MARCELLUS 

SHALE COALITIONJune 16, 2014 

Re: Comments on EPA White Paper for Oil and Natural Gas Sector Hydraulically 

Fractured Oil Well Completions and Associated Gas during Ongoing Production 

To whom it may concern, 

The Marcellus Shale Coalition (MSC), a regional trade association with a national membership, 

appreciates the opportunity to comment on the U.S. Environmental Protection Agency (EPA) 

White Paper for the Oil and Gas Sector Hydraulically Fractured Oil Well Completions and 

Associated Gas during Ongoing Production. 

The MSC was formed in 2008 and is currently comprised of approximately 300 producing and 

supply chain members who are fully committed to working with local, county, state and federal 

government officials and regulators to facilitate the development of the natural gas resources in 

the Marcellus, Utica and related geological formations. Our members represent many of the 

largest and most active companies in natural gas production, gathering and transmission in the 

country, as well as the suppliers, consultants and contractors who serve the industry. MSC 

member companies have a steadfast commitment to strengthen communities by making our 

region a better place to live, work and raise our families — for our generation and for future 

generations. Our members have a strong and unwavering commitment to the safety of our 

employees, contractors and communities. More information about our organization can be found 

at http://marcelluscoalition.org . 

As background, the Marcellus Shale Formation is the most prolific natural gas production basin 

in the U.S., generating approximately 14 billion cubic feet per day and contributing more than 

20% of daily U.S. supply. The Marcellus is making a significant contribution to energy security, 

while generating sustainable economic and environmental benefits for the nation. According to a 

recent economic analysis, the natural gas industry invested more than $12 billion in Pennsylvania 

in 2011 while supporting more than 230,000 new hires in the region. Domestically produced 

natural gas has provided a clean-burning energy resource for power generation that is 

contributing to air quality improvements in the U.S. According to the U.S. Energy Information 

Administration, nationwide energy-related carbon dioxide emissions dropped 3.8% in 2012 

versus 2011. In addition, the U.S. Environmental Protection Agency has determined that carbon 

dioxide emissions from power plants decreased 10% in 2012 versus 2010. Both of these 

emission reductions were attributed, in large part, to the increased use of natural gas. 

24 Summit Park Drive • 2" Fl • Pittsburgh PA 15275 I P 412.706.5160 I F 412.706.5170 I www.marcelluscoalition.org 
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In addition to the specific comments below, the MSC also wishes to take this opportunity to 

voice our support for all comments submitted by the American Petroleum Institute (API), 

Western Energy Alliance (WEA), and the Interstate Natural Gas Association of America 

(INGAA). 

1.) The MSC would like to clearly point out that during flowback gas is only vented long 

enough (typically less than a day, not 3 to 7 days as indicated in the white paper) to 

develop flow at the necessary pressure to be routed to a test or production separator. 

After the separator the gas is either combusted or delivered to the sales line. Gas is not 

vented during the entire flowback period. 

2.) It is not very clear to the reader that the emissions are represented as potential 

uncontrolled emissions. The emissions estimates in this paper do not represent actual 

emissions and this distinction needs to be more apparent. 

3.) By using uncontrolled emission numbers and over estimating the venting duration, the 

VOC and Methane emissions are greatly overstated. Subsequently, these numbers lead to 

an incorrect cost/benefit analysis as they indicate a greater economic benefit than is 

actually present. 

4.) The MSC believes the white paper does an inadequate job of detailing and representing 

current industry practices used in controlling emissions from venting. 

5.) It appears that many operators have voluntarily reported completion emissions from oil 

producing formation in the GHGRP. This data should be considered and incorporated 

into any analysis performed by EPA on this topic. It is the most recent and most accurate 

data available. The data in the GHGRP for 2011 and 2012 indicates 1,004 oil well 

completions were reported with 64% using some sort of REC's. The emissions from 

these reports are substantially lower than what was used for purposes of this white paper. 

6.) The MSC would like to identify delays in Federal permitting as a major impediment to 

infrastructure construction and, subsequently increasing the amount of emissions vented 

rather than sold. 

MSC is concerned that the compressed time schedule for EPA to develop additional 

requirements for the Oil and Gas Industry will not include recent study data or recent regulatory 

requirements in its evaluation of any new regulations. There are numerous studies currently 

underway evaluating methane sources and regional methane emissions across the country, which 

should be reviewed and considered. MSC member companies are voluntarily participating in 

several of these studies because the resulting information is valuable. 

In addition, MSC is unsure whether the recent emission reduction requirements for the Oil 

and Gas Industry in Pennsylvania can be evaluated under this schedule. These requirements 

include NSPS 0000, Peimsylvania Department of Environmental Protection's General Permit 5 

MARCELLUS 

' SHALE COALITION'?" 
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(GP5) and Pennsylvania's Exemption #38 for wellpads. MSC believes this information should 

be considered as additional requirements are considered for the industry. 

MSC appreciates the opportunity to comment on the white paper and looks forward to further 

opportunities to work with EPA to develop regulations and guidelines that are economically and 

environmentally sound. If you have any questions, please do not hesitate to contact the 

undersigned. 

Yptcs truly, 

David Spigelmyer 

President 

6 MARCELLUS 

SHALE COALITIONT" 
MARCELLUS 

11111 SHALE COALITIONT"