motion for adverse inference w/ exhibits (kiskadden v. pa dep and range resources)

EXHIBIT 1

09/17/2013

07/19/2013

MR LOREN KISKADDEN

V .

COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF ENVIRONMENTAL PROTECTION and RANGE RESOURCES APPALACHIA, LLC, Permittee

EHB Docket No. 2011-149-R

ORDER

AND NOW, this 19t1 day of July, 2013, after review of Appellant's Motion to Compel

Discovery Responses from Permittee and Appellant's Motion to Renew Motion to Compel Against

Permittee, Permittee's Responses, and following Oral Argument before the Pennsylvania

Environmental Hearing Board, it is ordered as follows:

I)

Appellant's Motion to Compel production of documents responsive to Appellant's

Second Request for Production Nos. 1, 2-7, 9-13, 19,22-26, and 28-29 is granted.

2) Permittee shall produce such additional documents on or before August 20, 2013.

3) If Permittee has already provided all documents responsive to any of the above

Requests for Production then it shall provide a signed verification in accordance with

the Pennsylvania Rules of Civil Procedure so indicating.

4) Appellant's Motion to Compel further responses to Appellant's First Set of

Interrogatories, Nos. 3 & 7 is granted and Nos. 4-5 is denied.

5) Permittee shall further respond to Interrogatories Nos. 3 & 7 on or before August20, U

2013.

6) Appellant's Motion to Compel admissions to Appellant's Second Set of Admissions

____- —NOS44j48v34 & 52 is granted. EXHIBIT

09/17/2013

07/19/2013 k

7) Permittee shall either admit or deny the above Requests for Admission on or before

August 20, 2013.

8) Appellant's Motion to Compel admissions to Appellant's Second Set of Requests for

Admissions Nos. 45,47, 48, 49 & 50 is denied.

9) Appellant's Motion to Renew Motion to Compel is granted. On or before August

20, 2013, Permittee shall provide Appellant with a list identifying any and all

proprietary chemicals comprising each and every product identified by Permittee as

used at the Yeager Site. In addition, Permittee will provide Appellant with a list of

all chemicals for each Material Safety Data Sheet of the products Permittee earlier

identified as used at the Yeager Site that lacked full information regarding all of the

chemicals and components of those particular products.

ENVIRONMENTAL HEARING BOARD

THOMAS W. RENWAND Chief Judge and Chairman

DATED: July 19,2013

c: For the Commonwealth of PA, DEP: Michael J. Heilman, Esquire Richard Watling, Esquire Office of Chief Counsel - Southwest Region

09/17/2013

07/19/2013

j EHB Docket No. 2011-149-R Page 3

For Appellant: Kendra L. Smith, Esquire John M. Smith, Esquire SMITH BUTZ LLC 125 Technology Drive, Suite 202 Bailey Center I Canonsburg, PA 15317

For Permittee: Kenneth S. Komoroski, Esquire Jeremy A. Mercer, Esquire Matthew Sepp, Esquire Steven E.H. Gibbs, Esquire FULBRGHT & JAWORSKI, LLP Southpointe Energy Complex 370 Southpointe Blvd, Suite 300 Canonsburg, PA 15317

Michael C. Steindorf, Esquire Tyler H. Lipp, Esquire FULBRIGHT & JAWORSKI, LLP 2200 Ross Avenue, Suite 2800 Dallas, TX 75201-2784

Dennis St. J. Mulvihill, Esquire Bruce E. Rende, Esquire Erin J. Dolfi, Esquire ROBB LEONARD MIJLVIHILL, LLP 500 Grant Street, 73rd Floor Pittsburgh, PA 15219

09/17/2013

EXHIBIT 2 09/17/2013

p

COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD

LOREN KISKADDEN )

Appellant. Docket No. 2011-149-R

vs.

DEPARTMENT OF ENVIRONMENTAL PROTECTION

Appellant,

VS.

RANGE RESOURCES - APPALACHIA, LLC,

Permittee.

PERMITTEE RANGE RESOURCES - APPALACHIA, LLC'S RESPONSES AND OBJECTIONS TO APPELLANT'S REQUEST FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSION

Pursuant to 25 Pa. Code § 1021.102 and Rules 4009.12 and 4014 of the Pennsylvania

Rules of Civil Procedure, Permittec Range Resources - Appalachia, LLC ("Range"), hereby

serves these Responses and Objections ("Responses") to Appellant's Request for Production of

Documents and Request for Admission (collectively, "Requests").

GENERAL OBJECTIONS

Range makes the following General Objections to the Requests. These General

Objections are part of the Responses to each and every Request. The assertion of the same,

similar, or additional objections in the individual objections to these Requests, or the failure to

assert any additional objections, does not waive any of Range's General Objections as set forth

below:

EXHIBIT

09/17/2013

RESPONSE: In addition to the General Objections, which are incorporated by

reference, Range objects to this Request as overly broad and unduly burdensome. Range also

objects to this Request as seeking to expand the requirements of the Pennsylvania Rules of Civil

Procedure. Range objects to this Request as premature. Range has not yet identified and

disclosed its testifying experts. Range will respond to this Request pursuant to applicable

Pennsylvania rules of Civil Procedure and Board Orders.

37. Please produce any and all documents, including but not limited to MSDS, which

identify all proprietary chemicals, substances and products used to treat the Yeager

Impoundment and Drill Cuttings Pit.


reference, Range also objects to this Request as seeking to expand the requirements of the

Pennsylvania Rules of Civil Procedure and applicable Pennsylvania law, which only require

AIML Range to produce documents in its possession or control. Range objects to this Request as

improperly seeking confidential and proprietary information. Range objects to this Request as

vague, ambiguous and compound because of the use of the undefined terms "identify,"

"chemicals," "substances," "products," and "treat." Finally, Range objects to this Request as

seeking documents which are either already in Appellant's or Appellant's counsel's possession

or are equally accessible to Appellant through numerous document requests to and file reviews

already conducted by Appellant or Appellant's counsel at DEP or through third-party subpoena

productions.

Subject to and without waiving the foregoing objections, Range will produce responsive,

non-priy~g!g itpaiQJk&Ludi.doun1entsexisL

9573*4414 29

09/17/2013


kor identify all proprietary chemicals, substances and products used in any drilling fluid or mud at

the Yeager Site.

RESPONSE In addition to the General Objections, which are incorporated by



Range to produce documents in its possession or control. Range objects to this Request as



"chemicals," "substances," and "products." Finally, Range objects to this Request as seeking

documents which are either already in Appellant's or Appellant's counsel's possession or are

equally accessible to Appellant through numerous document requests to and file reviews already

3

conducted by Appellant or Appellant's counsel at DEP or through third-party subpoena

productions.


non-privileged documents in its possession to the extent such documents exist


identify all proprietary chemicals, substances and products used in any drilling fluid or mud at

the Sicrezega Drill Site.


refermw-, Range objects to this Request as overly broad and unduly burdensome. Range also

objects to this Request as seeking to epand the requirements of the J'ejnsyjvania Rules of Civil

Procedure, which only require Range to produce documents in its possession or control Range

09/17/2013

42. Please produce any and all documents., including but not limited to MSDS, which

identify all proprietary chemicals, substances and products used in stimulating the Yeager Well

7FL




Range to produce documents in its possession or control. Range objects to this Request as



"chemicals," "substances," and "products." Range objects to this Request as seeking documents

which are either already in Appellant's or Appellant's counsel's possession or are equally

accessible to Appellant through numerous document requests to and file reviews already

conducted by Appellant or Appellant's counsel at DEP or through third-party subpoena

productions. Finally, Range objects to this Request to the extent it seeks information and/or

documents that are subject to the attorney-client privilege, attorney work product privilege,

consulting expert privilege, or any other applicable legal protection.


non-privileged documents in its possession to the extent such documents exist.

41 Please produce any and all documents relative to any spills, releases, discharges

and/or reniediatlon which have occurred or are presently occurring at the Yeager Drill Site.


to this Request as also

objects to this Request as seeking to expand the requirements of the Pennsylvania Rules of Civil

931492A 32

09/17/2013

EXHIBIT 3 09/17/2013

Transcript of the Testimony of

Date: December 17, 2012 Volume:

Case: Loren Kiskadden v. Department of Environmental Protection

Eagle Feather Reporting Phone: 724-746-3383

Fax: 724-746-3383 Email:[email protected]

[ IM

09/17/2013

31 33

1 request for productions 37 through 39 and 1 chemicals that are in this particular product. 2 question 42 we asked for the identification of 2 MR.. KOMOROSKJ: And so I want to b 3 all proprietary chemicals used by Range 3 clear, if we have it, we'll provide it. We 4 specific to the Yeager site. Again, we 4 wont say that we have it but we won't disclose 5 received some things from the DEP that have 5 it Unless - I can't imagine this to be the 6 Sierzegas on it. We didn't receive anything 6 case -- unless we have some confidentiality 7 from you guys responsive to that. 7 agreement. 8 So, again, I wanted to clarify we're not S But the way things typically work is Range 9 looking for anything from Sierzegas. We're 9 will ask to have a certain situation addressed.

10 looking for just the Yeager site. And, in 10 And a vendor will come in and say I am going t 11 particular, some of the documents we did 11 use this and I will represent that it will 12 receive from the DEP, there's MSDS sheets that 12 solve your problem or the best we have to try 13 have been produced. But the MSDS sheets lists 13 to solve your problem. But we don't typically 14 for instance, on a couple products 100 percent 14 ask them how chemically it works or what the 15 proprietary. 15 constituents are. 16 So what we're looking for when we say 16 So it's typically the case that we would 17 proprietary we're looking for the actual 17 not know what - if they don't share with us. 18 chemicals, the names of them. [can't believe 18 Of if they have a name and its like a Beta 19 there's anything exotic that I haven't heard of 19 product or it's Beta 900. If we know it's Beta 20 before. But the fact of the matter is on the 20 900, we'll tell you what that is. And whatever 21 MSDS sheets, some of the things that the DEP 21 Material Safety Data Sheet they made available 22 provided to us that they believe were used at 22 for it, we can provide that. 23 Yeager indicates that they are 100 percent 23 1 just don't want to overcommit to 24 proprietary so we have no idea what that might 24 something. And my view is if it's available 25 be. 25 you should have it and we should have it. So

32 34

1 MR. KOMOROSIU: Well, that one, if we 1 if it's available, you'll have it and we'll 2 have the information on what the proprietary 2 have it 3 chemicals are, we'll provide it If we don't 3 MS. SMITH: So I guess that's the 4 have it because it's - because the vendor 4 point that were kind of stuck on is if it's 5 considers it proprietary, then we won't 1 5 available. Because for us there's no other way 6 don't know if there's -- I don't know what we 6 to get it other than to ask you guys for it. 7 could do better than that. 7 MR. KOMOROSKI: Right 8 MS. SMITH: Okay. Because here's my 8 MS. SMITH: So there is no other 9 issue with that. We're not asking for - so 9 avenue for us to go. And, obviously, with

10 that we're clear, we're not asking for the 10 regard to our burden to have to prove on this 11 breakdown or formula, so to speak. We're 11 appeal it becomes essential to know exactly 12 asking for what the actual chemical was. 12 what's in there in terms of making a 13 MR, KOMOROSKI: Okay. 13 hydrogeological connection between the site an 14 MS. SMITH: You know what I mean. 14 Mr. Kiskadden's water supply. 15 And my understanding is with a lot of vendors 15 Sowe do have an issue with that I 16 or manufacturers of this the thing they hold 16 understand what youre saying that Range may 17 near and dear as proprietary is the actual 17 not know. But, again, were not in a position 18 formulation of it Because that's unique in 18 where we can go and ask, you know, Range's 19 and of itself. That's really what they attempt 19 subcontractor, whatever, for that proprietary 20 to protect. It's not necessarily the chemicals 20 information. That's not something we can do or 21 that are used. Its the quantity of the 21 our own. 22 chemicals used in the product. 22 So that's kind of sticking point with me. 23 So at this point what we're asking for when 23 Because while I understand the position that 24 we're asking for the proprietary chemicals is 24 Range is in in not knowing some of those 25 exactly what What are the names of the 25 things, its something that we do need to know

Eagle Feather Reporting [email protected] 724-746-3383

09/17/2013

35 37

1 for purposes of this case. 1 motions. 2 MR. KOMOROSKJ: How about this? Hoi 1 2 Again. I would rather have all the 3 about if we don't have the information on a 3 information out there. I mean, let's find out 4 particular chemical, then we will ask the 4 if there is anything that we used that ended up 5 vendor for that information. As Range we'll 5 in Mr. Kiskadden's water supply or didn't. An 6 ask for it and provide you what we obtain. And 6 whether there's official negative inference or 7 then go on from there. 7 not,inrnymind,thelackof -- theabsenceof 8 MS. SMITH: Well, I am agreeable to 8 information creates a void that is going to be 9 that as long as what you obtain from them is 9 filled with something. I would rather till the

10 we're not giving you the proprietary chemicals 10 void with facts and science rather than what 11 because that's not what we're going to do. You 11 someone might suppose from something that 12 understand the position it puts me in because 12 neither one of us occasioned. So, no, we'll 13 now I don't know what is there. You guys don't 13 use best efforts. 14 know what is there. 14 We can inform the Judge. If anyone has 15 So how do I go forward with this and saying 15 ideas how to get that information, obtain that 16 1 don't - you know, Judge I would love to tell 16 information well pursue it We want to 17 you what's in there and whether its shown up 17 accomplish - I have tried to put myself in 18 in my client's water but I can't tell you 18 your shoes. I don't do that well, but I - and 19 because Range doesn't know. 19 so I think that's a reasonable request. And 20 MR. KOMOROSKI: Right. 20 we'll do everything possible to get the 21 MS. SMITH: Because at that point - 21 information so that we know, okay, this 22 what I am trying to avoid with this, Ken, is 1 22 material was used at this concentration. And 23 am trying to avoid then asking the court for a 23 then compare that with what is found in Mr. 24 negative inference against you guys. I don't 24 Kiskadden's water supply and see if there is a 25 want to hold you accountable for something you 25 connection or not.

36 38

1 don't know. But at the same time if you're the 1 But if something is found there and you 2 only source of the information for us, I don't 2 say, well, we know 95 percent of what Range 3 have any options. 3 used, but we don't know that other five 4 MR. KOMOROSKI: Again, we'll work 4 percent, that's a problem. That's a problem 5 with you. I mean, we'll try to find a way to 5 for you and its a problem for us. 6 get the information. Range doesn't have any 6 MS. SMITH: Okay. So we can let the 7 interest in keeping it proprietary. 7 Judge know that we've tentatively reached an 8 MS. SMITH: Sure. 8 agreement on that And it's really contingent 9 MR KOMOROSKI: So to the extent -- 9 on what the manufacturers are willing to give

10 it would be better for Range to share - to get 10 Range to give to us. 11 all the proprietary information and to share it 11 MR KOMOROSKI: How that actually 12 with you. That way there can't be any issue of 12 evidences itself, yes. 13 negative inference or anything else. 13 MS. SMITH: Okay. And then request 14 MS. SMITH: So can we agree to this 14 44 was — again, goes to water testing supplies 15 and maybe let the Judge know this on Thursday. 15 at the Yeager site itself. And I think we have 16 That what we've agreed to is that Range is 16 covered that. That you're willing to give us 17 going to go heck and ask for all the 17 any and all testing that was done along with 18 proprietary information. We just don't know 18 all the QA/QC data for each of the tests; is 19 where that stands yet? 19 that right? 20 MR. KOMOROSKI: Yes. We can do th 20 MR. KOMOROSKI: That's correct 21 And, again, I will commit to you that well use 21 MS. SMITH: Okay. So we're good on 22 our best efforts to get the information. I 22 that one. Then this one l think kind ofgoes 23 mean, conversely we won't use some half attemp t 23 back to - 1 was searching for it before when 24 to say, hey, it's okay for you to say it's 24 we were talking about the Notices of Violaxkr 25 proprietary but we've got to go through the 25 and any consent orders and that sort of thing.

-9(Pag35. to 3.8..1...


09/17/2013

EXHIBIT 4 09/17/2013

11 COMMONWEALTH OF PENNSYLVANIA

ENVIRONMENTAL HEARING BOARD'

MR. LOREN KISKADDEN

versus

COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF ENVIRONMENTAL PROTECTION and RANGE RESOURCES APPALACHIA, LLC, Perrnite


Verbatim transcript of hearing held at the

it Pittsburgh Office and Court Facility, Piafl Place,

301 Fifth Avenue, Suite 310, Pittsburgh, Pennsylvania,

Thursday, December 20, 2012,

2:00 p.m.

BEFORE: THOMAS W. REN WAND, Administrative Law Judge

ADELMAN REPORTERS 302 Torrey Pine Drive it - Mars, Pennsylvania 16046 MOBIT

09/17/2013

I APPEARANCES: KENDRA L. SMIT ESQUIRE JENNIFER L FAHNESTOCK, ESQUIRE 125 Technology Drive, Suite 202 Bailey Center Canonsburg, PA 15317

ALSO PRESENT: Maryann Wesdock, Esquire Jim Pinta

LF-A

For - Mr. Loren Kiskadden

RICHARD I. WAILING, ESQUIRE Department of Environmental Protection Southwest Regional Counsel 400 Waterfront Drive Pittsburgh, PA 15222

For - Commonwealth of Pennsylvania, Department of Environmental Protection

KENNETH S. KOMOROSKI, ESQUIRE MATTHEW H. SEPP, ESQUIRE Southpointe Energy Complex 370 Soutpointe Boulevard Suite 300 Canonsburg, PA 15317

For— Range Resources Appalachia, LLC

09/17/2013

3

Ii ADMINISTRATIVE LAW JUDGE RENWAND: As I

2 understand it, the first motion was you worked it out,

3 right?

4 MR. KOr4OROSKI: I believe so, yes.

5 ADMINISTRATIVE LAW JUDGE RENWAND: The motion to

6 compel.

7

MS. SMITH: Yes. Your Honor, with the motion to

i compel, we did meet and confer for two hours on Monday,

9 Mr. Komoroski and myself and Ms. Fahnestock.

10 ADMINISTRATIVE LAW JUDGE RENWAND: Great. Thank

I,

11

you.

12

MS. SMITH: And what resulted from that was Range

13 has agreed, and please correct me if I am wrong, Ken has

14 agreed to re-answer all of this request for admission,

15 request for production of documents that we put in a

16 letter, 17-page letter, to them as to what we had

17 objections to, has agreed to re-answer them.

18

There is only one caveat to that: that one is we

19 had requested a request for production of all the names

20 of all of the proprietary chemicals that were used up at

the Yeager site. Mr. Komoroski has made me aware that

22 he will do his best to get those from Range.

23 However, Range may not have some of that

241 information, because they would be with the third-party

tractor w-ho actually applied that or the manufacturer

09/17/2013

if of that particular product. And so obviously, I would

2 still have an issue with that but Mr. --

3

ADMINISTRATIVE LAW JUDGE RENWAND: If that comes

4 out where, you know, you don't get all of it or

whatever, just let me know. We will discuss that. I

6 understand that you can't guarantee that right now.

7

MR. KOMOROSKI: That is right, Your Honor. Yes,

8 we -- on absolutely every item that was part of the

9 motion to compel, we agreed to improve upon our answers

10 and our production and in all of the request for

11 admission, that we are going to provide much more

12 elaborate and helpful answers to those requests. And

13 the only one that I just simply wasn't able to -- what I

14 said as far as proprietary chemicals, if we don't -- we

15 don't have that information. The vendor has it.

16

We will use our best efforts. We will make

17 personal inquiry to the vendor, ask for them to provide

18 it and then we will inform the Board; and perhaps there

19 is something -- if we don't get it, perhaps there is

20 something the Board can do; so, perhaps everything that

21 is in the motion to compel, we agreed to improve upon

22 our answers, our production, redo more elaborately our

23 responses for request for admission; but on that one, it

24 is honestly the best that we can do.

I

!j

DMI-WI-STRA-T--IV--LAW_JUDG&REWWAND: Okay. I ----------------------------------------

09/17/2013

EXHIBIT 5

09/17/2013

S COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD

LOREN KISKADDEN

Appellant, Docket No. 2011-149-R

vs.


Appellant,

VS.


Permittee.

PERMITTEE RANGE RESOURCES - APPALACHIA, LLC'S

S

AMENDED RESPONSES AND OBJECTIONS TO APPELLANT'S REQUEST FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSION

Pursuant to 25 Pa. Code § 1021 .102 and Rules 4009.12 and 4014 of the Pennsylvania

Rules of Civil Procedure, Permittee Range Resources - Appalachia, LLC ("Range"), hereby

serves these Amended Responses and Objections ("Responses") to Appellant's Request for

Production of Documents and Request for Admission (collectively, "Requests").

GENERAL OBJECTIONS

Range makes the following General Objections to the Requests. These General

Objections are part of the Responses to each and every Request. The assertion of the same,

similar, or additional objections in the individual objections to these Requests, or the failure to

assert any additional objections, does not waive any of Range's General Objections as set forth

below:

.

EXHIBIT

09/17/2013

F- L-1 RESPONSE; The "Excavation Summary Report," as referenced in the Yeager

Drill Pit Closure Plan, is just another name for the "Range Resources Post Remediation

Summary Report" prepared by Weavertown Environmental Group. Despite the October 20,

2011 date on the report, it was not provided to Range until December 2011. Range submitted the

report on December 22, 2011. A copy of the report has already been produced and is available at

RRA-LK_002022.

35. Please produce copies of all expert reports, including all references relied upon

and cited, by any and all experts Range Resources intends on calling at the hearing/trial of this

matter.

RESPONSE; Range is unable to respond to this request because it has not yet

identified its testifying experts. Range will respond to this request as soon as possible. Please

feel free to contact Range's counsel to discuss this further.

36. Please produce copies of all resumes and/or curriculum vitae of any and all

experts Range Resources intends on calling at the hearing/trial of this matter.

RESPONSE: Range is unable to respond to this request because it has not yet

identified its testifying experts. Range will respond to this request as soon as possible.


identify all proprietary chemicals, substances and products used to treat the Yeager

Impoundment and Drill Cuttings Pit,

RESPONSE: At various times, the Impoundment and Drill Cuttings Pit were

treated with defoamers and biocides/bacteriacides. Range has produced the MSDS for each of

these products, as well as any other documents that help identify the products.

20

09/17/2013

.


identify all proprietary chemicals, substances and products used in any drilling fluid or mud at

the Yeager Site.

RESPONSE: Range has produced documents identifying the chemicals,

substances, and products used at the Yeager Site. The MSDS are often useful for developing

some understanding of what is in a particular chemical or product. However, they vary widely in

terms of usefulness. Some manufacturers include very little information about the actual

components of a particular product. As a. result, Range is currently in the process of seeking

additional information from manufacturers that have failed to provide enough information about

their products in the MSDS. We will supplement our responses and production as we receive

that information.

.

In addition, below is a list of the products that were used in connection with drilling fluid

or mud at the Yeager site:

ABS MUL ABS-40 Mud/Slurry ABS-40 Barite

S Ca! Carb Mix S Calcium Chloride S FLR S FM Sperse S FM VIS LS

FM WA U S GXM S ABSORB-N-DRY S HUBERCARS Q40-200 S PERMASEAL S TRU VIS

. __

09/17/2013

Drill Site. See Transcript of meet-and-confer at pp. 8-11, December 17, 2012. As a result,

Range will not respond to this request.


identify all proprietary chemicals, substances and products used in stimulating the Yeager Well

7H.

RESPONSE: Range has produced documents identifying the chemicals,

substances, and products used in the Yeager Well 7H, as well as others that are used above the

surface. The MSDS are often useful for developing some understanding of what is in a

particular chemical or product. However, they vary widely in terms of usefulness. Some

manufacturers include very little information about the actual components of a particular

product. As a result, Range is currently in the process of seeking additional information from

manufacturers that have failed to provide enough information about their products in the MSDS.

We will supplement our responses and production as we receive that information.

In addition, below is a list of the products that were used in the hydraulic fracturing

process at the Yeager 7H Well:

• MC SS-5075 • MC 8-8650 • MCS-2510T • FRW-200 • HVG-i • Unigel CMHPG Guar Product / Carboxymethlhydroxypropyl guar

The MSDS for each of these products has been produced.

43. Please produce any and all documents relative to any spills, releases, discharges

and/or remediation which have occurred or are presently occurring at the Yeager Drill Site.

