedandsupporttheTexasAdministrativeCodelistedaboveandwerewoninacourtoflaw.Theolderthecasethelongerithaswithstoodtimethebetterthecase.TheseCasesareavailablefromtheTexasStateLawLibrary.PleasereviewthesecasesandyouwillseethattheTCEQhasnotfollowedthelaw.PleaseenforcetheTexasAdministrativeCodeandtheintentthatitwaswritten.Thankyouforyourhelp.Sincerely,SandraKDenBraberATTORNEY GENEIkL

OF TExAs GREG ABBOTT September

15, 2011 Ms. Sandra

K. DenBraber 114 Ray St. Arlington,

TX 76010 Dear Ms. DenBraber: We are in receipt
of your recent letter
to the Office
of the Attorney General. Please understand
that this office

is prohibited

by law from providing legal advice, counsel, representation

or interpretations

of the law to private individuals. The policies and procedures

of the Texas Commission

on Environmental Quality (TCEQ)
are developed and overseen

by the administrators

of that agency and are not subject

to review
by the Office
of the Attorney General. You may wish
to continue working with TCEQ regarding your issue. Ultimate oversight

of state agencies

is maintained

by the Texas Legislature.
You may wish
to contact your legislators regarding your concerns.

If you need assistance

in determining
who your legislators
are, you may wish
to contact your county tax assessor/collector’s

office
or use the “Who Represents Me” feature

on the Texas Legislature Online website

at www.capitol.state.tx.us. Finally, you may wish
to discuss this matter with

a private attorney. The Lawyer Referral Service

of the State Bar of Texas can assist you in contacting

an attorney

in Texas with relevant expertise.
The Lawyer Referral Service can be reached

at (800) 252-9690

or (512) 463-1463. Thank you for writing. Sincerely, Andreea Flores Public Information

& Assistance Office
of the Attorney General

of TexasPOST OFFICE Bo 12548.AUsTIN.TExAS 78711-2548TEL: (512) 463-2100WWW.TEXASATTORNEYGENERAL.GO’AnEgoolEmpioymn,OpporroniyEoployr.PrintodonRoqddPprpfacUclVes/‘JoL01ejp-1dkwCit-h15-AI1es(1rfVjave3ttefl-iQ,.-fLMLLSI&j-CjcfeiI.-iiM;(1dt4’McI;D)t-PprflI5L•t5—fr4JPage1of2SandraDenBraberFrom:‘SandraDenBraber”<skdbrn@ticnet.com>To:<Mark.Vickery@tceq.texas.gov>;<Bryan.Shaw@tceq.texas.gov>;<Carlos.Rubinstein@tceq.texas.gov>;<Buddy.Garcia@tceq.texas.gov>;<Stephine.BergeronPerdue@tceq.texas.gov>Sent:Monday,September26,20119:53AMAttach:GULF%2OWAR%2OSYNDROM.jpgSubject:ReasearchsupportswhyIwasmadeillToWhomthismayconcern,HereisadditionalresearchthatsupportswhyIwasmadeillfromtheCarrizoOilandGasdrillsiteonUTAproperty.ItissadyoudonotfollowTexasLawandwhatresearchisfindinganddocumenting.PleaseletmeknowifyoulookedupthecaselawcasesthatIgaveyoutoshowyouthatyoudidnotfollowtheTexasAdmininstrativeCode.SandraDenBraberNewsPlumeWhyUTSouthwestern’sGulfWarSyndromeResearchisaThreattoTheWayTCEQDoesBusinessThursday,September15,2011Dr.CharlesHaleyatUTSouthwesternhasbeenstudyingGulfWarSyndromealmostsinceitsinceptionasaconditionintheearly1990’s.Downwindershasbeenfollowinghisworkforthebetterpartoftwodecades.Why?Becausehistheoriesabouthowourservicemenandwomenwereinflictedwiththisillnesscloselycorrespondtotheperspectiveofcitizenslivingnextdoortoindustrialpolluters.Thatis,constantlow-levelexposurestochemicalscanhaveseriouslife-longhealtheffects,eveniftheexposuresarebelow“levelsofregulatoryconcern.”Likecitizensbattlingcementkilns,gasfacilities,leadsmelters,orrefineries,thosewhosufferwithGWSdrewscornandridiculefromtheiropponents.Theywereaccusedofhaving“psychologicalissues”thatwerenotgroundedinhumanphysiologybecausenohighlevelsoftoxinswereeverrecordedduringofficialsamplingormonitoring.Therejustwasn’tenoughcrapintheairtomakeyousickaccordingtoindustryandtheirapologistsattheTexasCommissiononEnvironmentalQuality.Today’samiouncementthatDr.Haley’sground-breaking,outside-the-boxresearch,alongwithDownwinder-likepersistencehasproducedlandmarkdefinitiveresultsisnotgoodnewsfortheTCEQorthepollutersitprotectsthroughantiquatedtheoreticalrisk-assessmentexercisesthathavelittletodowithreality.Theagencydependsonthehypothesisthatlongtermexposuretosmallamountsofpoisonswillnotcauseharm-notevenshorttermacuteharm,muchlesslife-longconditions.Youmayhaveheardthisapproachdescribedasthe“thedosemakesthepoison.”Youonlyhavetoworryabouthigh-levelexposures,andaperson’sresponsetothepoisonis“linear”-thelarger9/28/2011Page

