## MARCELLUS 1W SHALE COALITIONT"

June 16, 2014

Re: Comments on Environmental Protection Agency (EPA) Oil and Natural Gas Sector Compressors

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) Oil and Gas Sector Compressors.

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 P 412.706.5160 1 F 412.706.5170 1www.marreiluscoalition.orgIn 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.) It is important to note that RPM, rod diameter, horsepower and suction pressure variations will greatly affect rod packing leaks. These variations need to be considered and therefore it is not appropriate to apply emission factors from one industry sector to all the subsets of the oil and gas industry. 2.) The MSC recommends that the EPA use the vast amount of emissions data collected through the GHGRP for compressors in the transmission, processing and storage sectors of the oil and gas industry. 3.) The EPA needs to recognize that the percentage of centrifugal compressors equipped with wet seals in all oil and gas sectors is much lower than the 80% assumed in the U.S. inventory. API/ANGA indicates centrifugal compressors in service with wet seals are closer to 20% and data from the GHG reporting indicate their prevalence is in the range of 30 to 35% nationwide. 4.) The MSC would like to point out that a rod packing "maintenance" program may be more efficient and effective than a mandatory replacement program. There are many situations where a complete replacement is a waste of perfectly functional components and money. A mandatory replacement program eliminates any incentive for a rod packing manufacturer to develop a better, longer lasting more effective system. It would also eliminate any incentive for an operator to use a better system that may come with a higher up front cost. 5.) In determining the cost effectiveness of mandatory replacements programs for rod packing we recommend the EPA consider the substantial differences in vent rates for the compressors in different industry sectors. Each industry sector (transmission, processing, storage, production, and gathering) have unique rod packing vent rates due to variables in engine size, speed and operating conditions. It is not appropriate to apply emission factors for compressors in transmission service to compressors at production locations.
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



### MARCELLUS Nillk SHALE COALITION'1

<

David Spigelmy President Page 3

include NSPS 0000, Pennsylvania Department of Environmental Protection's General Permit 5 (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.



### MARCELLUS

SHALE COALITION"Page 4



# 4:4 MARCELLUS

SHALE COALITION'