RESPONSE; Range has produced documents relevant to any spills, releases,

discharges, and remediation at the Yeager Drill Site. Two of the spills/releases were particularly

23

09/17/2013

EXHIBIT 6 09/17/2013

0 SMITH BUTZ

A Ivw,ccoLr'n.n- C,.zre. Ar'*\t,' , A i L'

125 tedint1ogv Drive, Suite 201 5aiky Center I. Southrltnte Ct,oc*.urg.. PA 15317

February 22, 2013

74 EMAIL AND REGUL4R MAIL Kenneth Ko,noroski, Esq. Michael Steindort Esq. Matthew Sepp Esq. Fuibright & Jaworski, LLP 370 Southpointe Blvd., Suite 100 Canonsburg, PA 15317

Re: Loren Kiskadden v. Department of Environmental Protection EHB Docket No 2011-149-R

Dear Counsel:

I am in receipt of Range's Responses and Objections to Appellant's First Set of Interrogatories, Second Set of Requests for Production of Documents and Second Set of Requests for Admissions (collectively, the "Discovery Responses") relative to the above-captioned matter. I am writing pursuant to 25 Pa. Code § 1021.93 in an attempt to confer with you and avoid the necessity of a Motion to Compel. I will address the issues with each section of the Discovery Responses in turn below.

INTERRIOGATORIES

First, reference is made to Range's Responses to Appellant's First Set of Interrogatories. Range did not provide full responses to Interrogatories Nos. 3, 4, 5 and 7. With regard to Interrogatory No. 3, Appellant asks that Range identify all products applied to McAdams Road to prevent the spreading of dust. Range explains that "water" was applied "either by Range or on behalf of Range." This response does not identify the type of water applied nor does it identify who applied the water to the road "on behalf of Range." Range's response that "water" was applied is insufficient in light of the fact that "water" can be used to refer to a 'variety of fluids in the context of this Appeal, i.e., brine water, frac water, flowback., produced water or freshwater. As a result, please identify the type of water applied to McAdams Road and specifically identify who, on behalf of Range, was responsible for its application. Such a response was and is required as part of Appellant's Interrogatory No. 3.

Interrogatories Nos. 4 & 5 ask that Range identify where "in the analytical resting" of the soil sampling for the Yeager Pad Drill Pit Closure and Water Quality Monitoring Plan does it indicate that acetone and methyl-ethyl ketone (MEK) were the result of laboratory contamination. In response to these Interrogatories, Range makes reference to an EPA document which described that acetone and MEK may be common laboratory contaminants.

EXWU

Writer's email: k1sm thithsznithbutzlaw.cont 741121 . 24 74 12', • u, ,n,.tht'u4ilj orfl

09/17/2013

Range Counsel February 22, 2013 Page 2

As explained in the Yeager Pad Drill Pit Closure and Water Quality Monitoring Plan, CEC relied on the fact that acetone and MEK are common laboratory contaminants to support its claim that they are "not suspected to be associated with drill pit operations." While the EPA document may be appropriate guidance, Range has failed to reference any actual analytical data which supports would support claim that acetone and MEK were in fact laboratory contaminants during the testing of soil samples S-Ol through S-17. Appellant requests that Range respond to these Interrogatories in order to properly answer the question originally presented.

Further, Range failed to respond to Interrogatory No. 7. In particular, Interrogatory No. 7 requested, in part, that Range identify whether certain listed products were used at the Yeager Wells, '(eager Impoundment and/or the Yeager Drill Cuttings Pit, including identification of for what purpose the products were used for. Range responded by stating that, "the following products pay have been used at the Yeager Drill Site." (emphasis in original). Additionally, Range further qualified its response by stating that, "the above list includes products that are commonly used for the purposes referenced above but may not have been used at the Yeaer Drill Site." (emphasis added). Because of these qualifications, Range has not answered Appellant's request

The question presented by Interrogatory No. 7 is specific to the Yeager Site. Of most importance, Appellant's inquiry attempts to differentiate those products utilized at specific aspects of the '(eager Site from those that were not used. Although Range identified some products used in "hydraulic fracturing," or "rotary air drilling," it failed to identify from those products which were used specifically at the Yeager Site. Rather, as explained above, Range qualified its response such that any product listed "may not have been used at the '(eager Drill Site." This entirely dodges the impetus of Interrogatory No. 7.

As a result. Appellant is requesting that Range provide a complete response to Interrogatory No. 7 by specifically identifying and including, without qualification, those products actually used at the '(eager Site, the chemical that make-up the product, and the purpose for which it was used.

REQUESTS FOR PRODUCTION OF DOCUMENTS

Second, reference is made to Range's Responses to Appellant's Second Set of Requests for Documents wherein Range failed to produce the documentation responsive to Request Nos. 1,2-7,9-13, 19,22-26 and 28-29. Appellant Will address each in turn below:

With regard to Request No. 1, Appellant requested all documents that Range has collected regarding Appellant's history. Range admitted to performing background research on Appellant, which includes criminal histories and complaints about Appellant's property. However, Range failed to produce any documents it collected relative to the same. Additionally, Range failed to raise a proper objection as Appellant is entitled to any documents that Range has collected regarding his personal life and history.

Writer's email: [email protected]

09/17/2013


Such documentation is discoverable and relevant as it will likely lead to evidence to be used at trial. As a result, Appellant requests that Range produce all documents encompassed by this Request

With regard to Request Nos. 2-7, Appellant requested a variety of documents relative to the March 24, 2010 release from the Yeager Drill Cuttings Pit. Specifically, Appellant made requests for documents, including but not limited to, "inspection reports, notes, memoranda, correspondence, emails, internal company memoranda, summaries and Notices of Violation" Range failed to produce any emails or internal company memoranda responsive to Appellant's requests made in Nos. 2-7 regarding the March 24, 2010 leak, subsequent excavation and clean-up and analytical testing which took place as an incident thereto. Appellant requests that Range supplement Its production to include these documents requested.

With regard to Request No. 9, Appellant requested "any and all documents," including "emails" and "internal company memoranda," regarding the flushing of the Yeager Drill Cuttings Pit with 30,000 gallons of water on July 14, 2011. Range again failed to produce any emails or internal company memoranda responsive to Appellant's request made in No. 9. Appellant requests that Range supplement its production to include these documents requested.

With regard to Request Nos. 10-13, Appellant requested "any and all documents," including "emails" and "internal company memoranda," regarding: 1) the March 2010 release from the Yeager Drill Cuttings Pit, 2) the soils removed from the Pit in May 2011; and 3) any rips, holes and/or tears in the liner of the Pit. While Range provided reference to some documents which were previously produced, none of these documents fell within Appellant's request for "emails" or other "internal company memoranda." Furthermore, in many cases, Range acknowledges that there are "many documents responsive to this request" Yet, Range again failed to produce any emails or internal company memoranda responsive to Appellant's requests made in Nos. 10-13. Appellant requests that Range supplement its production to include these documents requested.

With regard to Request No. 19, Appellant requested "any and all documents," including "emails" and "internal company memoranda," regarding the closure of the Yeager Impoundment. Range failed to produce any emails or internal company memoranda responsive to Appellant's request made in No. 19. Appellant requests that Range supplement its production to include these documents requested.

With regard to Request Nos. 22-23, Appellant requested "any and all documents" relative to drilling fluids bubbling through the stone of the cellar of Yeager Well 7H. Range responded that none of the documents referenced by Appellant refer to "drilling fluids bubbling through the stone." While Appellant used the term "bubbling" to describe the occurrence referenced in RRA-LK 004118, Appellant acknowledges that the document

A- Big

Writer's email: kIsmithsmithbutzawccm

09/17/2013


Nevertheless, Appellant provided reference to the proper documentation such that Range was on notice of what Appellant was referring to in his request. Range further responds that "there was no testing performed" and the "site inspection reports at the most significant documents that address the drill mud in the cellar of Yeager Well 714."

Please note that Appellant requested "any and all documents" - which is not limited to those Range deems "most significant" Furthermore, RRA-LK 004118 indicates that R.R. & Sons was on site digging for the cellars. Additionally, RR.A-LK 004119 indicates that Myzac was on site to clean up the drill mud in the stone pad. Appellant's request encompasses documents relative to these events and the work performed on site. Range's production fails to provide any documents regarding either of these events which were apparently taken in response to the "drill mud pumping through the stone" at Yeager 7Ff. Appellant requests that Range supplement its production to include these documents as well as any other documents as requested.

With regard to Request No. 24, Appellant requested documents regarding "any tiowback or produced water emptied into the Yeager Drill Cuttings Pit as referenced in RRA-KA 004099 [sic].... " Appellant's reference to "RRA-KA 004099" was a typographical error. The proper reference is to "RRA-LK 004099" which describes "flowback trickling into the pit" Notwithstanding this error, Appellant's request for any and all documents regarding flowback in the Yeager Drill Cuttings Pit stands. Range failed to produce any documents responsive to the same. As a result, Appellant requests that Range supplement its production to include these documents.

With regard to Request No. 25, Appellant requested documents addressing the rebuilding of the Yeager Drill Cuttings Pit. While Range produced certain documents which it believes "help summarize those activities," Range failed to produce any documentation indicating how the drill pit was rebuilt, what tasks were undertaken as a part of the rebuilding and who was responsible for those tasks. These documents would clearly fall within the purview of a request for "any and all documents" regarding the Yeager Drill Cuttings Pit rebuilding. As a result, Appellant requests that Range supplement its production to include documents responsive to this request

With regard to Request Nos. 26 and 28. Appellant requested the documents that Range relied upon in its August. 12, 2011 letter to state that: 1) "sodium bicarbonate" is typical groundwater in Appellant's area and 2) elevated levels of iron and manganese suggest that a water well penetrates a coal seam. In response, in part, Range stated that there are publicly available documents which would support this contention. Range further references an EPA study which "may be a useful resource." However, such an explanation fails to response to Appellant's request as presented. Appellant requested ft pecific documents that Range relied ,tpoii when it drafted its August 12, 2011 letter to

Mr. Kiskadden.

Writer's email: [email protected]

09/17/2013


In drafting its August 12, 2011, if Range solely relied upon the referenced EPA study as a basis for its contentions, please confirm that this is the case. Otherwise, Appellant requests that Range supplement its production to include any such docwnentation..

With regard to Request No. 29, Appellant requested any and all methane testing and corresponding QA/QC data. Range responded by providing what it believed in its "opinion" were the "three noteworthy documents" that relate to the methane analysis. However. Appellant requested "any and all" documents, not only those that Range has deemed "noteworthy:' If there are no other documents in existence other than those referenced by Range, please confirm that this is the case. Otherwise, Appellant requests that Range supplement its production to include all documents responsive to the request.

REOUESTS FOR ADMISSION

Third, reference is made to Range's Responses to Appellant's Second Set of Requests for Admissions wherein Range failed to provide an adequate answer to Request Nos. 4, 11, 18, 28, 34, 45, 48-50 and 52. Appellant presented such admission requests to Range in order to narrow the issues for trial and condense the case to be presented before the Board. However, Range fails to respond to the requests as presented by Appellant which fails to allow Appellant to proceed in this fashion. In particular, Appellant has noted the following issues with Range's responses:

Regarding Request Nos. 4, 11, 18, 28, 34 and 52, Appellant requests that Range make admissions regarding certain chemicals being a component of products used in the drilling process at the Yeager Site. In response, Range explains that it cannot admit or deny these requests because, although a chemical may be a component of certain products included in Range's PPC Plan, "most of these products were never even at the Yeager Site, much less used." As such, responses to these requests can be made in conjunction with a complete response to Interrogatory No. 7 which requires Range to specifically identify those products in fact used at the Yeager Site, as explained above. Once Range has identified those products used at the Yeager Site, it can either admit or deny whether certain chemicals identified by Appellant are components of such a product. A response in this fashion would appropriately satisfy the request as presented by Appellant.

- Regarding Request Ns. 45 and 48-50, Appellant requests that Range make certain admissions regarding chemicals that were reported as detected in background soil samples taken pursuant to the Yeager Pad Drill Pit Closure and Water Quality Monitoring Plan. In its responses to these requests, Range fails to answer the question presented by Appellant. For example, in Request No. 45, Appellant asks that Range admit that benzene was NOT detected in the background soil sample. Range admits that "the Pace Report" indicates that benzene was detected in the background soil sample. However, Appellant's request did not ask Range to admit that which was reported by Pace Analytical.

Writer's email: k1smith(4smithbutz1aw,com

09/17/2013


Rather, Appellant's request required Range to review the actual data accompanying the "Pace Report" to determine whether benzene was in fact present in the background soil sample, regardless of the narrative provided. The same is true for Request Nos. 48-50 which make mirroring inquiries regarding toluene and xylene.

I am also in receipt of Range's Amended Responses and Objections to Appellant's Requests for Production of Documents and Requests for Admissions (collectively, the "Amended Discovery Responses"). Pursuant to the Board's Order, counsel for Appellant and counsel for Range previously met to confer regarding the responses Range previously submitted to Appellant's first set of discovery requests. The Amended Discovery Responses were produced by Range pursuant to an agreement reached between the Parties at the "meet and confer" session relative to Appellant's first set of discovery in lieu of Appellant pursuing an already-filed Motion to Compel. However, with Board permission, Appellant reserved his right to pursue his Motion if Range failed to produce documents that were properly requested, including documents relative to the proprietary information of the products used by Range at the Yeager Site (See, Request Nos. 37, 38 and 42). In its Amended Discovery Responses, Range indicated it was seeking the proprietary information sought from the product manufacturers To date, Appellant has not received any additional documentation from Range in this regard. Please advise as to the status of this endeavor and when Appellant can expect to receive the proprietary information requested. If Range is unable to satisfy this production by March 4, 2013. Appellant will be forced to renew his Motion to Compel on this matter before the Board.

As a result of the foregoing, I am requesting that you please send revised answers that fully respond to Appellant's requests. Such a course of action will appropriate limit the issues for the Board's consideration at trial. Because these responses were already submitted pursuant to an extended deadline, I am requesting your response no later than March 4, 2013. In the event that you are unable to supplement your responses in the manner requested above, I will be forced to file a Motion to Compel. I look forward to hearing from you..

V truly yours,

Cc: Rick Watling, Esq.

Writcr' email: [email protected]

09/17/2013

EXHIBIT 7

09/17/2013

Transcript of the Testimony of March 12, 2013 meeting

Date: March 12, 2013 Volume:

Case: Loren Kiskadden v. Department of Environmental Protection

Eagle Feather Reporting Phone: 724-746-3383

Fax: 724-746-3383 Email:[email protected]

FXHIW

09/17/2013

147

1 that would be used in the drilling process.

2 MS. SMITH: That's why we asked in

3

the Interrogatories be specific about. Because

4 otherwise this is just around and around and

5

around. It doesn't solve the problem. Again,

6 our goal for this is to narrow the issues for

7

trial. To agree upon the products that were

8

there. And agree upon their content.

9 It seems like it would be a fairly simple

10 task. Which, obviously, it's not. But seems

11 like it would be a very simple task to get to

12 and get done because Range has knowledge of

13 what was used there. They have the MSDS for

14 the product. And the product will list what

15 the chemical is. And then if there's a

16 proprietary chemical, then that's also

17 addressed in our letter.

18 You weren't at the first meet and confer

19 with Mr. Kornoroski where he indicated that he

20 was going to do his best to get all of that

21 information to us. He then represented that in

22 a hearing before the Judge where the Judge

23 indicated you will get it to us. And if you

24 run into problems in trying to get that from

25 your you us-e-,---then


09/17/2013

148

1 you come back and you tell us.

2 The response that we got to that in

3 discovery was we're still trying.

4 MR. GIBBS: Yes. I can tell you

5

that.

6

MS. SMITH: I appreciate the trying.

7

But this is now four months old since the first

8 time we had the meet and confer and conference

9 with the Judge.

10

MR. GIBBS: In December?

11 MS. SMITH: Was it December?

12 MR. GIBBS: Three months. I mean, I

13 can you tell you that responses are trickling

14 in. And we will, in fact, produce all the

15 documents we get in response. Not all

16 responses are positive. But you know --

17 MS. SMITH: I think -- and maybe this

18 will help because if you're getting responses

19 from the third-party contractor saying we're

20 not giving it to you, then that needs to be

21 identified to us. Because then what the Court

22 indicated is he'll give us an order making them

23 give it to us. So for you as Range asking for

24 it, they won't provide it to you, the Court

25already said he will issue an order to get


09/17/2013

149

1 So if you can identify -- right now

2 identify the ones that say, nope, we're not

3 giving it to you, then I can take that to the

4 Court. And we can get that done that way.

5 That takes that off your plate to give to us.

6

If you're getting responses, you know, from

7 people, identify the people you're getting

8 responses to and we'll hold off on compelling

9

anything from them. But if you've gotten

10 people that say definitely not, identify those

11 people to us and we'll go to court with it.

12 Because the whole conversation with the Judge

13 was and Mr. Komoroski -- and I take him at his

14 word -- said we'll do our very best to get this

15

information. But understand because some of it

16

is proprietary they may not be willing to give

17

it to us.

MR. GIBBS: Right.

19

MS. SMITH: I understand that. The

20

Judge's response to it was we're going to get

21 it one way or the other. You make your best

22 effort to get it. If you get road blocked, you

23 come back to me and we'll go another avenue to

24 get it. So that's why I am requesting here

25 today with regard to proprietary stuff as you


09/17/2013

150

1 have represented you have got some positive

2 responses and some not so positive responses.

3

If you have gotten ones that say we're not

4 going to provide that to you or you have got to

5

jump through a million hoops to get it, please

6 identify those people for us in the letter on

7

Tuesday. And then we'll take it from there

8 with the Judge to say, Your Honor, these are

9

the ones that Range identified that will not

10 produce the documents. And then the Judge has

11 already said he will do what he needs to do to

12 make that happen.

13

MR. GIBBS: Okay. I mean, there are

14 some who have committed to, you know, research

15 the issue and get back to us. I certainly

16 don't want to push them with an order from the

17 Judge at this point.

18 MS. SMITH: And that's our problem.

19 At this point it needs to be pushed. Because

20 we have deadlines coming and going left and

21 right. And that was part of the reason for

22 getting the continuance yesterday was here are

23 the proprietary chemicals that we have no

24 knowledge of. Range has answered in Request

25 for Admissions they don't know. The DEP has


09/17/2013

151

1 answered in Request for Admissions they don't

2 know. So the only person that has that is this

3 third-party contractor who is not a party to

4 this case who has to be in some way made to

5 give this information because this information

6 is needed by our experts to complete their

7 reports.

8 And so there is -- time is of the essence

9 now in terms of getting that information. We

10 have waited and we have waited. So if they

11 have gotten back to you and said, yeah, we will

12 get back to you, there's got to be some

13 timeframe with that. It's not that they get

14 back to us in a year. I mean, this case won't

15 be around in a year. So if they're dragging

16 their feet on it -- it's been several weeks or

17 several months, you know, then that needs to be

18 indicated, too. So we can we make a decision

19 along with the Judge as to how we're going to

20 proceed.

21 Maybe that's a conference. Maybe that's a

22 conference call with the Judge to say, look,

23 Your Honor, these five companies have said

24 absolutely we're not giving it to you. These

25 companies say we're looking into. We'll get


09/17/2013

152

1 back to you. Have not yet. And then maybe the

2 Judge issues some sort of order that puts a

3 deadline on it. Something so that we are

4 advancing the ball forward. Because I ant sure

5 it doesn't look like from your perspective.

6 But from our perspective it looks like the ball

7 has been stagnant for three months. Because we

8 have had no response. We have had no

9 supplement. We have no information given to us

10 where this stands.

11 And the Judge has asked us to come back.

12 In fact, we have a motion pending. And he

13 said, you come back, that motion is renewed and

14 I will rule on it. So we're kind of in this

15 limbo area.

16 MR. GIBBS: Right. And I mean, I

17 think it's important to understand, too, that

18 those requests to the third parties did not go

19 immediately in December. I mean, first we had

20 to go through and identify each third party.

21 Locate them. Determine what was, in fact,

22 missing on their MSDS so that we could give an

23 appropriately precise description of what we're

24 seeking. And so you know a lot of those didn't

25 go out until February. So we still --I think


09/17/2013

153

1 that it's appropriate to leave additional time

2 for the third parties to --

3 MS. SMITH: I am not saying that I am

4 objectionable to that. That needs to be laid

5 out in a letter. Like, you know, these are the

6 companies we sent out to, you know, information

requests to these particular companies on these

dates. To date, we have received nos from

whomever. We have received we're looking into

10 it from whoever. We've received, you know,

11 definitely yes and have received documents in.

12 If you already have documents in under the

13 discovery rules, you have to supplement when

14 you get them. So we would request that you

15

provide them.

16

But in that letter give us an indication

17

so we can go back to the Court and say, look,

18 Your Honor, at this point you know we may need

19 your help because it doesn't appear as though

20 -- it appears that Range is doing what they

21 need to do but these other companies are a bit

22

of a stone wall for it. So we're asking for

23

your intervention with it. So that we can

24 provide an update because there is that motion

25pending out there that he is ready to rule on,


09/17/2013

154

1 you know, given whatever comes back from those

2 companies.

3 MR. GIBBS: All right. I can try to

4 sort of compile everything into, you know, a

5 single spread sheet or something like that and

6 let you know the status of --

7 MS. SMITH: That would be great. And

8 if you could incorporate that into the letter

9 that would be very helpful. So that we can

10 kind of make a decision as to what we need to

11 move on. What we can wait on. And that sort

12 of thing.

13 MR. GIBBS: Okay.

14 MS. SMITH: And then so going back to

15 our Request for Admission I think we covered

16 it. So our point with asking about the

17 chemicals is these are the products on site,

18 admit that within these product these are the

19 chemicals. And that's how those two are tied

20 together.

21 So when there's clarification from you guys

22 as to specifically what was used at the site in

23 terms of the product, then I think that the

24 Request for Admissions you guys need to go back

- 25 and be specific and answer, yes, this chemical


09/17/2013

EXHIBIT 8

09/17/2013

Kendra L Smith, Esq. March 25, 2013 Page 4

Product

Manufacturer

Response Notes Date

ASS-40

LTD 3/20113

LTD 3/20/13

LTD 3/20/13

Email response seeking additional background on the case, which was provided on 3,20. Awaiting follow-up response. Email response seeking additional background on the case, which was provided on 3/20. Awaking follow-up response. Email response seeking additional background on the case, which was provided on 3/20. Awaiting follow-up

requesting that we resend the MSDS. Awaiting additional

3/5/13

requesting that we resend the MSDS. Awaiting additional

Products Corporation manufactures Berkebile Starting

Berkeb0e 2+2 Staling

The Berkebile Oil

Fluid. A letter will be sent to Cornoanv. Inc.

counsel. Awaiting follow-up /1

96075747.1

09/17/2013

Kendra L. Smith, Esq. March 25, 2013 Page 5

Federal stated that It does not manufacture FED SEAL Federal directed us to Cedar Fiber Company. A letter has been sent to Cedar Fiber

Fed Seal Federal 3/11/13 Response by letter stating that Clearwater does not manufacture Flo Stop P but purchases it from another company, applies a label, and resells It The letter directed us to a company called Ineos. A letter will be sent to Ineos

Flo Stop P Clearwater International 3113/13 seeking the same information. Email response seeking additional background on the case, which was provided on 3/20. Awaiting fbHow-up

FIR Fluids Management; LTD 3/20/13 response.

Eureka Chemical Fluid Film Non-Aerosol Company

Email response seeking additional background on the case, which was provided on

FM Sperse AES Drilling Fluids, LLC 3/20/13 response.

Emall response seeking additional background on the case, which was provided on 3120. Awaiting follow-up

FM VIS LS AES Drilling Fluids, LL.0 3/20/13 response Email response seeking additional background on the case, which was provided on 3120. Awaiting fbIlow-up

FM WA II AES Drilling Fluids, LLC 3120113 response

FRW200 idustrfal Compounding.


GX M Fluids Management; LTD 3f20/13 reeponse Outside counsel sent a letter staffing that the information would not be provided because it is proprletanj and disclosure would

HI-Mar DEC. 503/Octafoam 270 HI-Mar SpecIalties 31

cause substantial harm to I-fl- 2/13 Mar's business.

r1v Indusiel Compounding,

96078747.1

09/17/2013

Kendra 1. Smith, Esq. March 25, 2013 Page 6

Hydrous Silicate of Alumina / Wyoming Sodium Bentonite I

Technical data sheet providing

Industrial Enamel,

Return to sender. Will attempt to find alternative address and/or source of information. Return to sender. Will attempt to find alternative address and/or source of information.

Delivery refused; return to sender. Will attempt to find alternative address and/or source of uformatlon.

Letter enclosing current Safety Data Sheet Phone call and email. Original Rapid Tap replaced by "New Rapid Tap." Provided MSDS for "New Rapid Tap" Letter stating that the requested Information will not be provided without a protective order. Follow-up phone call to discuss possibility of additional disclosure. Awaiting additional information. if any.

North America 3/7/13

Jvi ranItus.. - MC 8-8650 MC DF-7120 MC S-251 OT MC 55-5075

MOBIL RARUS 427 MOBIL RARUS SH( 1026

68

PS Penetrating Catalyst /

3

3/1 mall response seeidng

additional backgrod on the case, which was provided on 30. Awaiting follow-up

GASKET MARKER 50Z

STARTING FLID I The

96015747.1

09/17/2013

Kendra L Smith, Esq. March 25, 2013 Page 7

- Outside counsel sent letter stating that requested information would not be provided. Enclosed information in support of the products non toxicity and environmental soundness. Also provided 2010

Simple Green Sunshine Makers 3/12/13 and 2011 MSDS. Sperlan Sterile Saline Spartan Eye & Face Solution Protection, Inc.