2 of2 the dose, the worse the health effects. This

is what the TCEQ’s “Effects Screening Levels”
are all about. Readings below the ESL for

a specific contaminant

is no cause for concern because they’re below

a level that TCEQ has determined SHOULDN’T cause harm based on... .well, based on lots of conjecture

for the most part. Readings above

it, unless their extremely high, are also discounted because

of the “conservative nature”

of the ESL’s to begin with. But what
if all chemicals didn’t always act in the human body the same way. What
if some of them caused harm even
at low levels previously thought

to be “safe?” What
if the dose-effect
was “non-linear,” meaning

it did more harm at low levels over

a long period
of time than
in short large bursts
of exposures? Then the way the TCEQ currently regulates
the public risk to exposure

to these chemicals would
be not just wrong, but completely, utterly wrong. From Today’s Dallas Observer piece on Dr. Haley’s work: “There’s

no denying

it now: Gulf War Syndrome, characterized

by memory loss, lack of concentration, neuropathic
pain and depression,

is a physiological illness, not

a psychological

one. A UT Southwestern study, published

in the journal Radiology, used

a specialized MRI that specifically measures blood flow
in the brain and detected marked abnormalities

in the brains
of those with Gulf War Syndrome. Not only have those abnormalities persisted
for 20 years, but in some cases they’ve worsened. The findings mark

a significant advancement

in our understanding

of the syndrome, which was for years written off by the Defense Department

and the Department

of Veterans Affairs

as a form of combat stress rather than an objectively diagnosable injury. Dr. Robert Haley, chief epidemiologist

at UT Southwestern,

and

a cadre of clinicians
and researchers, have struggled with the government

for some

18 years for research funding and to have the syndrome recognized

as a legitimate
war injury caused
by chronic exposure

to minimal amounts

of sarin gas.” (injury caused
by chronic exposures

to minimal amounts”

of poison. Those are the words that make the way the TCEQ does business instantly obsolete. They won’t say so of course. They’ll attempt

to limit this conclusion very narrowly. And there’s this- it took
18 years and numerous fights over funding

to get this conclusion. How many years might we have
to wait until J all 80,000 chemicals

on the marketplace

get this kind of rigorous attention Lto their public health effects? But Dr. Haley has produced

the kind of research that’s

a chink

in the wall, that eventually leads
to a crack that produces more cracks until the entire thing comes down for lack of structural integrity.
For now, take heart citizens. There’s new science that says it’s not your imagination,

it’s their pollution.

9/28/2011Page1of2SandraDenBraberFrom:SandraDenBraber<skdbrn@ticnet.com>To:“AlyssaTaylor<Alyssa.Taylortceq.texas.gov>Sent:Tuesday,August09,201111:00AMSubject:CarrizoSoundslikeCarrizoistryingtoplaynicetododirty.SandyDenBraberCarrizoOil&GastohelppayfornewdaycareatUTArlingtonPostedMonday,Aug.08,20110CommentsPrintReprintsShareBySusanSchrocksschrock(dstar-telegram.comARLINGTON--Thecompanythathasdrilled22naturalgaswellsattheUniversityofTexasatArlingtonisnowhelpingbuildanewchild-care\‘9’çcenteronaquietercornerofcampus.TheYWCAArlingtonChildDevelopmentCenterisexpectedtomoveintoalarger,$2millionbuildingnextyearawayfromtherapidlydevelopingeasternedgeofUTA,wherea6,500-seatspecial-eventscenterandmajormixed-usedevelopmentwillsoonopen.CarrizoOil&Gashasagreedtopay$1.12milliontorebuildthechild-carecenteronatree-linedlotonSouthDavisDriveatthenorthwestedgeofcampus.—-“It’sasizableinvestment,butUTAhasbeenverygeneroustoCarrizoallowingustousetheirproperty,”saidRustyWard,Carrizo’svicepresidentofregulatoryaffairs.“Thisissomethingthecompanywantedtohelpwith.”TheYWCAserveschildrenfromlow-incomefamiliesandthosestayinginhomelessshelters,inadditiontofamilieswhopaythefullchild-carerate.YWCAExecutiveDirectorCarolKioceksaidtheexisting8,000-square-footcenterthatitownsismorethan20yearsoldandneedssignificantrenovations.Thenewbuildingisexpectedtobeabout10,000squarefeetandsurroundedbytreesnexttoacommunitygarden.“It’sreallygorgeous,”Kioceksaid.“We’reprettyexcitedaboutit.”ThecurrentcenterisdifficulttoaccessandisnexttothebusyContinuingEducationandWorkforceDevelopmentbuildingandfacultyparkinglots,UTAspokeswomanKristinSullivansaid.TheCollegeParkCenterspecial-eventsbuildingandamixed-usedevelopmentthatwillhouse600studentsarealsosettoopenalongCenterStreetnextyear,soofficialssaidtheywantedtomovethechild-carecentertoalesscongested,morevisibleareaofcampus.9/29/20114.-,.—“YouaregoingtogetevenmoretrafficbecauseofthedevelopmentoftheentireCollegeParkDistrict.Ourintentistohaveeventsthereallthetime,”SullivansaidoftheCollegeParkCenter.TheYWCA’smoveisnotbecauseofitsproximitytoCarrizo’swellsite,whichhasbeeninproductionsince2008,officialssaid.Thoughnearbyresidentshaveraisedconcernsaboutairpollutionfromthesite,Kioceksaidparentsofchildrenatthedaycarehavenotcomplainedaboutthedrillingactivity.CarrizoofficialssaytheTexasCommissionforEnvironmentalQualityhasrepeatedlytestedthesiteinresponsetoresidents’concerns.“ThatisthemostheavilyscrutinizeddrillsiteintheBarnettShale,”WardCarrizohasnoimmediateplanstodrillmorewellsoncampus,butthechild-carecenter’srelocationwouldfreeupspaceforfuturedrillingactivity,Wardsaid.Theuniversity,whichwillspendnearly$800,000onthenewcenter,willleasethebuildingbacktotheYWCA.Theleaseagreementwillgiveuniversitystudents,facultyandstaffpriorityuseofthechildcarecenterandwillallowstudentsandfacultytouseitasalearninglaboratory,schoolofficialssaid.SusanSchrock,817-390-7639 4Fi 5•fPage2of2said.1cs--Tee(c:eYzO-1-clv-iLI:njQ)flâ+taJitr/rs;k+t4o(t4-Oh-IDdcus1+ —9/29/2011Testimony

