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EXHIBIT 1

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07/19/2013

MR LOREN KISKADDEN
V.

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

EHB Docket No. 2011-149-R

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

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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

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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

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EXHIBIT 2

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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:

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

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-pri y~g!g

itpaiQJk&Ludi.doun1entsexisL

9573*4414

29

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38.

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

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

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 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," 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

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-privileged documents in its possession to the extent such documents exist 39. Please produce any and all documents, including but not limited to MSDS, which

identify all proprietary chemicals, substances and products used in any drilling fluid or mud at the Sicrezega Drill Site. RESPONSE: In addition to the General Objections, which are incorporated by

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

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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 RESPONSE:
reference,

In addition to the General Objections, which are incorporated by

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 Range to produce documents in its possession or control. Range objects to this Request as improperly seeking confidential and proprietary information. Range objects to
vague, ambiguous and
this

Request as

compound because of the use of the undefined terms "identify,"

"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. Subject to and without waiving the foregoing objections, Range will produce responsive, 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.
RESPONSE:

In addition to the General Objections, which are incorporated by to this Request as also

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

931492A

32

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EXHIBIT 3

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Transcript of the Testimony of

Date: December 17, 2012 Volume: Case: Loren Kiskadden v. Department of Environmental Protection

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IM

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31

33

1 chemicals that are in this particular product. 1 request for productions 37 through 39 and 2 MR.. KOMOROSKJ: And so I want to b 2 question 42 we asked for the identification of 3 clear, if we have it, we'll provide it. We 3 all proprietary chemicals used by Range 4 wont say that we have it but we won't disclose 4 specific to the Yeager site. Again, we 5 received some things from the DEP that have 5 it Unless - I can't imagine this to be the 6 case -- unless we have some confidentiality 6 Sierzegas on it. We didn't receive anything 7 7 agreement. from you guys responsive to that. S 8 But the way things typically work is Range So, again, I wanted to clarify we're not 9 will ask to have a certain situation addressed. 9 looking for anything from Sierzegas. We're 10 And a vendor will come in and say I am going t 10 looking for just the Yeager site. And, in 11 11 use this and I will represent that it will particular, some of the documents we did 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 15 constituents are. proprietary. 16 16 So what we're looking for when we say 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 Of if they have a name and its like a Beta 18 chemicals, the names of them. [can't believe 19 there's anything exotic that I haven't heard of 19 product or it's Beta 900. If we know it's Beta 20 900, we'll tell you what that is. And whatever 20 before. But the fact of the matter is on the 21 MSDS sheets, some of the things that the DEP 21 Material Safety Data Sheet they made available 22 22 provided to us that they believe were used at for it, we can provide that. 23 1 just don't want to overcommit to 23 Yeager indicates that they are 100 percent 24 proprietary so we have no idea what that might 24 something. And my view is if it's available 25 you should have it and we should have it. So 25 be. 32 34

1 if it's available, you'll have it and we'll MR. KOMOROSIU: Well, that one, if we 1 2 have it 2 have the information on what the proprietary 3 3 chemicals are, we'll provide it If we don't MS. SMITH: So I guess that's the 4 4 have it because it's - because the vendor 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 MR. KOMOROSKI: Right 7 could do better than that. 8 8 MS. SMITH: Okay. Because here's my 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 20 to protect. It's not necessarily the chemicals information. That's not something we can do or 21 our own. 21 that are used. Its the quantity of the 22 22 chemicals used in the product. 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

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35 1 2

37

1 motions. for purposes of this case. 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 if there is anything that we used that ended up 4 5 in Mr. Kiskadden's water supply or didn't. An 5 vendor for that information. As Range we'll 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 material was used at this concentration. And 22 what I am trying to avoid with this, Ken, is 1 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 MS. SMITH: Sure. 8 8 agreement on that And it's really contingent MR KOMOROSKI: So to the extent -9 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...

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EXHIBIT 4

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11
COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD' MR. LOREN KISKADDEN versus COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF ENVIRONMENTAL PROTECTION and RANGE RESOURCES APPALACHIA, LLC, Perrnite EHB Docket No. 2011-149-R

it

Verbatim transcript of hearing held at the 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

it

ADELMAN REPORTERS 302 Torrey Pine Drive Mars, Pennsylvania 16046

MOBIT

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APPEARANCES: KENDRA L. SMIT ESQUIRE JENNIFER L FAHNESTOCK, ESQUIRE 125 Technology Drive, Suite 202 Bailey Center Canonsburg, PA 15317 For - Mr. Loren Kiskadden RICHARD I. WAILING, ESQUIRE Department of Environmental Protection Southwest Regional Counsel 400 Waterfront Drive Pittsburgh, PA 15222

ALSO PRESENT: Maryann Wesdock, Esquire Jim Pinta

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

LF -A

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Ii
2 3 4 5 6 compel. 7 right?

ADMINISTRATIVE LAW JUDGE RENWAND: As I understand it, the first motion was you worked it out,

MR. KOr4OROSKI: I believe so, yes. ADMINISTRATIVE LAW JUDGE RENWAND: The motion to

MS. SMITH: Yes. Your Honor, with the motion to compel, we did meet and confer for two hours on Monday,

i
10 11 12

9 Mr. Komoroski and myself and Ms. Fahnestock. ADMINISTRATIVE LAW JUDGE RENWAND: Great. Thank you. MS. SMITH: And what resulted from that was Range

I,

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

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

2 3 still have an issue with that but Mr. -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

!j

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

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EXHIBIT 5

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S
LOREN KISKADDEN

COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD

Appellant, Docket No. 2011-149-R vs. DEPARTMENT OF ENVIRONMENTAL PROTECTION Appellant,

VS.

RANGE RESOURCES - APPALACHIA, LLC, Permittee. PERMITTEE RANGE RESOURCES - APPALACHIA, LLC'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:
.

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F-

L-

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

identify all proprietary chemicals, substances and products used to treat 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

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38.

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

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 Ca! Carb Mix Calcium Chloride FLR FM Sperse FM VIS LS FM WA U GXM ABSORB-N-DRY HUBERCARS Q40-200 PERMASEAL TRU VIS

S S S S S

S S S S S

__

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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. 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 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

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EXHIBIT 6

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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 abovecaptioned 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. INTERRIOGATORI ES 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

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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.
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Range Counsel February 22, 2013 Page 3 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
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Range Counsel February 22, 2013 Page 4 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.
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Range Counsel February 22, 2013 Page 5 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

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Range Counsel February 22, 2013 Page 6 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: kismith@smithbualaw.com

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:elefeatherreporting@comcast.net

FXHIW

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147 1 2 3 that would be used in the drilling process. MS. SMITH: That's why we asked in the Interrogatories be specific about. Because

4 otherwise this is just around and around and 5 6 7 8 9 10 11 around. It doesn't solve the problem. Again, our goal for this is to narrow the issues for trial. To agree upon the products that were there. And agree upon their content. It seems like it would be a fairly simple task. Which, obviously, it's not. But seems 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 15 the product. And the product will list what the chemical is. And then if there's a

16 proprietary chemical, then that's also 17 18 addressed in our letter. 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 24 25 indicated you will get it to us. And if you run into problems in trying to get that from your

you us-e-,---then
Eagle Feather Reporting
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148 1 2 3 4 5 6 7 that. MS. SMITH: I appreciate the trying. But this is now four months old since the first you come back and you tell us. The response that we got to that in discovery was we're still trying. MR. GIBBS: Yes. I can tell you

8 time we had the meet and confer and conference 9 with the Judge. 10 11 12 13 14 MR. GIBBS: In December? MS. SMITH: Was it December? MR. GIBBS: Three months. I mean, I can you tell you that responses are trickling in. And we will, in fact, produce all the

15 documents we get in response. Not all 16 17 18 19 responses are positive. But you know -MS. SMITH: I think -- and maybe this will help because if you're getting responses from the third-party contractor saying we're

20 not giving it to you, then that needs to be 21 22 identified to us. Because then what the Court 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 Eagle Feather Reporting

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149 1 2 3 4 5 6 So if you can identify -- right now identify the ones that say, nope, we're not giving it to you, then I can take that to the Court. And we can get that done that way. That takes that off your plate to give to us. If you're getting responses, you know, from

7 people, identify the people you're getting 8 9 responses to and we'll hold off on compelling 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 15 16 17 word -- said we'll do our very best to get this information. But understand because some of it is proprietary they may not be willing to give it to us. MR. GIBBS: Right. 19 20 21 22 MS. SMITH: I understand that. The Judge's response to it was we're going to get it one way or the other. You make your best 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 Eagle Feather Reporting

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150 1 have represented you have got some positive 2 3 responses and some not so positive responses. 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 8 9 Tuesday. And then we'll take it from there with the Judge to say, Your Honor, these are 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 14 15 MR. GIBBS: Okay. I mean, there are some who have committed to, you know, research the issue and get back to us. I certainly

16 don't want to push them with an order from the 17 18 Judge at this point. 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 25 knowledge of. Range has answered in Request for Admissions they don't know. The DEP has Eagle Feather Reporting
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151 1 2 3 4 answered in Request for Admissions they don't know. So the only person that has that is this third-party contractor who is not a party to this case who has to be in some way made to

5 give this information because this information 6 7 8 is needed by our experts to complete their reports. And so there is -- time is of the essence

9 now in terms of getting that information. We 10 11 12 13 14 15 16 17 18 have waited and we have waited. So if they have gotten back to you and said, yeah, we will get back to you, there's got to be some timeframe with that. It's not that they get back to us in a year. I mean, this case won't be around in a year. So if they're dragging their feet on it -- it's been several weeks or several months, you know, then that needs to be indicated, too. So we can we make a decision