Return to sender. Will attempt to find alternative address and/or

SPIFaX(R) S 80W-140 Equllon Enterprises LLC 3/10/13 source of information.

Stripe Fluorescent Phone call and email. Full Red/Orange Seymour of Sycamore 3/4/13 formula provided.


Fluids Management 3/20. Awaiting follow-up TRU VIS Division of AES LLC 3/20/13 response.

Unigal CMHPG Guar Product W.O. Defoam

Response by letter stating that the requested information would be provided if a protective order were In place. However, the

United States Gypsum information will not be provided W-0 Gypsum Cement Company 3113/13 without a protective order.

White Collar Bestolife Corporation Multiple phone calls and emalls. A ZEP employee explained that Cherry Bomb" Is a cleaning

product for use on the skin and non-hazardous. Provided "Product Specification Report"

ZEP Cherry Bomb ZEP Manufacturing 315/13 AwaitIng follow-up NOW as welt. Multiple phone calls and emalls. Provided "Product Specification Report" Awaiting follow-up letter

ZEP Groovy ZEP Manufacturing 3/5113 as well,

96018747.1

09/17/2013

EXHIBIT 9 09/17/2013

1


MR. LOREN KISKADDEN

versus

COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF ENVIRONMENTAL PROTECTION and RANGE RESOURCES APPALACHIA, LLC, Permittee


*****

Verbatim transcript of hearing held at the Pittsburgh Office and Court Facility, Piatt Place,

301 Fifth Avenue, Suite 310, Pittsburgh, Pennsylvania,

Thursday, June 26, 2013

10:15 am.

BEFORE: THOMAS W. REN WAND, Administrative Law Judge

ADELMAN REPORTERS 302 Torrey Pine Drive

Mam '16046

9

09/17/2013

APPEARANCES: KENDRA L. SMITH, ESQUIRE JENNIFER L. FAHNESTOCK, ESQUIRE 125 Technology Drive, Suite 202 Bailey Center I Canonsburg, PA 15317

ALSO PRESENT; Maryanne Wesdock, Esquire Bruce E. Rende, Esquire Paul K. Vey, Esquire

For - Mr. Loren Kiskadden

RICHARD I. WAILING, ESQUIRE MICHAEL J. HEILMAN, ESQUIRE Department of Environmental Protection Southwest Regional Counsel 400 Waterfront Drive Pittsburgh, PA 15222

For - Commonwealth of Pennsylvania, Department of Environmental Protection

4~~

STEVEN E.H. GIBBS, ESQUIRE Southpointe Energy Complex 370 Soutpointe Boulevard Suite 300 Canonsburg, PA 15317

For - Range Resources Appalachia, LLC

09/17/2013

U

19

21

because of the proprietary nature or the MSDS where It

doesn ' t have the other 70 percent."

This all links back to why we need to know what

that proprietary information is; because seemingly, it

is stopping Range from even being able to answer

requests for admissions that would, on their face, seen

simple to answer if you would know that information

So, all of those go to specific chemicals and I

won't go through each one. But I've listed for you what

those requests for admissions are. But they do go to

specific chemicals within products, again, linking it

back to you need to know what those are. That is the

gamut of everything for Range the two Range motions

to compel.

JUDGE RENWPND: What is the law, you know, in

this area in terms of if somebody alleges, you know,

that their property is polluted by, you know, the

permittee and permittee says, 'Well, we don't know

what's in our the chemicals that we used." Did you

find any law on that?

MS. SMITH: In terms of whether

JUDGE RENWAND: I mean, you find chemicals. I

assume you find, you know, chemicals A, B and C. And

you ask them to admit that was in their products and we

don't know. We don't know what is in the product

1

requesting is for them to tell me what chemicals are in

2

there. So, I don't think -

3

JUDGE RENWAND: But you want the chemicals

4

listed, you know, just chemicals, whatever chemicals are

5 there?

6

MS. SMITH: EXdCtly, Your Honor. And so

7

JUDGE RENWAND: And what I'm asking you, I assume

8 this has come up in other contexts where companies find

9 themselves in the same position that Range is in now.

10

And where does the you know, are there

11 inferences or presumptions that are made?

12

MS. SMITH: Right. So, the case law that I'm

13 familiar with, Your Honor, if the company for whatever

14

reason can't give up that proprietariness of their

15 product which the case law --

16

JUDGERENWAND: They are going to tell me, I'm

17 sure from what I've read, that we would love to give you

18 that. I think Attorney Komoroski said that in one of

19 the transcripts, but we don't have the information.

20

You know, these various companies have it and we

21 wrote to them and they told us we are looking at it or,

22 you know, we don't reveal this information. It is

23 company policy not to reveal it.

24

MS. SMITH: Right, right.

25

JUDGE RENWAND: You know, other legal speak which

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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IN 25

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because we ask the people who we bought the products

from and they say, "We cant tell you. It is

proprietary."

MS. SMITH: Right. And I think where that comes

in, Your Honor, is kind of in a couple of different

areas of the law. Number one, with regard to the

proprietary information, that is where this kind of

dovetails with the proprietary information while the

manufacturer may be the holder of that trade secret;

certainty, that information can be divulged and

protected in some way. So, it is not as though you

can't s et to it and have it. And certainly if -

JUDGE REqWAND: You are not asking for the

formula either, are you? You are just asking for the

components?

MS. SMITH; Yes. For purposes of this case, Your

Honor, that is what I reed to know to say, "This is whit

is in Mr:. Kiskadden's water. You used it up at, the

site, It was in the empiiernent. It was in the drill

cuttings pit. Thse things leaked. They are in Mr.

- d -i

So, hLs ra y stym.us this who PrccesC3to

gttirq 'o that rvJ pi rt. And t, t t 1i rqetirg

o t speak, Ca-Cola fcrmiU. rn

1 ends up in you don't know what it is, and they don't

2 know what it is

3

MS. SMITH: Right. So, I think where the

4 crossroads come down to if the company is not willing to

5 give that proprietary information, then it leaves us in

6 the position of asking the court for an adverse

7

inference, that if you are not going to tell us what is

8 there, then what we can identify as being there came

9 from you.

10

I mean t that is our alternative. i don't

11

necessarily think that is fait, to Range to do that, hut

12

if Range isn't willing to talk to the manufacturers to

13 get that information more so - I mean, Mr. Komoroski

14 characterized it as their good faith effort and they

15

have no obligation to do that. Well, if that is tru.y

16 how Range feels that they have no obligation to do i,

17

then in turn, Your Honor, t would ask for an adverse

18

inference

19

JUDGE RENWAND: That is hre 11 ask for Lh

20

law, because I haven't

w cn get that to y;u, ''our

23

TJYJE RNWAND mean, you don ' t 'e to qTt

24

to ne now 'cause th issue i in frr:oflt or ne,

23

but it; is going ti be That covers

09/17/2013

23

25

IM

1 everything with -

2 MS. SMITH: for Range.

3 JUDGE RENWAND: For Range, okay.

4 MS. SMITH: Thank you, Your Honor.

5 MR. GI8BS: Good morning, Your Honor.

6 JUDGE RENWAND: Good morning.

7 MR. GIBBS: Steve Gibbs of Fuibright and Jaworski

8 on behalf of Range.

9 As an initial matter, I think that we set forth

10 the law in our response to appellant's motion to compel

11 and it is fairly clear that according to Rule 4009.21,

12 the proper procedure for compelling production of

13 documents in the possession or the control of a third

14 party is through a subpoena to the third party; and as a

15 result, Range has made a good faith effort to obtain the

16 information from the third parties.

17 Counsel for appellant indicated that if Range

18 didn't wasn't willing to communicate with the third

19 parties, then an adverse inference was appropriate, I'm

20 not even sure that is true; but obviously, Range sent

21 letters to every single one of the third parties,

22 communicated with and followed up; and beyond that,

23 Range really does not have control over the

24 JUDGE RENWAND: But Range used all these

25 products.

I , all the chemicals that are hazardous are listed,

2 right?

3 MR. GIBBS: Correct, that is my understanding.

4 JUDGE RENWAND: So, what they are saying is what

5 is proprietary is water, things like that?

6 MR. GIBBS: There may be another point that

7 should be made here. On the MSDS themselves, some of

B the hazardous -- some of the compounds that may have a

9 hazardous component are also the same as proprietary

10 that doesn't occur in some instances.

11 JUDGE RENWAND: I guess as she is saying, she is

12 not asking for the formula. She is just asking for the

13 listing.

14 HR. GIBBS: Of every element or compound that --

15 JUDGE RENWAND: Right. These are chemicals that

16 are put into the ground, Into the environment.

17 MR. GIBBS: In some instances.

18 JUDGE RENWAND: Well, what instances aren't

19 there?

20 MR. GIBBS: Range sent letters to every third

21 party that both hadn't provided an WEDS where the

22 chemicals added up to 100 percent of the formula by

23 volume or weight and for which the chemicals or the --

24 I'm sorry, the products were actually on site at some

25 point,

24

1 MR. GIBBS: That is correct

2 JUDGE RENWAND: And you haven't told the

3 Department what is in those products; is that my

4 understanding?

5 MR. GIBBS: The MSDS sheets list -- my

6 understanding is that they list all the hazardous

7 chemicals. Now, beyond that, there may be non-hazardous

8 chemicals and certain companies list those as well,

9 certain companies don't.

10 JUDGE RENWAND: So, your position is that they

11 list all the hazardous chemicals? And she has the list

12 of the hazardous chemicals, that would be by this MSDS

13 definition of hazardous chemicals?

14 MR. GIBBS: That is correct, Regardless of that,

15 Range realty there is nothing more that Range can do

16 to--

17 JUDGE RENWAND: Really? Really? Range can't do

18 anything more, huh?

19 MR. GIBBS: Well, I mean, Range has sent

20 OOrte5pcndence to every one of those.

22 ;;R.ciIoEl : EcU 11.5 .sieoec cc. iouecotse

23 sac, "Thiele proprietary."

24 JUt/If RENWAND: And it's proprietary, because it

25 3a not the formula. Whet coo 'cc said is on lihe3e sheets

26

1 So, in other words, if Range already had 100

2 percent of the formula, no Correspondence was sent. And

3 for MSDS and, for example, the PlC plan for which the

4 products were never at the site, Range didn't send

5 correspondence for that. It was simply products that

6 were at the site for which part of the formula was

7 missing.

8 JUDGE RENWAND: Well, what you are saying is you

9 didn't send letters to somebody whose product you didn't

10 use at that site?

11 MR. GIBBS: Correct. And so, to your point, that

12 includes things such as paint and duct tape, things that

13 did not go into the ground.

14 JUDGE REN1,1AN;3: Right. I didn't think -- okay.

15 I didn't think that would be that encompassing.

16 MR. GIBBS: Well, my understanding was that you

17 were saying that everything -- these chemicals were our

18 into the ground, and that is not true at all in this

19 tnstance.

20 JUDC' Pc' : .952.0....

act a itmt of all the chemiC5s that mete

22 put sub coo r,osi.O

23 MR. G', BPS: No, we sent a itst of all the

24 products with their associated ESUS.

25 JUDGE P.EtISAND: You sent a iLtd, of sit the

09/17/2013

products; and I mean, we are sort of going around here

circularly. You are saying that the MSDS the MSDS

sheet has a list of all the products that could cause

anybody any harm?

MR. GIBBS: My understanding of what an MSDS

sheet contains is that it contains all of the hazardous

chemicals. Whether or not there is the potential for

harm from something else, I'm not prepared to make that

representation. I would imagine I could get harmed by

eating too many Twinkles.

JUDGE RENWAND: But you say those other, whatever

they are, ingredients, you are not going to -- you can't

get that information. The companies have revealed the

Benzene, the Toluene, the whatever, the stuff that could

hurt you but this other stuff is proprietary. That is

the argument?

MR. GIBBS: Not in all instances. I'm simply

saying that in some instances, that is the way it breaks

down. And, in fact, there are a number of companies

that sent either their entire formula or some sort of

additional information about chemicals or chemicals that

were not listed on the MSDS.

JUDGE RENWAND: Okay.

MR. GIBBS: In

JUDGE RENWAND: So, your response to the listing

1

JUDGE RENWAND: Yeah, I think if she tells you

2 that it is chemical A and you contact one of these

3 companies and they say, "We are all full of chemical A,"

4 do you think you get it from them?

5

MR. GIBBS: I mean, based on

6

JUDGE RENWPND: But you are saying the risk

7 should fall on Mr. Kiskadden?

8

MR, GIBBS: You mean, in terms of obtaining the

9 information or

10

JUDGE RENWAND: You say Range is an innocent

11 party here, that Range put products into the ground but

12 you can't tell her -- correct me if I am wrong. I mean,

13 her argument is you can't tell her what is in those

14 arguments and what you are saying is, "We've done our

15 best. We've contacted all of these people who aren't

16 parties to this action, and we've asked them for their

17 ingredients and they've told us no."

18

MR. GIBBS: That is correct but except for the

19 fact that they have the MSDS which, at least in theory,

20 represent all of the hazardous components in those

21 products.

22

JUDGE RENWAND: Yeah. I guess the question is if

23 all the hazardous components are in those products and

24 the non-hazardous components are like water and

25 whatever, I mean, why is that fight being made? I don't

27

8

9

10

11

12

13

14

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18

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20

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20

28

of all the chemicals is what?

MR. GIBBS: With respect to?

JUDGE REMWAND: To her motion to compel.

MR. GIBBS: As an initial matter, it simply isn't

within Range's control to provide this information.

There is no relief available, because Range can't be

compelled to provide information that it does not have.

Now, I mean, Range is willing to cooperate in any

way possible. No path forward has been suggested.

It might he helpful if appellant were able to put

together a list of things that he believes may be in his

water and Range could go back to the companies and say,

"Do you does your product contain any of these?"

We sent interrogatories asking for what appellant

alleges contaminated his water, and we were told that

required an expert opinion. And during our meet and

confer we were, in fact, told that, yea, appellant's

counsel would be able to answer a question like that but

because appellant himself could;;' t, we don't gel that

answer.

30

1 understand.

2

MR. GIBBS: I assume for the same reason that,

3 you know, Coca-Cola wouldn't give you their product

4 information because you could then replicate their

5 product. That is --

6

JUDGE REMWAND: Well, I think if you look at a

7

Coca-Cola can, it will tell you what the ingredients

8

are. I'm looking at a Gatorade can right now, and it's

9 telling me everything that is in here. Now, these are

10 different, literally comparing apples and oranges here.

11

But, as I understand it, that is all she is

12 asking for. And I guess to analogize it, one of the

13

things in here is citric acid, sucrose, salt. Water is

14 one of them. I guess the way you are telling me would

15

be like if Gatorade said, "Okay. We will tell you abujt

16 the sucrose, citric acid, at cetera, but we are not

17 saying anything about that water." Is that what you are

18

telling me?

19

MR. GIBBS: Perhaps, not exactly. Because when

Imean, on askod tot each cOsuonent 'icc rtnibut ion to

22 uaruasi px rl05 c aid i5kiri7 Locs fwn ii wit:: or upriaLir - i 22

Ih.i oh Ia Si a percuitagu.

23 t force:: ;ur: it would be s'slpfu l jr we could narrow Inc 23

So, I mean, i suppose it is cuss ible that cotta in

24 soup.n of than in some way. That doesn't zneari that Insy 24 compa flies ubj acted to I not . tii I whet: we soc,ke to then,

25 mc ecirP to he my sore :aii]irgto provide it but 25

1 a lot ow- up irid ii be:1 for, you mow, a s t 51 113 thaI hey

09/17/2013

EXHIBIT 10 09/17/2013

August 20, 2013

VIA FEDERAL EXPRESS

John M. Smith, Esq. Kendra L. Smith, Esq. Smith Butz, LLC 125 Technology Drive, Suite 202 Bailey Center I, Southpointe Canonsburg, PA 15317

Michael Heilman, Esq. Richard Watling, Esq. Department of Environmental Protection Southwest Regional Office 400 Waterfront Drive Pittsburgh, PA 15222

A NORTON ROSE FULBRIGHT Fuibright & Jaworski LLP Southpointe Energy Complex 370 Southpointe Boulevard, Suite 300 Canonsburg, Pennsylvania 15317 United States

Kenneth S. Komoroski Partner-in-Charge, Pittsburgh-Southpolnte Direct line +1 724 416 0420 kenneth.komoroskinortonrosefulbright.com

Tel +1 724 416 0400 Fax +1 724 416 0404 nortonrosefulbright.com

Re: Kiskadden V. Dep't of Envtl. Prot. , EHB Docket No. 2011-149-R

Dear Counsel:

As mandated by the Board's July 19, 2013, Order [Dkt. 196], please find enclosed Permittee Range Resources - Appalachia, LLC's ("Range") Amended Responses to selected portions of Appellant's First Set of Interrogatories and Second Set of Requests for Admission.

In addition to these responses, we have also attached a separate spreadsheet that summarizes Range's efforts to date with regard to obtaining manufacturer information for proprietary compounds. In these charts, Range has provided a list of products and their ingredients as listed on the MSDS sheets, and, if applicable, any further response that Range has received from the product manufacturer. As discussed during the recent status conference, Range is currently exploring additional options in this regard, and Range remains committed to doing everything it can to further the efforts to obtain this information.

Also enclosed is a disc containing a supplement to Permittee Range Resources —Appalachia, LLC's ("Range") previous productions that occurred on or around October 29, 2012, November 21, 2012, January 15, 2013, and April 10, 2013. The documents in this production are bates numbered RRA-LK_001 1304 - RRA-LK_0014239. Range reserves the right to supplement this production on a rolling basis.

Documents bates numbered RRA-LK_001 1304 - RRA-LK_0013487 are the documents from the August 7, 2013, Haney Action production. Documents bates numbered RRA-LK_001 3488 to RRA-LK 0014239 are specifically responsive to certain of your requests in this action, but they have not yet been produced in the Haney Action. We will be supplementing this production with additional productions from the Haney Action in the coming weeks and months. Once those productions are complete, we will let you know, and Range will provide a signed verification.

Should you have an questions, please feel free to contact me at your convenience---

Fuibrlght & Jaworski LIP is a limited liability partnership registered under the laws of Texas. F)(HIBIT Fuibright & Jaworsic LIP, Norton Rose Fulbrlght LIP, Norton Rose Fulbitght Australia, Norton Rose Fulb1ght Canada tIP, South Africa (incorporated as Deneys Reltz. Inc.), each of which Is a separate legal entity, are members of Norton Rose F. Verein. Details of each entity, with certain regulatory Information, are at nortonrosefulbrlght.com . Norton Rose Fuibright Verei activities of the members but does not itself provide legal services to clients.

09/17/2013

John M. Smith Kendra L. Smith

Michael Heilman Richard Watling

August 20, 2013 Page 2

A,

NORTON ROSE FULBRIGHT

Sincerely,

156 Kenneth S. Komoroski

KSK Enclosures

cc: Bruce Rende

..-.-.- -..- -

96201285.2

09/17/2013

Information Responsive to Paragraph 9 of July 19, 2013 EHB Order

09/17/2013

09/17/2013

MC FA-4012 Foaming Agent I S Corvr4lon Inhibitor Combination MC E4O12 Foaming Agent I S Carrkn Inhibitor CombInation MC -4O12 Foaming Agent I S Corrosion Inhibitor Combination

Multi-Chem

Multi-Chem

LIC

LLC

LLC

1.2 Ethanediol

Unidentified

Ether <10%

<8.5%

Me

Multi-Chem

lOT

133K

133K nti-Seize Lubricant BOZ 133K Anti-Seize Lubricant 80Z

A Brand of ITW Devcon A Brand of ITW Devcon A Brand of 11W Devcon

A Brand of 11W Devcon

'i -. >2->8_I >83-<.5% 1-109 15-21.

I

tit Stun Gasket Maker 502 CO

Inc. Terminated

I

09/17/2013

201 10

<1 Cl

D

acetate

1 ore I

F

flgHUIcI sgray'rc pose eane Simple Cleaner IDees&I

Green Scrubbing Pad Sunshine ipos. Cleana Simple I ClewwF Degeaserl Green Scrubbino Pad Sunshine

Inc undikited

Inc. Unidantif cal Companies, Inc. Carbon C cat Companies. Inc. Distillatei

al Companies. Inc. Solvent r cal Companies. Inc. Distillate

a1 cornoanies. Inc. Diorook

roleum, he • solvent-d ethyl ether

arom.

>94%

I

5

09/17/2013

09/17/2013

Information Responsive to Paragraph 9 of July 19 2013 EHB Order

Product Information Based on Manufacturers ' Responses to Range's Requests for Additional Product Information

Silicate of Alumina / Wyoming Bentonita/Sodium Montrmorlllonite Black Hills Bentonite

Silicate of Alumina / Wyoming Bentonite/Sodium Montrmoilllonite Black Hills Bentonite

P)rupI.x Blue 2 BP Lubricants USA 1

no chemicals or

Calcium Carbonate 5-10% N 250- Severely

Sciv1 Reined Heavy Pamifinic Palrvisum ON

Baseail- hiityreflned (100%) Hygold L2000 - Hydrotreated Heavy Naphthenlc Distillate

Base oil - hy refined 1 (100%)

Sodium hydroxide 1.3% 2-Acrylamido-2-methyl- 1 -propanesulfonic acid 70.73%

Glacial acrylic acid 22.25%

Ammonium persulfate 2.90%

2-Mercaptoethanol 2.78% Silicone Polymer Emulsion 0.04%

M'ulac*Jrer response at RRA-LX 011184

Manidacturer response at RRA-LK 011184

Manufacturer response and typical chemical analysis at RRA-t.K 01 1219

Manufacturer response and typical chemical analysis at RRA-LK 011219 Manufacbser response at RRA-U( 010830

response at

Manufacturer response at RRA-LK 010830 Manufacturer response at RRA-LK 011243 Manufacturer response at RRA-LK 011243 Manufacturer response at RRA-LK 011243 Manufacturer response at RRA-LK 011243 Manufacturer response at

LRRALK 011243 Manufacturer response at RRA-LK 011243

Blue 2

USA

Blue 2 BPLubdcants USA Inc,

Fritz Industries, Inc.




PC



1

09/17/2013

mducrsplacedbyNaw Rapid Tap for which composition Is provided In Columns C and D. Manufacturer response at

Rapid Isp Raton Corpprathcn 100 Nel OR 41.82% RRA-LK 010851 roductrep4acedby"Now

Rapid Tap for which - composition Is provided In

Columns C and D. Manufacturer response at

Rapid Tap Ralton Cxporation Chlonvax 5OLV 36.37% RRA-LK 010851 Product replaced by New Rapid Tap,* for composition is provided in Columns C and D. Manufacturer response at

(Ij Rapid Tap Ralton Corporation Lubdzol 5347 5.00% RRA-LK 010851 Product replaced by *New Rapid Tap, for which composition Is provided in

• Columns C and D. Manufacturer response at

___ 1 RapId Tap Refton Corporation LtrtuiI 5340MW 0.75% RRA-Lt( 010851 Product replaced by "New Rapid Tap," for which composition Is provided In Columns C and D.

________

Manufacturer response at

O,in Rapid To Raltan Corporelion EWS Lard Ci 4.62% RRA-LK 010851 Product replaced by 'Mew Rapid Tap" for which composition Is provided In Columns ç and D. Manufacturer response at

Ck1gInlRzq3ld lap Rattan Corporation PPG-425 4.80% RRMJ( 010851 Product - Vy New Rapid Tap, for which con ip osldo,i Is provided Wi Co&imnsCandQ.

cimaman BQ Manufacturer response at

0In4 Rapid Tap lRokon Caporatlon 14MIlPF 10.06% JRRA4U( 010851

09/17/2013

p

iporetlon Lubrtzd3l4OJ 020% Naphtha (petroleum),

of Sycamore hydrotreated light 19.15%

of Sycamore - propane 15.13%

of Sycamore Calcium Carbonate 12.07%

of Sycamore n-butane 8.88%

of Sycamore V.T. Alkyd Resin 10.40%

of Sycamore Mineral Spirits 3.78%

of Sycamore isobutyl acetate 3.23%

of Sycamore TLnitan Tnoleate 0.75% boiling point

of Sycamore htha 1 0.64%

X Soybean c 6.00

.100 0.10

Rapid Tap," for which composition is provided In Columns C and D. Mnufacturer response at RRA-ILI( 010851 Product replaced by "New Rapid Tap,' for which composition is provided In Columns C and D. Manufacturer response at RRA-LK 010851 Product replaced by 'New Rapid Tape" for which composition Is provided In Columns C and D. Manufacturer response at RRA-LK 010851 Product replaced by 'New RapldTap,' for which composition Is provided in Columns ç and D. Manufacturer response at RRA..U( 010851 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857

3

09/17/2013

M

Green

Green

mmoruum

~ Olourescent Red/Orange Seymour of Sycamore Montmorillonite

~ iIourescent Red/Orange Seymour of Sycamore xylene (mix)

1lourescent Red/Orange Seymour of Sycamore Poloxyethyene

Fiourescent Red/Orange Seymour of Sycamore isopropyl alcohol

Flourescent Red/Orange Seymour of Sycamore Soya Lecithin

~Iourescent Red/Oran ge Seymour of Sycamore Water

NOW for. trectk

%

0.17%

0.15%

0.12%

24.63%

0.99

<1%

<1%

>= 78%

<= 5%

<= 5%

<= 5%

<= 5%

<= 1%

<= 1%

terlle Saline Solution Sperlan Eye & Face Protection, Inc.