of Sharon Wilson Texas and Gulf Region Organizer Earthworks’

Oil & Gas Accountability Project 1612

K St., NW, Suite 808 Washington,
D.C. 20006 www.earthworksaction.org 940-389-1622 swiIsinearthworksaction.org Before the U.S. Environmental Protection Agency Oil and Natural Gas Sector Arlington,

TX September

29, 2011My name

is Sharon Wilson.

I am Texas and Gulf Region Organizer

for Earthworks’

Oil and Gas Accountability Project. We are

a nonprofit organization working nationally

to protect communities

and the environment
from the impacts

of irresponsible mineral and energy development. Earthworks

will submit technical comments

on the proposed rules. EPA invited me to your Research Triangle Park offices

in North Carolina and then
to Headquarters

in DC to help open your eyes
to the severity

of the problems people living

in the Gas Patch face every day.

I presented

to you real life examples

of health effects, environmental damage, diminished property value and how family and comm unity wellbeing
has suffered

in the Barnett Shale. We already have over 15,000 existing wells

in the Barnett Shale. [Show map of destruction] Although you seemed

to have heard our cries for help, and the new rules are

a step

in the right direction, without including existing sources these rules are little help to drilling saturated areas. The very same people whose stories you heard will continue

to suffer. You can ease their suffering

by strengthening EPA’s proposed New Source Performance Standards
and National Emission Standards

for Hazardous

Air Pollutants

to include

all new and existing wells and storage tanks, compressor

and processing facilities and all related equipment. We hear/have heard from industry about
all the jobs they provide and
in today’s economy,

we need
all the jobs we can get. But how much

is a job worth?

Is a job worth sacrificing

the health of our children?
Are these our choices then—jobs

or health? On EPA’s Natural Gas STAR Program website you list nearly 100 different proven, cost- effective industry-developed technologies

and practices that improve operational efficiency
and reduce methane emissions. Methane

is a surrogate
gas that carries toxic compounds
with

it. Yet, from all those technologies,
EPA has chosen only

5 for these new rules. If this industry can’t employ

its own technologies

to protect public health AND provide jobs AND make

a profit, then they need

a new business model. Stop coddling this industry. Help them step into the 21 st century and operate more efficiently

by requiring

all the best available technologies

for all emissions sources

at all stages
of production
and processing. Argyle and Bartonville citizens organized

to conduct baseline” testing

to measure
the quality

of their air before large-scale
gas development
took hold. Baseline testing, detected only seven
of the 84 air contaminants typically tested for by TCEQ.
As drilling, fracking and additional

oil and gas facilities moved into the area, TCEQ testing
— on the high school band practice

lot /2 mile from the offending facility— detected

65 of the 84 air contaminants usually tested for by the TCEQ. As scientists,
can you tell us what are the increased risks when children

go from breathing

7 chemicals

to breathing

a cocktail

of 65 different chemicals?They currently have only

2 of the 22 planned wells

in place. When they have
all 22 wells

in place, will this be one emission source? No, because

of a loophole

in the Clean Air Act,

it will be considered

as 22 different emission sources each with

a separate permit.
By promising

not to exceed the 25 tons per year (tpy) emissions
cap per well, all of those 22 emission sources are allowed

to pollute from the same pad site up to 550 tons per year of VOCs without triggering further scrutiny and regulation! We need the EPA to close the loophole

in the Clean Air Act so that oil and gas emissions are aggregated. We support the draft rules as
a first step and request that you go further

to include existing sources, employ

all available technologies, include

all emission sources and aggregate emissions. Thank you for being here.Comments

to the EPA- September

29, 2011 Good Evening.
My name

is Susan Read and

I live in Grand Prairie, Texas within

a 2 mile range
of at least

3 shale gas drilling pad sites. Members

of the Westchester community formed the Westchester-Grand
Prairie Community Alliance