19 along with the Judge as to how we're going to 20 21 22 proceed. Maybe that's a conference. Maybe that's a conference call with the Judge to say, look,

23 Your Honor, these five companies have said 24 25 absolutely we're not giving it to you. These companies say we're looking into. We'll get Eagle Feather Reporting
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152 1 back to you. Have not yet. And then maybe the 2 Judge issues some sort of order that puts a 3 4 5 6 7 deadline on it. Something so that we are advancing the ball forward. Because I ant sure it doesn't look like from your perspective. But from our perspective it looks like the ball 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 11 12 13 14 15 16 17 18 19 20 21 where this stands. And the Judge has asked us to come back. In fact, we have a motion pending. And he said, you come back, that motion is renewed and I will rule on it. So we're kind of in this limbo area. MR. GIBBS: Right. And I mean, I think it's important to understand, too, that those requests to the third parties did not go immediately in December. I mean, first we had to go through and identify each third party. 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 25 seeking. And so you know a lot of those didn't go out until February. So we still --I think Eagle Feather Reporting
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153 1 2 3 4 5 that it's appropriate to leave additional time for the third parties to -MS. SMITH: I am not saying that I am objectionable to that. That needs to be laid 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 15 16 17 you get them. So we would request that you provide them. But in that letter give us an indication 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 23 of a stone wall for it. So we're asking for 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, Eagle Feather Reporting
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154 1 2 3 4 5 6 7 8 you know, given whatever comes back from those companies. MR. GIBBS: All right. I can try to sort of compile everything into, you know, a single spread sheet or something like that and let you know the status of -MS. SMITH: That would be great. And 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 13 14 of thing. MR. GIBBS: Okay. MS. SMITH: And then so going back to

15 our Request for Admission I think we covered 16 17 18 19 20 21 22 23 it. So our point with asking about the chemicals is these are the products on site, admit that within these product these are the chemicals. And that's how those two are tied together. So when there's clarification from you guys as to specifically what was used at the site in 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 Eagle Feather Reporting
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EXHIBIT 8

09/17/2013

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

Product

Manufacturer

Response Notes

Date
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

LTD

3/20113

LTD

3/20/13

ASS-40

LTD

3/20/13

requesting that we resend the MSDS. Awaiting additional 3/5/13 requesting that we resend the MSDS. Awaiting additional

Berkeb0e 2+2 Staling

The Berkebile Oil Cornoanv. Inc.

Products Corporation manufactures Berkebile Starting Fluid. A letter will be sent to

counsel. Awaiting follow-up /1

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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 seeking the same information. Email response seeking additional background on the case, which was provided on 3/20. Awaiting fbHow-up respon se. 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 response Email response seeking additional background on the case, which was provided on 3120. Awaiting fbIlow-up response Email response seeking additional background on the case, which was provided on 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 cause substantial harm to I-flMar's bus iness.

Flo Stop P

Clearwater International

3113/13

FIR Fluid Film Non-Aerosol

Fluids Management; LTD Eureka Chemical Company

3/20/13

FM VIS LS

AES Drilling Fluids, LL.0

3/20/13

FM WA II FRW200

AES Drilling Fluids, LLC idustrfal Compounding.

3120113

HI-Mar DEC. 503/Octafoam 270

r1v

HI-Mar SpecIalties Indusiel Compounding,

2/13 31

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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.

North America

3/7/13

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

MOBIL RARUS 427

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

MOBIL RARUS SH( 1026 Letter enclosing current Safety 68

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.

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

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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 and 2011 MSDS.

Simple Green Sperlan Sterile Saline Solution

Sunshine Makers Spartan Eye & Face Protection, Inc.

3/12/13

SPIFaX(R) S 80W-140
Stripe Fluorescent Red/Orange

Equllon Enterprises LLC Seymour of Sycamore

3/10/13 3/4/13

TRU VIS

Fluids Management Division of AES LLC

3/20/13

Return to sender. Will attempt to find alternative address and/or source of information. Phone call and email. Full formula provided. Email response seeking additional background on the case, which was provided on 3/20. Awaiting follow-up 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 information will not be provided without a protective order.

W-0 Gypsum Cement

United States Gypsum Company

3113/13

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 3/5113 ZEP Manufacturing as well, ZEP Groovy

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EXHIBIT 9

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COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD

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. EHB Docket No. 2011-149-R

BEFORE: THOMAS W. REN WAND, Administrative Law Judge

ADELMAN REPORTERS 302 Torrey Pine Drive

Mam

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APP EARA NCES: KENDRA L. SMITH, ESQUIRE JENNIFER L. FAHNESTOCK, ESQUIRE 125 Technology Drive, Suite 202 Bailey Center I Canonsburg, PA 15317 For Mr. Loren Kiskadden
-

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

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
-

19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

09/17/2013 21 1
2 3

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

requesting is for them to tell me what chemicals are in there. So, I don't think JUDGE RENWAND: But you want the chemicals listed, you know, just chemicals, whatever chemicals are there? MS. SMITH: EXdCtly, Your Honor. And so JUDGE RENWAND: And what I'm asking you, I assume this has come up in other contexts where companies find themselves in the same position that Range is in now. And where does the you know, are there

4
5

6 7
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

inferences or presumptions that are made? MS. SMITH: Right. So, the case law that I'm familiar with, Your Honor, if the company for whatever reason can't give up that proprietariness of their product which the case law -JUDGERENWAND: They are going to tell me, I'm sure from what I've read, that we would love to give you that. I think Attorney Komoroski said that in one of the transcripts, but we don't have the information. You know, these various companies have it and we wrote to them and they told us we are looking at it or, you know, we don't reveal this information. It is company policy not to reveal it. MS. SMITH: Right, right. JUDGE RENWAND: You know, other legal speak which

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

N I

25

20
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

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

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 crossroads come down to if the company is not willing to give that proprietary information, then it leaves us in the position of asking the court for an adverse inference, that if you are not going to tell us what is there, then what we can identify as being there came from you. I mean t that is our alternative. i don't necessarily think that is fait, to Range to do that, hut if Range isn't willing to talk to the manufacturers to get that information more so - I mean, Mr. Komoroski characterized it as their good faith effort and they have no obligation to do that. Well, if that is tru.y how Range feels that they have no obligation to do i, then in turn, Your Honor, t would ask for an adverse inference JUDGE RENWAND: That is hre law, because I haven't w cn get that to y;u, ''our 11 ask for Lh

4
5

6 7
8 9 10 11 12 13 14 15 16 17 18 19 20

17 18 19

Honor, that is what I reed to know to say, "This is whit is in Mr:. Kiskadden's water. site, You used it up at, the It was in the drill

It was in the empiiernent.

20

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

-i y stym.us this who

t, t t

23

So,

hLs ra

PrccesC3to
1i

23

TJYJE RNWAND
to ne now 'cause th

mean, you don ' t

issue i

'e to qTt
in frr:oflt or ne,

24 23

gttirq 'o that rvJ pi rt. And

rqetirg

24 23

o t speak, Ca-Cola fcrmiU.

rn

but it; is going ti be

That covers

23 1 2 3 4 5 6 7 everything with MS. SMITH: for Range. JUDGE RENWAND: For Range, okay. MS. SMITH: Thank you, Your Honor. MR. GI8BS: Good morning, Your Honor. JUDGE RENWAND: Good morning. MR. GIBBS: Steve Gibbs of Fuibright and Jaworski I 2 3 4 5 6

09/17/2013 25 , all the chemicals that are hazardous are listed, right? MR. GIBBS: Correct, that is my understanding. JUDGE RENWAND: So, what they are saying is what is proprietary is water, things like that? MR. GIBBS: There may be another point that On the MSDS themselves, some of

7 should be made here. B

8 on behalf of Range. 9 As an initial matter, I think that we set forth

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 12 13 14 15 JUDGE RENWAND: I guess as she is saying, she is not asking for the formula. She is just asking for the listing. HR. GIBBS: Of every element or compound that -JUDGE RENWAND: Right. These are chemicals that

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 18 didn't Counsel for appellant indicated that if Range wasn't willing to communicate with the third

16 are put into the ground, Into the environment. 17 18 19 there? 20 21 22 23 24 25 MR. GIBBS: Range sent letters to every third party that both hadn't provided an WEDS where the chemicals added up to 100 percent of the formula by volume or weight and for which the chemicals or the -I'm sorry, the products were actually on site at some point, MR. GIBBS: In some instances. JUDGE RENWAND: Well, what instances aren't

19 parties, then an adverse inference was appropriate, I'm 20 21 22 23 24 not even sure that is true; but obviously, Range sent letters to every single one of the third parties, communicated with and followed up; and beyond that, Range really does not have control over the JUDGE RENWAND: But Range used all these products.

IM

25

24 1 2 3 4 5 MR. GIBBS: That is correct JUDGE RENWAND: And you haven't told the Department what is in those products; is that my understanding? MR. GIBBS: The MSDS sheets list -- my 1 2 3 4 5 So, in other words, if Range already had 100

26

percent of the formula, no Correspondence was sent. And for MSDS and, for example, the PlC plan for which the products were never at the site, Range didn't send correspondence for that. It was simply products that

6 understanding is that they list all the hazardous 7 chemicals. Now, beyond that, there may be non-hazardous 8 9 10 11 chemicals and certain companies list those as well, certain companies don't. JUDGE RENWAND: So, your position is that they list all the hazardous chemicals? And she has the list

6 were at the site for which part of the formula was 7 8 missing. 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 of the hazardous chemicals, that would be by this MSDS 13 definition of hazardous chemicals? 14 15 MR. GIBBS: Range realty That is correct, Regardless of that,

12 includes things such as paint and duct tape, things that 13 did not go into the ground. 14 15 16 JUDGE REN1,1AN;3: Right. I didn't think -- okay. I didn't think that would be that encompassing. MR. GIBBS: Well, my understanding was that you

there is nothing more that Range can do

16 to-17 18 19 JUDGE RENWAND: Really? Really? Range can't do anything more, huh? MR. GIBBS: Well, I mean, Range has sent

17 were saying that everything -- these chemicals were our 18 19 20 into the ground, and that is not true at all in this tnstance. JUDC' Pc' : .952.0....

