|
Timing
|
|
-0008,
9, 10, 11 (dup 16), 13 (dup 17), 15, 18, 35, 53
|
Requested
more time (either 30-days or 60-days) to comment on the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0007,
21, 27, 28, 29, 30, 31, 34, 35, 36, 40, 41, 42, 45, 46, 48, 49,
50, 51, 52, 54, 58, 59, 60 (dup 62), 61, 65, 70
|
Request
for more time to respond to each part of the ICR. Reasons
include:
Location
and consistency of data across several databases and hard copy
records
Data
collection and sampling efforts
Inclement
weather during field work
Avoid
overlap with GHGRP and permit compliance reports
Avoid
winter heating season where personnel are already stretched thin
EPA’s
intent to mail Part 1 will reduce response time
Significant
field work and travel time on respondents
Holiday
seasons, personnel vacations
Operators
have more than 30 facilities
Due
to the need to hire contractors to complete this work, need
additional time to draft contracts/get contracts in place
Using
the same system for both the ICR responses and the GHGRP
reporting risks overloading the e-GGRT system and the
third-party help desk contracted by EPA.
Industry
is generally not familiar with the CARB sampling methodology, a
method, as discussed infra, that is not typically used by the
laboratories relied on for analysis.
Extend
deadline to allow sufficient time for the agency to compile a
representative sampling pool for gathering and boosting
stations.
October
30th is not a business day.
|
While
EPA acknowledges commenters’ concerns with completing the
ICR within the required timeframe, the response deadline will
remain at 30 days (Part 1) and 120 days (Part 2) past receipt of
the final ICR (see Comment Response Memo).
|
-0021,
27, 28, 29, 30, 31, 34, 36, 40, 41, 46, 48, 49, 50, 51, 52, 54,
58, 59, 60 (dup 62), 61, 65, 70
|
Requested
Time Frames:
-0028,
29, 30, 48, 49, 51, 61 = Allow 180 days to respond to both parts
of the ICR.
-0070,
46, 52 = Allow 240 days to complete both parts
-0050
= Allow 60 days for Part 1.
-0036
= Allow 90 days for Part 1.
-0040
= Allow 60-120 days for Part 1
-0034
= Extend Part 1 deadline to February 27, 2017.
-0021,
41 = Allow 180 days for Part 1 (April 2017).
-0036,
40, 50, 59 = Allow 180 days for Part 2 (April 2017).
-0021,
27, 31, 34, 54, 58 = Extend Part 2 deadline to June 2017 (8
months).
-0041
= Allow 1 year for Part 2.
|
While
EPA acknowledges commenters’ concerns with completing the
ICR within the required timeframe, the response deadline will
remain at 30 days (Part 1) and 120 days (Part 2) past receipt of
the final ICR (see Comment Response Memo).
|
-0028,
36, 48, 59
|
ICR
should be conducted in two separate phases; Finish Part 1 and
learn from it to create final Part 2.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0028,
29
|
EPA/OMB
does not have enough time to analyze all of the submitted
comments.
|
EPA
has analyzed all submitted comments to the Oil and Gas ICR.
|
-0028,
29, 30, 48, 51, 59
|
Deadlines
for both Part 1 and Part 2 should be the same, as any analysis of
the ICR will incorporate both Part 1 and Part 2 data.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0035
|
ICR
was published on the same day as final OOOOa, which did not allow
for full industry engagement on the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0037,
39, 43, 47, 55, 56
|
EPA
should work move as quickly as possible to gather data through
the ICR.
|
The
response deadline will remain at 30 days (Part 1) and 120 days
(Part 2) past receipt of the final ICR (see Comment Response
Memo).
|
-0036
|
Clarify
whether the surveys will be sent simultaneously.
|
Part
1 and Part 2 of the ICR will be sent simultaneously.
|
-0046,
52
|
EPA
should delay the Part 2 ICR surveys at least until after
companies report gathering and boosting facilities under the
GHGRP in March of 2017. Doing so will provide EPA a more
comprehensive list of gathering and boosting companies.
|
While
EPA acknowledges commenters’ concerns with completing the
ICR within the required timeframe, the response deadline will
remain at 30 days (Part 1) and 120 days (Part 2) past receipt of
the final ICR (see Comment Response Memo).
|
-0020,
36
|
Postpone
the ICR until after OOOOa information is received and evaluated.
|
While
EPA acknowledges commenters’ concerns with completing the
ICR within the required timeframe, the response deadline will
remain at 30 days (Part 1) and 120 days (Part 2) past receipt of
the final ICR (see Comment Response Memo).
|
|
Burden
Estimates
|
|
-0007,
21, 28, 29, 35, 36, 40, 41, 42, 45, 46, 48, 49, 50, 51, 52, 54,
58, 59, 60 (dup 62), 61, 65, 70
|
ICR
will be burdensome / more burdensome than projected
Part
1 ICR cost/time estimate is low. Reasons include:
Part
2 ICR cost/time estimate is low. Reasons include:
Calculation
error in Total Labor Cost/Activity
Underestimated
cost of tank liquid sampling and analysis (at least
$2600/sample)
Did
not include costs associated with internal database
modifications that will be required to comply with the ICR
Did
not include costs associated with the increased personnel hours
needed to obtain the information
Underestimated
hours per facility (should be 15-25)
EPA
does not consider the planning, travel and other logistical
requirements to complete field visits
The
analysis fails to consider that technical expertise (e.g., third
parties) may be required to execute these activities in many
cases.
The
definitions and equipment categories inconsistencies with
Subpart W definitions will preclude the use of existing data and
associated processes for data collection, require a new effort
to understand the applicability of the revised definitions and
categories, and require operators to implement a program to
gather the data.
Estimate
for reading/understanding instructions is too low
EPA
underestimates the prevalence of equipment at T&S segment
facilities.
EPA
underestimated the time required for equipment leaks (Collection
activity 2H), blowdown events (2I), pneumatic counts (3A), and
equipment counts (3B).
Two
separators and four tanks are an appropriate estimate for the
gathering and boosting (“G&B”) sector. It is not
appropriate to assume that there are the same number of
separators and tanks at processing facilities as there are at
G&B sites.
EPA
is failing to take into account the varying number of pneumatic
devices per site
Less
than half of G&B sites will have an AGRU on site. EPA’s
estimate that half of the processing sites will have AGRUs is
reasonable.
EPA’s
estimate that half of the G&B sites will have a dehydrator
unit is an underestimate.
EPA’s
estimate of one dehydrator per processing site is an
underestimate.
EPA
does not specify what the makeup is of the four compressors
assumed to be at a site. EPA should clarify whether it is four
reciprocating compressors, four centrifugal compressors, or a
combination of both. GPA Midstream estimates that 10 compressors
per processing plant is a more appropriate estimate.
Using
the same basis for all industry sectors is inaccurate, as it
does not accurately reflect differences among sectors.
One
flare and one vapor recovery unit (“VRU”) may be an
appropriate estimate for the G&B sector, but the same
estimate is not appropriate for processing.
Actuation
Consumption Rate is not known or readily available. EPA only
estimated 0.5 hours of instrument tech time and 0.5 hour of
engineer time per actuator in overall burden estimates which
significantly underestimates the level of effort required to
complete this information and is unrealistic for the effort
involved for data collection.
General
reasons:
Should
be reevaluated to include cost for facilities that are not
automated or that do not have remote monitoring
Did
not include additional time for data validation
Contractor
costs, especially if many operators are trying to hire the same
contractors
Did
not include additional time for e-GGRT submittal
EPA
must consider that burden and provide adequate additional time
for recipients operating more than 500 facilities to provide the
response to the ICR.
|
EPA
has revised the burden estimate to reflect all changes to the
ICR.
|
-0029,
40
|
Cost
could be reduced by reducing number of operators being required
to submit information. Within EPA’s statistical review,
EPA data indicated that statistically reliable information could
be acquired with 1/7th
the number of surveys.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0031
|
EPA
underestimated time and cost required for the field physical
counts of all equipment components >5 wt % of any VOC, CH4,
CO2 at each facility. Actual time ranged from 20-40
hours/facility. Total cost could range up to $4,500/facility.
|
EPA
has revised the burden estimate to reflect all changes to the
ICR.
|
-0040
|
Sampling
and analysis of feed material was not included in the time and
cost estimates in any states except California.
|
EPA
has included sampling and analysis for all states in the burden
estimates.
|
-0050,
49
|
Modify
both cost and time burden for completing the equipment leak
survey. LDAR requirements do not currently apply to all
operators across all jurisdictions, and many who are subject to
LDAR are not collection certain types of the information
requested. This would require additional costs, such as hiring
and training contractors, transportation of OGI equipment to new
locations, and compensating employees needed to conduct the
surveys.
|
EPA
is requesting data from previous leak surveys to be provided in
Part 2 of the ICR. EPA is not requiring facilities to complete
any additional leak surveys.
|
-0064,
59
|
EPA
needs to provide information supporting the validity of their
assumption of two wells per facility. The assumption of two wells
per facility is grossly underestimated, therefore the
corresponding burden and costs would also be vastly understated.
|
EPA
based the assumption of 2 wells per facility from the NSPS OOOOa
technical support document. We have revised the definition of
facility for production facilities, referred to as the “well
site facility” to be similar to the well site definition in
NSPS OOOOa. The well site facility consists of a well surface
site and its centralized production surface site. By aligning the
facility definition for production facilities with the well site
definition in NSPS OOOOs, we consider the analysis conducted to
establish the average of two wells well site to be directly
applicable to the impact estimates for this ICR.
|
|
Statistical
Sampling Approach
|
|
-0061
|
Support
for a modified GOR approach for Part 2:
Add
“Stripper Wells with low production”
Increase
margin of error for populations with low variability from 10%
(suggested 20% or 30%)
Allowing
a voluntary process for operators to correct contact
information, therefore reducing the need to arbitrarily increase
the number of ICRs mailed above the statistical estimates (see
mailing list comment)
|
EPA
has amended the statistical sampling approach to include
“Stripper wells, production ≤ 15 BOE/day.” See
Comment Response Memo for more information.