3tertle Saline Solution Spenan Eye & Face Protection, Inc.

Sterile Saline Solution Spartan Eye & Face Protection, Inc.

Sterile Saline Solution Sperian Eye & Face Protection, Inc. green All-Purpose Cleaner; Simple Dncentrated Cleaner I Degreaser I er Simple Green Scrubbing Pad Sunshine Makers, Inc. reen All-Purpose Cleaner; Simple Dncentrated Cleaner / Degreaser / .er, Simple Green Scrubbing Pad Sunshine Makers, Inc. reen All-Purpose CIeaner, Simple oncentrated Cleaner / Degreaser / :er Simple Green Scrubbing Pad Sunshine Makers, Inc. reen All-Purpose Cleaner; Simple ncentrated Cleaner / Degreaser /

er Simple Green Scrubbing Pad Sunshine Makers, Inc.

pPurpose Cieaner Simple ted Cleaner I Degreaserle Green Scrubbing Pad Sunshine Makers, Inc. Purpose Cleaner; Simple ted Cleaner I Degreaserle Green Scrubbing Pad Sunshine Makers, Inc.

reen All-Purpose Cleaner; Simple

+ncentrated Cleaner / Degreaser I r; Simple Green Scrubbing Pad Sunshine Makers, Inc.

Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at

RA-LK 010857 Manufacturer response at

RA-LK 010857 Manufacturer response at RRA-LK 010857 Manufacturer response at RRALK 010828

Mantthcturer response at RRA-LK 010828 Manufacturer response at RRA-U( 010828 Manufacturer response at RRA-LK 010828

Manufacturer response at RRA-LK 011248

Manufacturer response at FkRA-LK 011246






Water Phosphate

asIc rdrate Phosphate Anhydrous

i Chloride

VMiTl

Sodium Citrate

4

09/17/2013

09/17/2013

EXHIBIT I I 09/17/2013

Range Resources — Well Completion Reports

Page 1 of 23

as'/.fas•,., LOt SCOt

78.92 1' 0,3010380

ROME OUR COMPANY 00ERA!1u$3 INETOR RELATIONS OWNER RELATIONS NEWSROOM OUR COMMITMENT CAREERS CONTACT

Well Completion Reports

Range Resources announced on July 14. 2010 that the Company would voluntarily disclose the composition of each of the hydraulic fracturing components for all the wells operated by Range Resources with the Pennsylvania Department of Environmental Protection (DEP) completed in the Marcellus Shale.

[ Click here for original press release and attachments]

Range's disclosure initiative will provide regulators, landowners and citizens of the Commonwealth an accounting of the highly diluted additives used at each well site, along with their classifications, volumes, dilution factors, and specific and conunoti purposes. fIat information will be submitted to the DEP as part of Ranges well completion reports and on the Company's

websile,

This voluntary initiative will increase transparency and allow people to better understand that the Marcellus Shale is a valuable resource that can be pursued responsibly and for the benefit of all of tlse citizens of Pennsylvania At shown below, all of the additives Range uses are highly diluted. carefully managed and in many cases commonly used in our everyday lives. We are hopeful that our voluntary disclosure will help dispel Site snisconceptions that have persisted and allow Range and others to deliver on the potential of this extraordinary resource base.

Range believes that the hydraulic fracturing process is environmentally safe. The location of the Marcellus is generally over a mile below the water table for our drinking water and is isolated by more than three million pounds of steel and concrete as shown in the diagtmns below.

http://www.rangeresources.comlgetdoc/50e3bc03 -3bf6-45 1 7-a29b-e2b8ef0afe4f/WeIl-Co... 9/17/2013

09/17/2013

Range Resources - Well Completion Reports

Page 2 of 23

http://www.rangeresources.comlgetdoc/50e3bc03-3bf6-45 1 7-a29b-e2b8efDafe4f7Well-Co... 9/17/2013

09/17/2013

of 23 Range Resources - Well Completion Reports

Well Record and Completion Reports

As filed wit/i the Department of Eni,ronmenial protection, Co,nrnonwealtli of Pennsylvania

6/1/2013

Chechuck George Unit 1 H - Washington County

6/1/2013

Chechuck George Unit 2H Washington County

6/112013

Chechuck George Unit 3H - Washington County

5/31/2013

Chechuck George Unit 4H Washington County

5/30/2013

Petricca Daniel Unit I H - Washington County

5/30/2013

http://www.rangeresources.com/getdoc/50e3bc03 -3bf6-45 1 7-a29b-e2b8efOafe4f7Well-Co... 9/17/2013

09/17/2013


Page 4 of 23

Petricca Daniel Unit 2H - Washington County

5126/2013

Petricca Daniel Unit 3H - Washington County

51412013

Hanes Donald Et Al Unit 7H - Washington County

5/3/2013

Hanes Donald Et Al Unit 3H - Washington County

4/25/2013

Hanes Donald Et Al Unit 8H Washington County

412512013

Hanes Donald Et Al Unit 9H Washington County

4/20/2013

Bovard Dorothy Unit 4H Allegheny County

4/20/2013

Bovard Dorothy Unit SI-f - Allegheny County

4/20/2013

Bovard Dorothy Unit SH - Allegheny County

4/20/2013

Bovard Dorothy Unit BR Allegheny County

4/16/2013

SGL 075A Unit 1 H - Lycoming County

4/10/2013

Shipman Goodwill Unit 1H - Lycoming County

4/9/2013

Castro Et Al Unit 3H Washington County

4/512013 Null Bobst Unit 1H Lycoming County

4/5/2013

Sten Unit SR - Washington County

4/5/2013

1

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Sten Unit 6H - Washington County

4/5/2013

Sten Unit 7H - Washington County

4/5/2013 Sten Unit 8H - Washington County

4/1/2013

Strawn Robert Unit 3H Washington County

3W/2013 McWilliams Unit 6H - Lycoming County

3/29/2013 Cornwall A Unit I H - Lycorning County

3/18/2013

Cross Creek County Park Unit 46H Washington County

3/17/2013

Cross Creek County Park Unit 46H - Washington County

3117/2013

Cross Creek County Park Unit 47H - Washington County

3/17/2013 Cornhifl C Unit 4H - Lycoming County

31/8/2013

Franklin Lakeview Estates Unit 6H - Washington County

3/17/2013 Cornhill C Unit 5H - Lycoming County

3/17/2013


3/17/2013


3// 1/2013


3111 t2013

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3111/2013 Franklin Lakeview Estates Unit 15H - Washington County

3119/2013 Cross Creek County Park Unit 18H - Washington County

319/2013

Cross Creek County Park Unit 17H Washington County

3/9/2013 Cross Creek County Park Unit 19H - Washington County

3/7/2013

Schiller Gerald Unit 3H - Allegheny County

3/7/2013

Schiller Gerald Unit 6H Allegheny County

3/3/2013 Schiller Gerald Unit 1 H - Allegheny County

3/3/2013

Schiller Gerald Unit 2H - Allegheny County

313/2013 Schiller Gerald Unit 4H - Allegheny County

2/27/2013 Folly Hollow Farm Unit 8H - Washington County

2/2712013

Folly Hollow Farm Unit 9H Washington County

2/22/2013 Folly Hollow Farm Unit 6H - Washington County

2/2212013

Folly Hollow Farm Unit 4H - Washington County

2/22/2013

Folly Hollow Farm Unit 3H - Washington County

2/22/2013

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Page 7 of 23

Cross Creek County Park Unit 51 H - Washington County

2/22i2013 Cross Creek County Park Unit 49H - Washington County

2/22)2013 Cross Creek County Park Unit 48H - Washington County

2/14/2013 Cross Creek County Park Unit 53t-I - Washington County

2/13/2013 Cross Creek County Park Unit 52H Washington County

2/13/2013 Cross Creek County Park Unit 50H - Washington County 41 1

2/13/2013 Red Bend B Unit 4H - Lycoming County

2/I 2/2013 Laurel Hill A Unit I - Lycoming County

2/4/2013 Corson Unit 1 H - Lycoming County

Green Dorothy Unit 5H Washington County

2/2/2013 Green Dorothy Unit 2H - Washington County

2/1/2013 Green Dorothy Unit 1 H - Washington County

1/26/2013 Bare Warren Unit 15H - Washington County

112612013 -. Bare Warren Unit 14H - Washington County -

1/1812013 Vamer Unit 10H - Washington County

1/18/2013

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Page 8 of 23

Varner Unit 4H - Washington County

1/17/2013 Varner Unit 9H - Washington County

1/13/2013

Krajacic Unit 5H - Washington County

1/1312013

Krajacic Unit 4H - Washington County

1/1312013 Krjacic Unit 3H - Washington County

1/10/2013

Varner Unit 8H Washington County

1/10/2013 Varner Unit 7H - Washington County

1/10/2013

Varner Unit 6H - Washington County

1/8/2013 Bobst A Unit 27H - Lycoming County

1/8/2013 Bobst A Unit 26H - Lycoming County

118/2013

Bobst A Unit 25H - Lycoming County

11/28/2012 Bobst kftn Hunting Club Unit 33H - Lycoming County

11/28/2012

Bobst Mtn Hunting Club Unit 32H - Lycoming County

11/21/2012

Bobst Mtn Hunting Club Unit 31H - Lycoming County

11121/2012 Bobst Mtn Hunting Club Unit 30H - Lycoming County

11/812012 -

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Bobst Unit 34H - Lycoming County

1118/2012


11/212012


11/212012

Bobst Unit 37H Lycoming County

10125/2012

Porter A Unit 3H - Lycoming County

10/2312012

Porter Stephen Unit 1 H - Lycoming County

9/18/2012

Lipped Unit 1 H - Crawford County

9/3/2012

Null Eugene A Unit 3H - Lycoming County

9/2/2012

Null Eugene A Unit 2H - Lycoming County

8/23/2012

Red Bend B Unit 3H Lycoming County

8/20/2012

Red Bend B Unit 2H Lycoming County

8/20/2012

Red Bend B Unit I H Lycoming County

8/1212012

Red Bend C Unit 5H - Lycoming County

8/1212012

Red Bend C Unit 4H - Lycoming County

81812012

Red Bend C Unit 3H - Lycomirig County

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09/17/2013


Page 10 of 23

817/2012

Red Bend C Unit 1H - Lycomtng County

8/6/2012

Red Bend C Unit 2H Lycoming County

7/29/2012

Bobst Mountain Hunting Club Unit 191-1 - Lycoming County

7/29/2012

Ogontz Fishing Club Unit 29H - Lycoming County

7/28/2012


7/25/2012


7/22/2012


7/20/2012

Ogontz Fishing Club Unit 251-1 - Lycoming County

7/7/20/2

Bobst Mountain Hunting Club Unit 19H Lycoming County

717/2012

Bobst Mountain Hunting Club Unit 18H - Lycoming County

6/18/2012

Hess Unit 1H Clearfield County 6 S-

513112012

Bobst Mountain Hunting Club Unit 21 H - Lycoming County

8/30/2012

Bobst Mountain Hunting Club Unit 23H - Lycoming County

5/00/2012 -

Bobst Mountain Hunting Club Unit 22H - Lycorning County

5/8/20/2

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Page 11 of 23

5/3/2012

Paulhamus Frederick Unit 61-1 - Lycomirrg County

5/1/2012

Pauihamus Frederick Unit 7H - Lycorning County

4/20/2012

Ogontz Fish/rig Club Unit 32H - Lycoming County

4119/2012

Ogontz Fishing Club Unit JON - Lycoming County

4/9/2012


4/8/2012


4/3/2012


4/2/2012

Ogontz Fishing Club Unit 351-1 Lycoming County

4/2/2012

Ogonlz Fishing Club Unit 34H - Lycoming County

3/26/2012

Fuller Eugene Unit 31-1 - Lycoming County

2/29/2012

Goodwill Hunting Club Unit 5H - Lycoming County

2121/2012

Shipman, James Unit 1 H Lycoming County

2/14/2012

Null, Eugene A. Unit I H - Lycoming County

1/24/2012

Menichi Unit 2H - Washington County - - -

1124/2012

Menichi Unit 3H - Washington County

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Page 12 of 23

1/24/2012

Mentcht Unit 5H - Washington County

1/24/2012

Menichi Unit 8H Washington County

1/24/2012 Menichi Unit 10H - Washington County

1/24/2012

Gulf USA Unit 63H - Centre County

1//3/2012 Mohawk Lodge Unit 3H - Clinton County

1/10/2012

Rush, John Unit I - Washington County

1/10/2012 Rush, John Unit 2H - Washington County

/f10/20I2 Rush, John Unit 3H - Washington County

1/10/2012

Rush, John Unit 4H - Washington County

///0/2012

Rush, John Unit 51-1 - Washington County

1/10/2012


1/10/2012

Rush, John Unit 7H Washington County Ltd

1/10/2012

Rush, John Unit 8H - Washington County

1/tO/2012


1/05/20/2

Winner Unit 5H-Clinton County

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Page 13 of 23

1212012011 Winner Unit 41-1 Clinton County

12/0912011

Arrowhead Hunting Club Unit 1 H - Clinton County

11/30/2011

Lindley, John Unit 5H - Washington County

11/2912011

Lindley, John Unit 51-1 Washington County

11/29/2011

Lindley, John Unit 6H - Washington County

11/29/2011 Laurel Hill Game Club Unit 1 H - Lycoming County

11/912011

Red Bend Hunting & Fishing Unit 4H - Lycoming County

11/812011


11/8/2011


11/7/2011

Zeigler, Bruce E. Unit 1H -Warren County

10/2412011

Lone Walnut Hunting Club Unit 3H - Lycoming County

10/24/2011

Lone Walnut Hunting Club Unit 7H - Lycoming County

1012112011 Rukavina Unit 51-1 - Washington County

10121/2011

Rukavina Unit 4H - Washington County

Rukavina Unit 3H - Washington County 10/21/2011

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Page 14 of 23

10/21/2011

Rukavina Unit 2H Washington County

10/21/2011

Rukavina Unit 1H - Washington County

10/21/2011 Lone Walnut Hunting Club Unit 9H - Lycoming County

10/20/2011 Lone Walnut Hunting Club Unit 1OH - Lycoming County

10/20/2011 Lone Walnut Hunting Club Unit 11 H - Lycomlng County

08/1/2011 Ogontz Fishing Club Unit 23H - Lycoming County

9/30/2011


9/30/20I1


9/24/2011


9/2412011 Ogontz Fishing Club Unit 18H - Lycoming County

9)73/2011


09/31)7011 Engel Unit 5H - Washington County

08/31/2011 Engel Unit 4H -Washington County

08/31/2011

Engel Unit 3H - Washington County -

09/27/2011

Shohocken Hunt Club Unit 2H Lycoming County

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09/17/2013

Range Resources - Well Completion Reports Page 15 of 23

08/27/2011

Shohocken Hunt Club Unit 4H Lycoming County

08/19/2011

Shohocken Hunt Club Unit 1 H - Lycoming County

08/19/2011

Shohocken Hunt Club Unit 3H - Lycoming County

08/19/2011 Shohocken Hunt Club Unit SH Lycoming County

07/29/2011

Paulhamus, Frederick Unit 5H - Lycoming County

07/26/2011

Fuller, Eugene Unit 2H - Lycoming County

07/22/2011

Phelan Unit 4H - Washington County Ld

07/18/2011

Ogonlz Fishing Club Unit 17H - Lycoming County

07/18/2011 Ogontz Fishing Club Unit 1EH - Lycoming County

07/15/2011

OgonIz Fishing Club Unit 12H - Lycoming County

07/15/2011


07/14/2011

Hewitt, Douglas Unit 1 H - Washington County

07/14/2011

Hewitt, Douglas Unit 2H - Washington County - -

07/14/2011

Hewitt, Douglas Unit 3H - Washington County

07/14/2011

Hewitt, Douglas Unit 4H Washington County

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09/17/2013


07/14/2011

Hewitt. Douglas Unit 5H Washington County

07/14/2011


07/14/2011


071I4/2011


07/14/2011


07/14/2011

Painter Unit 4H - Washington County

07/14/2011


07/14/2011

Painter Unit 311 - Washington County

07/7/2011

Painter Unit 1 - Washington County

LW I

07/7/2011


06/28/2011

Herman, Lewis Unit 1 H - Lycoming County

06/26/20/1

Godwin Unit 311 Washington County

06/22/2011

Carter, R Unit 3H - Venango County

06/15/20//

McAdoo Unit 2I- - Washington County

06/13/2011

McAdoo Unit 1 - Washington County Ld

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09/17/2013


05/26/2011 Godwin Unit 2H - Washington County

05/24/2011

Day L&L Unit 1 H - Washington County

05/24/201/

Day L&L Unit 2H - Washington County

05/24/2011 Day L&L Unit 3M Washington County

05/24/2011 Day L&L Unit 4H - Washington County

04/1312011

Worstell Unit 3M Washington County

04/13/2011 Weimer Lillian Unit 1 H - Washington County

04/13/2011

Weimer Lillian Unit 2H - Washington County

04/13/2011 Weimer Lillian Unit 3M - Washington County

04/13/2011


04/13/2011


04/13/2011

Weimer Lillian Unit GM - Washington County

04/04/2011


04/04/2011


04/04/2011

Gulf USA Unit itOH - Centre County

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Page 18 of 23

0312112011

Dog Run Hunting Club Unit 1H - Lycoming County

03/28/2011

Dog Run Hunting Club Unit 21-1 - Lycoming County

03/2812011

Dog Run Hunting Club Unit 31-1 Lycoming County

03/23/2011

Drugmand Unit 61-1 Washington County

03/23/2011

Drugmand Unit 5H - Washington County

03123/2011

Drugrnand Unit 41-1 Washington County

03/22/2011

Drugmand Unit 31-1 - Washington County

03/13/2011


03/12/2011

Drugmand Unit 1H - Washington County

03/12/2011


03/12/2011

Drugmand Unit 8H Washington County

03/02/2011

Johnson, Gerald Unit 1H - Washington County

03812/2011

Johnson, Gerald Unit 4H - Washington County

02/12/2011

Bednaraki Unit 4H - Washington County

02/14/2011

Bednarski Unit 5H - Washington County -

. ..-'---

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8212112011

Bednarski Unit 61-1 - Washington County

02/21/2011

Bednarskl Unit 7H - Washington County

02/14/2011

Bodnarski Unit 8H - Washington County

02/21/2011 Bednarski Unit 9H Washington County

02/15/2011

Troyer Space Management Unit 1 H - Washington County

02115/2011

Troyer Space Management Unit 2H - Washington County

01/2812011


02/05/2011

Troyer Space Management Unit 414 Washington County

02/03/2011


01/28/2011

Troyer Space Management Unit iON - Washington County

02/05/2011

Troyer Space Management Unit 11 H - Washington County

1/18/2011

Chappet Unit 1 H - Washington County

1/18/2011

Chappel Unit 21-4-Washington County

T 1/18/2011

Chappel Unit 4H - Washington County

1/19/2011

Chappel Unit 5H- Washington County

http://www.rangeresources.comlgetdoc/50e3bc03 -3bf6-45 1 7-a29b-e2b8emafe4f'We1l-Co... 9/17/2013

09/17/2013


2/3/2011


11112011


1/3/20/I


1/3/2011


12/18/20/0

Sierzega Unit 2H - Washington County

1111/201/

Siersega Unit 3H Washington County

/2/5/2010

Sierzega Unit 5H Washington County

1/6/20/1


1/5/20/1


1/5/2011

Sierzega Unit 11 H - Washington County

/2/21/2010

Siei-zega Unit 12H Washington County

12/7/2010

Yut8 Unit 4H - Allegheny County

11/17/2010

Gentner Unit 3H - Lycoming County

11/17120l0

Gentner Unit 41-f - Lycoming County

11/17/2010

Gentner

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Page 21 of 23

11/17/2010

Gentner Unit 6H Lycoming County

11/15/2010

Gentner Unit 7H Lycoming County

11/18/2010

John Miller Unit I H - Washington County

11111/2010 John Miter Unit 3H - Washington County

11/13/2010

John Miller Unit 4H Washington County

11/19/2010

John Miller Unit 5H Washington County

11/2012010 John Miller Unit 6H Washington County

11/12/2010

John Miller Unit 8H - Washington County

11/3/2010

Worstell Unit I Washington County fj

10/23/2010


10123/2010

Sierzega Unit 9H Washington County

19/15/2010

Hardie Unit 1 H - Greene County

09/27/2010

Hardie Unit 2H - Greene County

09/14/2010

Ferguson Unit I H - Washington County

09/14/2010

Ferguson Unit 2H - Washington County

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09/17/2013


Page 22 of 23

0811/2010

Huffy Unit 4H - Washington County

08/24/20/0 Huffy Unit 7H - Washington County

08/14/2010

Johnston Unit IOH - Washington County

08/1412010

Johnston Unit 12H Washington County

08-24-2010 Goettel Unit #7H - Washington County

08-24-2010 Goettel Unit #8H Washington County

08-24-2010

Goettel Unit #9H - Washington County

08-24-2010

Goettel Unit #11 H Washington County

08-24-2010

Goettel Unit #12H - Washington County

08-04-2010 Baker Unit #4H - Washington County

08-04-2010 Baker Unit #5H - Washington County

08-04-2010

Baker Unit #6H - Washington County

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OPERATIONS f MARCELLIJSCIIS1SION t WELL COMSIEIION

REPORTS

PRINT

05 TSR CEMIIRTON SPREES SUITE 1200 FORT 'NORTH, Di 76102 EMAIL US PRIVACY NOTICE LEGAL NOTT1E SITE MAP 055

T 0T7-670-2A121 F OSAQ9100

INFIIU8/RANGTTNEEOURCFS GUM

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09/17/2013


Ro Co ,.,tOn, A

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09/17/2013

5500-FM000004 Rev. 2/2001

RAVINAOR DEPARTMENT OF ENVIRONMENTAL PROTECTION

MAqw COMMONWEALTH OF PENNSYLVANIA

OIL AND GAS MANAGEMENT PROGRAM

WELL RECORD AND COMPLETION REPORT

DEP USE ONLY

js4teld P*mlyFacNykl

Ctent Id 5ub-tocty Id

well 0pertor F6FP DI Welt API I (Pemilt I RegJ Prc4ect Number Aces

Range Resources -Appalachia, LLC 141142 37-125-24024 583 c*iess well Fonrt Nome well I J Se?d I 380 Southpointe Blvd, Suite 300 Sierzega j 6l1 J

Coy State fip Code County Mril4X*ty

Canonsburg PA 15317 Washington Amvmll Phone FcQK USGS 7.5 mln, quackongle map

724-743-6700 724-743-6790 Amity

Chack all that ply 00r9naiWelIRewd XONin CornpletlonReMl DMendea Well Record DAInan1 OorTMon Report

WELL RECORD AofFo c law 2) Well Type Gas 0 Oil 0 Combination Oil & Gas 0 Injection 0 Storage 0 Disposal

Drilling Rotary - Air 23 Rotary - Mud 0 Cable Tool Date Drilling Started Dote DrtIa'g Completed Surface Bevoltoi, Total Depth - or" Total Depth Logger

4/912010 _612612010 1147ft _11920 ft 11920 ft Cement returned on surface casing? Yes 0 No Casing and Tubing Cement returned on coal protective casing? N Yes EEI No 0 N/A

Hole pipe Size wt. Thread Amount fri Material Behind Pipe Packer / Hardware I Ces*azers Date

LYii WeHifti Type and Amount Type Size Dep Run 30' 28 1065 Thread 32' Driven - 28" 32' 4/9110

24 2ff 81.35 Thread 33T ClassAGaaBlock,360sx G8 20" 337' 5(19/10

17-1/2" 13-3/8" 54.55 Thread 1103' Claws A Gas Blo*820sx G8 13-3/8' 1103' 5/12/10

12-114' 9-5/8 405 Thread 2939' Class A Gas Mock, 95Oxk GS 9-5/8' 2939' 5/15/10

8-3/4' 5-1/2' 205 Thread 11891' Extendacern,8908x FS 5-1/2" 11891" 6125/10

Hal light,890sx,Fraccem360sx

U_- COMPLETION REPORT

PerforationRecord StimulationRecord Interval P.rfo,ofed

D Interval Fluid Propping Agent Average

Dote from To Of erVOl rea Type Amount Type Amount Injection

12/2812011 11,771'MD 8,687MD 1/5/2011 Marceflus Shale Slick H20 90,082 bbl Sand 5,594 lOb 632 bpm