20 OOrte5pcndence to every one of those.

act a itmt of all the chemiC5s that mete

22

;;R.ciIoEl : EcU 11.5 .sieoec cc. iouecotse sac, "Thiele proprietary." JUt/If RENWAND:
3a

22 23 24 25

put sub coo r,osi.O MR. G', BPS: No, we sent a itst of all the products with their associated ESUS. JUDGE P.EtISAND:
You sent a iLtd, of sit the

23 24 25

And it's proprietary, because it

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

27

09/17/2013
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

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
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

JUDGE RENWAND: Yeah, I think if she tells you that it is chemical A and you contact one of these companies and they say, "We are all full of chemical A," do you think you get it from them? MR. GIBBS: I mean, based on JUDGE RENWPND: But you are saying the risk should fall on Mr. Kiskadden? MR, GIBBS: You mean, in terms of obtaining the information or JUDGE RENWAND: You say Range is an innocent party here, that Range put products into the ground but you can't tell her -- correct me if I am wrong. I mean, her argument is you can't tell her what is in those arguments and what you are saying is, "We've done our best. We've contacted all of these people who aren't parties to this action, and we've asked them for their ingredients and they've told us no." MR. GIBBS: That is correct but except for the fact that they have the MSDS which, at least in theory, represent all of the hazardous components in those products. JUDGE RENWAND: Yeah. I guess the question is if all the hazardous components are in those products and the non-hazardous components are like water and whatever, I mean, why is that fight being made? I don't

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

17 18 19 20 21 22 23 24 25

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

IM,

25

28 1
2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

30
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19

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.

understand. MR. GIBBS: I assume for the same reason that, you know, Coca-Cola wouldn't give you their product information because you could then replicate their product. That is -JUDGE REMWAND: Well, I think if you look at a Coca-Cola can, it will tell you what the ingredients are. I'm looking at a Gatorade can right now, and it's telling me everything that is in here. Now, these are different, literally comparing apples and oranges here. But, as I understand it, that is all she is asking for. And I guess to analogize it, one of the things in here is citric acid, sucrose, salt. Water is one of them. I guess the way you are telling me would be like if Gatorade said, "Okay. We will tell you abujt the sucrose, citric acid, at cetera, but we are not saying anything about that water." Is that what you are telling me? MR. GIBBS: Perhaps, not exactly. Because when

Imean, on askod tot each cOsuonent 'icc rtnibut ion to 22

23 24 25
t

uaruasi px rl05 c aid i5kiri7 force:: ;ur:

Locs

fwn ii wit:: or upriaLir i jr

22
23 24 25

Ih.i oh Ia Si

a percuitagu.

it would be s'slpfu l

we could narrow Inc

So, I mean, i suppose it is cuss ible that cotta in compa flies ubj acted to I not
. tii I

soup.n of than in some way. That doesn't zneari that Insy mc ecirP to he my sore :aii]irgto provide it but

whet: we soc,ke to then,

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

NORTON ROSE FULBRIGHT

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
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. 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.

F)(HIBIT

John M. Smith Kendra L. Smith Michael Heilman Richard Watling August 20, 2013 Page 2

A,

09/17/2013

NORTON ROSE FULBRIGHT

Sincerely,

Kenneth S. Komoroski KSK Enclosures cc: Bruce Rende

156

..-.-.-

-..-

96201285.2

09/17/2013

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

09/17/2013

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 Me

Ether

<10% <8.5%

Multi-Chem lOT 'i -. >2>8_I 133K A Brand of ITW Devcon A Brand of ITW Devcon A Brand of 11W Devcon A Brand of 11W Devcon

>83<.5% 1-109 15-2 1

.

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

tit Stun Gasket Maker 502 CO

Inc.

Terminated

09/17/2013

201

10 <1
Cl
D

acetate 1 I

ore
F

flgHUIcI

sgray'rc Sunshine Sunshine Inc Inc. cal Companies, Inc.

cat Companies. Inc. al Companies. Inc. cal Companies. Inc. a1 cornoanies. Inc.

pose eane Simple Cleaner IDees&I Green Scrubbing Pad ipos. Cleana Simple I ClewwF Degeaserl Green Scrubbino Pad

undikited Unidantif Carbon C

Distillatei Solvent r Distillate Diorook

>94% roleum, he solvent-d ethyl ether arom.

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
M'ulac*Jrer response at RRA-LX 011184

no chemicals or

Manidacturer response at

RRA-LK 011184
Silicate of Alumina / Wyoming Bentonita/Sodium Montrmorlllonite 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

Black Hills Bentonite

Silicate of Alumina / Wyoming Bentonite/Sodium Montrmoilllonite P)rupI.x Blue 2

Black Hills Bentonite BP Lubricants USA 1 Calcium Carbonate

Blue 2

USA

Blue 2

BPLubdcants USA Inc,

Fritz Industries, Inc. Fritz Industries, Inc. Fritz Industries, Inc. Fritz Industries, Inc.

PC

Fritz Industries, Inc. Fritz Industries, Inc.

5-10% N 250- Severely Sciv1 Reined Heavy Pamifinic Palrvisum ON response at Baseail- hiityreflned (100%) Hygold L2000 Hydrotreated Heavy Naphthenlc Distillate Manufacturer response at Base oil - hy refined 1 (100%) RRA-LK 010830 Manufacturer response at Sodium hydroxide 1.3% RRA-LK 011243 2-Acrylamido-2-methylManufacturer response at RRA-LK 011243 1 -propanesulfonic acid 70.73% Manufacturer response at Glacial acrylic acid 22.25% RRA-LK 011243 Manufacturer response at Ammonium persulfate 2.90% RRA-LK 011243 Manufacturer response at 2-Mercaptoethanol 2.78% LRRALK 011243 Silicone Polymer Manufacturer response at Emulsion RRA-LK 011243 0.04%

09/17/2013

Rapid Isp

Raton Corpprathcn

100 Nel OR

41.82%

Rapid Tap

Ralton Cxporation

Chlonvax 5OLV

36.37%

(Ij Rapid Tap

Ralton Corporation

Lubdzol 5347

5.00%

___ 1 RapId Tap

Refton Corporation

LtrtuiI 5340MW

0.75%

O,in Rapid To

________ Raltan Corporelion

mducrsplacedbyNaw Rapid Tap for which composition Is provided In Columns C and D. Manufacturer response at RRA-LK 010851 roductrep4acedby"Now Rapid Tap for which composition Is provided In Columns C and D. Manufacturer response at RRA-LK 010851 Product replaced by New Rapid Tap,* for composition is provided in Columns C and D. Manufacturer response at RRA-LK 010851 Product replaced by *New Rapid Tap, for which composition Is provided in Columns C and D. Manufacturer response at RRA-Lt( 010851 Product replaced by "New Rapid Tap," for which composition Is provided In Columns C and D. Manufacturer response at

EWS Lard Ci

4.62%

Ck1gInlRzq3ld lap

Rattan Corporation

PPG-425

4.80%

0In4 Rapid Tap

lRokon Caporatlon

cimaman BQ 14MIlPF

10.06%

RRA-LK 010851 Product replaced by 'Mew Rapid Tap" for which composition Is provided In Columns and D. Manufacturer response at RRMJ( 010851 Product V y New Rapid Tap, for which con ip osldo,i Is provided Wi Co&imnsCandQ. Manufacturer response at JRRA4U( 010851
-

09/17/2013

X Soybean c

6.00

Rapid Tap," for which composition is provided In Columns C and D. Mnufacturer response RRA-ILI( 010851

at

Product replaced by "New Rapid Tap,' for which

composition is provided In Columns C and D. Manufacturer response at RRA-LK 010851

.100

0.10

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 and D. Manufacturer response at iporetlon
of Sycamore of Sycamore of Sycamore of Sycamore of Sycamore of Sycamore of Sycamore of Sycamore of Sycamore

Lubrtzd3l4OJ
Naphtha (petroleum), hydrotreated light - propane Calcium Carbonate n-butane V.T. Alkyd Resin Mineral Spirits isobutyl acetate TLnitan Tnoleate boiling point htha

020%
19.15% 15.13% 12.07% 8.88% 10.40% 3.78% 3.23% 0.75%

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

0.64%

M
09/17/2013

~ Olourescent Red/Orange ~ iIourescent Red/Orange

Seymour of Sycamore Seymour of Sycamore Seymour of Sycamore Seymour of Sycamore Seymour of Sycamore Seymour of Sycamore

mmoruum Montmorillonite xylene (mix) Poloxyethyene isopropyl alcohol Soya Lecithin Water

Manufacturer response at RRA LK 010857 Manufacturer response at

-

RRA LK 010857
-

Manufacturer response at 0.17% 0.15% 0.12% 24.63%

lourescent Red/Orange

RRA LK 010857
-

Fiourescent Red/Orange Flourescent Red/Orange

~ Iourescent Red/Oran ge
terlle Saline Solution
3tertle Saline Solution

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

NOW for. trectk Sperlan Eye & Face Protection, Inc.