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit https://oilandgasicr.rti.org/ before October 30,
2016 to make any necessary corrections.
|
-0038
|
The
population distribution is skewed and better modeled as
log-normal rather than Gaussian. A relatively small number of
sources contribute a large fraction of the emissions. With a
heavy-tailed distribution that is skewed to the right, use of the
population median multiplied by the total number of facilities
will substantially underestimate total sector emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0038
|
Based
on the Proposed ICR, it appears that there will be a single
parameter selected from each population subgroup for which a mean
value will be computed. ODEQ requests clarification as to which
parameter EPA is investigating. If more than one parameter is
being investigated, ODEQ is requesting additional clarification
of the statistical approach.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0038
|
Although
the arithmetic mean is the appropriate measure for use in scaling
emissions to estimate sector-wide emissions (a bottom-up
estimate), the skewed nature of the distribution makes it likely
that the standard deviation of the mean wellhead facility GHG
emissions will be found to exceed the mean emission rate. This
property is mentioned in the Supporting Statement where the ratio
of the standard deviation to the mean value was assumed to be 3,
because “emission values often vary over 4 to 5 orders of
magnitude”. Supporting Statement for Public Comment:
Information Collection Effort for Oil and Gas Facilities (2016)
at 21. Use of standard statistical descriptors like the mean
value +/- standard error (with symmetrical error bars) may yield
a negative value for the low end of the range. This is
impossible, because facility GHG emissions must be zero or
positive.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0038
|
No
more than 5% of the total number of detailed surveys should
target wells drilled in 2011 or later. A substantial number of
emission units (e.g., tanks, pneumatic devices, etc.) located at
facilities associated with wells completed after August 23, 2011
are subject to New Source Performance Standards. In some state
programs, these wells are permitted and have been inventoried in
detail as point sources, with the emissions from those facilities
well characterized.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0038
|
Samples
should be stratified in a two-tier approach: by the age of the
wells (primary stratification) and by basin (second level of
stratification). Gathering data on formation types would be
helpful, but should not be used to stratify the population.
Similarly, absolute production data (i.e., not just the GOR
ratio) would also be gathered for each response to the detailed
survey. EPA should target older wells for which little
information is available.
|
EPA
will sample based on the explained GOR approach. See Comment
Response Memo for more information.
|
-0050
|
General
support of stratification of operator population by geographical
region for Part 2. The regulatory environment is driven by
region, not GOR range.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
For
the T&S segments, due to the limited variability in the types
of sources and operation, and/or availability of information
through other regulatory programs, a smaller percentage of
facilities will be sufficient to provide a representative sample,
reducing the amount of resources needed to respond to the ICR and
to analyze the information submitted.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Alternative
approach:
EPA
categorize wells according to three broad factors—well
production level, whether a well reports to Subpart W, and the
geological basin in which a well is located — and tailor
its sampling approach to each category. Suggested approach
results in 18 total strata that capture these distinctions.
EPA
consider using available emissions and production information to
tailor the sampling approach for particular well types within
each stratum:
Non-marginal
reporters – For this stratum, Subpart W provides
information for each operator on average emissions per well.
Therefore, we propose that EPA sample proportionally to average
well emissions, which means higher emitters are more likely to
be selected for the survey.
Non-marginal
non-reporters – For higher producing wells that do not
report to Subpart W, EPA should sample proportionally to
production.
Marginal
wells (both reporters and non-reporters) – The
characteristics of marginal oil and gas wells may be different.
For instance, marginal oil wells may not be connected to gas
gathering infrastructure and so can have emissions from casing
head gas, tank vapors, and equipment leaks. Also, neither GOR
nor production is a good metric to tailor sampling from these
sources. For these reasons, we suggest simple random sampling
from these strata.
For
the remaining industry segments, we do not propose additional
stratification, although for certain segments, we recommend that
EPA pursue an emissions-based sampling approach in which Subpart
W provides additional data and distinct approaches where the
universe of facilities is small or the agency is still in the
process of collecting Subpart W information.
For
the Natural Gas Processing, Transmission, and Underground
Storage strata, we recommend EPA pursue an emissions-based
sampling methodology, leveraging facility-level data from
Subpart W.
For
the Gathering and Boosting and Natural Gas Transmission Pipeline
Facility strata, we support EPA retaining its proposed approach,
focusing on simple random sampling.
For
LNG storage and LNG import/export facilities, due to the small
population of facilities, we support EPA’s proposal to
perform a census—that is, to include all facilities in the
sample.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should develop a methodology to avoid disproportionately
burdening a particular operator with an overwhelming number of
requests.
|
The
burden that a company experiences will be proportional to number
of facilities that company operates. EPA is requesting a
representative
sampling of facilities, which will not necessarily be spread
burden evenly across operators.
|
-0049
|
EPA
should avoid oversaturating a particular region with requests
which could lead to a flawed understanding of industry operations
and economics.
|
EPA
will be sure that each basin is sampled proportional to the
number of wells in each GOR range for each basin (proportioning
method is described in the ICR Supporting Statement).
|
-0049
|
Alternative
Option:
Rather
than guessing at what might be representative based on GOR or
basin, we recommend that EPA base its selections on the Part I
ICR responses. By analyzing that information, EPA will have a
much better understanding of how to target Part II requests. It
strikes us as a missed opportunity for EPA not to leverage the
valuable information it is collecting under Part I, and is
another reason the Part II data collection should occur after and
not simultaneous with Part I.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should limit its request to areas designated in attainment or
unclassifiable under the current Ozone National Ambient Air
Quality Standard. This will facilitate EPA avoiding duplicative
or confusing requirements for existing sources in nonattainment
areas that are already regulated by states.
|
EPA
is requesting information in both attainment and non-attainment
areas to accurately account for all oil and gas operations in the
country.
|
-0046
|
GPA
Midstream requests clarification about whether the final sampling
size will be adjusted once a more accurate number of facilities
is established.
|
EPA
will continue to employ the same method for determining sample
size no matter what the population is. We also note that the
number of facilities selected is quite independent of the actual
number of facilities in the population when that population is
large and it is the large industry segments with very large
numbers of facilities where we have the greatest uncertainties in
the number of facilities, so the number of samples from these
population s is not expected to vary.
|
-0052,
46
|
EPA
has not properly characterized the facility count for oil and gas
industry sources. There is a high probability that EPA has
under-counted facilities in the gathering and boosting segment.
EPA should delay the ICR process pending EPA's collection of more
accurate facility count data through the implementation of new
GHGRP provisions applicable to the gathering and boosting sector
|
While
EPA acknowledges commenters’ concerns with completing the
ICR within the required timeframe, the response deadline will
remain at 30 days (Part 1) and 120 days (Part 2) past receipt of
the final ICR (see Comment Response Memo).
|
|
Mailing
List
|
|
-0049,
61
|
EPA
should establish a voluntary process for operators to
identify/correct the preferred contact prior to releasing the
ICR.
|
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit
https://oilandgasicr.rti.org/
before October 30, 2016 to make any necessary corrections.
|
-0027
|
Publish
preliminary list of target facilities as part of next ICR public
comment period.
|
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit https://oilandgasicr.rti.org/ before October 30,
2016 to make any necessary corrections.
|
-0054,
58
|
EPA
should mail or email each ICR letter to the appropriate company
e-GRRT Designated Representative for the company that operates
the facility targeted by the ICR. This will increase the
probability of a high response rate to the ICR letters.
|
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit https://oilandgasicr.rti.org/ before October 30,
2016 to make any necessary corrections.
|
-0054
|
EPA
include an interim review step to assess equitable distribution
of burden for all affected companies – i.e., a
proportionate share of ICR letters.
|
The
burden that a company experiences will be proportional to number
of facilities that company operates. EPA is requesting a
representative
sampling of facilities, which will not necessarily spread burden
evenly across operators.
|
-0054
|
EPA
should consider developing a stakeholder group to develop “model
facilities” and related information that can be used to
assess equipment, emissions, and reduction opportunities.
|
EPA
will consider use of “model facilities” once the ICR
data has been received.
|
-0049
|
EPA
should clarify that any party receiving either part is only
required to respond and provide information for wells where it is
the operator.
|
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit https://oilandgasicr.rti.org/ before October 30,
2016 to make any necessary corrections.
|
|
Part
1 Questionnaire
|
|
|
Instructions
|
|
-0061
|
Update
Part 1 instructions to include:
|
EPA
has added definitions of “Well surface site” and
“Centralized production surface site” to the ICR and
removed the definition of “Facility” from Part 1 to
provide clarity.
EPA
is requiring best available data as of November 1, 2016.
|
-0050,
49
|
Clarify
that EPA is seeking information only on those wells operated by
the company so as to eliminate duplicate reporting from both
owner and operator.
|
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit
https://oilandgasicr.rti.org/
before October 30, 2016 to make any necessary corrections.
|
-0050,
49, -0064
|
EPA
should better define its scope so as to make clear whether it
intends to include facilities that are connected but not
collocated (and vice versa).
|
EPA
has added definitions of “Well surface site” and
“Centralized production surface site” to the ICR and
removed the definition of “Facility” from Part 1 to
provide clarity.
|
|
Table
1: Parent Company General Information
|
|
-0049
|
a.
General Facility Information
Employee
counts are not useful to EPA from an emissions perspective.
Therefore it is recommended that EPA strike this request from
the ICR.
Alternatively,
EPA should instead focus on whether the respondent is a small
business in order to more easily quantify the impact of the ICR
on small businesses. To accomplish this, it is recommended that
EPA indicate that the Small Business Administration’s
definition of a small entity is 1,250 employees excluding
contractors and ask respondents to indicate whether they fall
under this definition.
|
EPA
has amended Table 1 to request “Average Number of
Employees” and has provided a picklist of employee number
ranges.
|
|
Table
3: Facility Description
|
|
-0061
|
Add
basin level reporting to Part 1. Include the following:
Basin
Identifier
Number
of manned onshore well sites in basin
Is
electrification from grid power available in basin?
Approx.
number of wells that have access to gas infrastructure in basin
Move
“Is facility manned?” to basin level reporting (see
above comment).
Move
“Does the facility have electricity?” to basin level
reporting (see above comment).
|
EPA
has removed “Is the Facility Manned?” and “Does
the facility have electricity?” from Part 1 of the ICR.
|
-0061
|
If
an operator owned the facility on December 31, 2015 then that
operator would report readily available information for Part 1,
as records and data are not typically available in a format that
allows for a timely response after a purchase of an asset.
Step
3 should be modified to remove reference to ‘managed’
assets. Only the owner and operator as of December 31, 2015
should be required to report for Part 1 information. This will
eliminate confusion for facilities with multiple operators and
clarify who is responsible for reporting facilities that have
joint owners, which are operated by one of the owners.
|
EPA
is requiring best available data as of November 1, 2016.
|
-0050
|
Clarify
whether EPA considers temporary generators to be connected to the
electrical grid.
|
EPA
has removed “Does the facility have electricity?”
from Part 1 of the ICR.
|
-0050
|
Clarify
what encompasses the electrical grid within the proposed ICR.
|
EPA
has removed “Does the facility have electricity?”
from Part 1 of the ICR.
|
-0049,
48
|
Recommend
instead that EPA make availability of electricity part of its
Part 2 request.
|
EPA
has removed “Does the facility have electricity?”
from Part 1 of the ICR.
|
-0049,
48
|
Recommend
that EPA clarify that facilities not connected to the electrical
grid but merely using temporary generators not be considered
electrified. These generators do not necessarily remain onsite
and may not have the capacity to operate instrument air pneumatic
systems or other systems.
|
EPA
has removed “Does the facility have electricity?”
from Part 1 of the ICR.
|
-0061
|
Move
“Distance from facility to field office (miles)” to
Part 2
|
EPA
has removed “Distance from facility to field office
(miles)” from Part 1 of the ICR.
|
-0021,
61
|
In
requesting the distance that a facility is from to a field
office, is this the distance as the crow flies or the driving
distance?
|
EPA
has moved “Distance from facility to field office (miles)”
from Part 1 of the ICR to Part 2. Distances should be measured
as driving distance.
|
-0050,
49, 48, 59
|
Provide
explanation on why “distance from facility to field office”
is necessary to regulate methane and VOC emissions from O&G
industry.