in the summer

of 2010 when we realized that there was

a serious problem

in our community. Seismic testing trucks had descended

on our community

of over 2,000 homes without warning

in June 2010 even though our Westchester Association

of Homeowners

had decided that we would not (as

a group) sign

a lease back
in 2007. In the meantime,
one site— the Corn Valley

A (there’s

a B, too) Pad Site, 850 feet from the Joe Pool Lake Dam, and 537 feet from homeowners,

had been permitted

by the Texas Railroad Commission

in 2009 and our city was ready

to permit

it. We held

a community-wide meeting

on July 19, 2010, attended

by more than 500 Westchester neighbors, thinking that we might stop
it. But even with
so many opposed

to all of it, our City permifted this pad site the very next day. Soon, we realized that there had NEVER been any public discussion about any of it and that this was because
we had no SUP for Gas Drilling. Meaning: With few exceptions,

all gas drilling permits submitted through the Texas Railroad Commission were being approved “administratively,” by the Grand Prairie,
TX Environmental Services Dept. After attending Planning and Zoning Commission Meetings,

we discovered
that this Commission knew less than we did about shale gas drilling. And they had never had any presentations about any of it. It didn’t take long
to realize we were
in serious trouble. Through meetings and

a lot of hard work we realized that our city’s Gas Drilling Ordinance
was basically

an open door for gas drilling

in our neighborhoods.

Then we got to work. Page

1 of
3Comments

to the EPA- September

29, 2011 Through

a petition signing effort,

a neighborhood
blog the Westchester Gasette (we’re
on Facebook,
too) and speaking regularly before our City Council, lots of emails...

by November
18t, 2010 we had

a Moratorium

on all Shale Gas Drilling

so that the Ordinance could
be strengthened.

Yay! (Pause) Then Chesapeake began their Campaign. That Campaign included

a Public Meeting held on December

7th, 2010 that requested

all those “Lessors”

the landowners
who had signed leases with them Chesapeake wanted everyone

to go to City Hall and protest this Moratorium

and the 1,000 setback that might
be part of
a Revised and New Ordinance. To see

a Corporation telling

a community

to come together and go against protective actions that our Community Group had worked

so hard
to make happen... well,

it was unbelievable

to see this. They even told this large gathering

of well over 700 or 800 people stuffed into

a community building that they could invoke “Force Majeure,”

if necessary
and
if the City kept this Moratorium

in place very long. They mentioned
that we probably didn’t even know what that teas.. .but they would explain

it to us. When one of our group yelled out from the Center

of the room, “What about the Process,”
the response back was, “Oh, we’re not going

to address
the process tonight. And we won’t
be taking am, gues tions, either.” One young man came up to me after this meeting trying

to convince
me and others that there wasn’t anything wrong with hydraulic fracturing. Page 2of3Comments

to the EPA— September

29, 2011 I asked him who he worked
for and he told me, “Chesapeake,”

and that he was

a Hydraulic Engineer and that hydraulic fracturing
was “God’s Laws of Physics.” More shocking experiences were
to follow when our City,
in fact, did lift the Moratorium
only

2 months later... it was to have been

a 6-month Moratorium,

but pressure from the industry was too great for our City. What we have here are HUGE GAPS

in the regulation

of the very dangerous shale gas drilling industry. Our communities

are under siege by these people physically, psychologically

and economically. After seeing that our city and state are firmly

in the grip of the O&G Industry,
our community group, the Westchester-Grand
Prairie Community Alliance
has come

to the conclusion
that the EPA

is our last hope for change. We thought that the very name
of the oil and gas regulation agency (The Texas Railroad Commission) would finally get

a new name
in this last legislative session... and our state legislature could not even get that changed. This

is unbelievable

in America. People are suffering. And will suffer more and more
in the very near future unless we can STOP this industry’s rampage. More shale gas drilling infrastructure

is going
in as we sit here tonight. They do all their work ahead
of time and by the time they ask for the rubber stamp from the state regulators... it’s

a Done Deal. We will do whatever

we can, as
a group and as
a community,

to support the efforts

of the EPA
to gain regulation

of this industry.