Water
Phosphate asIc

0.99

Manufacturer response at RRALK 010828 Mantthcturer response at RRA-LK 010828 Manufacturer response at

Spenan Eye & Face Protection, Inc.

rdrate

Phosphate
Sterile Saline Solution Spartan Eye & Face Protection, Inc.
i

Anhydrous
Chloride

<1%
<1%

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

Green

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. Purpose Cieaner Simple
-

Manufacturer response at

>= 78%

RRA-LK 011248
Manufacturer response at FkRA LK 011246
-

<= 5% VMiTl <= 5%

Manufacturer response at

RRA-LK 011246
Manufacturer response at RRA LK 011248
-

<= 5%

Green

ted Cleaner I Degreaser

Sunshine Makers, Inc.

le Green Scrubbing Pad Purpose Cl ea ner; Simple ted Cl ea ner I Degreaser le Green Scrubbing Pad reen All Purpose Cleaner; Simple
-

Sodium Citrate

<= 5%

Manufacturer response at RRA-LK 011246 Manufacturer response at RRA-LK 011246 Manufacturer response at

Sunshine Makers, Inc.

<= 1%

+ncentrated Cleaner / Degreaser I r; Simple Green Scrubbing Pad

Sunshine Makers, Inc.

<= 1%

RRA-LK 011246

09/17/2013

09/17/2013

EXHIBIT I I

Range Resources Well Completion Reports

Page 1 of 23
09/17/2013

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

Range Resources - Well Completion Reports

Page 2 of 23
09/17/2013

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Range Resources - Well Completion Reports

Page 3 of 23
09/17/2013

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

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Range Resources - Well Completion Reports

Page 4 of 23
09/17/2013

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

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Range Resources - Well Completion Reports

Page 5 of 23
09/17/2013

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

Franklin Lakeview Estates Unit 4H - Washington County

3/17/2013

Franklin Lakeview Estates Unit 5H - Washington County

3// 1/2013

Franklin Lakeview Estates Unit 12H - Washington County

3111 t2013

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Page 6 of 23
09/17/2013

Franklin Lakeview Estates Unit 14H - Washington County

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
09/17/2013

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
09/17/2013

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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Page 9 of 23
09/17/2013

Bobst Unit 34H - Lycoming County

1118/2012

Bobst Unit 35H - Lycoming County

11/212012

Bobst Unit 36H - Lycoming County

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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Page 10 of 23
09/17/2013

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

Ogontz Fishing Club Unit 27H - Lycoming County

7/25/2012

Ogontz Fishing Club Unit 28H - Lycoming County

7/22/2012

Ogontz Fishing Club Unit 26H - Lycoming County

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

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
09/17/2013

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

Ogontz Fishing Club Unit 31H - Lycoming County

4/8/2012

Ogontz Fishing Club Unit 39H - Lycoming County

4/3/2012

Ogontz Fishing Club Unit 33H - Lycoming County

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
09/17/2013

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

Rush, John Unit 61-1 - Washington County

1/10/2012

Rush, John Unit 7H Washington County

Ltd

1/10/2012

Rush, John Unit 8H - Washington County

1/tO/2012

Rush, John Unit 91-1 - Washington County

1/05/20/2

Winner Unit 5H-Clinton County

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Page 13 of 23
09/17/2013

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

Red Bend Hunting & Fishing Unit 5H - Lycoming County

11/8/2011

Red Bend Hunting & Fishing Unit 3H - Lycoming County

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

10/21/2011

Rukavina Unit 3H - Washington County

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Page 14 of 23
09/17/2013

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

Ogontz Fishing Club Unit 22H - Lycoming County

9/30/20I1

Ogontz Fishing Club Unit 21H - Lycoming County

9/24/2011

Ogontz Fishing Club Unit 20H - Lycoming County

9/2412011

Ogontz Fishing Club Unit 18H - Lycoming County

9)73/2011

Ogontz Fishing Club Unit 19H - Lycoming County

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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Range Resources - Well Completion Reports

Page 15 of 23
09/17/2013

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

Ogontz Fishing Club Unit 14H - Lycoming County

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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Page 16 of 23
09/17/2013

07/14/2011

Hewitt. Douglas Unit 5H Washington County

LW I

07/14/2011

Hewitt, Douglas Unit 6H - Washington County

07/14/2011

Hewitt, Douglas Unit 7H - Washington County

071I4/2011

Hewitt, Douglas Unit 8H - Washington County

07/14/2011

Hewitt, Douglas Unit 9H - Washington County

07/14/2011

Painter Unit 4H - Washington County

07/14/2011

Painter Unit 5H - Washington County

07/14/2011

Painter Unit 311 - Washington County

07/7/2011

Painter Unit 1 - Washington County

07/7/2011

Painter Unit 2H - Washington County

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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9/17/2013

Range Resources - Well Completion Reports

Page 17 of 23
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

Weimer Lillian Unit 4H - Washington County

04/13/2011

Weimer Lillian Unit 5H - Washington County

04/13/2011

Weimer Lillian Unit GM - Washington County

04/04/2011

Ogontz Fishing Club Unit 7H - Lycoming County

04/04/2011

Ogontz Fishing Club Unit 9H - Lycoming County

04/04/2011

Gulf USA Unit itOH - Centre County

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Range Resources - Well Completion Reports

Page 18 of 23
09/17/2013

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

Drugmand Unit 71-1 - Washington County

03/12/2011

Drugmand Unit 1H - Washington County

03/12/2011

Drugmand Unit 21-1 - Washington County

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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Range Resources - Well Completion Reports

Page 19 of 23
09/17/2013

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

Troyer Space Management Unit 3H - Washington County

02/05/2011

Troyer Space Management Unit 414 Washington County

02/03/2011

Troyer Space Management Unit 9H - Washington County

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

1/18/2011

Chappel Unit 4H - Washington County

1/19/2011

Chappel Unit 5H- Washington County

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Page 20 of 23
09/17/2013

2/3/2011

Chappel Unit 7H - Washington County

11112011

Chappel Unit 8H - Washington County

1/3/20/I

Chappel Unit 9H - Washington County

1/3/2011

Chappel Unit 10H - Washington County

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

Sierzega Unit 6H - Washington County

1/5/20/1

Sierzega Unit 7H - Washington County

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
09/17/2013

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

Sierzega Unit 8H - Washington County

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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Range Resources - Well Completion Reports

Page 22 of 23
09/17/2013

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 REPORTS

MARCELLIJSCIIS1SION

WELL COMSIEIION PRINT

05 TSR CEMIIRTON SPREES SUITE 1200 FORT 'NORTH, Di 76102 T 0T7-670-2A121 F OSAQ9100 INFIIU8/RANGTTNEEOURCFS GUM

EMAIL US

PRIVACY NOTICE

LEGAL NOTT1E

SITE MAP

055

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Range Resources - Well Completion Reports

Page 23 of 23
09/17/2013

Ro

Co ,.,tOn, A

http://www.rangeresources.comlgetdoc/50e3bc03 -3bf-45 1 7-a29b-e2b8efljafe4f7Well-Co... 9/17/2013

09/17/2013 5500-FM000004 Rev. 2/2001

RAV IN

MAqw
well 0pertor c*iess

AOR

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION OIL AND GAS MANAGEMENT PROGRAM

DEP USE ONLY

s4teld Ctent Id

P*mlyFacNykl 5ub-tocty Id

WELL RECORD AND COMPLETION REPORT

Range Resources -Appalachia, LLC 380 Southpointe Blvd, Suite 300
Coy Canonsburg
Phone FcQK

Welt API I (Pemilt I RegJ F6FP DI 141142 37-125-24024 well Fonrt Nome State

Prc4ect Number well I Mril4X*ty

Aces

fip Code

Sierzega
County Washington USGS 7.5 mln, quackongle map

583 J Se?d I

6l1 J

PA 15317 724-743-6790

Amvmll

724-743-6700

Amity

Chack all that ply 00r9naiWelIRewd XONin

Corn pletlonReMl DMendea Well Record DAInan1 OorTMon Report

Well Type Drilling Date Drilling Started

Gas

WELL RECORD AofFo c la w 2) Oil Injection Combination Oil & Gas Storage 0 0 0 0 0 Disposal 23 Rotary - Mud Rotary - Air 0 Cable Tool
Dote DrtIa'g Completed

4/912010

_612612010

Surface Bevoltoi, 1147ft

Total Depth - or" _11920 ft

Total Depth Logger 11920 ft

Casing and Tubing

Hole pipe Size wt. Thread

Yes Cement returned on surface casing? Cement returned on coal protective casing? Material Behind Pipe
Type and Amount Driven ClassAGaaBlock,360sx Claws A Gas Blo*820sx Class A Gas Moc k , 95Oxk Extendacern,8908x Hal light,890sx,Fraccem360sx WeHifti 32' 33T 1103' 2939' 11891' Type G8 G8 GS FS

0 No N Yes EEI No 0 N/A

Date Size 28" Dep 32' 337' 1103' 2939' 11891"

Amount fri

Packer / Hardware I Ces*azers

LYii
30' 28 1065 Thread 81.35 Thread

Run
4/9110 5(19/10
5/12/10

24
17-1/2"

2ff

20"
13-3/8' 9-5/8' 5-1/2"

13-3/8" 54.55 Thread 405 Thread 205 Thread

12-114' 9-5/8 8-3/4'

5/15/10
6125/10

UPerforationRecord
Dote Interval P.rfo,ofed from To 12/2812011 11,771'MD 8,687MD

_
5-1/2'