An
employee or contractor will not travel to a facility, back to
the field office, then on to the next facility, and so on, but
will instead visit several facilities while away from the field
office on a pre-planned route. Therefore, the distance to the
nearest field office doesn’t provide EPA with much insight
into how field operations are conducted.
Recommend
that the distance be the shortest year-round driving distance
between a field office and the facility which would allow EPA to
gain a better understanding of how easily accessible a facility
is on a year-round basis.
EPA
should have a pull down set of ranges that can be more simply
answered (e.g., 0-10 miles, 10-25 miles, 25-50 miles, etc.).
|
EPA
has moved “Distance from facility to field office (miles)”
from Part 1 of the ICR to Part 2. Distances should be measured
as driving distance. EPA has also added “How frequently is
well site visited by field office personnel?” to Part 2 of
the ICR.
|
-0050
|
Servicing
staff is made up of a roving team of responders. Many times
these responders are responding from his/her own house or another
location as opposed to responding directly from the field office.
|
EPA
has moved “Distance from facility to field office (miles)”
from Part 1 of the ICR to Part 2. Distances should be measured
as driving distance. EPA has also added “How frequently is
well site visited by field office personnel?” to Part 2 of
the ICR.
|
-0061
|
Move
“Distance from facility to nearest natural gas gathering
line (miles)” to Part 2.
|
EPA
has moved “Distance from facility to nearest natural gas
gathering line (miles)” from Part 1 of the ICR to Part 2.
EPA has clarified that this information should only be provided
if well sites are not connected to a gathering and boosting or
transmission pipeline.
|
-0021
|
In
requesting the distance that a facility is from the nearest gas
gathering line, is this the distance as the crow flies or the
distance of a feasible pipeline route to that gathering line?
|
EPA
has moved “Distance from facility to nearest natural gas
gathering line (miles)” from Part 1 of the ICR to Part 2.
EPA has clarified that this information should only be provided
if well sites are not connected to a gathering and boosting or
transmission pipeline. Distances should be measured as driving
distance.
|
-0050,
49, 48, 59
|
Provide
explanation on why “Distance from facility to nearest
natural gas gathering line” is necessary to regulate
methane and VOC emissions from O&G industry.
All
natural gas wells should be exempted from this requirement, as
no rational operator would develop a natural gas well without
takeaway capacity, and reporting the distance to gas gathering
lines is not a worthwhile exercise.
An
oil well that is connected to gas gathering should simply be
able to satisfy EPA with a yes or no answer.
If
an operator has an existing contract with a specific midstream
operator to tie in all wells in an area to their pipeline, there
may be a closer gathering line that the survey respondent is not
going to connect to for contractual or logistical reasons.
Reasons could include not having rights-of-way to connect to the
closest gas gathering line, or having gas that is not of
sufficient quality to connect to the nearest gathering line.
Calculating
distance to natural gas gathering lines creates a burden on
respondents to locate irrelevant lines that far outweighs the
useful benefit of this information. In many instances, operators
are contractually obligated to use a particular midstream gas
gathering company. Additionally, many marginal oil wells do not
produce enough gas to warrant a midstream company to invest in
gas gathering lines.
A
more appropriate question is whether the facility is connected
to a natural gas sales line, rather than distance to the nearest
gathering line.
|
EPA
has moved “Distance from facility to nearest natural gas
gathering line (miles)” from Part 1 of the ICR to Part 2.
EPA has clarified that this information should only be provided
if well sites are not connected to a gathering and boosting or
transmission pipeline. EPA has also requested reasoning for any
lack of connection.
|
-0064
|
From
which point of the hundreds of wells, or other associated
equipment, would one measure the distance to the nearest
gathering line?
|
Facilities
should measure the distance to the nearest natural gas
transmission or gathering and boosting pipeline from the centroid
of the wells.
|
-0050,
48
|
EPA
should request information on whether a facility is connected to
a natural gas sales line. (instead
of distance to gathering line).
|
EPA
has amended Part 2 of the ICR to request “Quantity of
natural gas leaving the facility (sales) in the 2015 calendar
year (thousand standard cubic feet).”
|
-0048,
49, -50, 59, 61
|
To
reduce burden on operators to collect data that cannot inform a
rulemaking and without an identifiable benefit, collecting
liquids unloading data should be removed from Part 1.
The
mere occurrence of liquids unloading reveals little information
of use to EPA, as it does not address the timing, frequency,
technique, or other pertinent information about the process.
The
data in Part II would prove much more useful than the data in
Part I. We encourage EPA to remove liquids unloading from Part I
requirements.
Liquids
unloading will be highly variable over the life of the well and
can change in response to shut-ins and other events.
The
regulation of liquids unloading is not suitable for a standard,
industry-wide regulation.
|
EPA
has removed the collection of liquids unloading data from Part 1
of the ICR.
|
-0021
|
In
requesting whether wells conduct liquids unloading can EPA be
more specific as to what they are looking for. Oil wells are
continually unloading liquids as a form of production. Only dry
gas wells do not unload liquids.
|
EPA
has removed the collection of liquids unloading data from Part 1
of the ICR.
|
-0061
|
Is
there a flare or thermal combustor present at the facility?’
should be removed from the Part 1 ICR. The presence of a flare or
thermal combustor is not a useful data parameter in the current
format for Part 1 since the form does not identify the emission
source that is controlled.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0067
|
EPA
should refine its question in Part 1, Question 3 and replace with
the following three questions:
• Is
there a flare present at the facility?
• Is
there an internal thermal combustor present at the facility?
• Is
there a vapor recovery unit present at the facility?
|
EPA
has amended Part 1 of the ICR to include “Is there a flare
or thermal combustor present at the surface site?”
|
-0068
|
Add
the following questions to Table 3:
If
the facility is unmanned, how often does an operator visit the
site? (Number of visits per year)
Is
this facility connected to a natural gas gathering line?
Does
this facility vent associated gas? If so, how much was vented in
2015?
Does
this facility flare associated gas? If so, how much was flared
in 2015?
Does
this facility produce water?
|
EPA
has amended Part 1 of the ICR to include “Latitude of
surface site centroid (degrees decimal)” and “Longitude
of surface site centroid (degrees decimal).” Part 2 now
has a more detailed question regarding whether a facility is
manned. EPA has also added “Is there a flare or thermal
combustor present at the surface site?” to Part 1 of the
ICR.
|
|
Table
3: Equipment Counts
|
|
-0035
|
EPA
is requesting the number of producing wells for a facility. Many
wells are currently shut in due to the economic environment –
the operating cost is greater than the revenue produced by the
well. Does this count as a producing well? What time period
should we consider for a producing well that has been shut in?
|
EPA
has amended Part 1 of the ICR to request “Well Type”
for each Well ID at a well surface site.
|
-0061,
48, -0035, 59, -0049
|
‘Number
of Capped or Abandoned Production Wells’ should be removed
from the ICR. Data for historically abandoned or capped wells may
not be readily available, and in some instances, information may
not exist. Information on many ‘capped or abandoned wells’
is unavailable due to divestitures, mergers, and bankruptcies.
Furthermore, this information is not readily available on a per
facility basis and will require a considerable amount of time to
obtain.
|
Companies
should provide best available data when responding to the ICR.
|
-0049
|
h.
Number of Separators
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Add
the following to the facility-wide equipment counts:
Number
of water tanks <10 bbl/day
Number
of water tanks ≥10 bbl/day
API
gravity of hydrocarbon liquids going to the tank
Number
of pneumatic devices
Number
of dehydrators
Number
of flares
Number
of AGR units
Number
of heaters/treaters
Number
of headers
Number
of metering skids
|
EPA
has amended Part 1 of the ICR to include number of dehydrators.
|
|
Table
3: Well Identification
|
|
-0061
|
Add
Well Classification parameter to align with the sampling approach
selected for Part 2. API recommends the following categories:
Dry
Gas
Wet
Gas
Coalbed
Methane
Associated
Gas/Light Oil
Heavy
Oil
Stripper
|
EPA
has amended Part 1 of the ICR to request “Well Type”
for each Well ID at a well surface site.
|
|
Other/General
|
|
-0021
|
EPA
should be more specific regarding the information requested.
Specifically how would EPA handle reporting the following
situations?
1.
A compressor is located on the well pad of well A. This
compressor is a gas lift compressor that provides gas lift to
wells B and C. This is a small compressor that is not required
to be permitted and receives gas from a gathering line and is not
tied to well A in anyway. Wells B &C flow to a central tank
battery different from well A. How would this “facility”
be reported in the Part 1 information request?
2.
A centralized gas lift facility with multiple compressors
provides gas lift to potentially 50 wells. These 50 wells flow
to 20 different intermediate pads with the initial separation
equipment on them and then to 4 different centralized tank
batteries. Do these wells need to be listed on the gas lift
facility, the intermediate pad, and the individual tank batteries
they flow to? How should this “facility” be reported
in Part 1 of the information request?
3.
In an area where the well head is on one pad, the production
equipment (separator and heater treater) are located on an
“intermediate pad”, and the final separation and
storage takes place at a centralized tank battery how should this
be reported in the Part 1 information request given that
intermediate pads don’t have names and are low emission
sites that often don’t require permits?
4.
At a location a compressor is used to boost pressure along a
pipeline. The compressor is not attached to any particular well
and does not require a permit. How would this facility be
reported in Part 1 of the information request? Would we be
required to list all the wells that are on that pipeline?
|
EPA
has added definitions of “Well surface site” and
“Centralized production surface site” to the ICR and
removed the definition of “Facility” from Part 1 to
provide clarity.
Assuming
A, B, and C fit the definition of well surface site, then the
o/o will have to report information on well surface sites A,B,
and C in Part 1. The o/o will also report information on central
tank battery and this will be considered a centralized
production surface site. The compressor is part of Well Surface
Site “A” and would be reported under well surface
site A in Part 1.
Each
of the 20 intermediate pads would likely be considered a well
surface site and the o/o will have to fill out Part 1 as well
surface sites, and each of the 4 centralized tank batteries
would be a centralized production surface site and would be
reported as such in Part 1. The centralized gas lift facility
would also be considered a well surface site and these wells
reported as injection wells.
All
three appear to be independent surface sites.