Natsclt Open How -r Ii I Natural Rack

,00 small o measure Pro e Too small to measure Hours Days After Treatment ____ Ti3 Treatment Open Flow Old t24 Rock Press" MA@24 tws post treatment Hours Days

Well Service Companies - Provide the name, address, and phone number of all welt service companies Involved. Home Ncn

Well Services (Frac Tech Ade,s Adckess

4501Lamesa Highway _730 Braddock View Dr 1 16858 1H20 State

- % Braddock, j 6437 ane 325-574-6300 _724-430-6201 I 817-850-1008

09/17/2013

5500FM-OG0004 Rev. 212001

__ LOG OF FORMATIONS Well API# 37-125-24024

Formation Name or Type J° Source of Data

A' 4fl' flriliørs I an

Sand 40' 160' Drillers Loa Shale 160' 220' Drillers Log

Sand 220' 340' Drillers Log

Sandy Shale 340' 611 Drillers Log

Shale 611' 685' Drillers Log

Coal, Shale and Sand 685' 803' Drillers Log

Sand and Shale 803' 931 Drillers Log Sandy Shale 931' 995' Drillers Log

Shale 995' 1059' Drillers Log

Sand, Shale and Coal 1059 1125' Drillers Log

Shale Coal 1125' 1172' Drillers Log Shale 1172' 1301' Drillers Log Sandy Shale 1301' 1355' Drillers Log

Shale 1355' 1370' Drillers Log Coal 1370' 1382' Drillers Log Sandy Shale 1382' 1455' 1438 i Drillers Log Shale and Coal 1455' 1460' Drillers Log

Shale 1460' 1478' Drillers Log Coal 1478' 1484' Drillers Log Shale 1484' 1650' Drillers Log Sandy Shale 1650' 1765' '/wtr©1684 Drillers Log Shale 1765' 1803' Drillers Log Sandy Shale 1803' 1817 Drillers Log Sand 1817' 2068' 1860 Drillers Log Sand 2068' 2101' Drillers Log Shale 2101' 2164' Drillers Log Sand and Shale 2164' 2325' Drillers Log Sandy Shale 2325' 2401' Drillers Log Sand 2401' 2500' Drillers Log Sandy Shale 2500' 2555' Drillers Log White Sand 2555' 2668' Drillers Log Sandy Shale 2668' 2832' 2600 Drillers Log Shale 2832' 3104' 2882 Drillers Log Sand and Shale 3104' 3167' Drillers Log Shale 3167' 3710' Drillers Log Sand and Shale 3710' 5470' Drillers Log Shale 5470' 6120' 5690 Drillers Log Limestone 6120' 7330' Drillers Log Shale 7330' 7440' 7370 Drillers Log Limestone 7440' 7450' Drillers Log Horizontal Drillers Log Shale 5810' 8050' Drillers Log Limestone 8050' 8170' Drillers Log Shale 8170' Drillers Log Drillers Total 1192 ers Log ____

Please delete empty rows if necessary to make all of page 2 fit on one

WWI Opsratqrs Signatur.: DEP USE ONLY L Reviewed by: Dote:

Co Dote: 1131/2011 Comments:

Completion Engineer, Hurey

09/17/2013

LI RANGE RESOURCES

Slerzega Unit #6H Completion Date: 12/28110 - 1/5111

Composition of Hydraulic Fracture Fluid

Amb

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LM

-

......... . .... ... .-

09/17/2013

Ii Composition of Components in Marcellus Shale Hydraulic Fracturing Fluid

RANGE RESOURCES tlsim GoncsnVao of

______ H.za,dous MIDI Cnpon.r Gns MIDI N$0l Co wit v To Coo,n Nwu. £ Iuçipsr Con ______ ______

SuppiN' chs,,*.0 iIn. Dssct&n C M p , MISd Puipo.. Sl5M % of Co.ipvn.ot Wi 5bgs Fk$dan us" Clrn4cof

%V.I %WsfgM

31% IICL HC4. CIwi ,ifrr,I 370% •02:2 - 0.01M 0.5% -

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7.5% 14c1 ii CI.100 OCI._____

FT.cT.dlI ____ II0O

roMls Pfovwft umU 0.0% WA - WA WA

FEIOM. 00% N/A N/A WA

tOThi. 5.0154% O.01S3%

4.4. 13 15.0% 501.19 0.0141% _0Q133%

3,4.4.

AbMIs Tr1msli&... , obw*ww 50% 35.10 0410% _CD000%

A9irt 24ivio24ipii4.1-

1.0% 5.11 0.X07% 00O2% A..4L.o,W Aplt ______

FO 05%.. 353 0.0001% 0.0001%

GIdsP o 00033% 0.0045%

4C 5.1542 ri.r1 MI* bsr .áTUI IS Wi

— ..- sow 2220 0.0005% 0.0007%

- EVIO - 1.0% 222 00001% 0.0001% TOTIL OM58 0.5I4%

byvol%bywelght% SUMMARY 1 0.031% 1 0.021%

-4-

09/17/2013

5500-FM000004 Rev, 212001 COMMONWEALTHOF PENNSYLVANIA am DEPARTMENT OF ENVIRONMENTAL PROTECTION

OIL AND GAS MANAGEMENT PROGRAM

OEP USE ONLY Site Id 1trocatykl

Cent d Sob-Sadly Id

WELL RECORD AND COMPLETION REPORT Watt Operutor DEP ID# Wst 01#(F Nuner Acres

Range Resources-Appalachia, LLC 141142 37-125-23938 441 AdAess Well Form Name Well a JSedcI #

380 Southpointe Blvd. Suite 300 Sierzega 9H City Stale Zip Code County MiiEcipty

Canonsburg PA 15317 Washington JAmwell hone - Fox USGS 7,5 rri, quadioroe map

724-743-6700 724-743-6790 Amity Check all that apply: 0t1gind Welt Recd x Original Completion Report DArrtertded Well Record DAmended Completion Report

WELL REC ionvsss io ciçmi (pui 2

Well Type Gas El oil 0 Combination Oil & Gas D Injection 0 Storage 0 Disposal

Drilling Method j [J Rotary - Au' Z Rotary - Mud 0 Cable Tool Date DrllIg Storied We DiMng Conrç4eted Sa1ace Bevatlo Totat Depth - DitRer Total Depth- logger

12/5/09 1 4123/10 1 1147 ft. 1 11296 ft 11296 ft Cement returned on surface casing? Yes 0 No

- Casing and Tubing returned on coal protective casing? E Yes 0 No N/A Hole Pipe Size Wt Thread Amount in Maleital 8,&iind Pipe Packer I Hardware I Cenfrazers Date

size ______ L Llc Well (ft) Type and Amount Type Size Depth Run

30' 26' 108# Thread 40' DrIven - 2(r 40' 1215/09

24' 20' 81# 3/28/10 335' Class A Cement, 389 ax GS 20' 335' 3/26/10

12-1/4' 9-5/8' 400 4/3/10 3063' Uni Block, 1290 sx GS 9-518' 3063' 4/3/10

4/23/10 10927' Extendacem, 960 ax FS 5-1/2' 10927' 4/23/10

Hall Lite, 485 ax_____

Fraccem 370 ax

1'R1

Perforation Record Stimulation Record mfh. °PPn9 Agent Average

Date To Date Interval Treated Type Amount Type Amount Injection

10-19-10 10,823' MO 8,097 MD 10-24-10 Marcellus Shale Ick H20 91,982bbl Send 5,072Kib 63.8 bpm

Naltrol Open how Natural Rock Too small to measure

Natural small to measure Hours Days

After Treatment After Treatment 0 matid 24lira post treatment Rock Pressure NSA Q 24trrs post treatment Hours Days open Flow

Well Service Companies - Provide the name, address, and phone nurrthor of all aell service companies Involved. Name Name Name

Patterson UTI Universal Welt Services Frac Tech Address

4501 Lamesa Highway 730 Braddock View Dr 16858 1H20

Clty-State-T Cily-Slate- Snyder, TX 79549 Mt. Braddock, PA 16485 Clsco, TX 78437

t1none -P F1066 Phone 325-574-6300 724-430-8201 817-850-1008

09/17/2013

5600-FM-000004 R.'. 2/2001

LOG OF FORMATIONS WellAPl#: 37-125-23938

-_Formation Name or Type TopBottom Gas at 00 at Water at Source of Data

Fill 0' 42' Geophysical Log Shale 42' 114' Geophysical Log Sandy Shale 114' 172' Geophysical Log Sand 172' 225' Geophysical Log Sandy Shale 225' 350' Geophysical Log Shale 350' 430' Geophysical Log Sand and Shale 430' 550' Geophysical Log Shale 550' 610 Geophysical Log

Sand and Shale 610' 730' Geophysical Log

Shale 730' 1150'

Geophysical Log

Sand 1150' 1260' Geophysical Log

Shale 1260' 1510' Geophysical Log





Sand and Shale 2580' 2700 Geophysical Log

Shale 2700' 2860 Geophysical Log





Sandy Shale 4410' 5140' Geophysical Log




Sandy Shale 6450' 6570' Geophysical Log


Limestone 7150' 7215' Geophysical Log



Horizontal



Shale 7670' Geophysical Log

Drillers Total Depth 11296 Geophysical Log

Please delete empty rows if necessary to make all of page 2 fit on one p*.

Ws p SIatur: 1DEP USE ONLY Reybewed by DCjIc

Me: Comme: Completions En neer Mike 11-5-10

09/17/2013

III RANGE RESOURCES

Sierzega Unit #9H Completion Date: October 19- 23, 2010

Composition of Hydraulic Fracture Fluid (b - ow ,,.)

NAM &AMM MAMPM

=

lan

Lux

PrAhMAMOW am

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.. ... .....

09/17/2013

Composition of Components in Marcellus Shale Hydraulic Fracturing Fluid

RANGE RESOURCES

sa Cnos ai'

Comm,i n. 4 $4 C CIISMá ______ dSonI 30S M5O C...4N4M s

_____ Cu...,it lSsd on Piop001 Wu % of In I(I1 d suww%Vo

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TOTAL I 3.00(3% I U035%

byvol% bywe1ght]

SUMMARY _0.023% 1 0.017%

-4-

09/17/2013

EXHIBIT 12 09/17/2013

INDUSTRIAL COMPOUNDING LLC. 2500 HWY 62 WEST

CIIICK4&SH, OK 73018

PAGE I OF'3

MATERIAL SAFETY DATA SHEET I. PRODUCT NAME: FRW-200, POLYMERIZED FRICTION REDUCER FORMULA: Polymeric Hydrocarbon Mixture CHEMICAL FAMILY: Polymeric Mixture DOT HAZARD CLASSIFICATION:NON-REGULATED

TELEPHONE NUMBER: 1-800-349-9355 EMERGENCY NUMBER 1-800-535-5053

IL PHYSICAL DATA/ PRODUCT CHARACTERISTICS

BOILING POINT: Not Determined SPECIFIC GRAVITY: .96 - .99(M 77 deg F FREEZING POINT: Not Determined SOLUBILITY IN WATER Mtsezble PHYSICAL STATE: Liquid ODOR: Aromatic

ILL FIRE & EXPLOSION INFORMATION

FLASH POINT: > 200 DEC F EXTINGUISHING MEDIA: Foam or Dry Chemical UNUSUAL FIRE OR EXPLOSION HAZARDS: NONE KNOWN

IV. REACTIVITY INFORMATION

STABILITY: STABLE HAZARDOUS DECOMPOSITION PRODUCTS: Cm NOj6 SOt INCOMPATIBILITY: Oxidizing Agents, concentrated Sulfuric or Nitric Acid CONDITIONS TO AVOID: Flamea, , heat above tlnah point

- - 7fl --

09/17/2013

V. HEALTH HAZARD iNFORMATION PAGE20F3

PRIMARY ROUTES OF ENTRY FOR INJURY CAUSING EXPOSURE:

EYES: IRRITATION SKINPOSSIBLE IRRITATION. Skin pbsorbtlpu possible to harmful limits INHALATION: IRRITATION. CNS depression, dizziness, confusion, nausea CARCINOGENICITY: UNKNOWN MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: UNKNOWN

VI. FIRST All) RECOMMENDATIONS

EYES: FLUSH EYES WITH WATER OF AT LEAST 15 MINUTES. HOLDING EYELIDS APART. CALL PHYSICIAN SKIN: WASH AFFECTED AREA WITH SOAP AND WATERINGESTION: DO NOT INHALATION: REMOVE VICTIM TO FRESH AlL IF SYMPTOMS PERSIST CALL PHYSICIAN.

VII. PERSONAL PROTECTIVE INFORMATION

VENTILATION REOUIBEMENTS GENERAL ARE EXHAUST: LOCAL EXHAUST:

PERSONAL PROTECTIVE EQUIPMENT: EYE PROTECTION: GO1GI1S OR FACE SHIELD SKIN PROTECTION: RUBBER GLOVES. BOOTS. AND SPLASH APRON RESPIRATORY PROTECTION: VAPOR MASK OTHER REQUIRED EQUIPMENT:

VIII. SPILL PROCEDURES & WASTE TREATMENT

SPILL PROCEDURES ABSORB SPILL AND CONTAINERIZE FOR DISPOSAL

Lt'i Il4

r-r-r-r., t..

09/17/2013

OF3

LX SUBSTANCE CONTROL ACT INFORMATION

nis prsduet contaiae one or mere substances fluted as hazardsui, tozk or fliamable air pollutants under Sectios 112 at the Clean /elrAct. Consuls Beaza. standard 29 CFR 19101021 There may be apecifle replad.ea sub, local (ml that pertain to this product

CONDITIONS: THE ABOVE INFORMATION IS ACCURATE TO THE BEST OF OUR KNOWLEDGE. HOWEVER, SINCE DATA, SAFETY STANDARDS, AND GOVERNMENT REGULATIONS ARE SUBJECT TO CHANGE AND THE CONDITIONS OF HANDLING AND USE, OR MISUSE ARE BEYOND OUR CONTROL, WE MAKE NO WARRANTY, EITHER EXPRESS OR IMPLIED, WITH RESPECT TO THE COMPLETENESS OR CONTINUING ACCURACY OF THE INFORMATION CONTAINED HEREIN AND DISCLAIM ALL LIABILITY FOR RELIANCE THEREON USER SHOULD SATISFY HIMSELF THAT HE HAS ALL CURRENT DATA RELEVANT TO HIS PARTICULAR USE.

PREPARED:

HMIS RATING HEALTH: 1 FLAMMABILITY: 1 REACTWITY: ()

11

=

DEPO1 83

09/17/2013

Ll INDUSTRIAL COMPOUNDING LLC

A SUBSIDIARY OF FRAC TECH SERVICES, LTD. 915 N. 16M STREET

cmcKAsIL4, OK. 73018

PACE I OF)

MATERIAL SAFETY DATA SHEET I. PRODUCT NAME: RVG-1, FAST HYDRATING GUAR SLURRY DOT PROPER SHIPPING NAME: COMBUSTIBLE LIQUID NOS I,NA1993, PGII1,PETROLEUM DISTILLATES)

MATERIALS I d/ WAY HAZARD DATA (TLV

PETROLEUM 1 >50% N/A

TELEPHONE NUMBER: 1-800-349-93551-903-238-8593 EMERGENCY NUMBER INFOTRAC 1-800-535-5053

II. PHYSICAL DATA) PRODUCT CHARACTERISTICS

BOILING POINT: NID

Q SPECIFIC GRAVITY:! 05 x 834(water) PH: N/A MELTING POINT: N/D SOLVEILITY IN WATER: NOT SOLUBLE COLOR REDISH BROWN ODOR MILD SULFUR

IlL FIRE & EXPLOSION INFORMATION

FLASH POINT: 159 DEG F EXTINGUISHING MEDIA: FOAM, DRY CHEMICAL, OR WATER SPRAY UNUSUAL FIRE OR EXPLOSION HAZARDS: THIS LIQUID IS VOATILE AND GIVES OFF iNVISIBLE VAPORS. WHICH MAY SETTLE IN LOW AREAS AND TRAVEL TO IGNITION SOURCES WHERE THEY MAY IGNITE OR EXPLODE.

IV. REACTIVITY INFORMATION

STABILITY: STABLE HAZARDOUS DECOMPOSITION PRODUCTS: OXIDES OF CARBON INCOMPATIBILITY: STRONG ACIDS: X STRONG ALKALIS: C STRONG OXIDIZERS: Y(

OTHER:

CONDITIONS TO AVOID nEAT: X OPEN FLAMV. X SPARKS: X IGNITION SO(JRCES:X

09/17/2013

*i I

V. HEALTH HAZARD INFORMATION PACE 2OF3

PRiMARY ROUTES OF ENTRY FOR INJURY CAUSING EXPOSURE:

SYMPTOMS OF EXPOSURE: EYES: SUGUTLY IRRITATING BUT DOES NOT INJURE THE EYE. SKIN: LOW ORDER OF TOXICITY. PROLONGED OR REPEATED CONTACT CAN CAUSE IRRITATION TO THE SKIN. INGESTION: SMALL AMOUNTS OF THIS PRODUCT ASPIRATED INTO THE RESPIRATORY SYSTEM DURING INGESTION OR VOMITING MAY CAUSE MILD TO SEVERE PULMONARY INJURY, POSSIBLY PROGRESSING TO DEATH. INHALATION: 111CR VAPOR CONCENTRATIONS ATTAINABLE AT ELEVATED TEMPERATURES WELL ABOVE AMBIENT ARE IRRITATING TO THE EYES AND RESPIRATORY TRACT, AND MAY CAUSE HEADACHES, DIZZINESS, ANESTESIA, DROWSINESS, UNCONSCIOUSNESS AND OTHER CENTRAL NERVOUS SYSTEM EFFECTS INCLUDING DEATH. CARCINOCENICITY:NOT LISTED MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: NO DATA

0 VI. FIRST AID RECOMMENDATIONS

fli BEFORZREUSL INGESTION: DO NOT INDUCE VoMff]NG: INILALATION: REMOVE V—TCM TO FRESH _ IF SYl

VII. PERSONAL PROTECTIVE INFORMATION

Iiv' 'i kaJ1 !.1t *fl

i'1

q1! PROTECTION:

,1_JaL:4,1s

09/17/2013

0 61 SPILL PROCEDURES: ELIMINATE ALL IGNITION SOURCES. CONTAIN AND &ssogpspuj.

AND CONTAINERIZE FOR DISPOSAL.

WASTE TREATMENT: DISPOSE OF ACCORDING TO FEDERAL STATE. AND LOCAL LAWS.

PAGE 0F3

IX. TOXIC SUBSTANCE CONTROL ACT INFORMATION T.C.S.A.: ALL COMPONENTS OF THIS PRODUCT ARE REGISTERED UNDER THE REGULATIONS OF THE TOXIC SUBSTANCE CONTROL ACT AS REQUIRED.

S.A.R.A.: CHEMICAL COMPONENTS SUBJECT TO THE REPORTING REQUIREMENTS Of SECTION 313 OF TITLE III OF THE SUPERPUND AMENDMENTS AND REAUTHORIZATION ACT OF 1956 AND 4$ CFR PART 372 ARE AS FOLLOWS:

CHEMICAL NAME % BY WEIGHT CM REG. # PETROLEUM 50% 64742-47-8 DISTILLATES

CONDITIONS: THE ABOVE INFORMATION IS ACCURATE TO THE BEST OF OUR KNOWLEDGE. HOWEVER, SINCE DATA, SAFETY STANDARDS, AND GOVERNMENT REGULATIONS ARE SUBJECT TO CHANGE AND THE CONDITIONS OF HANDLING AND (ISE OR MISUSE ARE BEYOND OUR CONTROL, WE MAKE NO WARRANTY, EITHER EXPRESS OR IMPLIED, WITH RESPECT TO THE COMPLETENESS OR CONTINUING ACCURACY Of THE INFORMATION CONTAINED HEREIN AND DISCLAIM ALL LIABILITY FOR RELIANCE THEREON. USER SHOULD SATISFY HIMSELF THAT HE HAS ALL CURRENT DATA RELEVANT TO HIS PARTICULAR USE.

PREPARED

-- DATE 07d1

BY: D. RARVELL

HTMIS RATING; HEALTH-1, FLAMMAJ3LLITY-2 REACTIVITY-0 -

09/17/2013

EXHIBIT 13 09/17/2013

Announcing the new Energy Global iPhone app

8/30/13

Range Resource spearheading soluntary initiatie

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Range Resource spearheading voluntary initiative Range Resources Corp. announced today that it has submitted its first hydraulic fracturing

disclosure forms to the Pennsylvania Department of Environmental Protection (DEP) and has

posted the information on the Range swsbsite. The information covers the first three Marcellus

Shale wells in Pennsylvania that Range has hydraulically fractured since implementation of the

voluntary initiative. As additional Marcellus wells are drilled, Range will provide similar information

within approximately 30 days of completion.

On July 14, 2010. Range announced its voluntary initiative to disclose Marcellus Shale hydraulic

fracturing additives. The purpose of the initiative is to provide regulators landowners and citizens

of Pennsylvania an accounting of the highly diluted additives used at each well site. In reaction to

the initiative, Range has received supportive response from policy makers regulators,

Pennsylvania citizens and environmental and conservation groups. Commenting on the effort, US

Congressman Mike Doyle (DPA) said, With many questions about the environmental impact of

hydraulic fracturing in the Marcellus Shale still unanswered, I commend Range Resources for its

decision to voluntarily disclose information about the contents of the fluids they are using in that

process on a per well basis, and I strongly encourage other companies drilling in the Marcellus

Shale to disclose the components of their fluids in that kind of detail as well.'

The decision to disclose the exact chemical composition of the chemical additives used in

hydraulic fracturing (fracking), has come about because people are distrustful of the potential

damage tracking could cause. Concerns over groundwater contamination have already led some

shale projects in New York state to be cancelled on the grounds they might pollute the state's

groundwater. Hopefully this initiative should assuage fears over shale projects and allow shale gas

full potential to be realised. Shale gas has already been described as a 'gamechanging' energy

resource by Industry chiefs, and with Americas enormous shale assets, which are large enough to

virtually guarantee America's energy security, it is essential that the industry gets the American

public on side.

'We are very pleased with the response we have received to our initiative and our commitment to

achieving the proper balance of pursuing the enormous opportunity that the Marcellus Shale

provides and implementing a standard of care for the environment and the communities where we

live and work. We're hopeful that our voluntary effort will help to dispel misconceptions about the

process and allow Range and others to deliver on the potential of this extraordinary resource

base, said John Pinkerton, Chairman and CEO of Range Resources.

Published on 13i08'2010

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EXHIBIT 14 09/17/2013

8/30/3

Marceflus driller volunteers to disclose tracking chemicals - Philly.com

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Marcellus driller volunteers to disclose fracking chemicals

A Range Resources rrg in S4arc all us Shale, "Our hope is that it wit alleviate the concerns, an official said of disclosure

By Andrew Maykuth, Inquirer Staff Writer

Pos'rw July 15, 2010

The company that pioneered Marcellus Shale exploration announced

Wednesday that it was voluntarily disclosing the chemicals used to

hydraulically fracture its natural gas wells, in an effort to defuse

criticism about the process.

Range Resources Corp., which has deeloped more Pennsylvania

Marcellus wells than any other company since it drilled the first well in

2003, said it would provide a list of the chemical additives in an effort to

demystify a technique the company says has been safely employed

thousands of times.

"I'm confident, when people see the information, think about it, and

understand it, our hope is that it will alleviate the concerns," said John

Pinkerton, chief executive officer of the Fort Worth, Texas, firm.

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Find More Stories About Environmental groups and legislators, who have pressed for fighter

regulation of the industry, welcomed Range's moe. Chemicals

"We need to see more details and the disclosure in action, but

prosiding more information is a step in the right direction," U.S. Sen. EXHIBIT Bob Casey (D., Pa.), a sponsor of the Fracturing Responsibility and

Awareness of Chemicals (FRAC) Act, said through a spokesman. One

of the ERAC Acts provisions Is to require operators to disclose their

chemical recipes. if I En',imonmentalists said they were encouraged by the firm's step.

Baizel, senior start attorney with Eithworka Oil & Gas Accountability Project,

Though the oil and gas industry has employed hydraulic fracturing for decades to stimulate well production, the process has come

under close scrutiny recently as fossil-fuel exploration has moved into more 'unconventional' geologic formations like shale and

as well size has grown dramatically through the use of horizontal-drilling techniques.

articles. phi lly.corr2010-0T 151business/249689341cherricals-natural-9 as-drilling 1/2

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8/3O/3 Marcel lus driller volunteers to disclose fracking chencals - Pbllly.com

In "fracking," millions of gallons of high-pressure water, sand, and chemicals are injected into a well to shatter the shale to release

trapped natural gas. Sand particles remain in the hairline fractures to allow pathways for the gas to escape to the well. Some of

the wastewater is recovered and recycled or treated and disposed of.