COMPLETION REPORT
StimulationRecord
D Of 1/5/2011
erVOl rea Interval

Fluid

Propping Agent
Sand 5,594 lOb

Type Amount Type Amount

Average Injection 632 bpm

Marceflus Shale Slick H20 90,082 bbl

Natsclt Open How After Treatment Open Flow

-r Ii o measure ,00 small

Old t24

____

I Natural Rack
Pro e

Too small to measure

MA@24 tws post treatment

Hours Hours

Days Days

Ti3 Treatment
Rock Press"

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 B radd oc k, j 6437 ane 325-574-6300 _724-430-6201 817-850-1008

09/17/2013
5500FM-OG0004 Rev. 212001

__ LOG

OF FORMATIONS
4fl'

Well API# 37-125-24024 Source of Data

Formation Name or Type Sand Shale Sand Sandy Shale Shale Coal, Shale and Sand Sand and Shale Sandy Shale Shale Sand, Shale and Coal Shale Coal Shale Sandy Shale Shale Coal Sandy Shale Shale and Coal Shale Coal Shale Sandy Shale Shale Sandy Shale Sand Sand Shale Sand and Shale Sandy Shale Sand Sandy Shale White Sand Sandy Shale Shale Sand and Shale Shale Sand and Shale Shale Limestone Shale Limestone Horizontal Shale Limestone Shale Drillers Total

J
A'

flrilirs I an

Drillers Loa Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log i Drillers Log 1438 Drillers Log Drillers Log Drillers Log Drillers Log '/wtr1684 Drillers Log Drillers Log Drillers Log Drillers Log 1860 Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log Drillers Log 2600 Drillers Log 2882 Drillers Log Drillers Log Drillers Log Drillers Log 5690 Drillers Log Drillers Log 7370 Drillers Log Drillers Log Drillers Log 5810' 8050' Drillers Log 8050' 8170' Drillers Log 8170' ers Log 1192 Please delete empty rows if necessary to make all of page 2 fit on one
Reviewed by: Dote: 1131/2011 Comments:

40' 160' 220' 340' 611' 685' 803' 931' 995' 1059 1125' 1172' 1301' 1355' 1370' 1382' 1455' 1460' 1478' 1484' 1650' 1765' 1803' 1817' 2068' 2101' 2164' 2325' 2401' 2500' 2555' 2668' 2832' 3104' 3167' 3710' 5470' 6120' 7330' 7440'

160' 220' 340' 611 685' 803' 931 995' 1059' 1125' 1172' 1301' 1355' 1370' 1382' 1455' 1460' 1478' 1484' 1650' 1765' 1803' 1817 2068' 2101' 2164' 2325' 2401' 2500' 2555' 2668' 2832' 3104' 3167' 3710' 5470' 6120' 7330' 7440' 7450'

____

WWI Opsratqrs Signatur.:

DEP USE ONLY L

Dote:

Co Completion Engineer,

Hurey

09/17/2013

LI

RANGE RESOURCES

Slerzega Unit #6H

Completion Date: 12/28110 - 1/5111

Composition of Hydraulic Fracture Fluid

Amb

am

LM

.........

....

...

.-

09/17/2013

RANGE RESOURCES
Coo,n Nwu. SuppiN' ______ Iuipsr chs,,*.0 iIn. Con
Dssct&n

Ii
7.5% 14c1 ii

Composition of Components in Marcellus Shale Hydraulic Fracturing Fluid

H.za,dous ______ CM p , MISd an us"

Puipo..

tlsim GoncsnVao of MIDI Cnpon.r Gns MIDI N$0l Co wit v To ______ 5bgs Fk$d Co.ipvn.ot Wi Sl5M % of
Clrn4cof

%V.I 31% IICL CI.100 II0O FEIOM. HC4. _____ ____ roMls Pfovwft umU 0.0% 00% WA N/A
tOThi.

%WsfgM 0.5% -

CIwi ,ifrr,I

370%

02:2 -

0.01M

O.OOCI.

FT.cT.dlI

WA N/A
5.0154%

WA WA
O.01S3%

4.4.

13
AbMIs A9irt 3,4.4. Tr1msli&... , obw*ww 24ivio24ipii4.1______ FO GIdsP 4C 5.1542 ri.r1 MI* bsr ..- EVIO
.TUI

15.0% 50% 1.0%

501.19 35.10 5.11 353

0.0141%

_0Q133%

0410% _CD000% 0.X07% 0.0001%

A..4L.o,W Aplt

00O2%
0.0001% 0.0045%

05%..

o
IS Wi

00033%

sow

2220
- 1.0% 222 TOTIL

0.0005% 00001% OM58

0.0007% 0.0001% 0.5I4%

byvol%bywelght% SUMMARY

0.031%

1 0.021%

-4-

am
Watt Operutor AdAess
City

5500-FM000004 Rev, 212001 COMMONWEALTHOF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION OIL AND GAS MANAGEMENT PROGRAM Site Id Cent d

OEP USE ONLY 1trocatykl Sob-Sadly Id

09/17/2013

WELL RECORD AND COMPLETION REPORT

DEP ID#
Wst 01#(F

Nuner Well a

Acres

Range Resources-Appalachia, LLC 380 Southpointe Blvd. Suite 300

Stale

141142 37-125-23938
Well Form Name

441
JSedcI #

Sierzega
Zip Code

9H
MiiEcipty

County

Canonsburg
hone 0t1gind

PA
Fox

15317

Washington
USGS 7,5 rri, quadioroe map

JAmwell
Record
DAmended Completion

724-743-6700 Check all that apply:

724-743-6790 Welt Recd x

Original

Amity
DArrtertded Well

Completion Report

Report

WELL REC
Well Type Gas

ionvsss io cimi

(pui 2

El oil 0 Combination Oil & Gas D I njection Drilling Methodj [J Rotary - Au' 0 Cable Tool Z Rotary - Mud
Date DrllIg Storied

0 Storage

0 Disposal
11296 ft

12/5/09
-

We DiMng Conr4eted

4123/10

Casing and Tubing

Yes Cement returned on surface casing? returned on coal protective casing?

Sa1ace Bevatlo

Totat Depth - DitRer

Total Depth- logger

1147 ft.

11296 ft

Hole Pipe Size Wt Thread Amount in Well (ft) size

Maleital 8,&iind Pipe

Type and Amount DrIven Class A Cement, 389 ax

E Yes No N/A Packer I Hardware I Cenfrazers Date

0 No
Size

______
26' 20' 9-5/8'

L Llc

Type GS GS FS

Depth 40' 335' 3063'

Run 1215/09 3/26/10 4/3/10 4/23/10

30' 24'

108# Thread 81# 3/28/10 400 4/3/10 4/23/10

40' 335' 3063' 10927'

2(r 20' 9-518' 5-1/2'

12-1/4'

Uni Block, 1290 sx

Extendacem, 960 ax Hall Lite, 485 ax_____ Fraccem 370 ax

10927'

1'R1
Perforation Record
Date mfh. To Date 10-24-10 Interval Treated Marcellus Shale

Stimulation Record
PPn9 Agent
Type Amount Type Amount Average Injection 63.8 bpm

10-19-10 10,823' MO 8,097 MD

Ick H20 91,982bbl Send 5,072Kib

Naltrol Open how After Treatment open Flow Name Patterson

Too small to measure 0 matid 24lira post treatment

Natural Rock After Treatment Rock Pressure

small to measure NSA Q 24trrs post treatment Name Frac Tech

Address

Hours Hours

Days Days

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

UTI

Name Universal Welt Services 730 Braddock View Dr Clty-State-T Mt. Braddock, PA 16485 -P 1 F066 724-430-8201

4501 Lamesa Highway Snyder, TX 79549

t1 none

325-574-6300

16858 1H20 Cily-SlateClsco, TX 78437 Phone 817-850-1008

09/17/2013
5600-FM-000004 R.'. 2/2001

LOG OF FORMATIONS
Formation Name or Type -_ Fill Shale Sandy Shale Sand Sandy Shale Shale Sand and Shale Shale Sand and Shale Shale Sand Shale Sand Shale Sand Shale Sand and Shale Shale Sand Sand and Shale Shale Sand Sandy Shale Shale Sand and Shale Shale Sandy Shale Shale Limestone Shale Limestone Horizontal Shale Limestone Shale Drillers Total Depth TopBottom 0' 42' 114' 172' 225' 350' 430' 550' 610' 730' 1150' 1260' 1510' 1580' 1700' 2250' 2580' 2700' 2860' 2940' 3310' 4020' 4410' 5140' 5378' 5778' 6450' 6570' 7150' 7215' 7443' 6230' 7552' 7670' 42' 114' 172' 225' 350' 430' 550' 610 730' 1150' 1260' 1510' 1580' 1700' 2250' 2580' 2700 2860 2940' 3310' 4020' 4410' 5140' 5378' 5778' 6450' 6570' 7150' 7215' 7443' 7456' 7552' 7670' 11296 Gas at 00 at

WellAPl#: 37-125-23938 Water at Source of Data Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log Geophysical Log

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

Ws

p SIatur:
Reybewed by

1DEP USE ONLY

DCjIc

Me: Completions En neer Mike

Comme: 11-5-10

09/17/2013

III

RANGE RESOURCES

Sierzega Unit #9H

Completion Date: October 19- 23, 2010

Composition of Hydraulic Fracture Fluid

(b - o w ,,.)

NAM

&AMM MAMPM

=
Lux

PrAhMAMOW

lan

am

-.-l-t

..

...