If
the compressor is before the point of custody transfer and on a
surface site, then it needs to be reported as a surface site, if
it is beyond the point of custody transfer, it would likely be
considered a gathering and boosting station facility and would
not be required to fill out Part 1.
|
-0064
|
The
Part 1 and Part 2 spreadsheets envisions a maximum of
approximately 20 wells at a facility. As established above, a
facility can consists of hundreds or thousands of wells. If a
facility has more than the 20 wells associated with a facility,
will the Part 1 and Part 2 spreadsheets be unprotected?
|
EPA
has amended Part 1 of the ICR to request information from “Well
Surface Sites” and “Centralized Production Surface
Sites.” If additional rows/columns are required, facilities
should contact EPA to request a larger/additional spreadsheet.
|
|
Part
1 Definitions
|
|
-0049
|
“API
Well ID” and “US Well ID” are listed twice,
despite seemingly being the same thing. We suggest EPA combine
these definitions to avoid confusion.
|
EPA
has included only the definition of US Well ID.
|
-0061
|
ATMOSPHERIC
STORAGE TANK:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0036,
-0050, -0065, -0064
|
FACILITY:
|
EPA
has added definitions of “Well surface site” and
“Centralized production surface site” to the ICR and
removed the definition of “Facility” from Part 1 to
provide clarity.
|
-0068
|
FLOWBACK:
|
EPA
has amended the definition of “Flowback” to include
oil wells.
|
-0050
|
GAS-TO-OIL
RATIO:
|
EPA
has revised the definition of gas-to-oil ratio after considering
this and other comments on this definition for Part 2..
|
-0068
|
HYDRAULIC
FRACTURING:
The
current proposed definition includes the phrase “pressurized
fluids containing any combination of water, proppant, and any
added chemical” (emphasis added), but water is not the
only base fluid used in hydraulic fracturing; some operations
use gas or a mixture of gas and water as the base fluid.
The
current proposed definition specifies that hydraulic fracturing
is used to penetrate “tight formations,” but does
not define this term. Hydraulic fracturing is also used in
conventional formations with higher permeability (for example,
to bypass formation damage near the wellbore).
The
current proposed definition includes the phrase “subsequently
require high rate, extended flowback to expel fracture fluids
and solids during completions.” The terms “high
rate” and “extended” are vague and undefined.
Additionally, not all fracturing jobs may require “high
rate” or “extended” flowback, particularly
lower-volume hydraulic fracturing.
EPA
should collect data on all types of fracturing, not only
high-volume, high-pressure fracturing which occurs in
unconventional reservoirs, and should revise the definition.
|
EPA
has amended the definition of “Hydraulic Fracturing”
to include all types of fracturing.
|
-0061
|
INJECTION
WELL:
Injection
wells as utilized in the well site definition in Part 1, Table 3
should be limited to wells that store natural gas or carbon
dioxide in depleted natural reservoirs.
Recommendation:
Injection
Well – Underground Injection Control (UIC) permitted well
intended to store natural gas or carbon dioxide in depleted
reservoirs. It does not include wells permitted for produced
water or O&G waste disposal, injection of fluids (i.e.,
water, steam or carbon dioxide) for the purpose of Enhanced Oil
Recovery (EOR), or to inject crude oil, condensate, or LPG into
salt dome for storage purposes.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
MANNED
FACILITY:
EPA
should define the minimum expectation for operators to determine
if a facility is “manned”.
Recommendation:
Manned
Facility – Any facility that is visited by employees for
at least 40 hours per week.
|
EPA
has moved manned facility to Part 2.
|
-0061
|
ONSHORE
PETROLEUM AND NATURAL GAS PRODUCTION FACILITY:
Since
the definition requires the facility to have a well that
produces crude oil and/or natural gas, then a more appropriate
term for this definition would be “onshore production well
facility”.
Producing
wells may be co-located with other facilities such as a
compressor station, central tank battery, or gas processing
plant that processes crude oil and natural gas from other
locations. The current definition of facility would include this
equipment that is not the target of Part 1 surveys. This
confusion could be eliminated by including “from wells
located on that surface site and” before the phrase
“located at the facility” at the end of the current
definition.
|
EPA
has deleted the word “facility” from this term and
revised its definition to define the production industry segment.
We also removed the definition of “facility” from
Part 1 and added definitions of “Well site facility,”
“Well surface site” and “Centralized production
surface site” to the ICR to provide clarity for information
requested in the Part 1 survey.
|
-0061
|
ONSHORE:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
SEPARATOR:
Separator
is a general term that typically means any vessel that separates
phases (either gas from liquid or hydrocarbon liquid from
aqueous liquid) by differences in density. The definition
provided is much narrower and is better described by the term
“production or inlet separators”.
The
phrase “whose liquid portion flows directly to an
atmospheric storage vessel” should be added at the end of
the definition to exclude separators that do not feed liquid
directly to an atmospheric storage vessel.
|
EPA
has considered and evaluated this comment. For the purpose of
this ICR, we specifically want the term separators to refer to
vessels that perform gas-liquids separation. We have generalized
this definition to note that the gas may be separated “from
one or more liquid fluids.”
|
-0036
|
SEPARATOR:
Should
exclude the term “tank”
Recommendation:
Separator
– a cylindrical or spherical vessel used to separate oil,
gas, and water from the total fluid stream produced by a well.
|
EPA
has adjusted the definition of Separator to mean, “A
process vessel specifically designed to separate gaseous fluids
from one or more liquid fluids produced from a well or as
received via a pipeline. Generally, separators are operated at
pressures greater than ambient air pressure.”
|
-0061
|
STRIPPER
WELL:
|
EPA
has adjusted the definition of Stripper well to mean, “A
well that produces 15 barrels of oil equivalent (BOE) or less per
day on average over a 12-month period.”
|
|
WELL
SHUT-IN PRESSURE:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
WELL-SITE:
|
EPA
has added definitions of “Well surface site” and
“Centralized production surface site” to the ICR and
removed the definition of “Facility” from Part 1 to
provide clarity.
|
-0048
|
The
definition of “onshore petroleum and natural gas production
facility” and “facility” in Part 1 needs to be
removed to avoid confusion and inconsistencies in information
received. EPA defines several terms that make it confusing for
operators to interpret the data requested by facility in Part 1.
Specifically, EPA defines “facility”, “well
site”, and “onshore petroleum and natural gas
production facility” in Part 1, but these definitions are
not consistent and could lead operators to inconsistently report
Part 1 data due to the conflicting definitions. We are concerned
that these terms will cause confusion over which pieces of
equipment are intended to be included, and where the boundary
should be drawn for reporting.
|
EPA
has deleted the word “facility” from this term and
revised its definition to define the production industry segment.
We also removed the definition of “facility” from
Part 1 and added definitions of “Well site facility,”
“Well surface site” and “Centralized production
surface site” to the ICR to provide clarity for information
requested in the Part 1 survey.
|
|
Part
2 Questionnaire
|
|
|
Instructions
Tab
|
|
-0031
|
EPA
should provide additional clarification of date period of
information requested in the intro tab and each equipment tab.
Only blowdowns have been specified as 2015 data.
|
EPA
has amended the ICR to request RY 2015 data, when applicable.
|
-0049
|
EPA
clarify that only wells and equipment operated by the company are
included in the company’s response to EPA which will avoid
duplicative reporting by both the owner and operator
|
EPA
will allow operators to review and correct contact information
prior to sending out Part 1 and Part 2 of the ICR. Operators
should visit
https://oilandgasicr.rti.org/
before October 30, 2016 to make any necessary corrections.
|
-0061
|
If
an asset changed ownership after December 31, 2015, then the
facility should not be considered within the scope of the ICR
survey. Former owners and operators should not be required to
provide information about facilities no longer under their
control, even if some information is retained after closing. This
is consistent with the transition requirements in the GHGRP.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
EPA
should provide more detailed instructions for responding to each
data element of the ICR to ensure operators have a clear
understanding of the data EPA is requesting on each response tab.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Shifting
information from the Intro tab to the appropriate sheets would
facilitate responses.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
introduction must contain detailed information on how to make the
submittal using the e-GGRT system, including user registration
for those not already in the system
|
EPA
agrees with this comment and has implemented this suggestion.
e-GGRT directions will supplied with the ICR.
|
-0046
|
Edit
the Questionnaire Introduction/Instruction Sheet for “Tank
Separators” as follows:
This
information should be completed for all atmospheric storage
vessels at the facility, including produced water, condensate, or
hydrocarbon storage vessels except for tanks used to store glycol
(including, but not limited to, ethylene glycol, triethylene
glycol and propylene glycol), antifreeze, lube oil, used oil,
amine (including diethanolamine and diethylamine), methanol,
corrosion inhibitors (including H2S scavenger), solvent, diesel
(or generator fuel), and water treatment chemicals and other
auxiliary tanks.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
EPA
should only require Part 2 to be completed for two wells and
associated production equipment regardless of the total number of
wells within the contiguous property. This would be consistent
with the evaluation EPA performed for the ICR. The EPA should
default to the operator to select the second well (EPA will
provide the API well number for the first) which will be included
in the Part 2 response or the EPA should provide guidance on how
to select which two wells should be included in the response.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Acronyms/Definitions
Tab
|
|
-0054
|
The
Part 2 survey includes an Acronyms worksheet, but there are a
number of acronyms throughout the worksheets that are not
included on that sheet or defined. EPA should thoroughly review
all worksheets and list all acronyms in the Acronym worksheet.
|
EPA
has reviewed all acronyms within Part 2 of the ICR to assure that
they are defined in the Acronyms Tab.
|
-0064
|
It
should not be assumed that terms such as “abandoned well”
or “well pad” are consistent across the oil and gas
industry or consistently understood by the various entities that
regulate oil and gas facilities.
|
EPA
is no longer using the term “well pad” and is using
the term “plugged” or “plugged/abandoned”
and has added a definition of “Plugged well”.
|
-0049
|
“Oil
Well/Oil Reservoir” and “Gas Well/Gas Reservoir”
definitions in their current forms will create confusion and
should instead be amended to match state or land agency
definitions.
|
EPA
has considered and evaluated the impacts of this comment. We need
each respondent to use consistent definitions for these terms
consistent with our GOR groupings so we are not revising these
definitions.
|
-0027
|
EPA
should provide clarification/distinction between production well
sites and storage wellheads, particularly with respect to the
“Well Site” definition and the “Well Sites”
tab. Commenter is unsure if “Well Sites” tab in
applicable to storage operations.
|
EPA
has added the Injection-Storage Wells Tab to account for storage
operations.
|
-0064
|
Definitions
should be provided for terms such as “manned”, “field
office”, “general office”, “well pad”,
“capped well”, “abandoned well”,
“injection well”, “process tank”,
“gathering line”, “major process equipment”,
“leak”, “dump valve”, amongst others.
|
EPA
has considered this comment and has included some additional
definitions as appropriate.
|
-0046
|
The
following terms do not have definitions:
Equipment
Leaks: “Gas Service,” “LNG Service,”
“Light Crude Service,” and “Heavy Crude
Service” (40 CFR 60.481a, NSPS Subpart VVa has definitions
for “In gas/vapor service,” “In heavy liquid
service,” and “In light liquid service.” 40
CFR 60.5430a, NSPS OOOOa has a definition for “In light
liquid service.” GPA Midstream is not aware of a
definition for “LNG Service”)
Tanks
Separators: “Floating Roof” (40 CFR 60.111, NSPS
Subpart K has a definition for “Floating Roof”)
Tanks
Separators: “Gasketted, lockdown thief hatch,”
“Ungasketted, lockdown thief hatch,” “Gasketted,
spring-loaded thief hatch,” “Ungasketted,
spring-loaded thief hatch,” “Gasketted, dead-weight
thief hatch,” “Ungasketted, dead-weight thief
hatch.” GPA Midstream is not aware of where these terms
are currently defined.