It’s

a matter

of life and death. And we need help NOW. Thank you. Page 3of3IAMSUSANTURITZCOOPEROFRICHARDSON,TX.PLEASERECORDTHATIBROUGHTMYNEBULIZERANDINHALERTOMYPRESENTATIONTODAY.IHAVEBRONCHIECTASISANDALINGERINGCASEOFBRONCHITIS,CAUSINGCONTINUALSHORTNESSOFBREATH.IAMCONVINCEDTHATAIRPOLLUTIONANDGLOBALWARMINGAREEXACERBATINGMYRESPIRATORYAFFLICTION.SOOFTENIHAVESPOKENHEREANDPLEADEDFORCLEANAIRTOBREATHEANDCLEANWATERTODRINK.BOTHARENECESSITIESOFLIFE.NONEOFUSCANLIVEWITHOUTTHEM-NOTGLOBALWARMINGDENIERS,NOTEVENOFFICIALSOFOILANDGASCOMPANIES.IAMSTAGGEREDTHATFRACKINGISALLOWED.JOSHFOX,THEDIRECTOROFTHEMOVIEGASLAND,SAYSTHAT596DIFFERENTCHEMICALSAREUSEDINTHEFRACKINGPROCESSANDTHATTHEGASINDUSTRYISEXEMPTFROMREVEALINGTHEIRNAMES,BECAUSETHEINFORMATIONISPROPRIETARY.EMISSIONSFROMLEAKSAREFEARFULLYPOISONOUS,ANDLEAKSAREKNOWNTOOCCUR.HUMANHEALTHSHOULDBECONSIDEREDTHEFOREMOSTPRIORITY.THEIRRIGHTSENDWHEREMYAIRSPACEBEGINS!HOWSADITISTHATTHEIRPROFITMOTIVEISSOHIGHTHATTHEYAREWILLINGTOJEOPARDIZETHEHEALTHOFHUMANBEINGSANDESPECIALLYCHILDREN,TOCOMPOUNDTHEPROBLEMSOFRESPIRATORYDISEASES,TOCAUSEHIGHRATESOFCANCERINCOMMUNITIESLOCATEDNEARGASPIPELINES.ANDTHEYARESOCALLOUSABOUTTHEPOSSIBILITYOFPOISONINGOURPRECIOUSWATERSOURCES.THEAMERICANLUNGASSOCIATION,WHICHOBTAINSITSDATAFROMTHEEPA’SAIRQUALITYSYSTEMDATABASE,CONSISTENTLYRATESTEXASWITHAGRADEOFEFORFAILURE.IN OUR AREA, DALLAS COUNTY HAS HAD 24 ORANGE DAYS AND

2 RED DAYS; DENTON COUNTY,

33 ORANGE DAYS AND

3 RED DAYS. TARRANT COUNTY

IS FAR WORSE WITH
59 ORANGE DAYS,

4 RED DAYS AND-HEAVEN
HELP US-ONE PURPLE DAY. IN ROUND NUMBERS, FIGURES FROM THE AMERICAN LUNG ASSOCIATION INDICATE THE FOLLOWING RISK IMPLICATIONS FOR OUR AREA, DUE TO THE HIGH OZONE AND CHEMICAL AND PARTICULATE POLLUTANTS

IN OUR AIR: • PEDIATRIC ASTHMA-- 56,000 • ADULT ASTHMA— 113,000 • CHRONIC BRONCHITIS-71,000 • CARDIOVASCULAR DISEASE— 566,000 • 211,000 ADULTS ARE AT RISK • 690,000 CHILDREN UNDER

18 ARE AT RISK WHEN THESE NUMBERS TRANSLATE

TO HUMAN BEINGS, THE EFFECT

IS STAGGERING. NO PROFIT,
NO CORPORATE GREED,

IS WORTH THESE COLOSSAL RISKS TO LIFE ITSELF. THE SIERRA CLUB REPORTS THAT,

IN DALLAS/FORT WORTH, POLLUTION FROM OIL AND GAS FIELDS

IS WORSE THAN THE EXHAUST

OF ALL THE CARS

IN SOME OF OUR BIGGEST CITIES. REDUCING

OIL AND GAS POLLUTION WILL PROTECT OUR COMMUNITIES, CREATE JOBS, AND WILL OFTEN PAY FOR ITSELF AS COMPANIES STOP LEAKS AND KEEP NATURAL GAS
IN THE PIPELINE AND OUT OF OUR AIR. IT FURTHER SAYS: EACH NEW OIL OR GAS WELL CONTRIBUTES TO THE MILLIONS

OF TONS OF HARMFUL POLLUTANTS SPEWED INTO THE AIR FROM THIS INDUSTRY AND THAT THE DIRTY OIL AND GAS INDUSTRY

IS THE SECOND LARGEST STATIONARY SOURCE

OF GLOBAL WARMING POLLUTION

IN THE
U. S. EVEN WORSE, EVERY YEAR THE INDUSTRY EMITS MORE THAN 300 MILLION TONS OF POLLUTANTS,

LIKE METHANE AND SULFUR DIOXIDE.EMISSIONSFROMVEHICULARTRAFFIC,COALFIREDPOWERPLANTS,FRACKINGANDTARSANDSPIPELINES...ALLACCUMULATEANDCONTRIBUTETOGLOBALWARMING.EVERYONEOFUSONEARTHHASAMORALOBLIGATIONTONURTUREANDPROTECTTHISPRECIOUSPLANETEARTH.THISISOURONLYHOME.IWHOLEHEARTEDLYSUPPORTTHEEPAINREGULATINGTHESEINDUSTRIES.REGULATIONSMUSTBEIMMEDIATE,STRINGENTANDSTRICTLYENFORCED.EPA,WENEEDYOU.THISPLANETEARTHNEEDSYOU.ANDMYBRONCHITISANDINEEDYOU.THANKYOU.SUSANTURITZCOOPER1116GREENCOVELANERICHARDSONTX75081-3715972238-8653susanjack@juno.comI I Texas Independent Producers
and Royalty Owners Association Teddy Carter, Director

of Public Affairs September

29, 2011 My name

is Teddy Carter and

I am here today

to speak on behalf

of the Texas Independent Producers
and Royalty Owners Association, also known

as TIPRO. TIPRO has over 2,300 members, including small family-owned companies,

the largest publicly traded independents,

and large and small mineral estates and trusts. Let me first state, TIPRO and its member companies

are in favor
of clean air. People

in the oil and gas industry
live and work around their facilities,
and they want

to protect
the air their families breathe just
as much

or more than the EPA does. But new regulations, particularly

in the current economy, must

be reasonable
and based
on sound science. Oil and gas producers operate like any other business.

