MARCELLUS 

SHALE COALITIONJune 16, 2014 

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

Leaks 

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 Leaks. 

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.mamelluscoalition.org 
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In addition to the specific comments below, the MSC also wishes to take this opportmity 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.) When discussing leaks at Oil and Gas Production locations it is important to note that 

upwards of 90% of the emissions from leaks are generated by 1 to 2% of the total facility 

components and that the UT study 2013 suggests that 66% of production facilities have 

no leaks at all. 

2.) The MSC suggests the possible implementation of AVO's and a vigorous preventive 

maintenance program similar to that recently incorporated by the TCEQ in its permit-byrule program, instead of an overly burdensome and costly LDAR program. A 

preventative maintenance program using AVO would provide a platform for operators to 

inspect and replace components prior to failure rather than reacting to and repairing a 

leak at some arbitrary interval. 

3.) We encourage EPA to remove references to components designed with an inherent leak 

rate (thief hatches, pressure relief devices, etc.) from any leak definition going forward. 

These devices are designed to relieve pressure for safety and must do so to ensure proper 

operation. 

4.) Leaking from improperly controlled storage vessels as discussed in Section 1, and in that 

sections footnote, should not be considered a "leak" as those control devices would be 

regulated under a state permit or other state and/or federal regulation. 

5.) The MSC feels that leaks not repaired the day they are discovered are the only ones that 

should require documentation. If a repair requires procurement of a part or a facility, is 

required to be shut-in, etc., then documentation of this should be maintained. 

6.) We strongly encourage EPA to evaluate the different sectors (production, gathering, 

transmission, and processing) of the Oil and Gas industry separately when it comes to the 

economic aspect of leak detection and repair. There are different metrics for each of the 

industry sectors that impact economic feasibility. The EPA has also failed to perform 

verification of the costs referenced in the studies found in the White Paper. 

7.) EPA has left out many costs associated with finding leaks as well as those associated 

with recordkeeping and reporting. These are significant and will affect the bottom line. 

The MSC recommends a more complete cost analysis be performed before any new 

regulations are promulgated. 

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 

MARCELLUS 

W' SHALE COALITION- 
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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, 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. 

Yours t- ly, 

David`Spigel yer 

President 

t,* MARCELLUS 

SHALE COALITION!" 
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MARCELLUS 

SHALE COALITION!'" 

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