FromJamesE.Rosenberg555DavidsonRoadGrindstone.PDFVIP

From: James E. Rosenberg 555 Davidson Road Grindstone, PA 15442 jr@ To: Krishnan Ramamurthy Environmental Program Manager Division of Permits, Bureau of Air Quality 12th Floor, Rachel Carson State Office Building P. O. Box 8468 Harrisburg, PA 17105-8468 kramamurth@pa. gov Cc: Shawn M. Garvin Regional Administrator Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, PA 19103-2029 garvin.shawn@ Date: March 18, 2013 1 Pursuant to 43 Pa.B. 742, Saturday, February 2, 2013 , “Plan Approval and Operating Permit Exemptions”, I hereby register my strenuous objection to exemption B 38 for unconventional gas wells, on the following grounds: 1. Previous objections to Exemption B 38 are still valid. On Saturday, February 26, 2011, at 41 Pa.B. 1066, DEP issued a Notice of Intent to Reopen Public Comment 2 Period on Air Quality Permit Exemptions (DEP ID: 275-2101-003) Published at 40 Pa.B. 2822. At that time I supplied a Public Comment on that issue. The reasoning in that comment is still valid today, and has not been properly refuted by DEP. I therefore attach it to this comment as Appendix A. The points of that comment may be summarized as follows: • Oil and Gas Wells have a demonstrated Potential to Emit (PTE) Air Pollution in significant amounts. • The huge amounts of pressure required for hydraulic fracturing significantly increase the PTE from dissolved gases in produced water from unconventional Oil and Gas Wells. • The amount of air pollution emitted by an Oil and Gas Well can vary significantly based on construction metho