All business owners will tell you that, when
all is said and done, they are in business

to turn

a profit. Profitability allows businesses

to reinvest capital

to grow their business, retain and reward their current employees,
and hire new employees

to grow their workforce. There are approximately 5,000
oil and gas well operators

in Texas, many of them small independents

with limited capital resources. These operators work hard
at maintaining

a positive bottom line, and that includes examining
and implementing
every possible scenario

by which they may invest

in new technology, equipment,

or strategies to improve profitability.
Green completions

are

a strategy recommended

by EPA and often evaluated

by operators.
The EPA
is correct;

it makes economic sense

to perform these types

of completions where possible because

it results

in greater quantities of saleable product.
For this reason, many operators
will opt for green completions when circumstances permit; however,

a lack of readily available gathering lines often prohibits them from performing
one, and the alternative practice

of flaring

is often 1I‘ITexasIndependentProducersandRoyaltyOwnersAssociationTeddyCarter,DirectorofPublicAffairsSeptember29,2011prohibitedaswellduetomunicipalflaringrestrictions.Again,TIPROisinfavorofcleanair,butwebelievethatonesizedoesnotfitallwithregardtowhichwellsshouldhavegreencompletionsperformedonthemandthepracticeshouldcontinuetobeencouraged,butnotmandated.Secondly,EPA’sresidualriskreviewfoundthatthecurrentmaximumindividualcancerriskfromoilandnaturalgasproductionis40in1million,whichfallswithinarangeEPAconsidersacceptable.Theagency’sresidualriskreviewofairtoxicsstandardsfornaturalgastransmissionandstorageis90in1million,alsoalevelwhichtheEPAfindsacceptable.Thedictionarydefinesthewordacceptableas“abletobeagreedon;suitable;adequate;satisfactory;pleasing;welcome.”Iftheriskasitexiststodayisacceptable,thenwhypassregulationsthatwillneedlesslyharmbusinessesandjobs?TIPRObelievesthataprimaryreasonstandardsarereviewedperiodicallyissothatagenciesneednottrytoregulatebasedoneveryscenariotheycanimagine.WhentheaverageAmericanleavesforwork,theyknowthatanynumberofscenarioscouldhappenthatmaycausethemharm.Ameteorcouldfallfromthesky;theymightbeattackedbyanimalsescapedfromthezoo;itispossiblethattheywillbestruckbylightning.Butthemereexistenceofthesepossibilitiesisnotsufficientreasontostayhomefromwork.Instead,peopletakeactiontoreducerisktoacceptablelevels.Theylookbothwaysbeforecrossingthestreet;theyputonseatbelts;theyholdtightlytothestraponthesubway.Regulationshouldbebasedonactualfactsandevidence,nottheoriesorprojections.Ifcurrentevidenceshowsthatriskfromoilandgasisacceptable,thennoadditionalregulationshouldberequireduntilthenextreviewperiod.Regulationforregulation’s2TexasIndependentProducersandRoyaltyOwnersAssociationTeddyCarter,DirectorofPublicAffairsSeptember29,2011 sake

is a dangerous path that can potentially cause greater harm than good; TIPRO urges the EPA
to not present solutions

to problems that do not currently exist. Finally, this proposed rule package

is extremely complicated

and will require very extensive technical
and economic review

in order for stakeholders

to properly address
the operational

and cost consequences

that will arise
as
a result

of the rulemaking. Many TIPRO members

are small businesses
that do not have in-house staff with the proper knowledge

or expertise

to conduct such

a comprehensive review. The very short 60-day timeframe

for review and comment, even with the pre-publication version

of the rule available,
will pose

a significant hardship

to TIPRO members. EPA’s proposed timeline, with

a final action date mandated

by February 2012, will not allow for TIPRO members

to prepare

to implement

the rules, and could therefore place TIPRO members

in the untenable position

of operating
out of compliance,

as well as causing economic hardship because these businesses

will not have had the opportunity

to prepare

to incorporate

the costs
of the rule requirements

into their operating budgets. The Railroad Commission

of Texas (RRC) has unparalleled knowledge

of the oil and gas industry.
The Texas Commission

on Environmental Quality (TCEQ) has successfully reduced harmful emissions

at
a greater rate than any other state
in the country. Together, these agencies continue

to ensure compliance
and provide proper oversight based
on verifiable science and, although
the EPA is well intentioned, TIPRO believes that regulation

of oil and gas operations

in Texas should reside

at the state level. However,

if this rule package

is going

to continue

to move forward regardless

of that3Texas Independent Producers
and Royalty Owners Association Teddy Carter, Director

of Public Affairs September

29, 2011 fact, then TIPRO respectfully requests that EPA issue

a 90-day extension

to the comment period scheduled

to end on October
31, 2011,
as well as an extension

of the final action date by six months, in order

to allow stakeholders

the opportunity

to properly review and comment

on this very significant
rule package,

as well as to make plans for its implementation. Thank you for the opportunity

to address you today, TIPRO intends to submit more detailed written comments

on the specifics

of the proposed rule before the comment deadline. 49/29/2011 EPA TESTIMONY

— SEPTEMBER

29, 2011 nia Simonson, virginia.simonson@us.army.mil Bottom Line Upfront Fully Support New Source Performance Standards And Air Toxics Standards!