09/17/2013

Composition of Components in Marcellus Shale Hydraulic Fracturing Fluid RANGE RESOURCES

Comm,i n. 4
$4 C CIISM

suww

______ _____ Cu...,it lSsd on

Piop001

Wu % of

sa Cnos dSonI 30S M5O C...4N4M s I(I1 d In %Vo

ai'

3P% NQ,
1.3% MO (?i1c7.cII NEW

ICwww*wftdM0 Ad
Cci,i PMUM

37
___________ 3. 044
...-

0.00%
0% lJ 0000%
.:-

000W
0% 00000%

Pn E*lv iMAChftW

Pi*1i onj,o 00%

Room

P#A TOTAL

MIA NrA I 3.00(3% I U035%

byvol% SUMMARY _0.023%

bywe1ght]

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
Lt'i Il4
ABSORB SPILL AND CONTAINERIZE FOR DISPOSAL

r-r-r-r.,

t..

09/17/2013

PAGE3OF3

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:

11

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

DEPO1 83

09/17/2013

Ll
INDUSTRIAL COMPOUNDING LLC A SUBSIDIARY OF FRAC TECH SERVICES, LTD. 915 N. 16 M 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 PETROLEUM

1 >50%

d/

WAY

HAZARD DATA (TLV 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 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
nEAT: X

STRONG ALKALIS: C
SPARKS: X

STRONG OXIDIZERS: Y( IGNITION SO(JRCES:X

OTHER:

CONDITIONS TO AVOID
OPEN FLAMV. 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

VI. FIRST AID RECOMMENDATIONS

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

VII. PERSONAL PROTECTIVE INFORMATION Iiv' 'i

kaJ1 !.1t *fl

q1!
i'1

PROTECTION:
,1_JaL:4,1s

09/17/2013

0
61
SPILL PROCEDURES: ELIMINATE ALL IGNITION SOURCES. CONTAIN AND
AND CONTAINERIZE FOR DISPOSAL.

&ssogpspuj.

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 DISTILLATES

50%

64742-47-8

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

8/30/13 MAGAZINES -

Range Resource spearheading soluntary initiatie 09/17/2013

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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 Our most popular articles

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09/17/2013

EXHIBIT 14

8/30/3

Marceflus driller volunteers to disclose tracking chemicals - Philly.com

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Marcellus driller volunteers to disclose fracking chemicals

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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. Environmental groups and legislators, who have pressed for fighter regulation of the industry, welcomed Range's moe. "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. 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. En',imonmentalists said they were encouraged by the firm's step.

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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

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 09/17/2013 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.

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"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.

it

"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 hydraulicfracturing 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 amaykuth@phillynews.com .

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09/17/2013

EXHIBIT 15

8/30/13

The Mcollus Effect: Range Resources Promises ""Really Will" Disclose Frathng Chemicals Share 0 More Next Bloga Create Blog Sign In

09/17/2013

The Marcellus Effect

Thursday, July 29, 2010 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.

Range Resources Promises they "Really Will" Disclose Fracking Chemicals

photo of Bamatl shale well pmvided by Tim Ruggie,o.

story updated Thursday

afternoon
New York SGS links

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."

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.

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Sue Heavenrich

I write about science and environmental issues for both adults and children, lam a member of the Society of Environmental Journalists and the Society of Children's Book Writers & Illustrators.
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EXHIBIT 16

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Range Resources to Disclose Chenics Used in Gas Drilling WSJ.com

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By RUSSELL GOLD

0.

f;
Range Resources Corp.

MUMBloonlbsnj Ilces

Available to WSJ.com Subscribers

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

General Electric Set to Exit Retail Lending Insurance Subsidies Help Older Buyers

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. 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 gas drilling in the Marcellus Shale spreads across Pennsylvania and neighboring states. In a significant break from past practice, Range says it will begin submitting a detailed - . l't-of-alLchemicals and additives, and the volumes, used to -WeflStO the state. - --. - -- -

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"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 executive of the Fort Worth, Texas, company. Range holds leases for 13 million online .wsj.corrVarticl SB 10001424062748703834 4575365360901 763540. htrif

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8/30/13

Range Resources to Disclose Cherrcs Used in Gas Drilling - WSJ.com

09/17/2013

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. Range plans to make the disclosures with state Department of Environmental Protection within 30 days of "frac" jobs, and post the information online. 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 wellthe 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. "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 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. Veriion-Vodafone Impact: Colossal' Airlines Push F.arly Trial Start Renault C(X) (iits Alter Declaring himself CEO Ready America Movil May Pull KPN Bid Mercedes in Transition in China Market

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,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 itand 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. Jan .Jarrett, president of Citizens for Pennsylvania's Future, an environmental advocacy group, applauded Range's disclosure program as a "step in the right direction." She said the state should make it mandatory.

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09/17/2013

EXHIBIT 17

8/30/13

Range Resources - Well Completion Reports

SeamS

Sac

09/17/2013
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7520 Al0.37 0, 49
HOME OUR COMPANY OPERATIC NVEfOR RELATIONS OWNER RELATIONS NEWSROOM OUR COMMITMENT CAREERS CONTACT

IveU Csinpktttn 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 environmentally sale. The location 01 the Mareellus is geiterall over a

is

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

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Range Resources - Hdraric Fracturing Fluid Selection and Management

Search S is

09/17/2013
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 itte grcciii ,,ouse ga "Cs list and has pros en io be one it the n ens. st c henac a used in hdiauhc fracturing, Keep in mind that nitrogen cannot be used to stimulate all geologic tormsitionv. In other in tivi t ste hic'a t1i \ its i ccii
is

not lute, 1

sti

instances we may tie requr ed to utilize some concentrations

of

chemicals typically guar guns, foaming agents and polemitmally 1/2

wswv.rangereSources.con'Jg etdoc/20cc7d07-383b--476f-83a0-d4ab250a8757/Hydraulic- Fracturing- Floid-Selection- and- Manag errsnn.aspx

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.
09/17/2013

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 Fr Foicirs Groundwater Protection Council Interstate Oil and Gas Compact Commission

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HYDRAULIC FRACTURING FLUID SELECTION

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Copynghl 2010 Range Rc,nurces Corporation. All rrghts rereed.

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EXHIBIT 18

Range suppports disclosure, new technologies I OPINIONO2

Page 1 of 2
09/17/2013

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.

kfaa celia

EXHIBFT _

http:i \vww.observer-reporter.com/apps/pbcs.dl i/article?A ID /20 13 042310P1N 10N021 1304.

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- Range suppports disclosure, new technologies I OPINIONO2

Page 2 of 2
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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
r

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?. THOMSON REUTERS

I :

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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
(State or Other Jurisdiction of Incorporation or Organization)

34-1312571
(IRS Employer Identification No.)

100 Throckmorton Street, Suite 1200, Fort Worth, Texas

(Address of Principal Executive Offices)

76102
(Zip Code)

code (817) 870-2601 Securities registered pursuant to Section 12(b) of the Act:
Registrant's telephone number, including area

Title of Each Class Common Stock, $01 par value

Name of Exchange on Which Registered

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 Yes Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. 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 Non-accelerated filer RI 0 (Do not check if a smaller reporting company) Accelerated filer Smaller reporting company 0 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.

CIVIL DIVISION No. 2012-3534

DEFENDANT'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' FIRST SET OF REQUESTS FOR ADMISSIONS DIRECTED TO DEFENDANT RANGE RESOURCESAPPALACHIA, LLC

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.

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.

R0371852.1

ao

EXHiBIT

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

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

09/17/2013

EXHIBIT 21

09/17/2013

S
LOREN KISKADDEN
V.

COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD Appellant, 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

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

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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 "Nonhazardous and other components below reportable levels," and that less than 2% of this product is made up of crystalline silica quartz.

- ---------- - ---

15

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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 Production of Documents.
Admit Deny

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, 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

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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 Pennsylvania DEP document numbers 0068-0071 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents. 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 Production of Documents. Admit Deny

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 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

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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 Production of Documents. 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 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 DenyX

The MSDS states that the substances that make up greater than 80% of this product are "Nonhazardous 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

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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,, 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.

40.

Admit that the only information/documentation submitted to the Pennsylvania

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 the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the . Production of Documents. Admit X Deny

41. well.

Admit that diesel fuel was used as hydraulic fracturing fluid at the Yeager 7H

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

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No.!.

42

Admit that the kerosene used at the Yeager 7H well is also knows as Fuel Oil

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

Pennsylvania DEP document numbers 0086-0094 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

AdmitX

Deny

44.

Admit that the Pennsylvania DEP never requested that Range Resources

identified and submit information/documentation identifying what chemicals and/or substances that make up >84% of the product DesoDeflocculant, identified as Pennsylvania DEP document numbers 0086-0094 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

Admit .

Deny

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
w

go

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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.

45.

Admit that the only information/documentation submitted to the Pennsylvania

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 numbers 0086-0094 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.
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

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47.

Admit that the only information/documentation submitted to the Pennsylvania

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 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 X Deny

48.

Admit that the Pennsylvania DEP never requested that Range Resources

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

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, to the extent this Request asks the Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits.

49.

Admit that the only information/documentation submitted to the Pennsylvania

DEP by Range Resources identifying the chemical and/or other components of LD-9 was the

VA

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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 Production of Documents. 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 document numbers 0102-0105 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 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 Production of Documents. Admit Deny

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

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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 this singular product beyond the MSDS itself, then the Department admits.

52.

Admit that the Pennsylvania DEP does not have any knowledge of what

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."

53.

Admit that the only information/documentation submitted to the Pennsylvania

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 Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents. 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 the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the

24

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Production of Documents. Admit Deny

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, to the extent this Request asks the Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits.

55.

Admit that the Pennsylvania DEP does not have any knowledge of what

is

chemicals and/or substances make up the product Mil Glide-C?, identified as Pennsylvania DEP document numbers 0121-0125 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents. 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.