In the Marcellus, operators say that the fracturing occurs more than a mile below the surface and that the chemicals cannot

migrate upward through thousands of feet of rock into aquifers.

But the industry's assurances haw come under fire, and the process is being studied by the U.S. Environmental Protection

Agency.

The industry's reluctance to disclose "proprietary" chemical recipes has raised further suspicions. Some anti-drilling actttrsts say

the industry injects a "toxic brew" of as many as 596 chemicals into the wells.

Most companies say they use fewer than a dozen chemicals, most of them not toxic.

"A lot of the naysayers on the other side are just winging things out therewith no scientific basis, and that's really troubling,"

Pinkerton said,

Range says that the chemicals used in its frack fluid typically amount to 0. 14 percent of the total volume injected into a well and

that the chemicals listed as hazardous amount to 0.04 percent. The additives reduce the fluid's friction and inhibit formation of

scale or bacterial slime that can clog fractures.

By disclosing the chemicals, Pinkerton said, the industry can look for more environmentally friendly solutions.

"If there's something to replace it with that's greener, well do it," he said. 'fm a believer that the more light you shine on it, the

more people wifi look at it and the better solutions well come up with," he said.

For two years, the Pennsylvania Department of Environmental Protection has posted online a list of chemicals used in hydraulic-

fracturing operations.

Drilling companies are also required to post the chemicals at their well sites to provide emergency responders with recommended

first-aid treatments and handling instructions.

But environmentalists say the existing information is inaccessible or indecipherable. They said new federal laws were needed to

force a uniform disclosure.

If Range Resources is planning to disclose the chemicals it uses in its drilling operations, there is no reason other companies

can't do the same," said Elizabeth Maclin, TU's Vice President for Eastern Conservation. "With thousands of wells being drilled

throughout Pennsylvania, knowing what is in fracking fluids is an important step toward protecting the state's natural resources."

Contact staff writer Andrew Maykuth at 215-854-2947 or [email protected] .

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EXHIBIT 15 09/17/2013

Workshops, Seminars, Events

Monday, August 26 in Bath, NY- "Landowners & Gas

Leases: What are your Rights?" 7-9 pm at the Bath Fire

Hall, 50 East tvforris St. Information about compulsory

integration, expiring leases royalty payments

mortgage & homeowner insurance conflicts. Bring your

ease, Speakers: attorney Joe Heath and Fleased

organizer Ellen Harrison.

New York SGS links

• Nov. 2012 proposed Fracking Regulations

• Sept. 2011 release of ressed SGEIS

• DEC's page on all things SGEIS

EPA Hydrofracking Study

On Dec 21, 2012 EPA released an update on their

hydrofracking study. Conclusions due in 2014.

Report a Spill or Dumping

EPA Eyes On Drilling

Report non-emergency

dumping, illegal &

suspicious hauling,

disposal:

1-877-919-4372

eyosondrillingepa.gov

To report a spill in NY

state:

1-800-457-7362

To report an emergency

spitl or release of

hazardous material to

the National Response

Center:

1-800424-8802

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8/30/13

The Mcollus Effect: Range Resources Promises ""Really Will" Disclose Frathng Chemicals

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The Marcellus Effect

Thursday, July 29, 2010

Range Resources Promises they "Really Will" Disclose Fracking Chemicals

photo of Bamatl shale well

pmvided by Tim Ruggie,o.

story updated Thursday

afternoon

Two weeks ago Range

Resources announced that

they would voluntarily

disclose hydraulic fracturing

chemicals used in drilling

Marcellus Shale. At that

time they provided a link to

a "sample Marcellus Shale

Completion Report" and

seemed to imply that

interested people would be

able to find a list of all the fracturing chemicals they use somewhere on their website.

While it's tree that Range Resources has a link to the information on their home page,

some people were hoping for a handy list of all the fracking chemicals used in

Marcellus. At this point in time all that's posted is the initial press release, a description

of casing design and one sample completion report.

But that will change, says public affairs director, Matt Pitzarella. In a phone conersation

this morning, Pitzarella reiterated Range Resources' commitment to increased

transparency.

"Beginning now, completion reports will hate an addendum attached that lists the

fracturing chemicals, as well as their amounts, used in drilling each well," Pitzarella

said. These will be posted to the Company website as well.

Where, exactly? Pitzarella wasn't sure. "We're re-vamping the website and hope to

make it easier for people to find information," he said. Soon, meaning sometime within

the next 4 weeks (but earlier, he hopes), there should be a button on the left column

guiding people to "completion reports" or "hydraulic fracturing". He's still working out the

details.

After reminding me again that it was voluntary, Pitzarella said, "We're hoping that these

reports give people the facts they need to make their own decisions. Some people are

concerned that fracturing chemicals will get into their aquifers. So we want to make sure

they know what we're using and the [sery small] amounts."

°)stOd Cy ;r', 'i"'3t1' 3 31,1

The famous "TING" Binder

1 comment: J INVESTIGATES NATUPAL GAS

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J15 rrmrcell useffect.blog spot.com/2010/07/photo-of-barnatt-shale-wel l-prosided- by. html 1/5

09/17/2013

EXHIBIT 16 09/17/2013

8130/13 Range Resources to Disclose Chenics Used in Gas Drilling WSJ.com -4

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Natural-Gas Driller to Disclose Chemical Use Article Stock Quotes Comments (5) MORE IN 8US4SS.

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By RUSSELL GOLD

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Bloonlbsnj Ilces

Extracting natural gas from shale requires forcing in water and some chemicals to crack the rock open, worrying residents about pollution.

Range Resources Corp. LccJ says it plans to disclose the chemicals used

to hydraulically fracture natural-gas wells in Pennsylvania, confronting rising pressure

from environmental groups worded that drilling could contaminate drinking water.

Available to WSJ.com Subscribers

General Electric Set to Exit Retail Lending

Insurance Subsidies Help Older Buyers

The decision, which Range said was voluntary, reflects the mounting distrust that

energy companies face, especially in the wake of the ongoing oil spill in the Gulf of

)xico. Even before the offshore spill, the industry was facing increasing scrutiny as Verizon-Vodafone

gas drilling in the Marcellus Shale spreads across Pennsylvania and neighboring Impact: 'Colossal'

states. V4 __ ; " In a significant break from past practice, Range says it will begin submitting a detailed Second-Quarter GIT

- •. l't-of-alLchemicals and additives, and the volumes, used to .

-- WeflStO the state. - - - -- -. - -- - - -

"There has been so much misinformation about the Marcellus we think 's prudent" to

begin making this information public, says John Pinkerton, chairman and chief Don't Miss executive of the Fort Worth, Texas, company. Range holds leases for 13 million

online .wsj.corrVarticl SB 10001424062748703834 4575365360901 763540. htrif 1/4

09/17/2013

8/30/13 Range Resources to Disclose Cherrcs Used in Gas Drilling - WSJ.com

acres in the Marcellus and its ability to develop the gas is central to future growth. "It's

the right thing to do morally and ethically, but it's also right for our shareholders," he

says. IF Itil, I %, E ?c !, Range plans to make the disclosures with state Department of Environmental How to Gel the Bronx 14-Year-Old Billionaire Builds

Protection within 30 days of "frac" jobs, and post the information online. Most Out of Your Is Shot by Police High-End Resort

Mites Town in Swiss

Alps The decision was praised by environmental groups and some members of Congress

who have proposed a law to require similar levels of disclosure. More in Business

The industry has resisted disclosing the chemicals it uses, although that has been

softening recently. Exxon MabI Corp. [ 9] Chairman and Chief Executive

Rex Tillerson told Congress earlier this year he "wouldn't object to any disclosure."

Loosening gas molecules from dense shale rock requires drilling a well, then pumping

in thousands of gallons of fluid under high pressure to crack the rock open. Range

used 4.5 million gallons in a simple fracture of a recent well—the overwhelming

majority being water, according to a sample of the disclosure provided by the

company. It also used smaller amounts of chemicals such as sodium hydroxide,

ethylene glycol, hydrochloric acid and benzalkonium chloride.

Range says the purpose of disclosure was to dispel concerns that chemicals added

to fracture fluids are a risk. The fluid is being pumped a mile beneath the groundwater

and is 99.8% water and sand, the company says. And the chemicals are "comparable

to household chemicals in a very diluted form," says Ray Walker, a Range executive.

Some politicians and environmental groups that support increased use of natural gas

as a cleaner alternative to coal have expressed frustration with the industry's

disclosures. Tim Wirth, a former Democratic senator from Colorado who has been a

prominent advocate for natural gas, says the industry's penchant for secrecy is

making it harder to win over skeptics. 3 "If there's no problem, then disclose,' W. Wirth said. "That's the price of admission in

this day and age."

Amy Mall, senior policy analyst with the Natural Resources Defense Council, says the

industry has used hundreds of different chemicals in fracture fluids in the past. She 4 said the disclosure will help homeowners who have had difficulty figuring out what

chemicals to test for when they grew suspicious that their water well had been

contaminated. "Many of these chemicals aren't part of a standard test; you have to

know what to test for," she says. -

,Ajso, John Hanger, secretary of the Pennsylvania Department of Environmental

Protection, said he was pleased with Range's new policy. "If one company can do it,

everyone can do it—and should do it. The holding back of information in this area has

fueled public suspicion." He said these Range disclosures and an ongoing study by

the federal Environmental Protection Agency into chemicals used in fracture fluids

should go a long way to create confidence. STREAM

Jan .Jarrett, president of Citizens for Pennsylvania's Future, an environmental Corporate Intelligence: Live Coverage

advocacy group, applauded Range's disclosure program as a "step in the right

direction." She said the state should make it mandatory.

Write to Russell Gold at ri,iti.elLgold(diwsj.com

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online.wTj con'arlicic/SB10001424052748(038346O45753653t3O901 763540htcrd 214

09/17/2013

EXHIBIT 17 09/17/2013

8/30/13


SeamS Sac

r .. o. ' - -

7520 Al0.37 0, 49

HOME OUR COMPANY OPERATIC NVEfOR RELATIONS OWNER RELATIONS NEWSROOM OUR COMMITMENT CAREERS CONTACT

IveU Csinpktttøn Reports

Range Resources announced on July 14, 2010 that the Company would voluntarily disclose the composition of each of the hydraulic fracturing components for all the wells operated by Range Resources with the Pennsylvania Department of Environmental Protection (D E P) completed in the Marcellus Shale.

1 (ji,k tin iriginal press release and atia.hmenisl

Ranges disclosure initiative will provide regulators, landowners and ettisens of the Commonwealth an accounting of the highly ,

diluted additives used at each well site, along with their classifications, solumes, dilution factors, and specific and common

purposes. The information will be submitted to the DIP as part of Range's well eumpletem reports and on the Company's

as ebsite,

I his astluritaD initiative as ill increase transparency and jib's people to better understand that the Marcellus Shale vi a valuable

resource that can be pursued responsibly and for the benefit of all of the cttvens of Penns Ivania. As shown below, all of the

additive-. Range uses are highly diluted. trefully managed and in many eases commonly used in our everyday lives. We are

hopeful that out voluntary disclosure as ill help dispel the misconceptions that have pci stated and alibis Range and otheis to

deliver on the potential of this extraordinary resource base.

Range believe,, that the hydraulic fracturing process is environmentally sale. The location 01 the Mareellus is geiterall over a

mile helms the water table for our drinking as ater and is isolated by more than three million pounds of steel and concrete as

n in the diagrams hekiss

v.mw.rang eresources.cooVq etdoc/iTOe3bcO3-3b16'mSl 7 a29b-e2b8efedtIWell-Compleion-Repods.aspx 1/24

09/17/2013

8/30/13

Range Resources - Hdraric Fracturing Fluid Selection and Management

Search S is

r irr

7520 -4,0.3710.49'-

HOME OUR COMPANY OPERATIONS INVESTOR RELATIONS OWNER RELATIONS NEWSROOM OUR tMMI1M%ilT - CAREERS CONTACT

Hydraulic Fractunug Fluid Selection and Management

Fracturing Fluid Selection and Disclosure:

Hydraulic fracturing a time tested and proven technology utilized by the oil and natural gas industry for more than 60 years

and in more than 1 million wells. This is a process that requires the iniection of fluid, under pressure to create a network of

fissures for trapped hydrocarbons to safely flow to the surface through our production facilities and eventually to fuel our

homes, vehicles, electricity and businesses.

Transparency and open dialogue are vital to the continued progress of energy development. This pushed Range to become

the first company to voluntarily disclose the fracturing fluid for each completed well on our website. Range has supported

new regulations on disclosure through PA (Iii, 78 provisions, new legislation of Act 13 and trade group. efforts.

In Pennsylvania, kct 13 "enacted one of the most aggressive and transparent hydraulic fracturing disclosure laws in the country.....Colorado's requirements, upon which much of this Act's disclosure requirements were based, is ere hailed by progressive industry representatives.

environmental organizations and many other groups as a model for other states" - Pr'nnsvlvania Department of Jenvi,onme,mEaI Protection

States like Pennsylvania Colorado. Lunsnami and others require operators to submit a chemical disclose through

Frac Focus, a national chemical disclosure registry for oil & gas exploration founded by the Ground Water Protection

Council and the Interstate Oil & Gas Compact Commission.

Advanced planning is critical to eliminating any impacts from potential impacts. Even though chemical additives are

carefully managed, highly diluted, encompassed by secondary containment and injected through multiple cemented strings of

steel casing, Range selects vendors that utilize the most environmentally , friendly additives whenever technically possible

Roughly 99.9'U of the tiacturing fluid is water and sand, the rest is a blend of common chemicals that are a part at our everyday lives or as the Groundwater

Protection Council indicated essentially 'soap."

Many state, require Spill Prevention Control and Contingency (SPCC') plans for each well site, which describes the best

practices to be used in the event of a spill Active well locations maintain a series of onsite preventative technologies, such

as absorbent materials to soak up a contained spill and vacuum trucks to eliminate any spilled liquid on location

Range supports the ongoing scientific research of our industry (link collaboration tab here). Reputable universities such as

the gv,gs of J,exa', and gJJ have done intense scientific research on natural gas development in prominent shale plays

like the Barnett. the Marcellus and the llavne'svllle. These studies hound 'no e'vklence" of hydraulic fiacturing leading to

groundwater contamination.

In other states like Virginia. where Range develops a number of different geologic formations that produce hviirocarbonv

Range utili-z.,s a combination of nmtlogcu, water, sand and sonic chemicals. For instance the I ow er Huron Shale formation

in tivi t ste hic'a t1i \ its i ccii is not lute, 1 sti itte grcciii ,,ouse ga "Cs list and has pros en io be one it the n ens. st c henac a s

used in hdiauhc fracturing, Keep in mind that nitrogen cannot be used to stimulate all geologic tormsitionv. In other

instances we may tie requr ed to utilize some concentrations of chemicals typically guar guns, foaming agents and polemitmally

wswv.rangereSources.con'Jg etdoc/20cc7d07-383b--476f-83a0-d4ab250a8757/Hydraulic- Fracturing- Floid-Selection- and- Manag errsnn.aspx 1/2

09/17/2013

8/30/13

Range Resources - HdrauIic Fracturing Fluid Selection and Management

some other chemicals, all of which can be found at EtitcFocuorg on a per well basis.

Instates like Oklahoma we also utilize environmentally responsible fluids under strict state regulations. It is in Oklahoma

where the GroundwaterProtectRIls Council and the Interstate Oil and Cots Compact Commission are based. Those tWO

organizations jointly launched the widely lauded FracFocus effort, which Range participates in for all wells across the

company.

Links:

Range Resources Well Completion Reports

Hydraulle Fracturing Fact Sheet

Water Usage Fact Sheet

Frç Foicirs

Groundwater Protection Council

Interstate Oil and Gas Compact Commission

Back to Environment

HOME I OUR COMMITMENT I HYDRAULIC FRACTURING FLUID SELECTION

AP'10 MAMOLMO1ST

100 THROCKMORTON STREET. SUITE 1200 FORT WORTH, TX 76102

1817-870-2601 F 817-869-9100

E INFO( gRANG ERE SOURCES COM

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EMAIL US PRIVACY NOTICE LEGAL NOTICE SITE MAP RSS

Copynghl © 2010 Range Rc,nurces Corporation. All rrghts rereed.

2/2

09/17/2013

EXHIBIT 18 09/17/2013

Range suppports disclosure, new technologies I OPINIONO2

Page 1 of 2

observer-reporter.com S71'Itg uthwtteru PiiyJvwua

Letters

Range suppports disclosure, new technologies

Tuesday, April 23,2013

A recent letter by Brian Rothermund, "Range oblivious to irony," which appeared in the April 16 edition of the Observer-Reporter, repeated a false statement that the contents of fracturing fluid in oil and natural gas development are a secret. LII This is not the case. While all companies are required by regulation to disclose today, Range was actually the first company to voluntarily disclose fracturing fluids on a per well basis in the entire United States back in 2010. Not much was reported at the time locally, but The Wall Street Journal thought it was important enough to run the announcement on their front page.

Anyone interested can visit rangeresources.com for the information, for wells here or anywhere else in the nation. The contents are also listed at fracfocus.org a website run by the United States Groundwater Protection Council (GWPC).

Rothermund supported the notion that the public should be kept in the dark about decisions that our local governments make regarding commerce and private land development. He stated that government should not feel the least bit compelled to share the private dealings of our local representatives. We believe transparency and an open dialogue on issues that matter is of critical importance.

Range is on record on countless occasions being in support of, and in fact lobbying for, not against, smarter and tighter regulations that adapt to new and emerging technologies. Pennsylvania has consistently been ranked with high scores by independent teams from the GWPC and the Interstate Oil and Gas Compact Commission, which is made up of state and federal, regulators, academics, environmentalists and other nongovernmental organizations, and industry scientists.

Like many people in the natural gas industry, my family came to this country three generations ago and landed right here in Washington County. We all want to make sure our natural resources are responsibly developed and in a manner that maximizes those benefits for us all.

EXHIBFT kfaa celia _

http:i \vww.observer-reporter.com/apps/pbcs.dl i/article?A ID/20 13 042310P1N 10N021 1304. 9/1001 3

09/17/2013

- Range suppports disclosure, new technologies I OPINIONO2

Page 2 of 2

McMurray

Pitzarella is a spokesman for Range Resources.

Copyright 2012 Observer Publishing Company.All rights reserved. This material may not be published, broadcast, rewritten or redistributed.

http://www.observerreporter.corn/apps/pbcs.dll/article'?A1D/20 I 30423/OPINIONO2/1 304... 9/3/201 3

09/17/2013

EXHIBIT 19

09/17/2013

RANGE RESOURCES CORP (RRC)

10-K Annual report pursuant to section 13 and 15(d) Flied on 02/22/2012 Filed Period 12/31/2011

THOMSON REUTERS ACCEWS

, +'. •• k?.

I: THOMSON REUTERS

r

Ii EXHIBIT

09/17/2013

Table of Contents

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-K (Mark one)

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2011

OR

0 TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from to

Commission File Number: 001-12209

RANGE RESOURCES CORPORATION (Exact Name of Registrant as Specified in Its Charter)

Delaware 34-1312571 (State or Other Jurisdiction of (IRS Employer Incorporation or Organization) Identification No.)

100 Throckmorton Street, Suite 1200, Fort Worth, Texas 76102

(Address of Principal Executive Offices) (Zip Code)

Registrant's telephone number, including area code (817) 870-2601

Securities registered pursuant to Section 12(b) of the Act: Title of Each Class Name of Exchange on Which Registered

Common Stock, $01 par value New York Stock Exchange

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes 0 No 0

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes No

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes 0 No 0

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate website, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T during the proceedings 12 months (or for such shorter period that the registrant was required to submit and post such files). Yes 0 No

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K is not contained herein, and will not be contained, to the best of registrant's knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K. 0

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller reporting company. See the definitions of "large accelerated filer," "acceleratg flier" and "smaller reporting company" in Rule 12b-2 of the Exchange Act (check one):

Large accelerated filer RI Accelerated filer 0 Non-accelerated filer 0 (Do not check if a smaller reporting company) Smaller reporting company 0

Indicate by check mark whether the registrant is a shell company (as defined in 12b-2 of the Act). Yes 0 No

TheagegatemarkeLvalueoLthe voting and non-voting common equity held by non-affiliates as of June 30, 7011 was $8486,292,. Tldsamounti&

and directors of the registrant are not included in the computation. However, the registrant has made no determination that such individuals are "affiliates" within the meaning of Rule 405 of the Securities Act of 1933.

As of February 17, 2012, there were 161,748,938 shares of Range Resources Corporation Common Stock outstanding.

09/17/2013

Table of Contents

Business Strategy

Our objective is to build stockholder value through consistent growth in reserves and production on a cost-efficient basis. Our strategy to achieve our objective is to increase reserves and production through internally generated drilling projects coupled with occasional complementary acquisitions. Our strategy requires us to make significant investments in technical staff, acreage, seismic data and technology to build drilling inventory. Our strategy has the following principal elements:

Concentrate in Core Operating Areas. We currently operate in two regions: the Appalachian (which includes shale tight gas, coal bed methane and conventional natural gas, natural gas liquids, condensate and oil production in Pennsylvania, Virginia, and West Virginia) and Southwestern (which includes the Permian Basin of West Texas and the Delaware Basin of New Mexico, the Texas Panhandle, the Ardmore Basin in Southern Oklahoma, the Nemaha Uplift in Northern Oklahoma and the Anadarko Basin of Western Oklahoma). Concentrating our drilling and producing activities in these core areas allows us to develop the regional expertise needed to interpret specific geological and operating trends and develop economies of scale. Operating in multiple core areas allows us to blend the production characteristics of each area to balance our portfolio toward our goal of consistent production and reserve growth at attractive returns. Maintain Multi-Year Drilling Inventory. We focus on areas with multiple prospective, productive horizons and development opportunities. We use our technical expertise to build and maintain a multi-year drilling inventory. A large, multi-year inventory of drilling projects increases our ability to consistently grow production and reserves. Currently, we have over 8,600 proven and unproven drilling locations in inventory.

• Focus on cost efficiency. We concentrate in core areas which we believe to have sizeable hydrocarbon deposits in place that will allow us to consistently increase production while controlling costs. As there is little long-term competitive sales price advantage available to a commodity producer, the costs to find, develop, and produce a commodity are important to organizational sustainability and long-term shareholder value creation. We endeavor to control costs such that our cost to find, develop and produce natural gas and oil is in the best performing quartile of our peer group.

• Commitment to environmental, health and safety. We implement the latest technologies and best practices to minimize potential impacts from the development of our nation's natural resources as it relates to the environment, worker health and safety, and the health and safety of the communities where we operate. Working with peer companies, regulators, nongovernmental organizations, industries not related to the natural gas industry, and other engaged stakeholders, we consistently analyze and review performance while striving for continual improvement. In July 2010, we voluntarily elected to provide, on our website, the hydraulic fracturing components for all wells operated by us and completed to the Marcellus Shale formation.

• Maintain Long-Life Reserve Base. Long-life natural gas and oil reserves provide a more stable growth platform than short-life reserves. Long-life reserves reduce reinvestment risk as they lessen the amount of reinvestment capital deployed each year to replace production. Long-life natural gas and oil reserves also assist us in minimizing costs as stable production makes it easier to build and maintain operating economies of scale. We use our acquisition, divestiture, and drilling activities to assist in executing this strategy.

• Maintain Flexibility. Because of the risks involved in drilling, coupled with changing commodity prices, we remain flexible and adjust our capital budget throughout the year. If certain areas generate higher than anticipated returns, we may accelerate drilling and acquisitions in those areas and decrease capital expenditures and acquisitions elsewhere. We also believe in maintaining a strong balance sheet and using commodity derivatives, which allows us to be more opportunistic in lower price environments and provides more consistent financial results.

• Equity Ownership and Incentive Compensation. We want our employees to think and act like stockholders. To achieve this, we reward and encourage them through equity ownership in Range. All full-time employees receive equity grants. As of December 31, 2011, our employees owned equity securities in our benefit plans (vested and unvested) that had an aggregate market value of approximately $314.0 million.

09/17/2013

Table of Contents

We acquire significant amounts of unproved property to further our development efforts. Development and exploratory drilling and production activities are subject to many risks, including the risk that no commercially productive reservoirs will be discovered. We acquire both producing and unproved properties as well as lease undeveloped acreage that we believe will enhance growth potential and increase our earnings over time. However, we cannot assure you that all prospects will be economically viable or that we will not abandon our initial investments. Additionally, there can be no assurance that unproved property acquired by us or undeveloped acreage leased by us will be profitably developed, that new wells drilled by us in prospects that we pursue will be productive or that we will recover all or any portion of our investment in such unproved property or wells.

Our indebtedness could limit our ability to successfully operate our business

We are leveraged and our exploration and development program will require substantial capital resources depending on the level of drilling and the expected cost of services. Our existing operations will also require ongoing capital expenditures. In addition, if we decide to pursue additional acquisitions, our capital expenditures will increase, both to complete such acquisitions and to explore and develop any newly acquired properties.