19/29/2011Why•DFWisa“serious”nonattainmentareaforozoneVOCscontributetoozoneformation•HighlevelsofozoneandVOCsadverselyimpacthumanhealth•Consistentstandardsofprotectionareneeded—Differentrulesindifferentstates—DifferentruleswithinstatesindifferentcitiesTCEQDailyAirQualityForce-castsOzoneLevels•DailyEmails—Sep28,2011—UnhealthyforSensitiveGroups—Sep27,2011-UnhealthyforSensitiveGroups—Sep26,2011—Moderateorpossiblyhigherlevels—Sep25,2011—Moderateorpossiblyhigherlevels—Sep24,2011—UnhealthyforSensitiveGroups—Sep23,2011—UnhealthyforSensitiveGroups29/29/2011 Peak AQI- Aug 27, 2011 Houston-----..

4 V ‘pus Christi..-,

o100ODes.I.•.11II.-2I3IZ 4dland PeakAQI-Sep2l,2011 rCombined
AQI er212O11

Tulsa ppI’1i Norman- Memphis .1-

.•,F

•I Litd

e Pck las Jackson

. Austin Houson •3._ s Christi0II10001

39/29/2011 AQI Forecast

— Sep 29, 2011 4IaysAQI Forect

/‘ It

y, Seç*embqr

29, 2011 Daily Peak AQI
— Sep 28, 2011 ned PMd

49/29/2011 Daily Peak AQI— Sep 27, 2011 —

Gas Wells Permit Status FM

TCEQ Monitor

59/29/2011 r1IIV_____134!._______________AirMonitoringinFlowerMoundhttp://www.flower-mound.com/ensr_resources/env_resources_airquality.php•FlowerMoundAirQualitystudyconclusions:TheJanuary(2011)ambientairobservationsarenotindicativeofsignificantreleasesorfugitiveemissionsfromthenearbynaturalgasactivitiesinand/orsurroundingFlowerMound.”•ThisconclusionisincludedintheTown’sProposedOil&GasOrdinance•Supportsthequestionableconclusionthatcurrentairqualitydoesn’trequireanyvaporrecoveryoremissioncontrolsforexistingfrackingandcompressionoperationsBenzeneLevels(ppb)MonthlyHighsinMetroplexhillFloMoHighestBenzeneReadinginMetroplex(xc,far)In2011(8.63ppbOnlan29,2011,Windat183deg)r—._.j1/>I1FloMoODish•FtW•EagleMt.LIDecatur•DallasLJjftNovDecJanFebMarEffectsScreen:ngLevelsarechemical-specificairconcentrationssettoprotecthumanhealthandwelfare.RnnceneLongTermE5L1.4ppb69/29/2011VOCNofFM1171&RiverOaksAberdeenatEofHWY377ClearCreekFM24991CS5C513C5Carbon-14189.6Disulfide(STESL10)Carbonyl447417Sulfide(STESL55)“Ambient”KleinfelderReadingsJanuary25,2011WindwasblowingfromCCFto5Cs->1mileawayConclusions•Ourcitiesandourstatedonotplaceahighpriorityoncleanair,cleanwaterorcitizen’shealth•AirTestingcanbemanipulatedsothattheactuallevelsofVOCsinhaledbyresidentsisneverreallyknown•TheEPAneedstodowhatthestateandourcitieshavefailedtodoPasstheNewSourcePerformanceStandardsAndAirToxicsStandardsNow!7EPA TESTIMONY— SEPTEMBER

29, 2011VirginiaSimonson,virginia.simonson@us.army.milGoodAfternoon,MynameisVirginiaSimonson.IresideinFlowerMound,Texas.Ibecameinvolvedwitheffortstopromoteresponsibledrillingabout2yearsagoasgasdrillingactivitiessignificantlyexpandednearmyarea.AsacareerArmyOfficer,Ihavealwaysworkedthrough“thesystem’whateverthatsystemmayhavebeen.Asanactivist,Ihavecontinuedtoworkthroughtheestablishedsystems.In2010,IhelpedleadacitizenreferendumdrivethatledtoatemporarymoratoriumonnewdrillingpermitsandtheappointmentofanO&GAdvisoryBoardthatdevelopedrecommendationstoimproveourcityordinancesrelatedtogasdrillingactivities.Ihavealsospentsignificantamountsoftimedirectlylobbyingmycity,stateandfederalrepresentativespushingformoreresponsibledrillingregulationsandadvocatingfortherightsofsurfaceowners.IcouldspeakalldayontheroadblockstojusticeI,andotheractivists,faced&stillfaceeveryday,tryingtogetourlocalandstaterepstodotherightthing...Tryingtogetthemtotakeadequatestepstoprotectourair,ourwaterandourhealth.Ithasbecomepainfullyapparenttomethatourstateandlocalrepresentativesjustdonothavethewherewithalltotakethenecessarysteps.AndthatiswhyIhaveaskedto--,.—Bottom Line Upfront Fully Support New Sc rce Performance Standards And Air Toxics Standards! This

is about

as clear
as

I can be. When the state and municipal governments

fail to protect their citizens,

it is incumbent upon the Federal Government

to step in.