Tanks
Separators: “Continuous Monitor.” GPA Midstream in
unclear whether this is limited to a monitor that is sending
real time information to a control panel and/or data recorder.
Pneumatics:
“Chemical injection piston pump,” “Chemical
injection diaphragm pump,” “Liquid Circulation
(Kimray) pump.” (40 CFR 98.6 defines “Absorbent
circulation pump.”)
Equipment
Leaks: “Optical gas imaging,” “EPA Method
21/OVA,” “Any visible emissions using OGI”
(“OGI” is not defined). (40 CFR 60.18(g)(4) defines
“Optical gas imaging instrument.” For these
comments, GPA Midstream assumes “OVA” means “Organic
Vapor Analyzer”, not “Olfactory, Visual, Audible.”
Equipment
Leaks: “Screening/Infrared laser beam illuminated,”
“Screening/Acoustic leak detection”. GPA Midstream
is not aware of where these terms are currently defined (these
terms are used in the GHGRP but not defined).
Equipment
Leaks: “In-line heater.” GPA Midstream is not aware
of where this term is currently defined.
Compressors:
“Calibrated bagging,” “High volume sampler.”
(40 CFR 98.6 defines “Calibrated bag.”)
Compressors:
“Liquefied Petroleum Gas (LPG).” GPA Midstream is
not aware of where this term is currently defined.
|
EPA
has considered this comment and has included some additional
definitions as appropriate.
|
-0061
|
ARTIFICIAL
LIFT: Although the proposed definition comes from the final NSPS
OOOOa, it was not proposed and is not utilized in the regulation.
Recommendation:
Artificial
lift - A wellbore deliquification technique which utilizes added
energy, which includes surface compression, sucker rod pumps,
progressive cavity pumps, electric submersible pumps, jet pumps,
and gas lift.
|
EPA
has adjusted the definition of Artificial lift to mean, “A
wellbore deliquification technique that adds energy to the fluid
column in a wellbore. Artificial-lift systems use a range of
operating principles and include surface compression, sucker rod
pumps, progressive cavity pumps, electric submersible pumps, jet
pumps, and gas lift.”
|
-0061
|
ASSOCIATED
GAS: Currently, EPA’s definition of associated gas would
include any natural gas from a well that also produces liquid
hydrocarbons. This definition can be corrected by deleting the
phrase “that also produce hydrocarbon liquids” and
replacing it with “at oil wells”.
|
EPA
agrees and has adjusted the definition of Associated gas to mean,
“The natural gas which originates at oil wells and occurs
either in a discrete gaseous phase at the wellhead or is released
from the liquid hydrocarbon phase by separation.”
|
-0061
|
ATMOSPHERIC
STORAGE TANK: This definition from the Part 1 survey should be
added to the Part 2 survey definitions.
|
EPA
agrees and has added the definition of Atmospheric storage tank
to mean, “A class of storage tanks that store materials at
approximately atmospheric pressure. Atmospheric storage tanks
may store liquids at ambient temperatures or at elevated
temperatures (e.g., "heater treaters").”
|
-0054,
-0046, -0061
|
BLOWDOWN:
|
We
have revised our definition to make it clear that maintenance
releases are considered to be blowdowns. The adjusted definition
of Blowdowns is: “The act of releasing gas from a well,
process unit, or pipeline to reduce the pressure of the system or
to prepare equipment for maintenance or cleaning, such as
pigging.”
|
-0061
|
CENTRIFUGAL
COMPRESSORS: The definition should specifically exclude vapor
recovery compressors.
|
Vapor
recovery compressor is a compressor. EPA has added the data
field, “Operational Service” to include
Transportation, Vapor Recovery, Refrigeration, and Other.
|
-0064
|
The
definition of “centrifugal compressor” should be
limited to units compressing natural gas. In addition, the
definition should only apply to compressors which operate using
centrifugal action.
|
We
have added other compressor types including wet seal, screw, and
scroll compressors to the, “Compressor Type”
picklist.
|
-0046
|
COMPONENTS
(OR EQUIPMENT COMPONENTS):
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
COMPRESSOR
STATION:
|
The
term “Compressor station” is a general term that is
used in the various industry segment definitions, so we have
retained the general NSPS OOOO definition and we have refined the
industry segment definitions to clarify what equipment is
included at a facility within each industry segment. From these
definitions, it is clear that the presence of compressors at a
facility does not make that facility a gathering and boosting or
a transmission compression “compressor station”
facility.
|
-0054
|
COMPRESSOR:
From
40 CFR 98 subpart W, section 98.238: Compressor source means the
source of certain venting or leaking emissions from a
centrifugal or reciprocating compressor. For centrifugal
compressors, “source” refers to blowdown valve
leakage through the blowdown vent, unit isolation valve leakage
through an open blowdown vent without blind flanges, and wet
seal oil degassing vents. For reciprocating compressors,
“source” refers to blowdown valve leakage through
the blowdown vent, unit isolation valve leakage through an open
blowdown vent without blind flanges, and rod packing emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
CONDENSATE:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
-0054, -0046
|
CONTINUOUS
BLEED PNEUMATIC CONTROLLER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
CONTROL
DEVICE:
Recommendation:
Control
Device - For the purpose of this ICR, control device is limited
to equipment that is utilized to recover or reduce emissions
from a hydrocarbon process stream. A control device includes,
but is not limited to, traditional candlestick flares, enclosed
flares, thermal oxidizers/incinerators, vapor recovery units and
carbon adsorption systems. Engine catalysts are not included for
this request.
|
EPA
has added a general definition for “Control device”
and also a definition of “Organic emissions control device”
the latter being similar to the suggested definition. We also
revised the instructions in the control device tab to be specific
to organic emissions control devices.
|
-0049
|
The
definition of “Crude Oil” includes the term “drip
gases.” EPA should clarify whether drip gas is a reference
to condensate. If so, it should be removed from the crude oil
definition, as condensate is defined separately.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
CUSTODY
TRANSFER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
CUSTODY
TRANSFER:
|
Custody
transfer is used in the new definition of “Gathering and
boosting compressor station facility” so EPA has retained
this definition.
|
-0068
|
DIRECTIONAL
WELL:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
FACILITY:
GHGRP
section 98.6 “facility” definition is preferred.
The
final ICR should more clearly define “facility” for
transmission pipelines, and Subpart W definition is available.
|
EPA
has revised the definition of facility for the purposes of this
ICR and have added a number of other definitions such as “Well
surface site,” “Well Site Facility,” and
“Centralized production surface site” and “Gathering
and boosting compressor station facility” to help clarify
the definition of “Facility” for the purposes of
responding to Part 2 of this ICR.
|
-0046,
59
|
FACILITY:
|
The
revised definition of facility incorporates special definitions
for production, gathering and boosting, and transmission pipeline
facilities. We consider these special definitions of facility to
be more useful for supporting standards development for existing
sources. For other industry segments, the definition of facility
is consistent with the source determination rule..
|
-0049
|
The
current definition of “Facility” is unclear and could
be a source of confusion for locations that have physically
co-located but functionally unrelated equipment, or locations
that with functionally related equipment located off-site. For
instance, if an operator has a compressor for boosting pipeline
pressure and a tank battery on the same location that does not
sell to the pipeline, it is unclear if EPA would consider this
one or two distinct locations
|
We
have revised the definition of facility, which now incorporates
special definitions for production, gathering and boosting, and
transmission pipeline facilities to provide clarity. In any
event, all equipment (or pollutant-emitting activities)
co-located at a single surface site under common control is
considered to be one facility, regardless of “functionality.”
|
-0046
|
FIELD
QUALITY NATURAL GAS:
EPA
should evaluate this definition to determine whether it will
provide the agency the information it seeks, since the term
itself does not provide any information about gas composition.
Field
gas may be of an acceptable composition and heating value
(btu/scf) to be sent from the wellhead to transmission pipelines
without any processing. Field quality natural gas can be rich or
lean.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
GAS-TO-OIL
RATIO:
It
is unclear if “Gas-to-Oil Ratio” (GOR) is the same
GOR that an operator would obtain from a flash analysis after a
separator.
EPA
should clarify this definition to “the ratio of the amount
of hydrocarbon gas that is generated by the decrease in pressure
or increase in temperature to standard conditions to the amount
of hydrocarbon liquid that remains after the gas has been
liberated” which more accurately describes the necessary
change in pressure and temperature.
|
The
definition of Gas-to-oil ratio has been adjusted to mean, “The
ratio of the volume of natural gas that is produced or that comes
out of solution when crude oil is extracted from a well
equilibrated to standard conditions to the volume of hydrocarbon
liquids (oil and condensate) produced after the natural gas comes
out of solution. This is often calculated by dividing the
measured natural gas production by the measured crude oil and
condensate production.”
|
-0061
|
GAS-TO-OIL
RATIO (GOR) AND GAS LIQUID RATIO (GLR):
The
GOR definition proposed for Part 2 is in conflict with the GOR
definition in Part 1, the oil and gas industry’s
understanding of GOR, and application of GOR for use in the Well
Site, Table 2 General Well Information.
|
The
definition of Gas-to-oil ratio has been adjusted to mean, “The
ratio of the volume of natural gas that is produced or that comes
out of solution when crude oil is extracted from a well
equilibrated to standard conditions to the volume of hydrocarbon
liquids (oil and condensate) produced after the natural gas comes
out of solution. This is often calculated by dividing the
measured natural gas production by the measured crude oil and
condensate production.”
|
-0049
|
HEATER
TREATER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
HEATER
TREATER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
HORIZONTAL
WELL:
Revise
title to “Directional/ Horizontal well”
Recommendation:
Directional/ Horizontal well - Wells
where a section of the wellbore intentionally deviates from the
vertical, allowing access to oil and gas reserves located at
points different from directly beneath the wellhead.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
HYDRAULIC
FRACTURING:
Recommendation:
Hydraulic fracturing - The
process of directing pressurized fluids containing any
combination of water, proppant, and any added chemicals into
subsurface geological formations to improve or restore
permeability.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. Note, in response to
another comment, we did generalize the definition of hydraulic
fracturing to all types of formations (not just tight gas
formations).
|
-0061
|
INJECTION
WELL:
Recommendation:
Injection
Well – “Underground Injection Control (UIC)
permitted well intended to store natural gas or carbon dioxide
in depleted reservoirs. It does include wells permitted for
produced water or O&G waste disposal, injection of fluids
(i.e., water, steam or carbon dioxide) for the purpose of
Enhanced Oil Recovery (EOR), or to inject crude oil or LPG into
salt dome for storage purposes.”
|
EPA
has added an “Injection-Storage Wells” tab and
associated definitions. EPA does not intend to limit injection
wells to just natural gas.
|
-0054
|
INTERMITTENT
BLEED CONTROLLER:
Pneumatic
controller definitions should be consistent with the pneumatic
categories in Subpart W and Subpart OOOO; eliminate all of the
additional categories of pneumatic devices in the Proposed ICR.