The degree to which we are leveraged could have other important consequences, including the following:

we may be required to dedicate a substantial portion of our cash flows from operations to the payment of our indebtedness, reducing the funds available for our operations;

• a portion of our borrowings are at variable rates of interest, making us vulnerable to increases in interest rates;

• we may be more highly leveraged than some of our competitors, which could place us at a competitive disadvantage;

• our degree of leverage may make us more vulnerable to a downturn in our business or the general economy;

• we are subject to numerous financial and other restrictive covenants contained in our existing credit agreements the breach of which could materially and adversely impact our financial performance;

• our debt level could limit our flexibility to grow the business and in planning for, or reacting to, changes in our business and the industry in which we operate; and

• we may have difficulties borrowing money in the future.

Despite our current levels of indebtedness, we still may be able to incur substantially more debt. This could further increase the risks described above. In addition to those risks above, we may not be able to obtain funding on acceptable terms.

Our business is subject to operating hazards that could result in substantial losses or liabilities that may not be fully covered under our insurance policies

Natural gas, NGL and oil operations are subject to many risks, including well blowouts, cratenngs, explosions, uncontrollable flows of oil, natural gas or well fluids, fires, formations with abnormal pressures, pipeline ruptures or spills, pollution, releases of toxic gases and other environmental hazards and risks. If any of these hazards occur, we could Sustain substantial losses as a result of:

• injury or loss of life;

• severe damage to or destruction of property, natural resources and equipment;

• pollution or other environmental damage;

• clean-up responsibilities;

• regulatory investigations and penalties; or

• suspension of operations.

We maintain insurance against some, but not all, of these potential risks and losses. We may elect not to obtain insurance if we believe that the cost of available insurance is excessive relative to the risks presented. We have experienced substantial increases in premiums, especially in areas affected by hurricanes and tropical storms. Insurers have imposed revised limits affecting how much the insurers will pay on actual storm claimns plus the cost to re-drill wells where substantial damage has been incurred. Insurers are also requiring us to retain larger deductibles and reducing the scope of what insurable losses will include. Even with the increase in future insurance premiums, coverage will be reduced, requiring us to bear a greater potential risk if our natural gas and oil properties are damaged. In addition, pollution and environmental risks generally are not fully insurable. If a significant accident or other event occurs that is not fully covered by insurance, it could haves material adverse affect on our financial condition and results of operations.

21

09/17/2013

EXHIBIT 20 09/17/2013

IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY, PENNSYLVANIA

STACEY HANEY, individually and as parent and natural guardian of HARLEY HANEY, a minor, and PAIGE HANEY, a minor, and BETH VOYLES and JOHN VOYLES, husband and wife, ASHLEY VOYLES, individually, LOREN KISKADDEN, individually, GRACE KJSKADDEN, individually,

Plaintiffs,

V.

RANGE RESOURCES - APPALACHIA, LLC, NEW DOMINION CONSTRUCTION, INC., TERRAFIX ENVIRONMENTAL TECHNOLOGY,INC., SKAPS INDUSTRIES, INC., ENGINEERED SYNTHETIC PRODUCTS, INC., RED OAK WATER TRANSFER NE, LLC, MICROBAC LABORATORIES, INC., MULTI-CHEM GROUP, LLC, UNIVERSAL WELL SERVICES, INC., HALLIBURTON ENERGYSERVICES, INC., SAXON DRILLING, L.P., HIGHLAND ENVIRONMENTAL,LLC, EAP INDUSTRIES, INC., and TEST AMERICA, INC.,

Defendants.

CIVIL DIVISION

No. 2012-3534

DEFENDANT'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' FIRST SET OF REQUESTS FOR ADMISSIONS DIRECTED TO DEFENDANT RANGE RESOURCES-APPALACHIA, LLC

Filed on Behalf of Defendant Range Resources - Appalachia, LLC

Counsel of Record for This Party:

Dennis St. J. Mulvihill, Esquire, PA I.D. #16411 Bruce IL Rende, Esquire, PA I.D. #52714 Erin J. Dolfi, Esquire., PA I.D. #86472

ROBB LEONARD MULVIHILL LLP Firm #249 BNY Mellon Center 500 Grant Street, 23rd Floor Pittsburgh, PA 15219

Telephone: (412) 281-5431 Facsimile: (412) 281-3711

JURY TRIAL DEMANDED.

EXHiBIT R0371852.1 } ao

09/17/2013

29. Admit that Range does not know the chemical make-up of all the products used at

the Yeager Site.

RESPONSE: Range admits that it does not have an all-encompassing knowledge of the complete chemical formula of every product used at the Yeager Site by Range and/or its subcontractors, as some products contain proprietary compounds which may not be known to Range and many of the MSDS do not list the non-hazardous components of products. To the extent currently possible, the MSDS for the various products used at the Yeager Site have been produced to Plaintiffs.

30. Admit that Range conducted all of its investigations and made findings of water

quality without full knowledge of all chemicals used at the Yeager Site.

RESPONSE: Range admits that it did not have an all-encompassing knowledge of the complete chemical makeup of each chemical product used at the Yeager Site by Range and/or its subcontractors when Range conducted all of its investigations and made findings of water quality as some products contain proprietary compounds, which are not known to Range. However, Range does have a general working knowledge of the chemical makeup of the products used at the Yeager Site. To the extent currently possible, the MSDS for the various products used at the Yeager Site have been produced to Plaintiffs.

31. Admit that at least one outside slope of the Yeager Impoundment failed or

otherwise slide from its original position and had to be reconstructed.

RESPONSE: It is denied that at least one outside slope of the Yeager Impoundment failed or otherwise slide from its original position and had to be reconstructed. By way of further responses, while Range admits that there was a slight movement in the surface of sediment trap number 4, it is denied that the outside sloped moved from its original position.

32. Admit that at least one slope of a sediment trap at the Yeager Impoundment failed

or otherwise moved from its original position and had to be reconstructed.

RESPONSE: Range admits that there was a slight movement in the surface of sediment trap number 4, but the impoundment's embankment did not move from its original position.

09/17/2013

0

VERIFICATION

1, dk 0. 1.: on behalf of Range Resources - Appalachia.

LLC, verify that I am authorized to execute this Verification and that the statements made in the

foregoing Objections and Responses to Plaintiffs' First Set of Requests for Admissions Directed

to Defendant Range Resources-Appalachia, LLC are true and correct to the best of my

knowledge, information and belief and/or are based upon information that has been provided to

me by others, and are made subject to the penalties of 18 Pa.C.SA. § 4904 relating to unsworn

falsification to authorities.

Date: By:

•b Name

Title

0

09/17/2013

EXHIBIT 21 09/17/2013

S


LOREN KISKADDEN Appellant,

V. EHB Docket No. 2011-149-R

COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF ENVIRONMENTAL PROTECTION

Appellee,

RANGE RESOURCES-APPALACHIA, LLC

Permittee.

DEPARTMENT OF ENVIRONMENTAL PROTECTION'S RESPONES TO APPELLANT'S FIRST SET OF REQUESTS FOR ADMISSION

DIRECTED TO RESPONDENT PENNSYLVANIA, DEPARTMENT OF ENVIROMENTAL PROTECTION

0 Appellee, Department of Environmental Protection ("DEP" or "Department") makes the

following responses ("Responses") to Appellant Loren Kiskadden's First Set of Requests for

Admissions ("Requests" or "Requests for Admissions") Directed to Pennsylvania Department of

Environmental Protection pursuant to Rule 102 of the Environmental Hearing Board's Rules of

Practice and Procedure, 25 Pa. Code § 1021.102.

Appellant included a section entitled "Definitions and Instructions" in these Requests that

is identical to the "Definitions and Instructions" included in Appellant's First Supplemental Set

of Requests for the Production of Documents ("Supplemental Document Requests") served

concurrently with these Requests. The Department is serving its written response to Appellant's

Supplemental Document Requests concurrently with this written response to Appellant's

Requests for Admissions and incorporates herein the Department's "Prefatory Directions to

Requests" section of its response to the Supplemental Document Requests, inclusive of the

09/17/2013

The Department objects to this Request as not reasonably calculated to lead to the production of

admissible evidence because whether or not the Department requested or did not Request

additional information regarding a product identified in a specific MSDS is unrelated to the

conclusions set forth in the September 9th Letter on appeal in this matter. Subject to the

foregoing and without waiving the foregoing objections, page DEP0038 lists components of this

product.

31. Admit that the only information submitted to the Pennsylvania DEP by Range

Resources identifying the chemical/substance components of BioBlend B- 10 was the MSDS for

BioBlend B-10, BioLube RDP-100 identified as Pennsylvania DEP document numbers 0035-0044

in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the

Production of Documents.

AdmitX Deny

32 Admit that the Pennsylvania DEP does not have any knowledge of what

chemicals and/or substances that make up >90% of the product Sulfatrol, identified as

Pennsylvania DEP document numbers 0055-0058 in the Department's Responses to Appellant

Loren Kiskadden's First Set of Requests for the Production of Documents.

Admit DenyX

The MSDS states that the substances that make up greater than 90% of this product are "Non-

hazardous and other components below reportable levels," and that less than 2% of this product

is made up of crystalline silica quartz.

- ---------- - ---

15

09/17/2013

0 33 Admit that the Pennsylvania DEP never requested that Range Resources identify

and submit information/documentation identifying what chemicals and/or substances make up

>90% of the product Sulfatrol, identified as Pennsylvania DEP document numbers 0055-0058 in

the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the


Admit Deny


admissible evidence because whether or not the Department requested or did not request



foregoing and without waiving the foregoing objections, the MSDS states that the substances that

. make up greater than 90% of this product are "non-hazardous and other components below

reportable levels." Subject to the foregoing and without waiving the foregoing objections, to the

extent this Request asks the Department to admit that it never specifically requested additional

documents regarding the singular product named "Sulfatrol" beyond the MSDS itself, then the

Department admits.

Resources identifying the chemicals and/or other components of Sulfatrol was the MSDS for

Sulfatrol, identified as Pennsylvania DEP document numbers 0055-0058 in the Department's

Responses to Appellant Loren Kiskaddens First Set of Requests for the Production of

Documents.

Admit X Deny______

F11

09/17/2013

0 35. Admit that the Pennsylvania DEP does not have any knowledge of what specific

chemicals and/or substances found in or make up the product knows as Xan-plex D, identified as



Admit Deny X

The chemical name for this product on page DEP0068 is polysaccharide polymer.

36. Admit that the Pennsylvania DEP never requested Range Resources identify and

submit information/documentation identifying the chemical and/or substances that are found in or

make up the product Xan-plex D, identified as Pennsylvania DEP document numbers 0068-0071 in

go the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the


Admit Deny




conclusions set forth in the September 9 th Letter on appeal in this matter. Subject to the

foregoing and without waiving the foregoing objections, to the extent this Request asks the

Department to admit that it never specifically requested additional documents regarding the

singular product named "Xanplex D" beyond the MSDS itself, then the Department admits.

........... .-.. - --

17

09/17/2013

.

37. Admit that the only information/documentation submitted to the Pennsylvania

DEP by Range Resources identifying the chemical and/or other components of Xan-plex-D was

the MSDS for Xan-plex D, identified as Pennsylvania DEP document numbers0068-0071 0071

in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the


Admit X Deny

38. Admit that the Pennsylvania DEP does not have any knowledge of what

chemicals and/or other substances make up >80% of the product X-cide 102, identified as



Admit DenyX

The MSDS states that the substances that make up greater than 80% of this product are "Non-

hazardous and other components below reportable levels," and that less than 10 to 30% of this

product is made up of glutaraldehyde.

39. Admit that the Pennsylvania DEP never requested that Range Resources

identify and submit information/documentation identifying what chemicals and/or substances

that make up >80% of the product X-cide 102, identified as Pennsylvania DEP document

numbers 0072-0076 in the Department's Responses to Appellant Loren Kiskadden's First Set of

Requests for the Production of Documents.

Admit Deny

40 The Department objects to this Request as not reasonably calculated to lead to the production of

18

09/17/2013

S admissible evidence because whether or not the Department requested or did not request



foregoing and without waiving the foregoing objections,, to the extent this Request asks the

Department to admit that it never specifically requested additional documents regarding the

singular product named "X-cide 102" beyond the MSDS itself, then the Department admits.


DEl' by Range Resources identifying the chemicals and/or other components of X-cide 102

was the MSDS for X-cide 102, identified as Pennsylvania DEP document numbers 0072-0076 in


. Production of Documents.

Admit X Deny

41. Admit that diesel fuel was used as hydraulic fracturing fluid at the Yeager 7H

well.

Admit Deny

To the extent this Request asks whether the Department can admit or deny whether hydraulic

fracturing fluid at the Yeager 7H well was comprised of diesel fuel, then the Department can

neither nor admit nor deny this Request after a reasonable investigation because the Department

is not aware of Range Resources using diesel fuel as its hydraulic fracturing fluid at the Yeager

7H well.

------------- - - ---

...-.

-----------

us

09/17/2013

• 42

Admit that the kerosene used at the Yeager 7H well is also knows as Fuel Oil

No.!.

Admit

Deny

.

This Request is compound because it assumes that kerosene is used at the Yeager 7H and then

asks the Department to admit that kerosene is also known by another name. Because it is

compound, this Request is vague and ambiguous and thereby burdensome. Subject to the

foregoing and without waiving the foregoing objections, the Department admits that the

Department has referred to kerosene as fuel oil No. 1.

43. Admit that the Pennsylvania DEP does not have any knowledge of what specific

chemicals and/or substances make up >84% of the product Deso Deflocculant, identified as



AdmitX Deny


identified and submit information/documentation identifying what chemicals and/or substances

that make up >84% of the product DesoDeflocculant, identified as Pennsylvania DEP document



Admit . Deny



w

go

09/17/2013

additional information regarding a product identified in a specific MSDS has nothing to do with

the Department's conclusions set forth in the September 9th Letter on appeal in this matter.

Subject to the foregoing and without waiving the foregoing objections, to the extent this Request

asks the Department to admit that it never specifically requested additional documents regarding

the singular product named "DesoDeflocculant" beyond the MSDS itself, then the Department

admits.


DEP by Range Resources identifying the chemicals and/or other components of Deso

Deflocculant was the MSDS for Deso Deflocculant, identified as Pennsylvania DEP document



Admit X Deny

46. Admit that the Pennsylvania DEP does not have any knowledge of what chemicals

and/or substances make up 100% of the product Drispac (regular and super-b) polymer,

identified as Pennsylvania DEP document numbers 0095-0)01 in the Department's Responses to

Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

Admit X

The subject MSDS contains a statement that no components of this material were found on the

regulatory lists searched in preparation of the MSDS.

0

21

09/17/2013

0


DEP by Range Resources identifying the chemicals and/or other components of Drispac (regular

and super-b) polymer was the MSDS for Drispac (regular and super-b) polymer, identified as



Admit X Deny


identify and submit information/documentation identify what chemicals and/or substances make

up 1001/6 of the product Drispac (regular and super-b) polymer, identified as Pennsylvania DEP

document numbers 0095-0101 in the Department's Responses to Appellant Loren Kiskadden's

First Set of Requests for the Production of Documents.

Admit Deny






Department to admit that it never specifically requested additional documents regarding this

singular product beyond the MSDS itself, then the Department admits.


DEP by Range Resources identifying the chemical and/or other components of LD-9 was the

VA

09/17/2013

MSDS for Xan-plex D, identified as Pennsylvania DEP document numbers 0102-0105 in the

Departments Responses to Appellant Loren Kiskadden's First Set of Requests for the


Admit X Deny

50. Admit that the Pennsylvania DEl' does not have any knowledge of what

chemicals and/or other substances make up the product LD-9, identified as Pennsylvania DEP



Admit Deny X

The subject MSDS contains a statement that no components of this material were found on the

regulatory lists searched in preparation of the MSDS.

51. Admit that the Pennsylvania DEl' never requested that Range Resources identify

and submit information/documentation identifying what chemicals and/or substances that make

up the product LD-9, identified as Pennsylvania DEl' document numbers 0102-0105 in the

Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the


Admit Deny





09/17/2013

0 foregoing and without waiving the foregoing objections, to the extent this Request asks the




chemicals and/or substances make up >90% of the product LIGCO, identified as Pennsylvania

DEP document numbers 0106-0110 in the Department's Responses to Appellant Loren

Kiskadden's First Set of Requests for the Production of Documents.

Admit Deny X

The subject MSDS states that greater than 90% of the components are "Non-hazardous and other

components below reportable limits."


DEP by Range Resources identifying the chemicals and/or other components of LIGCO was the

MSDS for LIGCO, identified as Pennsylvania DEP document numbers 0106-0110 in the



Admit X Deny

54. Admit that the Pennsylvania DEP never requested that Range Resources identify

and submit information/documentation identify what chemicals and/or substances make up

>90% of the product LIOCO, identified as Pennsylvania DEP document numbers 0106-0110 in


.

24

09/17/2013

0 Production of Documents.

Admit Deny









is chemicals and/or substances make up the product Mil Glide-C?, identified as Pennsylvania DEP



Admit Deny X

Styrene is listed as comprising less than 1% of this product, and the remainder is identified as

"below reportable levels" on this MSDS.


DEP by Range Resources identifying the chemicals and/or other components of Mu-Glide CF

was the MSDS for Mil-Glide C?, identified as Pennsylvania DEP document numbers 0121-0125 in

- ------- -------

25

09/17/2013



AdmitX Deny

57. Admit that the Pennsylvania DEP never requested that Range Resources identify and

submit information/documentation identify what chemicals and/or substances make up the

product Mu-Glide CP, identified as Pennsylvania DEP document numbers 0121-0125 in the



Admit Deny









chemicals and/or substances make up the product Milstarch., identified as Pennsylvania DEP

document numbers 0142-0145 in the Departrnentrs Responses to Appellant Loren Kiskadden's First

Set of Requests for the Production of Documents.

• Admit . X

RM

09/17/2013

This MSDS states, among other things, that "The manufacturer lists no ingredients as hazardous"

and that "This product is not known to a 'hazardous chemical' as defined by the OSHA Hazard

Communication Standard, 29 CFR 1910.1200."


DEP by Range Resources identifying the chemicals and/or other components of Milstarch was the

MSDS for Milstarch, identified as Pennsylvania DEP document numbers 0142-0145 in the



AdmitX Deny


and submit information/documentation identify what chemicals and/or substances make up the

product Milstarch, identified as Pennsylvania DEP document numbers 0142-0145 in the



Admit Deny





foregoing and without s'aiving the foregoing objections, to the extent this Request asks the

27

09/17/2013

0 Department to admit that it never specifically requested additional documents regarding this


61. Admit that the Pennsylvania DEl' does not have any knowledge of what

chemicals and/or substances make up 60-80% of the product NewDrill, identified as



Admit DenyX

This MSDS states, among other things, that 60 to 80% of this product is "Non-hazardous and

other components below reportable levels."

S62. Admit that the only information/documentation submitted to the Pennsylvania

DEl' by Range Resources identifying the chemicals and/or other components of NewDrill was the

MSDS for NewDrill, identified as Pennsylvania DEl' document numbers 0146-0149 in the



AdmitX Deny

63. Admit that the Pennsylvania DEl' never requested that Range Resources identify

and submit information/documentation identify what chemicals and/or substances make up 60-

80°% of the product NewDrill, identified as Pennsylvania DEl' document numbers 0146-0149 in the

28

S

09/17/2013

.


Production of Documents

Admit Deny









S and/or substances make up 50% of the product HVG-1 Fast Hydrating Guar Slurry, identified as



Admit Deny X

This MSDS states that greater than 50% of this product is petroleum distillates.

65. Admit that only information/documentation submitted to the Pennsylvania DEP

by Range Resources identifying the chemicals and/or other components of HVG- I Fast

Hydrating Guar Slurry was the MSDS for HVG-I Fast Hydrating Guar Slurry, identified as



n Admit X Deny

w

29

09/17/2013

.


and submit information/documentation identify what chemicals and/or substances make up 50%

of the product HVG- I Fast Hydrating Guar Slurry, identified as Pennsylvania DEP document



Admit Deny





• foregoing and without waiving the foregoing objections, to the extent this Request asks the




and/or substances make up the product FRW 200 Polymerized Friction Reducer, identified as



Admit Deny X

This MSDS states among other things that this product is "non-regulated" under a "DOT Hazard

Classification."

30

09/17/2013

.


DEP by Range Resources identifying the chemicals and/or other components of IRW 200

Polymerized Friction Reducer was the MSDS for FRW 200 Polymerized Friction Reducer,

identified as Pennsylvania DEP document numbers 0181-0183 in the Department's Responses to

Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

Admit X Deny


and submit information/documentation identify what chemicals and/or substances make up

the product FRW 200 Polymerized Friction Reducer, identified as Pennsylvania DEP document

numbers 0181-0183 in the Departments Responses to Appellant Loren Kiskadden's First Set of

.


Admit Deny








70. Admit that the Pennsylvania DEP took more than one water sample from the

leak detection zone for the Yeager Impoundment.

.

AdmitX Deny

.•..

31

09/17/2013

EXHIBIT 22 09/17/2013


LOREN KISKADDEN

Appellant, Docket No. 2011-149-R

VS.


Appellant,

vs.


Permittee.

PERMITTEE RANGE RESOURCES - APPALACHIA, LLC'S AMENDED RESPONSES TO APPELLANT'S FIRST SET OF INTERROGATORIES

AND SECOND SET OF REQUESTS FOR ADMISSION

Pursuant to 25 Pa. Code § 102 1.102 and Rules 4006 and 4014 of the Pennsylvania Rules

of Civil Procedure, and as mandated by the Board's July 19, 2013 Order [Dkt. 196], Permittee

Range Resources - Appalachia, LLC ("Range"), hereby serves these Amended Responses

("Responses") to selected portions of Appellant's First Set of Interrogatories and Second Set of

Requests for Admission (collectively, "Requests").

AMENDED RESPONSES TO FIRST SET OF INTERROGATORIES

3. Please IDENTIFY any and all products, including but not limited to fluids and/or

its chemical components, applied to McAdams Road to prevent the spreading of dust or as a dust

suppressant or for any other purpose, including but not limited to, the contents of the product,

any testing performed on the product, the manufacturing information for the product and the

Ei *

09/17/2013

RESPONSE:

The only product Range applied to McAdams Road was fresh water, and Range has

supplied the water manifests in connection with the same. See also RRA-LK_0 10722 - 010772.

One shipment of water was obtained from the Lowry Meter Vault, which draws from the PA

American Water System. See RRA-LK_0 10722. One shipment of water was obtained from the

Carol Baker well site. See RRA-LK_0 10723. All other shipments of water were obtained from

the Washington County Fire Academy. See RRA-LK_010724 - RRA-LK 010772. Range is

not aware of any testing that was ever performed on the water. Range is not aware of any

manufacturing information regarding the water, Deeter Farms Construction, Inc. was the

company responsible for applying the water to the road.

7. Please IDENTIFY each and every of the following products listed in Table I

(below) by including the following:

(a) Whether the products was used at the Yeager Wells (including which of the Yeager wells), the Yeager Impoundment and/or the Yeager Drill Cuttings Pit;

(b) When the product was used at each of the applicable locations designated in subsection (a);

(c) The purpose for which the product was used at each of the applicable locations designated in subsection (a);

(d) What stage of drilling operations was the product used at each of the applicable locations designated in subsection (a);

(e) What company supplied the product to be used at each of the applicable locations designated in subsection (a);

(0 What chemicals, including all proprietary chemicals, make up the product;

(g) What company applied the product at each of the applicable locations designated in subsection (a); and

'1

09/17/2013

(h) All manufacturing information for the product

PRODUCT NAME

1. Caustic Soda

2. Caustic Soda

3. Asphasol Supreme

4. Tannathin

5. Sodium Bicarbonate

6. Super-Sweep

7. Salt Gel

8. Soda Ash

9. SAFE-SCAV HS

10. SAFE-CARB

11. QUICK SLIDE

12. POLYS WELL

13. Desco Deflocculant

14. Cal Carb Mix

15. FMVISRM

16. 'TIME

17. HUBERCARB Q40-2W

18. Calcium Chloride

TABLE 1

MANUFACTURER AND/OR SUPPLIER

- Baker Hughes Drilling Fluids

M-I SWACO

M-I L.L.C.

M-I L.L.C.

M-I SWACO

M-I L.L.C.