56.

Admit that the only information/documentation submitted to the Pennsylvania

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

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the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

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 Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

Admit

Deny

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, to the extent this Request asks the Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits.

58.

Admit that the Pennsylvania DEP does not have any knowledge of what

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 .

RM

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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."

59.

Admit that the only information/documentation submitted to the Pennsylvania

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 Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

AdmitX

Deny

60.

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 Milstarch, identified as Pennsylvania DEP document numbers 0142-0145 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

Admit

Deny

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 s'aiving the foregoing objections, to the extent this Request asks the

27

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Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits.

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 Pennsylvania DEP document numbers 0146-0149 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents. Admit

DenyX

This MSDS states, among other things, that 60 to 80% of this product is "Non-hazardous and other components below reportable levels."

62. 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 Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

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 6080% of the product NewDrill, identified as Pennsylvania DEl' document numbers 0146-0149 in the

S
28

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Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the
.

Production of Documents Admit Deny

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, to the extent this Request asks the Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits. 64. Admit that the Pennsylvania DEP does not have any knowledge of what chemicals

and/or substances make up 50% of the product HVG-1 Fast Hydrating Guar Slurry, identified as Pennsylvania DEP document numbers 0154-0156 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents. 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 Pennsylvania DEP document numbers 0154-0156 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.

n
w

Admit X

Deny

29

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66. Admit that the Pennsylvania DEP never requested that Range Resources identify 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 numbers 0154-0156 in the Department's Responses to Appellant Loren Kiskadden's First Set of Requests for the Production of Documents.
Admit Deny

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, to the extent this Request asks the Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits.

67. Admit that the Pennsylvania DEP does not have any knowledge of what chemicals and/or substances make up the product 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 Deny X

This MSDS states among other things that this product is "non-regulated" under a "DOT Hazard Classification."

30

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68. Admit that the only information/documentation submitted to the Pennsylvania

.

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

69.

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 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 Requests for the Production of Documents.
.

Admit

Deny

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, to the extent this Request asks the Department to admit that it never specifically requested additional documents regarding this singular product beyond the MSDS itself, then the Department admits.

70.

Admit that the Pennsylvania DEP took more than one water sample from the

leak detection zone for the Yeager Impoundment.

AdmitX
.

Deny
...

31

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EXHIBIT 22

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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 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 *

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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) (b) 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; When the product was used at each of the applicable locations designated in subsection (a); The purpose for which the product was used at each of the applicable locations designated in subsection (a); What stage of drilling operations was the product used at each of the applicable locations designated in subsection (a); What company supplied the product to be used at each of the applicable locations designated in subsection (a); What chemicals, including all proprietary chemicals, make up the product; What company applied the product at each of the applicable locations designated in subsection (a); and

(c) (d) (e)

(0
(g)

'1

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(h) All manufacturing information for the product

TABLE 1 PRODUCT NAME

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. Caustic Soda Caustic Soda Asphasol Supreme Tannathin Sodium Bicarbonate Super-Sweep Salt Gel Soda Ash SAFE-SCAV HS SAFE-CARB QUICK SLIDE POLYS WELL Desco Deflocculant Cal Carb Mix FMVISRM

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

16. 'TIME 17. 18. HUBERCARB Q40-2W Calcium Chloride

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19. 20. 21. 22. 23. 24. 25.

FMSperse ABSORB-N-DRY GXM FM WASH FM WA II ABS 40 ABS MIJL

Fluids Management, LTD Balcones Minerals Corporation Fluids Management, LTD Fluids Management, LTD Fluids Management, LTD Fluids Management, LTD Fluids Management. LTD Fluids Management, LTD Cortex Products Fluids Management, LTD Fluids Management, LTD Fluids Management, LTD Fluids Management, LTD Shrieve Chemical Products Co. Shrieve Chemical Products Co. M-I SWACO J&H Bunn Ltd Federal Wholesale Drilling Mud M-I SWACO M-1 L.L.0 M-ISWACO Fisher Scientific lGrinding & Sizing Co., Inc.

2E. TRU VIS 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. Cortex, 222 Barrier Cream PERMASEAL ABS40 MUD/SLURRY FM VIS LS FM VIS II BIO ADD 7555 BlO-COR 2899 G-SEAL Potassium Chloride FED ZAN D DRILZONE L DUROGEL

39 Citric acid 40; Ammonium phosphate, dibasic 41. X-TEND LUBE PLUS

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42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 54. 55. 56. 57. 58. 59. 60.

DESCO MF-55 Sodium Bicarbonate White Starch 40 HTL Corrosion Inhibitor

Agri-Empresa Agri-Empresa Agri-Empresa Agri-Empresa Industrial Compounding, LLC

APB-1, Ammonium Persulfate Breaker Frac Tech Services, LLC B-9, PH Increase Buffer BROMOCRESOL GREENMETHYL RED INDICATOR, ALCOHOLIC BXL-2, Crosslinker/Buffer 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 RICCA Chemical Company LLC Industrial Compounding, LLC Hach Company Industrial Compounding, LLC Industrial Compounding, LLC Industrial Compounding, LLC Coastal Chemical Co., L.L.C. RICCA Chemical Company LLC Industrial Compounding, LLC Industrial Compounding, LLC Industrial Compounding, LLC Industrial Compounding, LLC

1 61.

Industrial Compounding, LLC

RICCA CHEMICAL COMPANY LLC

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63. 64. 65, 66. 67. 68,

ICI-150 ICI-3240 KCLS-2, KCL Substitute LTA-1. Low Temperature Activator MA-844W 5040 Methyl Purple Indicator

Industrial Compounding, LLC Industrial Compounding, INC. Industrial Compounding, LLC Industrial Compounding, INC. CESI Chemical RICCA Chemical Company LLC Industrial Compounding, LLC Industrial Compounding, LLC

69. NE 100 70, 71. 72. 73. 74. 75. 76. NE 100 (winterized)

PHENOLPHTALEIN SOLUTIONS RICCA Chemical Company LLC POTASSIUM CHROMATE SOLUTIONS Shale Surf 1000 Silver Nitrate RICCA Chemical Company LLC Industrial Compounding, LLC RICCA Chemical Company LLC

SODIUM HYDROXIDE SOLUTIONS RICCA Chemical Company LLC Sulfuric Acid, 0.02N Sciencelab.com , Inc. RICCA Chemical Company LLC RICCA Chemical Company LLC Newpark Drilling Fluids, LLC Newpark Drilling Fluids, LLC Newpark Drilling Fluids, LLC Newpark Drilling Fluids, LLC Newpark Drilling Fluids, LLC Baker Hughes Drilling Fluids 113aker Hughes Drilling Fluids

77, Water Hardness Buffer 78. 79. 80. 81. 82. Water Hardness Indicators FlexFirm KS New Phalt - DynaPhalt NewBar - Barium Sulfate NewEase 203

83: NoFanr X, Octyl Alcohol 84. 85. Milstarch MIL-PAC LV

rel

09/17/2013

86. 87. 88. 89. 90.

MIL-PAC (ALL GRADES) MIL-GLIDE Citric Acid Solution, 50% HEC- 10, Hydroxyethyl Cellulose Oil Dry, Hydrous Magnesium Aluminum Silicate EXP-D256C-99 (REM) HYPERDILL AF 257 White Starch FORTA Super-Sweep 60/40 Blend AQUA PAC, Polyanionic cellulose derivative Aquabloc, Sodium Carboxymethyl Starch Desco Deflocculant Citric Acid, Anhydrou U.S.P./N.F. (Granular) POLY-PLUS RD

Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Newpark Drilling Fluids, Inc.

91. 92. 93. 94. 95. 96.

Drilling Specialties Company HYCHEM, INC. Newpark Drilling Fluids, LLC FORTA Corporation Newpark Drilling Fluids, LLC Newpark Drilling Fluids, LLC

97. 98. 99. 100.

Raw Materials Corporation Drilling Specialties Company Fisher Scientific

M-I L.L.C. M-I L.L.C. M-I L.L.0 M-I L.L.C. M-I L.L.C.

IC!. POLYPAC UL 102, POLYPAC SUPREME R 103. PIPE-LAX ENV 104. PECAN NUT PLUG 105, Myacide GA 25 106. M-I-X II

BASF Corporation M-1 SWACO

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. 114. XAN-PLEX D, Polysaccharide Walnut Shells

M-I L.L.C. M-I L.L.C. Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Chevron Phillips Chemical Company LP, Drilling Specialties Company Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Baker Hughes Drilling Fluids Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

115. TERRA-RATE 116. SULFATROL 117. Soltex Additive

118. 119. 120. 121. 122. 123. 124.

Sodium Chloride, Solid Sodium Bicarbonate Soda Ash, sodium carbonate Potassium Chloride SAPP PERMA-LOSE HT

NEW-DRILL, Anionic Polyacrylamide Copolymer Emulsion 125. CRUMB RUBBER 176. DESCO DEFLOCCULANT 127. DF-450 128. DF-900

09/17/2013

129.

DIASEAL M, DIATOMACEOUS EARTH

Anchor Drilling Fluids USA, Inc.

130. DIXIE-RED MUD 131. DRILL THIN 132. DRILLING PAPER 133. DRILL-OUT

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

134. DRISPAC (R & SL), Drispac Polymer Anchor Drilling Fluids USA, Inc. 135. DYNARED 136. FIBER PLUG 137. FIBER-SEAL Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

138. FLO-THIN HT, Anionic Polyacrylate Anchor Drilling Fluids USA, Inc. 139. 140. 141. FLOWZAN FOAM BREAK FOAMER CD Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

142. GILSONITE 143. GYPSUM, Calcium (11) Sulfate Dihdrate 144. HEC, Hydroxyeythyl Cellulose 145. HEC LIQUID 146. HIGH YIELD GEL 147. KCL SUBSTITUTE, Potassium Chloride 148. KNOCKOUT 50, Ammonium BisuIfiteSoIutio 149.' KNOCKOUT 1200, Zinc Salt of Polyphenolic Acid

Anchor Drilling Fluids USA, Inc.