The
additional data is not readily available.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
INTERMITTENT
BLEED CONTROLLER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
INTERMITTENT
VENT CONTROLLER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
ISOLATION
VALVE:
Isolation
valve term is included in Subpart W, section 98.238 definition
of compressor source but it is not defined. If this definition
is retained in the final ICR, INGAA suggests deleting “usually
for maintenance or safety purposes.”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
LIQUIDS
UNLOADING:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
MANNED
FACILITY:
|
A
drop down picklist has been added of how often the site is
visited.
|
-0046
|
MAXIMUM
AVERAGE DAILY THROUGHPUT:
EPA
should remove this term and not use this concept in the ICR,
because the throughput during the 30-day potential-to-emit
evaluation period may be irrelevant to current throughput.
This
term and concept were only recently introduced with NSPS OOOO,
so for existing tanks, this data will not be available.
The
forms generally contain terms like “average flow rate”
or “average throughput.” These terms are acceptable,
with the caveat that EPA should define calendar year 2016 as the
period/averaging period for all data to ensure a consistent
reporting basis across operators.
|
EPA
appreciates the comment and will implement as suggested and has
removed this definition.
|
-0046
|
NATURAL
GAS (NG):
GPA
Midstream notes that EPA does not define “pipeline
quality” and may want to do so, depending on the
application of this definition.
Assumed
this term is used to refer to gas that meets transmission and
distribution sector quality specifications. The processed gas
stream from a gas plant (residue gas) meets these kinds of
specifications, and field gas in some areas of the county may
also meet these specifications.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
NATURAL
GAS LIQUIDS:
This
definition is not adequate as it does not refer to the liquid
state of these hydrocarbons, it uses an undefined term
“extracted,” and it uses the term “field
quality” which seems to be an unnecessary qualifier for
“natural gas.”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
NATURAL
GAS TRANSMISSION PIPELINE FACILITY:
There
is an associated definition in Subpart W for pipeline operator
rather than “facility,” which includes similar text
to the proposed ICR definition (see next item below).
The
final ICR definition needs to more clearly delineate the
difference between “pipeline” facilities and
“compressor station” facilities to ensure boundaries
are defined and consistent responses are ensured. Additional
text should be included in final ICR definitions or in final ICR
support documents.
There
is an associated definition in Subpart W containing owner or
operator but it does not define “facility.”
See
comment above regarding the need for clear delineation of
segments – i.e., “natural gas transmission pipeline”
facilities and “natural gas transmission compressor
station” facilities.
There
is an associated definition in NSPS Subpart OOOO but it does not
define “facility.”
|
We
have defined “Transmission Pipeline Facility” to be:
“For the purposes of this ICR, all onshore transmission
pipelines within a given state that is under the control of the
same person (or persons under common control).”
|
-0046
|
NET
HEATING VALUE:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
ONSHORE
NATURAL GAS PROCESSING PLANT (FACILITY):
This
definition from NSPS, Subpart OOOO (and previously Subpart KKK)
has been clarified in Applicability Determinations (AP) to mean
“forced extraction”, thus eliminating gravity
separation of liquids from the interstage coolers on compressor
skids.
|
EPA
has adjusted the definition of Onshore
natural gas processing to
mean, “The oil and gas industry segment that is engaged in
the extraction of natural gas liquids from field quality natural
gas, fractionation of mixed natural gas liquids to natural gas
products, or both at an onshore facility. A Joule-Thompson
valve, a dew point depression valve, or an isolated or standalone
Joule-Thompson skid is not an onshore natural gas processing
facility.”
|
-0046
|
ONSHORE
NATURAL GAS PROCESSING PLANT (OR FACILITY):
To
avoid any confusion with facilities that have gravity separation
of liquids, GPA Midstream suggests that EPA revise the
definition as follows, along with the definition of “forced
extraction of natural gas liquids” proposed above.
|
EPA
has adjusted the definition of Onshore
natural gas processing
to mean, “The oil and gas industry segment that is engaged
in the extraction of natural gas liquids from field quality
natural gas, fractionation of mixed natural gas liquids to
natural gas products, or both at an onshore facility. A
Joule-Thompson valve, a dew point depression valve, or an
isolated or standalone Joule-Thompson skid is not an onshore
natural gas processing facility.”
|
-0054
|
ONSHORE
NATURAL GAS TRANSMISSION COMPRESSOR STATION:
|
EPA
has adjusted the definition of Onshore
natural gas transmission compression to
mean, “The oil and gas industry segment whose primary
function is to move natural gas from production facilities,
gathering and boosting facilities, natural gas processing plants,
or other transmission compressor stations through transmission
pipelines to natural gas distribution pipelines, LNG storage
facilities, or into underground storage using a combination of
onshore compressors. Facilities in this industry segment are
referred to as Onshore natural gas transmission compressor
stations and these facilities may include equipment for liquids
separation, and tanks for the storage of water and hydrocarbon
liquids; however; the Onshore natural gas transmission
compression industry segment does not include facilities that
have compressors but that are in the production, gathering and
boosting, or processing industry segments.”
|
-0054
|
ONSHORE
PETROLEUM AND NATURAL GAS GATHERING AND BOOSTING FACILITY:
|
EPA
has revised this series of definitions to define the industry
segment. The adjusted the definition of Onshore
petroleum and natural gas gathering and boosting
to mean, “The oil and gas industry segment that uses
onshore gathering pipelines and other equipment to collect
petroleum and/or natural gas from onshore petroleum and natural
gas production facilities and to compress, dehydrate, sweeten, or
transport the crude oil , condensate and/or natural gas to a
natural gas processing facility, a transmission pipeline or to a
natural gas distribution pipeline. See also Gathering and
boosting compressor station facility.”
|
-0046
|
ONSHORE
PETROLEUM AND NATURAL GAS GATHERING AND BOOSTING FACILITY:
Mixing
definitions for petroleum facilities with natural gas facilities
simply does not make sense and does not have reasonable
application.
Industry
does not think of the “gathering and boosting”
industry segment as an industry segment that moves petroleum;
rather it is a natural gas business.
Respectfully
requests that EPA not propagate this definition from the GHGRP
into this ICR process or into any future rulemaking for the
gathering and boosting industry segment.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
PNEUMATIC
CONTROLLER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0050
|
PNEUMATIC
CONTROLLERS –
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
PNEUMATIC
DEVICE:
Air
driven pneumatics devices are not regulated equipment. Eliminate
this separate definition for pneumatic device or ensure
consistency with more specific terms/definitions of continuous
bleed, intermittent bleed, zero bleed, no bleed pneumatics and
pneumatic controllers. If this definition is retained in the
final ICR, delete the word “pneumatic” prior to
valve actuators and pumps.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
PNEUMATIC
DEVICE:
The
phrase, “which generates or” should not be used, as
this would seem to include the air/gas compression system in
with the users of the pneumatic power.
Concerned
that EPA could adopt a very loose or overly broad interpretation
of “pneumatic device” to include any equipment that
generates natural gas emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
PNEUMATIC
DRIVEN, MOTORIZED ACTUATOR:
Recommendation:
Pneumatic
Driven, Motorized Actuator – A turbine operated actuator,
rotary vane actuator, or other pneumatic motor driven actuator
driven by natural gas that opens or closes a gate type isolation
valve, typically found in the transmission pipeline sector.
|
This
term is not used in the ICR. EPA has considered and evaluated
the impacts of this comment and has decided not to pursue any
further action.
|
-0049
|
PRESSURE
VESSELS:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
RECIPROCATING
COMPRESSOR:
Maintain
consistency with the definitions of “Compressor” and
“Centrifugal compressor” in the proposed ICR and to
align with the definition for reciprocating compressor found in
the GHGRP, Subpart W
Recommendation:
Reciprocating
compressor - A piece of equipment that significantly increases
the pressure of a gaseous stream by positive displacement,
employing linear movement of the driveshaft.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
The
definition of “reciprocating compressor” should be
limited to units compressing natural gas.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
ROTARY
VANE ACTUATOR:
New
definition that should be deleted. Rotary vane actuators should
be covered in a broader category that is reported consistent
with the GHGRP. Terms and definitions are introduced that are
inconsistent with existing nomenclature and pneumatic source
categorization.
If
retained, remove the term “vane” and focus on
defining a hydraulic gas actuated generic “Rotary
Actuator.”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
SEPARATOR:
Separators
are absolutely not tanks.
Recommendation:
Separator
- A process vessel
specifically designed to separate gaseous fluids from liquid
fluids produced from a well or as received via a pipeline.
Generally, separators are operated at pressures greater than
ambient air pressure.
|
We
have replace the word “tank” with the word “vessel”
in the definition of separator.
|
-0061
|
SEPARATOR:
Recommendation:
Separator
– A process tank specifically designed to separate gaseous
fluids from liquid fluids produced from a well, received via
pipeline,
or
other streams at a gas processing plant. For the purposes of
this ICR, the liquid portion flows directly to an atmospheric
storage vessel.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
The
term separator is defined as a “process tank”, but
there is no definition for “process tank”. Further,
by including the wording “specifically designed to separate
gaseous fluids from liquid fluids” in the definition of
“separator”, the EPA seems to be limiting this data
field to two-phase separators (i.e. separates gases from
liquids). Three-phase separators (i.e. separates gases, produced
water and crude oil) would be excluded as they are specifically
designed to separate crude oil from produced water and any
offgassed vapors that can be collected.
|
We
have replace the word “tank” with the word “vessel”
in the definition of separator. We have also clarified in the
definition that they are used to “separate gaseous fluids
from one
or more
liquid fluids” so as to explicitly include “three-phase”
separators.
|
-0049
|
“Separator”
should clarify whether it includes gunbarrel tanks since their
primary purpose is to separate water from oil and not gas from
liquids.
|
For
the purposes of this ICR, the term separator is specific to
gas-liquid separators. EPA has considered and evaluated the
impacts of this comment and has decided not to pursue any further
action.
|
-0054
|
SNAP
ACTING CONTROLLER:
Newly
added pneumatic category and definition. Terms and definitions
are introduced that may be inconsistent with existing
nomenclature and pneumatic source categorization. Snap acting
controllers should be covered in a broader category that is
already reported consistent with the GHGRP.
The
proposed definition is erroneous because “snap acting”
refers to the controller service not the bleed/vent type, and
continuous bleed controllers can be used for snap acting
service.
|
EPA
has revised the definition of snap acting controller to be: “A
controller that acts as an on/off switch and is either fully open
or fully closed. Most snap acting controllers, when functioning
properly, do not have a continuous gas bleed and vent gas only
when actuating and are, therefore, typically designed as
intermittent bleed pneumatic devices.” We have also added
snap acting continuous bleed device to the list of pneumatic
devices for which counts are required.
|
-0046
|
SNAP
ACTING CONTROLLER:
Classification
of intermittent vent controllers into throttling or snap-acting
should be removed.