2Why • DFW

is a “serious” nonattainment

area for ozone • VOCs contribute

to ozone formation • High levels
of ozone and VOCs adversely impact human health • Consistent standards

of protection

are needed— Different rules

in different states— Different rules within states

in different cities I have become jaded and tone-deaf

to cries for states rights.
To me, states rights

in Texas means the sanctioned elevation

of corporate rights over my individual rights
to breathe clean air, drink clean water and be relatively protected from toxic chemicals. The Clean Air Act, The Clean Water Act, the Super-Fund Clean-Up
Act and the Civil Rights Act all illustrate how the federal government

has had to step
in when cities and states failed
to protect their citizens. We are at the point now where

it is clear that the O&G industry has become such an overwhelming
force

in Texas, that we need the EPA to dictate improvements

for O&G drilling, production, storage

& transmission activities.

3TCEQDailyAirQualityForce-castsOzoneLevels•DailyEmails—Sep28,2011—UnhealthyforSensitiveGroups—Sep27,2011-UnhealthyforSensitiveGroups—Sep26,2011—Moderateorpossiblyhigherlevels—Sep25,2011—Moderateorpossiblyhigherlevels—Sep24,2011—UnhealthyforSensitiveGroups—Sep23,2011—UnhealthyforSensitiveGroupsIsubscribetotheTCEQAirQualitynotificationsystem.Everyday,Igetemailstellingmewhattypeofozonelevelswewillface.Theseareafewfromthelastweek.Whenyoureceivetheseemailsonaregularbasis,youunderstandwhyasthmarateshavesoaredinourareaoverthelastdecade.4AndwhenyoulookatthedailymapsprovidedbytheEPAandTCEQonAirQuality,youareremindedoftherelationshipbetweenairquality&gasdrillingactivities. PeakAQI-Aug27,

2011DailySaturday0.000:—:l-:8-:55Peak AQI- Sep 21, 2011oeooO;201t6.39.28Z6AQIForecast—Sep29,2011--Drec4tber29.2011?23t77Daily Peak AQI— Sep 28, 2011AQI(CnedPt4.5tember28.8Don’ttheresidentsoftheDFWnon-attainmentareadeserveashotatbetterairquality?DailyPeakAQI—Sep27,2011liedPtand03)9BeforeIclose,IwanttoshowafewquickslidestoillustratehowgasdrillingimpactsmelocallyinFlowerMound,Texas.Theseslidesareindicativeofresidentsexperienceinothercities,mostnotablyFt.Worth.Allofthewhitecirclesrepresentgaspads,whichcanhavefrom1-20wellsonthem).FlowerMoundisluckytohaveaTCEQAirMonitorwhichisdepictedbythebluecloudinthemiddleofthemap.TheblueinsertisadepictionofhistoricalwindpatternsinourareawhichpredominatefromtheSouth.10Air Monitoring

in Flower Moundhttp://wwwllower-moundcom/env_resources/enjesources_airquaIity.php Flower Mound Air Quality study conclusions: The January (2011) ambient

air observations

are not indicative

of significant releases

or fugitive emissions from the nearby natural gas activities

in and/or surrounding Flower Mound.” • This conclusion

is included

in the Town’s Proposed

Oil & Gas Ordinance • Supports
the questionable conclusion that current
air quality doesn’t require any vapor recovery

or emission controls
for existing fracking and compression operations Based
on city ordered

air testing and selected TCEQ air monitor readings,
the Town of Flower Mound concluded that we have no issues related

to gas drilling operations. The city feels
so strongly that we have no air quality issues related

to gas drilling that they put that so-called fact
in our brand new O&G ordinance.

11Benzene Levels (ppb) And yet, even within the limitations

of ambient

air monitoring,

we still experienced high levels
of hazardous VOCs. Note here, the benzene reading 8.63 ppb
in ian 2011. Monthly Highs

in Metroplex riii EJDishFt.W•EagleMt.DecaturDallasNovDecJanFebMarEffectsScreenngese;saechemcal-specificairconcentratorssettoprotecthemanhealthandwelfare.BerzeneLongrermESL1.4ppb

12VOC

N of FM1171

& River Oaks Aberdeen

at E of HWY 377 Clear Creek FM 2499 Also note the high levels
of carbon disulfide and carbonyl suflide

in the same month. “Ambient” Kleinfelder Readings January
25, 2011 ‘Cs 14 Carbon Disulfide (ST ESL 10)

5CS 18

13 CS 9.6 Ca rbonyl Sulfide (ST ESI 55)

17 Wind was blowing from CCF to
5 CS- >1 mile away

13Conclusions•Ourcitiesandourstatedonotplaceahighpriorityoncleanair,cleanwaterorcitizen’shealth•AirTestingcanbemanipulatedsothattheactuallevelsofVOCsinhaledbyresidentsisneverreallyknown•TheEPAneedstodowhatthestateandourcitieshavefailedtodoPasstheNewSourcePerformanceStandardsAndAirToxicsStandardsNow!14