09/17/2013

150. K-SEAL 151. LCF Blend 152. LCF 1/2 153. LIME, Calcium Hydroxide

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

154. LUBRA-GLIDE (FINE & COARSE) Anchor Drilling Fluids USA, Inc. 155. LW-200 156. MAGMA FIBER Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

157. MF-55, Polyacrylamide Mixture 158. 159. MICA (F,C), Muscovite M-I-X II

160. MUD SAFE CR 161. 162. MULTI-SEAL MYACIDE GA 25

163. NUTSHELL (F,M,C) 164. 165. OIL BASE MUD

OIL DRY, Hydrous Magnesium Aluminum Silicate 166. ORGANOLIG 167. PHENO SEAL 168. POLY PLUS 169. POLY STICKS

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

170. PROPANE, Dimethylmethane 171. REBOUND

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. 181. 182. CALCIUM HYPOCHLORITE CEDAR FIBER, Ground Wood ANCO SORB /ALCOSORB

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

183. ANCO SPA 184. 185. 186. 187. 188. ANCO SPERSE, Chrome Lignosulfonate ANCO STARCH (WHITE & YELLOW) ANCO TROL, Gilsonite

ANCO VIS L, Hydroxyethyl Cellulose Anchor Drilling Fluids USA, Inc. ANCO VIS N.S. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. 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. Anchor Drilling Fluids USA, Inc.

11

09/17/2013

194.

ANCO PHALT PLUS, Sulfonated Asphalt

Anchor Drilling Fluids USA, Inc.

195. ANCO PHALT S. Sulfonated Asphalt Anchor Drilling Fluids USA, Inc. 196. ANCO PIPE FREE 197. Anco Poly Beads 198. ANCO RIG WASH 199. ANCO ROPE, Terpene / Aliphatic Naphtha Blend ANCO SALT GEL, Attapulgite ANCO SHALE TREAT lAnchor Drillina Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

200. 201.

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

202. ANCO DD, Modified Alkanolamide

203. 204. ANCO DEFOAM ANCO-DRILL (A, N), Partially Hydrolized Polyacrylamide ANCO FIBER ANCO LIG, Leonardite Anco Liquid Phalt S ANCO MICRO BLEND

205. 206. 207. 208.

209. ANCO MIJL MOD 210. ANCOMULOW

211. 212. 213. 214. ANCOMIJLP ANCO

MUL S

Anco Mul T Plus ANCO MUL

12

09/17/2013

215. 216. 217. 218. 219. 220. 221. 222. 223. 224. 225. 226. 227. 228. 229. 230. 231.

ANCO MUL THIN VERSAMOD WT-22 X-CIDE 102 X-CIDE 207 XX-POLYMER ZINC CARBONATE

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

ALCOMER 74-L / ANCO THIN HT-L Anchor Drilling Fluids USA, Inc. ALCOMER 90L ALUMINUM STEARATE ALUMINUM SULFATE AMAIZO STARCH AMMONIUM NITRATE ANCO BAR (BARITE), Barium Sulfate ANCO BX ANCO CAT SODIUM HYDROXIDE (CAUSTIC SODA) Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

232.

233. 234.

SODIUM Anchor Drilling Fluids USA, Inc. TRIPOLYPHOSPHATE ANHYDROUS SOLTEX, Sodium Asphalt Sulfonate Anchor Drilling Fluids USA, Inc. STARCH (W & Y) PREGELANTINIZED SUNS WEEP Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc.

235.

13

09/17/2013

26. SUPERSLIDE GLASS BEADS (F, M, C, & MEGA) 237. 238. 239. 240. 241. 242. 243. 244. 245. 246. 247. 248. 249. 250. 251. 252. 253. 254. 55. 256. 257. SUPERS WEEP TORK BUSTER PLUS TORK BUSTER VARISEAL VERSA HRP SAPP SAWDUST SEA MUD, Sepiolite SHUR PLUG S.O. LUBE 1000 SOAP STICKS SODA ASH, Sodium Carbonate, Anhydrous SODIUM BICARBONATE POTASSIUM ACETATE POTASSIUM CHLORIDE (KCL) POTASSIUM HYDROXIDE RED STRIPE SACK FISHING TOOL SALT, Sodium Chloride Ammonium Bifluoride ACETIC ACID 60%
V

Anchor Drilling Fluids USA, Inc.

Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Anchor Drilling Fluids USA, Inc. Solvay Fluorides, LLC Clearwater International L.L.C.

14

09/17/2013

258. 259. 260. 261. 262. 264. 265. 266. 267. 268. 269. 270. 271. 272. 273. 274. 275. 276. 277. 278. 279. 280. 281.

ACID PENSURF BENZOIC ACID CARBO PROP Casing Inhibitor CLA-CHEL A CLA-CHEK LP NO. 2 Diesel Fuel EGM Solvent En-Breaker HPH En-Breaker FFL-10 FFL-20 Flomax5O FRP-121 Fumaric Acid H2S Scavenger Hydrochloric Acid Citric Acid, anhydrous IRON CHEK IRONSTA II C OX-BREAKER ARFLOW 7125 Paraffin Inhibitor PARANOX

Clearwater International L.L.C. Emerald Kalama Chemical, LLC CARBO Ceramics Universal Well Services, Inc. Clearwater International L.L.C. Clearwater International L.L.C. Phillips Petroleum Company Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Sagar Enterprises, Inc. Universal Well Services Inc. Sagar Enterprises, Inc. Sagar Enterprises, Inc. Clearwater International L.L.C. Clearwater International L.L.C. Universal Well Services Inc. Aquaness Chemical Universal Well Services Inc.

15

09/17/2013

282. 283. 284.

PARASOL II PARASURF Resin Coated Silica, Lake, and Bank Sands and Ceramic Silica Sand Soda Ash, Dense Sulfamic Acid TRANSFOAM-A 1 AQUET 921 Emulsifier UNIBAC BlO-CLEAR 1000 BIO-CLEAR 200 UNI-FLO UNIFLO 2 Unigel IXLR Unigel 5F Unigel 19XL Universal Well Services Inc. Santrol, Inc. U.S. Silica Company Clearwater International L.L.C. Sagar Enterprises, Inc. Clearwater International L. L.C. Aquaness Chemical Universal Well Services Inc. Clearwater International L.L.C. Clearwater International L.L.C. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. SNF INC. Clearwater International L.L.C. Universal Well Services Inc. Clearwater International L.L.C.

285. 286. 287. 288. 289. 290. 291. 292. 293. 294. 295. 296. 297.

298, FLOPAM AN 934 SH 299. 300. 301. 302. 303. AI-250 UNIHIB A QAI-815

CYANAFLO 105L Polymer Additive Kemira Water Solutions, Inc. UWS AGA-150 Universal Well Services Inc.

__________ --------------------------- ----

rri

09/17/2013

304. 305. 306. 307. 308. 309. 310. 311. 312. 313. 314. 315. 316. 317. 318. 319. 320. 321.

UWS BXL-A UWS NCL UWS NDL-100 UWS NE-50 UWS NE-70 UWS NE-80 UWS NE-90 UNILINKBXL ACID PENSURF M-1 BAR FED SEAL Hydrous Silicate of Alumina Microspheres, Cenospheres, Floating Ash, Hollow Spheres FLO-STOP P Cellosize (TM) Polymer HEC-18 CFL-25 Sodium Silicate 40 Grade FLO-STOP P

Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Universal Well Services Inc. Clearwater International L.L.C. M-I Drilling Fluids UK Ltd. FEDERAL Black Hills Bentonite, LLC USNR Coal Sales Universal Well Services Inc. The Dow Chemical Company Universal Well Services Inc. Clearwater International L.L.C. Universal Well Services Inc. Lafarge North America Inc. Universal Well Services Inc. Universal Well Services Inc. United States Gypsum Company

322, Lafarge Fly Ash & Bottom Ash 323. 324. 325. FOAM CHEK FOAM CHEK-L USG HYDROCAL Gray Gypsum Cement

17

09/17/2013

326. 327. 328.

Kol-Seal, Ground Coal MRA Portland Cements Potassium Chloride Salt Gel SC-900 Sodium Chloride Super Surf TI-2 Trisodium Phosphate Dodccahydrate 3M (TM) Glass Bubbles HGS2000, HGS3000, HGS4000, HGS5000, HGS6000 Cellophane Flakes UNIHIB A OAI-815 SAPP UWS CFL-1 17 UWS CR-220

WeiDril Products, Inc. Clearwater International L.L.C. Essroc Cement Corp. Clearwater International L.L.C. M-I Drilling Fluids UK Ltd. Clearwater International L.L.C. Mallinckrodt Baker, Inc. Clearwater International L.L.C. Universal Well Services Inc. Sagar Enterprises, Inc. 3M

329,
330. 331. 332. 333. 334. 335. 336.

337. 338. 339. 340. 341. 342.

M-1 Drilling Fluids UK Ltd. Universal Well Services Inc. Clearwater International L.L.C. Clearwater International L.L.C. Universal Well Services Inc. 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

product in the drilling process at the Yeager Site.

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

product in the drilling process at the Yeager Site.

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, 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

KZ5~ -

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).

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

Kenneth S. Komoroski, Esq.

Kai,

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