Depending
on the operational design, intermittent vent and continuous
bleed controller types can be either in on/off service or
throttling service.
|
EPA
has revised the definition of snap acting controller to be: “A
controller that acts as an on/off switch and is either fully open
or fully closed. Most snap acting controllers, when functioning
properly, do not have a continuous gas bleed and vent gas only
when actuating and are, therefore, typically designed as
intermittent bleed pneumatic devices.” We have also added
snap acting continuous bleed device to the list of pneumatic
devices for which counts are required.
|
-0054
|
STORAGE
TANK OR VESSEL:
Although
not defined in section 98.238, Subpart W section 98.233
(Calculating GHG emissions) contains important description,
explanation and distinctions for this unique source.
The
Subpart W section describes the tanks of interest for reporting
flashing emissions, but these sections do not apply to T&S
tanks.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
STORAGE
TANK OR VESSEL:
The
exclusion in the NSPS of “process vessels such as surge
control vessels, bottoms receivers or knockout vessels” is
not included in this ICR definition. This exclusion must be
included, as process vessels are present at existing oil and gas
operations but do not have emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
STORAGE
TANK OR VESSELS:
|
The
definitions for Storage tank or vessel has been made consistent
in Part 1 and 2.
|
-0061
|
THROTTLING
CONTROLLER:
|
EPA
accepts this definition and has added it to the spreadsheet.
|
-0054
|
THROTTLING
CONTROLLER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
THROTTLING
CONTROLLER:
EPA’s
proposed definition of throttling controller does not correctly
define throttling service and can apply to both a throttling
controller and an on/off controller that does not fully actuate.
EPA’s proposed definition of throttling controllers
confuses the effort of identifying controllers operating in that
service.
Recommendation:
Throttling
controller - A controller that is designed to hold an end device
in an intermediate position and move it from any position to
more (or less) open without a requirement to go to fully open or
fully shut every actuation cycle.
|
EPA
wants to collect more detailed information on pneumatic devices.
We have revised the definition of throttling controller to
conform with the recommended definition provided here and a
similar comment.
|
-0054
|
TOTAL
COMPRESSOR POWER RATING:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
TOTAL
COMPRESSOR POWER RATING:
Definition
mixes information about the compressor and the compressor driver
(which are nearly always separate and distinct pieces of
equipment).
Recommendation:
Total
compressor driver power rating - The nameplate brake horsepower
of the compressor driver.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
TURBINE
OPERATED ACTUATOR:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
UNDERGROUND
STORAGE VESSEL:
EPA
should modify this definition to align with concepts used in
SPCC (see 40 C.F.R. § 112.2) and RCRA (see 40 C.F.R. §
280.12).
GPA
Midstream cannot offer a specific definition for this term
because it is unknown how EPA intends to use it.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
VERTICAL
WELL:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
VOLATILE
ORGANIC COMPOUNDS (VOC):
There
is a typo at the end of this definition, “Compounds that
have been determined to have negligible photochemical
reactivity, such as methane and ethane, are excluded from the
define” [sic].
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
WELL
DEPTH:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
WELL
HEAD (OR WELLHEAD):
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
WELL
SITE:
|
EPA
has changed this to “Well Site Facility” and is now
consistent between Part 1 and Part 2.
|
-0064
|
The
definition of well site includes the term “facilities”.
A “facility” is defined as contiguous or adjacent
properties. Further explanation is needed as to how a well site
can incorporate numerous facilities.
|
EPA
has revised the definition of facility for the purposes of this
ICR and have added a number of other definitions such as “Well
surface site,” “Well Site Facility,” and
“Centralized production surface site” and “Gathering
and boosting compressor station facility” to help clarify
the definition of “Facility” for the purposes of
responding to Part 2 of this ICR.
|
-0061
|
WELL
TESTING: Match Subpart W definition.
|
The
definition of Well testing has been added to mean “The
determination of the production rate of a well or an assessment
of reservoir characteristics for regulatory, commercial, or
technical purposes. Well testing may or may not require venting
of gas at the well surface site.”
|
-0068
|
WELLBORE
LENGTH:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
ZERO
BLEED PNEUMATIC CONTROLLER:
New
definition that is not complete in the Proposed ICR or other
regulations. If this term is retained in the final ICR
definitions, the definition should differentiate between no
bleed, low bleed, and devices that may use solar, electric, or
instrument air. This definition should also address pneumatic
devices equipped with a gas capture system.
Related
definition in NSPS Subpart OOOOa provides for pneumatics driven
by a gas other than natural gas, with no natural gas emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
ZERO
BLEED PNEUMATIC CONTROLLER:
EPA
should delete this term from the ICR.
The
definition proposed in the ICR has two conflicting statements
and ultimately lead the user to determine the device is an
intermittent vent device, which EPA has already established as a
sub category.
If
the device does not release gas to the atmosphere there is no
value in the information reported and could not reliably be used
to determine overall impacts.
The
term zero bleed pneumatic controller is a marketing term with no
discernible meaning.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
ZERO
BLEED PNEUMATIC CONTROLLER:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Facility
Tab
|
|
|
Table
1: Parent Company General Information
|
|
-0046
|
Sub-Section
1. Parent Company General Information Recommend
that individual responders be allowed to decide the appropriate
Legal Name to use for each facility. What is often thought of as
one “company” often consists of a large family of
affiliated corporations, limited liability corporations, and
partnerships.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
1. Parent Company General Information EPA
should define or explain the term “Parent Company” in
this request, especially as compared to the GHGRP.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054,
48
|
Row
3 Column A - Number of Employees:
The
number of employees of the parent company is not pertinent to
the identification of the types and prevalence of emission
controls or emission reduction measures and potential costs for
the measures and controls. Remove question.
If
field is retained, provide drop down with bracketed counts.
Since this is for parent company, recommended drop down is [
<100 ] [ 101-5,000 ] [ >5,000 ]
EPA
could more easily address this question by providing the
necessary definition of a small business in the oil and natural
gas production industry and have a pull down “yes”
or “no” response.
|
EPA
has added the elements of the definition of “Small
Business” to the definitions tab and has amended Table 1 to
request “Does this company meet the definition of small
business?”
|
-0046
|
Sub-Section
1. Parent Company General Information The
number of employees is unnecessary information and can be
misleading. Depending on the legal name and entity, this number
could vary significantly due to the fact that employees may work
under one corporate entity but the site is owned by another.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
4 Column A - Dun and Bradstreet Number:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
1. Parent Company General Information Not
all corporate entities will have a Dun and Bradstreet number
assigned. That option should be factored in.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
1. Parent Company General Information There
is no reason for EPA to request the physical address for the
parent company. The mailing address should be adequate.
|
EPA
has removed requests for parent company physical address from
Table 1.
|
|
Table
2: Facility General Information
|
|
-0054
|
Row
25 Column B - Facility Type:
It
is possible to have a natural gas transmission compressor
station and an underground natural gas storage facility
operating at the same facility. The pull down only permits the
selection of one type.
Clarify
which option to select if operations are in more than one
segment. Definitions should clearly delineate what should be
reported for each facility where multiple segments may be owned
or operated by an ICR respondent.
The
Facility Types are modeled after GHGRP Subpart W industry
segments. However, related definitions from Subpart W are not
consistently used for ICR.
In
addition to consistency with GHGRP segment names in pull-down
menu, consistent definitions are needed for segments /
facilities. Not doing so creates an additional burden associated
with gathering information using new (or unclear) categories.
|
EPA
has amended Table 2 “Facility Type” to include
“Onshore natural gas transmission compressor station and
underground natural gas storage facility.”
Operators
should refer to the Definitions Tab to determine each facility’s
“Facility Type.”
EPA
has amended “Facility Type” to include “Other”
and will allow operators to specify.
|
-0061
|
‘Facility
Type’: The categories for random sampling were selected by
EPA so that the emissions from different sampling populations
would be similar, and could be used to estimate the emissions for
the entire population. Since EPA cannot be sure that the Surveys
sent to specific operators are correctly classified for each
industry segment, EPA should expect that some responses will not
align with the industry category that was assigned based on the
‘ICR ID’ used for sample selection. For example, EPA
may send a survey to an operator for gas processing, but the
facility may actually be a gathering and boosting compressor
station.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
‘Facility
Type Sub-Category’: Some facilities have unique operations
that will not be representative of other operations of a similar
‘Facility Type’. There should be an optional comment
field that will allow operators to provide information for these
operations, if applicable to the facility.
|
EPA
has amended “Facility Type” to include “Other”
and will allow operators to specify.
|
-0031
|
If
the facility type ‘pipeline’ is indicated in cell
B25, black out non-relevant facility information for pipelines
(Section 2, rows 27-34, 48, 49) in the Facility tab spreadsheet.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Facility
Type is currently a dropdown selection that only allows for one
option. This should be a multiple choice selection. Some
facilities fall into multiple industry segments.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“Are
greenhouse gas (GHG) emissions from this facility reported under
40 CFR part 98 subpart W?”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
27 Column B - Facility GHGRP ID, if applicable:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“Facility
GHGRP ID, if applicable”
|
EPA
has amended Table 2 to allow operators to specify a Facility
GHGRP ID if applicable.
|
-0046
|
“Physical
Address”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Manned
Sites: The pick list options for ‘Is this facility manned
while in operation?’ should be updated to reflect if the
site is consistently manned (24 hours a day, 7 days a week) or
manned for a shorter time period such as during weekly daytime
hours. This will more accurately reflect different operations
across the various industry segments.
|
EPA
has amended “Is this facility manned?” to include
more timing options.
|
-0027,
54
|
Classify
“Is Facility Manned?” as CBI.
|
See
the Comments Response Memo for answers to CBI questions.
|
-0046
|
“Is
this facility manned while in operation?”
It
is not clear whether a ‘manned facility’ requires
employees to be onsite 24 hours/day, 7 days/week, or some other
time frame. Alter the question to ask if operational staff are
on-site 24 hours per day. EPA could also include a dropdown with
different options (i.e. 24/7 or normal business hours).
|
EPA
has amended “Is this facility manned?” to include
more timing options.
|
-0054,
61, 46
|
Include
more detailed information on electrification
|
EPA
has amended “Does the facility have electricity available?”
to include a picklist of options.
|
-0054,
59, 46
|
Row
50 Column A - Year the facility first began operations can be
difficult to find
|
EPA
has removed “Year the facility first began operations”
from the Facility Tab.
|
-0054
|
Row
51 Column A - Number of months the facility operated in 2015
The
number of months the facility operated in 2015 is not pertinent
to the identification of the types and prevalence of emission
controls or emission reduction measures and potential costs for
the measures and controls. Emissions can occur in “operating”
mode or in “standby, not operating” mode. Remove
question.