M-I SWACO

M-I SWACO

- M-I SWACO

M-I SWACO

- Alpine Specialty Chemicals

- M-I SWACO

- Chevron Phillips Chemical Company LP

- Fluids Management, LTD

Fluids Management, LTD

M-1 Drilling Fluids UK Ltd

- J.M. Huber Corporation

- M.I. Drilling Fluids UK Ltd

09/17/2013

L I

L

19. FMSperse Fluids Management, LTD

20. ABSORB-N-DRY Balcones Minerals Corporation

21. GXM Fluids Management, LTD

22. FM WASH Fluids Management, LTD

23. FM WA II Fluids Management, LTD

24. ABS 40 Fluids Management, LTD

25. ABS MIJL Fluids Management. LTD

2E. TRU VIS Fluids Management, LTD

27. Cortex, 222 Barrier Cream Cortex Products

28. PERMASEAL Fluids Management, LTD

29. ABS40 MUD/SLURRY Fluids Management, LTD

30. FM VIS LS Fluids Management, LTD

31. FM VIS II Fluids Management, LTD

32. BIO ADD 7555 Shrieve Chemical Products Co.

33. BlO-COR 2899 Shrieve Chemical Products Co.

34. G-SEAL M-I SWACO

35. Potassium Chloride J&H Bunn Ltd

36. FED ZAN D Federal Wholesale Drilling Mud

37. DRILZONE L M-I SWACO

38. DUROGEL M-1 L.L.0

39 Citric acid M-ISWACO

40; Ammonium phosphate, dibasic Fisher Scientific

41. X-TEND LUBE PLUS lGrinding & Sizing Co., Inc.

4

09/17/2013

42. DESCO Agri-Empresa

43. MF-55 Agri-Empresa

44. Sodium Bicarbonate Agri-Empresa

45. White Starch Agri-Empresa

46. 40 HTL Corrosion Inhibitor Industrial Compounding, LLC

47. APB-1, Ammonium Persulfate Breaker Frac Tech Services, LLC

48. B-9, PH Increase Buffer Industrial Compounding, LLC

49. BROMOCRESOL GREEN- RICCA Chemical Company LLC METHYL RED INDICATOR, ALCOHOLIC

50. BXL-2, Crosslinker/Buffer

51. Cal Ver 2 Calcium Indicator

CS-250 SI

CS-650 OS, Oxygen Scavenger

CS-Polybreak 210

Diesel Fuel Low Sulphur

EDTA

FE- 1001, IRON CHELATOR

FRW-50

FTS WELLCLAY 100

HTLB-1, HIGH TEMPERATURE LIQUID BREAKER HVG-I, FAST HYDRATING GUAR SLURRY

Hydrochloric Acid, 0.001-0.49 Normal Aqueous Solutions

Industrial Compounding, LLC

Hach Company




Coastal Chemical Co., L.L.C.

RICCA Chemical Company LLC






RICCA CHEMICAL COMPANY LLC

52.

53.

54.

55.

56.

57.

58.

59.

60.

1 61.

5

09/17/2013

I •

63. ICI-150 Industrial Compounding, LLC

64. ICI-3240 Industrial Compounding, INC.

65, KCLS-2, KCL Substitute Industrial Compounding, LLC

66. LTA-1. Low Temperature Activator Industrial Compounding, INC.

67. MA-844W CESI Chemical

68, 5040 Methyl Purple Indicator RICCA Chemical Company LLC

69. NE 100 Industrial Compounding, LLC

70, NE 100 (winterized) Industrial Compounding, LLC

71. PHENOLPHTALEIN SOLUTIONS RICCA Chemical Company LLC

72. POTASSIUM CHROMATE RICCA Chemical Company LLC SOLUTIONS

73. Shale Surf 1000 Industrial Compounding, LLC

74. Silver Nitrate RICCA Chemical Company LLC

75. SODIUM HYDROXIDE SOLUTIONS RICCA Chemical Company LLC

76. Sulfuric Acid, 0.02N Sciencelab.com , Inc.

77, Water Hardness Buffer RICCA Chemical Company LLC

78. Water Hardness Indicators RICCA Chemical Company LLC

79. FlexFirm KS Newpark Drilling Fluids, LLC

80. New Phalt - DynaPhalt Newpark Drilling Fluids, LLC

81. NewBar - Barium Sulfate Newpark Drilling Fluids, LLC

82. NewEase 203 Newpark Drilling Fluids, LLC

83: NoFóanr X, Octyl Alcohol Newpark Drilling Fluids, LLC

84. Milstarch Baker Hughes Drilling Fluids

85. MIL-PAC LV 113aker Hughes Drilling Fluids

rel

09/17/2013

86. MIL-PAC (ALL GRADES) Baker Hughes Drilling Fluids

87. MIL-GLIDE Baker Hughes Drilling Fluids

88. Citric Acid Solution, 50% Baker Hughes Drilling Fluids

89. HEC- 10, Hydroxyethyl Cellulose Baker Hughes Drilling Fluids

90. Oil Dry, Hydrous Magnesium Newpark Drilling Fluids, Inc. Aluminum Silicate

91. EXP-D256C-99 (REM) Drilling Specialties Company

92. HYPERDILL AF 257 HYCHEM, INC.

93. White Starch Newpark Drilling Fluids, LLC

94. FORTA Super-Sweep FORTA Corporation

95. 60/40 Blend Newpark Drilling Fluids, LLC

96. AQUA PAC, Polyanionic Newpark Drilling Fluids, LLC cellulose derivative

97. Aquabloc, Sodium Carboxymethyl Raw Materials Corporation Starch

98. Desco Deflocculant Drilling Specialties Company

99. Citric Acid, Anhydrou Fisher Scientific U.S.P./N.F. (Granular)

100. POLY-PLUS RD M-I L.L.C.

IC!. POLYPAC UL M-I L.L.C.

102, POLYPAC SUPREME R M-I L.L.0

103. PIPE-LAX ENV M-I L.L.C.

104. PECAN NUT PLUG M-I L.L.C.

105, Myacide GA 25 BASF Corporation

106. M-I-X II I M-1 SWACO

7

09/17/2013

107. M-I WATE

108. M-I GEL WYOMING

109. LD-8

110. LD-9, Polyether Polyol

Ill. X-CIDE 102

112. W.O. DEFOAM

113. XAN-PLEX D, Polysaccharide

114. Walnut Shells

115. TERRA-RATE

116. SULFATROL

117. Soltex Additive

118. Sodium Chloride, Solid

119. Sodium Bicarbonate

120. Soda Ash, sodium carbonate

121. Potassium Chloride

122. SAPP

123. PERMA-LOSE HT

124. NEW-DRILL, Anionic Polyacrylamide Copolymer Emulsion

125. CRUMB RUBBER

176. DESCO DEFLOCCULANT

127. DF-450

128. DF-900

M-I L.L.C.

M-I L.L.C.

Baker Hughes Drilling Fluids








Chevron Phillips Chemical Company LP, Drilling Specialties Company








Anchor Drilling Fluids USA, Inc.




1

09/17/2013

129. DIASEAL M, Anchor Drilling Fluids USA, Inc. DIATOMACEOUS EARTH

130. DIXIE-RED MUD Anchor Drilling Fluids USA, Inc.

131. DRILL THIN Anchor Drilling Fluids USA, Inc.

132. DRILLING PAPER Anchor Drilling Fluids USA, Inc.

133. DRILL-OUT Anchor Drilling Fluids USA, Inc.

134. DRISPAC (R & SL), Drispac Polymer Anchor Drilling Fluids USA, Inc.

135. DYNARED Anchor Drilling Fluids USA, Inc.

136. FIBER PLUG Anchor Drilling Fluids USA, Inc.

137. FIBER-SEAL Anchor Drilling Fluids USA, Inc.

138. FLO-THIN HT, Anionic Polyacrylate Anchor Drilling Fluids USA, Inc.

139. FLOWZAN Anchor Drilling Fluids USA, Inc.

140. FOAM BREAK Anchor Drilling Fluids USA, Inc.

141. FOAMER CD Anchor Drilling Fluids USA, Inc.

142. GILSONITE Anchor Drilling Fluids USA, Inc.

143. GYPSUM, Calcium (11) Sulfate Anchor Drilling Fluids USA, Inc. Dihdrate

144. HEC, Hydroxyeythyl Cellulose Anchor Drilling Fluids USA, Inc.

145. HEC LIQUID Anchor Drilling Fluids USA, Inc.

146. HIGH YIELD GEL Anchor Drilling Fluids USA, Inc.

147. KCL SUBSTITUTE, Potassium Anchor Drilling Fluids USA, Inc. Chloride

148. KNOCKOUT 50, Ammonium Anchor Drilling Fluids USA, Inc. BisuIfiteSoIutioñ

149.'-

KNOCKOUT 1200, Zinc Salt Anchor Drilling Fluids USA, Inc. of Polyphenolic Acid

09/17/2013

150. K-SEAL Anchor Drilling Fluids USA, Inc.

151. LCF Blend Anchor Drilling Fluids USA, Inc.

152. LCF 1/2 Anchor Drilling Fluids USA, Inc.

153. LIME, Calcium Hydroxide Anchor Drilling Fluids USA, Inc.

154. LUBRA-GLIDE (FINE & COARSE) Anchor Drilling Fluids USA, Inc.

155. LW-200 Anchor Drilling Fluids USA, Inc.

156. MAGMA FIBER Anchor Drilling Fluids USA, Inc.

157. MF-55, Polyacrylamide Mixture Anchor Drilling Fluids USA, Inc.

158. MICA (F,C), Muscovite Anchor Drilling Fluids USA, Inc.

159. M-I-X II Anchor Drilling Fluids USA, Inc.

160. MUD SAFE CR Anchor Drilling Fluids USA, Inc.

161. MULTI-SEAL Anchor Drilling Fluids USA, Inc.

162. MYACIDE GA 25 Anchor Drilling Fluids USA, Inc.

163. NUTSHELL (F,M,C) Anchor Drilling Fluids USA, Inc.

164. OIL BASE MUD Anchor Drilling Fluids USA, Inc.

165. OIL DRY, Hydrous Anchor Drilling Fluids USA, Inc. Magnesium Aluminum Silicate

166. ORGANOLIG Anchor Drilling Fluids USA, Inc.

167. PHENO SEAL Anchor Drilling Fluids USA, Inc.

168. POLY PLUS Anchor Drilling Fluids USA, Inc.

169. POLY STICKS Anchor Drilling Fluids USA, Inc.

170. PROPANE, Dimethylmethane Anchor Drilling Fluids USA, Inc.

171. REBOUND Anchor Drilling Fluids USA, Inc.

ID:

09/17/2013

1 '2. CHEM-SEAL

173. CI-300A

174. CITRIC ACID

175. COTTONSEED HULLS

176. BENTONE 910

177. BIOZAN, Welan Gum

178. BLACKSEAL

179. CALCIUM CARBONATE (F,M,C)

180. CALCIUM HYPOCHLORITE

181. CEDAR FIBER, Ground Wood

182. ANCO SORB /ALCOSORB

183. ANCO SPA













184. ANCO SPERSE, Chrome Anchor Drilling Fluids USA, Inc. Lignosulfonate

185. ANCO STARCH (WHITE & Anchor Drilling Fluids USA, Inc. YELLOW)

186. ANCO TROL, Gilsonite Anchor Drilling Fluids USA, Inc.

187. ANCO VIS L, Hydroxyethyl Cellulose Anchor Drilling Fluids USA, Inc.

188. ANCO VIS N.S. Anchor Drilling Fluids USA, Inc.

189. ANCOZAN

190. AQUA PAC, Sodium Carboxymethyl Cellulose

191. BENTONE 38

192. ANCO PAC (REGULAR & SUPERLO), Polyanionic Cellulose



lAnchor Drilling Fluids USA, Inc.


11

09/17/2013

194. ANCO PHALT PLUS, Anchor Drilling Fluids USA, Inc. Sulfonated Asphalt

195. ANCO PHALT S. Sulfonated Asphalt Anchor Drilling Fluids USA, Inc.

196. ANCO PIPE FREE lAnchor Drillina Fluids USA, Inc.

197. Anco Poly Beads

198. ANCO RIG WASH

199. ANCO ROPE, Terpene / Aliphatic Naphtha Blend

200. ANCO SALT GEL, Attapulgite

201. ANCO SHALE TREAT

202. ANCO DD, Modified Alkanolamide

203. ANCO DEFOAM

204. ANCO-DRILL (A, N), Partially Hydrolized Polyacrylamide

205. ANCO FIBER

206. ANCO LIG, Leonardite

207. Anco Liquid Phalt S

208. ANCO MICRO BLEND

209. ANCO MIJL MOD

210. ANCOMULOW

211. ANCOMIJLP
















212. ANCO MUL S Anchor Drilling Fluids USA, Inc.

213. Anco Mul T Plus - Anchor Drilling Fluids USA, Inc.

214. ANCO MUL T Anchor Drilling Fluids USA, Inc.

12

09/17/2013

215. ANCO MUL THIN Anchor Drilling Fluids USA, Inc.

216. VERSAMOD Anchor Drilling Fluids USA, Inc.

217. WT-22 Anchor Drilling Fluids USA, Inc.

218. X-CIDE 102 Anchor Drilling Fluids USA, Inc.

219. X-CIDE 207 Anchor Drilling Fluids USA, Inc.

220. XX-POLYMER Anchor Drilling Fluids USA, Inc.

221. ZINC CARBONATE Anchor Drilling Fluids USA, Inc.

222. ALCOMER 74-L / ANCO THIN HT-L Anchor Drilling Fluids USA, Inc.

223. ALCOMER 90L Anchor Drilling Fluids USA, Inc.

224. ALUMINUM STEARATE Anchor Drilling Fluids USA, Inc.

225. ALUMINUM SULFATE Anchor Drilling Fluids USA, Inc.

226. AMAIZO STARCH Anchor Drilling Fluids USA, Inc.

227. AMMONIUM NITRATE Anchor Drilling Fluids USA, Inc.

228. ANCO BAR (BARITE), Barium Anchor Drilling Fluids USA, Inc. Sulfate

229. ANCO BX Anchor Drilling Fluids USA, Inc.

230. ANCO CAT Anchor Drilling Fluids USA, Inc.

231. SODIUM HYDROXIDE Anchor Drilling Fluids USA, Inc. (CAUSTIC SODA)

232. SODIUM Anchor Drilling Fluids USA, Inc. TRIPOLYPHOSPHATE ANHYDROUS

233. SOLTEX, Sodium Asphalt Sulfonate Anchor Drilling Fluids USA, Inc.

234. STARCH (W & Y) Anchor Drilling Fluids USA, Inc. PREGELANTINIZED

235. SUNS WEEP Anchor Drilling Fluids USA, Inc.

13

09/17/2013

26. SUPERSLIDE GLASS BEADS (F, M, C, & MEGA)

237. SUPERS WEEP

238. TORK BUSTER PLUS

239. TORK BUSTER

240. VARISEAL

241. VERSA HRP

242. SAPP

243. SAWDUST

244. SEA MUD, Sepiolite

245. SHUR PLUG

246. S.O. LUBE 1000

247. SOAP STICKS

248. SODA ASH, Sodium Carbonate, Anhydrous

249. SODIUM BICARBONATE

250. POTASSIUM ACETATE

251. POTASSIUM CHLORIDE (KCL)

252. POTASSIUM HYDROXIDE

253. RED STRIPE

254. SACK FISHING TOOL

55. SALT, Sodium Chloride V

256. Ammonium Bifluoride

257. ACETIC ACID 60%





















Solvay Fluorides, LLC

Clearwater International L.L.C.

14

09/17/2013

258. ACID PENSURF

259. BENZOIC ACID

260. CARBO PROP

261. Casing Inhibitor

262. CLA-CHEL A

264. CLA-CHEK LP

265. NO. 2 Diesel Fuel

266. EGM Solvent

267. En-Breaker HPH

268. En-Breaker

269. FFL-10

270. FFL-20

271. Flomax5O

272. FRP-121

273. Fumaric Acid

274. H2S Scavenger

275. Hydrochloric Acid

276. Citric Acid, anhydrous

277. IRON CHEK

278. IRONSTA II C

279. OX-BREAKER

280. ARFLOW 7125 Paraffin Inhibitor

281. PARANOX


Emerald Kalama Chemical, LLC

CARBO Ceramics

Universal Well Services, Inc.



Phillips Petroleum Company

Universal Well Services Inc.







Sagar Enterprises, Inc.







Aquaness Chemical


15

09/17/2013

282. PARASOL II

283. PARASURF Universal Well Services Inc.

284. Resin Coated Silica, Lake, and Bank Santrol, Inc. Sands and Ceramic

285. Silica Sand U.S. Silica Company

286. Soda Ash, Dense Clearwater International L.L.C.

287. Sulfamic Acid Sagar Enterprises, Inc.

288. TRANSFOAM-A 1 Clearwater International L. L.C.

289. AQUET 921 Emulsifier Aquaness Chemical

290. UNIBAC Universal Well Services Inc.

291. BlO-CLEAR 1000 Clearwater International L.L.C.

292. BIO-CLEAR 200 Clearwater International L.L.C.

293. UNI-FLO Universal Well Services Inc.

294. UNIFLO 2 Universal Well Services Inc.

295. Unigel IXLR Universal Well Services Inc.

296. Unigel 5F Universal Well Services Inc.

297. Unigel 19XL Universal Well Services Inc.

298, FLOPAM AN 934 SH SNF INC.

299. AI-250 Clearwater International L.L.C.

300. UNIHIB A Universal Well Services Inc.

301. QAI-815 - - Clearwater International L.L.C.

302. CYANAFLO 105L Polymer Additive Kemira Water Solutions, Inc.

303. UWS AGA-150 Universal Well Services Inc.

__________ --------------------------- ----

rri

09/17/2013

304. UWS BXL-A

305. UWS NCL

306. UWS NDL-100

307. UWS NE-50

308. UWS NE-70

309. UWS NE-80

310. UWS NE-90

311. UNILINKBXL

312. ACID PENSURF

313. M-1 BAR

314. FED SEAL

315. Hydrous Silicate of Alumina

316. Microspheres, Cenospheres, Floating Ash, Hollow Spheres

317. FLO-STOP P

318. Cellosize (TM) Polymer HEC-18

319. CFL-25

320. Sodium Silicate 40 Grade

321. FLO-STOP P

322, Lafarge Fly Ash & Bottom Ash

323. FOAM CHEK

324. FOAM CHEK-L

325. USG HYDROCAL Gray Gypsum Cement










M-I Drilling Fluids UK Ltd.

FEDERAL

Black Hills Bentonite, LLC

USNR Coal Sales


The Dow Chemical Company




Lafarge North America Inc.



United States Gypsum Company

17

09/17/2013

326. Kol-Seal, Ground Coal WeiDril Products, Inc.

327. MRA Clearwater International L.L.C.

328. Portland Cements Essroc Cement Corp.

329, Potassium Chloride Clearwater International L.L.C.

330. Salt Gel M-I Drilling Fluids UK Ltd.

331. SC-900 Clearwater International L.L.C.

332. Sodium Chloride Mallinckrodt Baker, Inc.

333. Super Surf Clearwater International L.L.C.

334. TI-2 Universal Well Services Inc.

335. Trisodium Phosphate Dodccahydrate Sagar Enterprises, Inc.

336. 3M (TM) Glass Bubbles HGS2000, 3M HGS3000, HGS4000, HGS5000, HGS6000

337. Cellophane Flakes M-1 Drilling Fluids UK Ltd.

338. UNIHIB A Universal Well Services Inc.

339. OAI-815 Clearwater International L.L.C.

340. SAPP Clearwater International L.L.C.

341. UWS CFL-1 17 Universal Well Services Inc.

342. UWS CR-220 Universal Well Services Inc.

RESPONSE

Please see the attached spreadsheet.

18

09/17/2013

AMENDED RESPONSES TO SECOND SET OF REQUESTS FOR ADMISSION

4. Admit that ethylbenzene was used by Range Resources as a component of a

product in the drilling process at the Yeager Site.

RESPONSE:

Admitted. Per their MSDS sheets, ethylbenzene is a .10% or .20% constituent part of

Industrial Enamel HS, Pure White and Industrial Enamel, Safety Red. After a good faith

investigation, Range has made a reasonable inquiry, and the information known or readily

obtainable to Range is insufficient to enable it to admit or deny that either type of paint was ever

used at the Yeager Site. Ethylbenzene is a component part of Xylene (Xylol), which was used in

the air rig involved in the drilling process. Range does not currently believe that ethylbenzene is

a constituent part of any other product used in the drilling process at the Yeager Site, and Range

does not believe that it was ever used as part of a downhole product.

11. Admit that toluene was used by Range Resources as a component of a product in

the drilling process at the Yeager Site.

RESPONSE:

Admitted. Per its MSDS sheet, Diesel Fuel No. 2 contains toluene in some concentration.

Diesel Fuel No. 2 was used to power some equipment during the air rig drilling process. Range

does not believe that it was ever used as a part of a downhole product.

18. Admit that xylene was used by Range Resources as a component of a product in

the drilling process at the Yeager Site.

RESPONSE:

19

09/17/2013

Admitted. Per its MSDS sheet, xylene is a constituent part of MC DF-7 120 defoamer,

and this defoamer was occasionally used at the Yeager Site, though Range does not believe that

it was used as a dovrnhole product. Based on the manufacturer response, xylene also makes up a

small part of Seymour of Sycamore's "Stripe Flourescent Red I Orange" product. After a good

faith investigation, Range has made a reasonable inquiry, and the information known or readily

obtainable to Range is insufficient to enable it to admit or deny that this product was ever used at

the Yeager Site. Xylene (Xylol) was also used in the air rig involved in the drilling process.

28. Admit that t-butyl alcohol was used by Range Resources as a component of a


RESPONSE:

Denied. Range does not currently believe that t-butyl alcohol is a constituent part of any

product used in the drilling process at the Yeager Site.

34. Admit that ethylene glycol was used by Range Resources as a component of a


RESPONSE:

Admitted. Per its MSDS sheet, ethylene glycol is a constituent part of MC S-25 I OT scale

inhibitor. This product was used during the fracturing of the Yeager 7H well.

52. Admit that acetone was used by Range Resources as a component of a product in

_the drilling process at the Yeager Site.

20

09/17/2013

RESPONSE:

Denied. Per its MSDS sheet, acetone is a constituent part of Aervoe Rust Proof Paint -

Aerosol. After a good faith investigation, Range has made a reasonable inquiry, and the

information known or readily obtainable to Range is insufficient to enable it to admit or deny

that this type of paint was ever used at the Yeager Site, and therefore denies this request. Range

does not currently believe that acetone is a constituent part of any other product used in the

drilling process at the Yeager Site.

21

09/17/2013

Date: August 20, 2013 Respectfully submitted,

KZ5~- Kenneth S. Komoroski, Esq.

Pennsylvania Supreme Court No. 52708 Matthew H. Sepp, Esq.

Pennsylvania Supreme Court No. 85406 Steven E.H. Gibbs, Esq.

Pennsylvania Supreme Court No. 314894 FULBRIGHT & JAWORSKI LLP Southpointe Energy Complex 370 Southpointe Boulevard, Suite 300 Canonsburg, PA 15317 Telephone: (724) 416-0400

Michael C. Steindorf, Esq. (admitted pro hoc vice) Texas State Bar No. 19134800

Tyler H. Lipp, Esq. (admitted pro hac vice) Texas State Bar No. 24070151

FULBRIGHT & JAWORSKI LLP 2200 Ross Ave., Suite 2800 Dallas, Texas 75201-2784 Telephone: (214) 855-8000

Dennis St. J. Mulvihill, Esq. Pennsylvania Supreme Court No. 16411

Bruce E. Rende, Esq. Pennsylvania Supreme Court No. 52714

Erin J. Dolfi, Esq. Pennsylvania Supreme Court No. 86472

ROBB LEONARD MULVIHILL LLP BNY Mellon Center 500 Grant Street, 23rd Floor Pittsburgh, PA 15219 Tel: (412) 281-5431 Fax: (412) 281-3711

Counsel for Range Resources - Appalachia, LLC

22

09/17/2013

VERIFICATION

I,_ am authorized to Act on behalf

of Range Resources - Appalachia., LLC. I verify that any factual averments contained in the

foregoing are true based on my knowledge or information and belief. I make this verification

subject to the penalties of 18 PA. CONS. STAT. ANN. § 4904 (relating to unsworn falsification to

authorities).

A

LLC

09/17/2013

*

CERTIFICATE OF SERVICE

I hereby certify that on the 20th day of August, 2013, the foregoing FERMITFEE

RANGE RESOURCES - APPALACHIA, LLC'S AMENDED RESPONSES TO

APPELLANT'S FIRST SET OF INTERROGATORIES AND SECOND SET OF

REQUESTS FOR ADMISSION was served via FedEx and first class United States mail,

respectively, postage prepaid, on the below-listed individuals:

John M. Smith, Esq. Kendra L. Smith, Esq.

Smith Butz, LLC 125 Technology Drive, Suite 202

Bailey Center I, Southpointe Canonsburg, PA 15317 Counsel for Petitioner

Michael Heilman, Esq. Richard Watling, Esq.

Department of Environmental Protection Southwest Regional Office

400 Waterfront Drive Pittsburgh, PA 15222

Counsel for the Pennsylvania Department of Environmental Protection

Kai, -/5 Kenneth S. Komoroski, Esq.

09/17/2013

motion for adverse inference w/ exhibits (kiskadden v. pa dep and range resources)

Documents

esquire erin

esquire steven

esquire jeremy

esquire tyler

esquire john

esquire bruce

review of appellants

products permittee