The
question as stated will require respondents to make subjective
judgments so the responses EPA receives will not be based on
consistent assumptions. For example, a compressor at a station
can be on stand-by (not compressing gas) due to pipeline
conditions and demand. In another scenario, other parts of the
facility such as pig launcher/receiver may operate while the
compressors are on stand-by or shutdown.
There
are many modes (e.g., not operating and depressurized) and
interpretations of “operated.”
What
if a facility operated for only a few hours or days in a
calendar month?
If
field is retained, clarify terms within the question (see
additional notes that follow). For example, regarding equipment
leak emissions, if the facility includes pressurized equipment
(e.g., compressors, piping), then the facility would be
“operational.” Revise header to: Number of months
the facility was ready for/capable of operation in 2015. Clarify
and define “operated.” Clarify and define “month.”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046,
49
|
“Quantity
of natural gas received by the facility in the 2015 calendar year
(thousand standard cubic feet). For production facilities, this
is the quantity extracted from all wells. For storage facilities,
this is the quantity place into storage.”
GPA
Midstream recommends that the word “Estimated” be
added beforehand because not all compressor stations have inlet
meters.
This
is reported in the GHGRP for processing facilities per
98.236(aa)(3)(i) and for storage facilities per
98.236(aa)(5)(i). This is a redundant information request and
should be removed from the ICR for processing facilities that
report under the GHGRP.
Associated
gas that is not sold is most likely directed to a control device
from multiple points in the separation process. Operators do not
meter gas directed to a control device because it is technically
infeasible.
Operators
will often use a gas to oil ratio (GOR) value to calculate total
gas production. Because GOR values change over time as oil
production declines, EPA should not take associated gas
production data as absolute and make unjustified assumptions.
|
Companies
should provide best available data based on existing records when
responding to the ICR.
|
-0046
|
“Quantity
of natural gas leaving the facility (sales) in the 2015 calendar
year (thousand standard cubic feet).”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Gas
Volumes: Depending on the industry segment, both the quantity of
gas received and leaving facility are not useful parameters for
emissions purposes. Only one of these values should be required
to establish the relative size of facility.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
54 Column B - Quantity of all hydrocarbon liquids (crude oil and
condensate, including NGLs) received by the facility in the 2015
calendar year (barrels). For production facilities, this is the
quantity extracted from all wells.
|
EPA
has amended Table 2 to black out information requested for
quantity of hydrocarbon liquids.
|
-0046
|
“Quantity
of all hydrocarbon liquids (crude oil and condensate, including
NGLs) received by the facility in the 2015 calendar year
(barrels). For production facilities, this is the quantity
extracted from all wells.”
This
is reported in the GHGRP for processing facilities per
98.236(aa)(3)(iii). This is a redundant information request and
should be removed from the ICR for processing facilities that
report under the GHGRP.
Natural
gas gathering and boosting facilities typically do not measure
liquids received at a facility; they only measure liquids
exiting the facility. Because of this, operators will only be
able to report the quantity of liquids leaving the facility as
an estimate for the quantity of liquids received by the
facility. This data element should be removed from the ICR for
all gathering and boosting facilities. At the very least, EPA
should add another statement defining the requirement for
non-production sites.
|
Companies
should provide best available data based on existing records when
responding to the ICR.
|
-0054
|
Row
55 Column B - Quantity of all hydrocarbon liquids (crude oil and
condensate, including NGLs) leaving the facility (sales) in the
2015 calendar year (barrels).
|
EPA
has amended Table 2 to black out information requested for
quantity of hydrocarbon liquids for T&S.
|
-0046
|
“Quantity
of all hydrocarbon liquids (crude oil and condensate, including
NGLs) leaving the facility (sales) in the 2015 calendar year
(barrels).”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
56 Column B - Miles of natural gas transmission pipeline
Applicable
to Pipelines only, not applicable to Transmission and Storage
facilities. Cannot assign pipeline miles to individual
facilities. For pipelines, the “facility” boundary
should be clearly identified. Without clarification, respondents
will likely have different interpretations and data quality may
be impacted.
Black
out for T&S.
|
EPA
has amended Table 2 to request “Miles of natural gas
transmission pipeline” from Natural Gas Transmission
Pipeline facilities and Gathering and Boosting facilities only.
|
-0046
|
“Miles
of natural gas transmission pipeline.”
This
is reported in the GHGRP for transmission pipeline facilities per
(aa)(11)(vi). This is a redundant information request and should
be removed from the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0061
|
Add
‘Well Classification’ for Onshore Production: In
order to appropriately classify data for Onshore production, the
GOR categories used for identifying the Part 2 recipients should
be included within the Survey for identification.
|
EPA
agrees with the commenter and is implementing this revision.
|
/-0031
|
For
natural gas pipelines, limit the ‘facility’ to one
state rather than the entire pipeline length. Performing a field
count on all equipment along an entire, multi-state length of
pipe would be costly and resource inefficient.
|
EPA
agrees with the commenter and is implementing this revision.
|
-0068
|
Add
the following questions:
For
production facilities, quantity of produced water (thousand
bbl/year in the 2015 calendar year).
Quantity
of natural gas leaving the facility by
pipeline
(sales) in the 2015 calendar year (thousand standard cubic
feet).
Quantity
of natural gas utilized at the facility in the 2015 calendar
year (thousand standard cubic feet).
Quantity
of natural gas leaving the facility (for sales) other than by
pipeline (e.g., trucked CNG) in the 2015 calendar year (thousand
standard cubic feet).
Quantity
of natural gas vented from the facility in the 2015 calendar
year (thousand standard cubic feet).
Quantity
of natural gas flared from the facility in the 2015 calendar
year (thousand standard cubic feet).
If
transmission compressor station, pipeline mileage from immediate
compressor station upstream
If
transmission compressor station, pipeline mileage from immediate
compressor station downstream
If
transmission compressor station, number of isolation valves
upstream up to immediate compressor station upstream
If
transmission compressor station, number of isolation valves
downstream up to immediate compressor station downstream
If
gathering and boosting facility, number of wells connected to
the station
If
gathering and boosting facility, pipeline mileage to the nearest
distance downstream to the next GB facility, transmission
compressor station, or processing plant
|
EPA
has amended Table 2 to include “For production facilities,
quantity of produced water (thousand bbl/year in the 2015
calendar year)” and “Quantity of natural gas vented
from the facility in the 2015 calendar year (thousand standard
cubic feet).”
|
|
Well
Site Tab
|
|
|
Table
1: Well Site Information
|
|
-0061
|
Distance
from field office should be clarified to specify that the
distance requested should be provided in road miles.
|
EPA
has amended Table 1 to request “Driving distance from field
office (road miles).”
|
-0061
|
Distance
to the nearest natural gas transmission or gathering pipeline is
not an appropriate data element for inclusion in the ICR. This
data element should be limited in scope, as it is not pertinent
to all facilities. The information should only be requested for
oil wells with associated gas that are not connected to a gas
gathering line.
|
EPA
has clarified that this information should only be provided if
well sites are not connected to a gathering and boosting or
transmission pipeline. EPA has also requested reasoning for any
lack of connection.
|
-0061
|
‘How
frequently is well site visited by field office personnel?’
should be updated to ‘How frequently does the well site
receive scheduled, routine visits by field office personnel?’
|
EPA
has amended “How frequently is well site visited by field
office personnel?” to allow a picklist of options to
choose.
|
-0061,
49
|
‘Is
land owned or leased?’ should be removed from the ICR. Land
leased/owned status has no relevance to emissions or cost of
controls.
|
EPA
has amended “Is land owned or leased?” to allow a
picklist of options.
|
-0061
|
Regulations
listed must be updated. Regulations should be limited to those
that may apply to individual wells, since they may not apply
uniformly to all wells on location.
This
list should be updated to ‘State / Local Environmental
Regulations or Permit’.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
requests the average age of wells onsite. There is no emissions
related benefit to EPA with this value. Therefore, it is
recommended that EPA strike the request for this information.
|
EPA
has amended the ProdnWells Tab to request “What is the age
(years) of the well at the well site?” on a per Well ID
basis.
|
-0068
|
Delete
“What is the average age of the wells at the well site?”
from Table 1 and move to Table 2.
|
EPA
appreciates the comment and will implement as suggested.
|
-0061
|
‘How
are produced waters managed?’ should be removed from the
well information. If it is stored onsite, relevant data will be
provided under storage tanks.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
‘Number
of wells at the well site’ can be determined by the number
listed in Table 2. General Well Information. This data element
should be removed from Table 1.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Add
the following questions to Table 1:
Specify
connectivity of wells: gathering pipeline, transmission
pipeline, distribution pipeline, end user, not connected
If
yes, what is the pipeline pressure?
Reservoir/formation
pressure
Who
owns the mineral rights; private, federal, or tribal?
Is
there a combustion device on or near the site?
If
combustion device is on or near site, what type of device is it?
(open flare, enclosed flare, thermal combustor, open pit flare,
other)
If
combustion device is on or near site, is it operational?
If
combustion device is near site, what is the distance of the
nearest flare?
If
combustion device is a flare, does it have a continuous pilot or
electronic ignition device?
If
the combustion device is a flare, does it have a monitor to
ensure a continuous flame?
If
the flare has a monitor to ensure continuous flame, describe the
device used.
Is
the site connected to a grid?
If
not, how far is the nearest grid connection (in miles)?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
2: General Well Information
|
|
-0061,
59
|
The
‘Well Type’ and ‘Date of last produce for
shut-in or abandoned wells’ should be removed because the
survey should only cover active wells. If EPA continues to
collect ‘capped or abandoned wells’ counts in Part 2,
then the instructions should clarify that this count only applies
to facilities that had active production at the end of 2015.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
49, 48, 59
|
Downhole
configurations can be much more complicated than this data
describes and unnecessary to determine emissions. Well bore
depth, length, shut-in pressure, casing diameter, and tubing
diameter are not sufficient to quantify emissions, may not
adequately characterize complex downhole configurations, and
should not be requested.
Information
like well depth and well bore length may not be straightforward
to obtain. Many wells have multilateral designs like tree roots.
Others have capillary strings to enable production from multiple
zones without comingling the oil, natural gas, and water from
each zone. A capillary string well produces to multiple
separators connected to their own tank batteries, with multiple
facilities receiving fluids from that single well. Some of the
requests in this section are only suitable for single well
bores, and can pose problems for other configurations.
For
older producing wells much of the data requested in this section
may be non-existent.
|
EPA
has amended Table 2 to include “Type of Well Bore” to
allow for further clarification on downhole configurations.
|
-0064
|
Acceptable
methods to determine production rates need to be clarified. For
California operations, wells undergo scheduled tests to measure
the volume of oil, produced water, and gas over a short time
period. This data is used to allocate the aggregate volume of oil
metered at the sales point back to the individual well. It is
likely that in most cases, a well test will not be available over
the last 30 days of operation. The EPA should specify how to
complete this entry when there are no meters on the individual
wells.
|
Companies
should provide metered data where available, otherwise use best
available data when responding to the ICR.
EPA
has expanded “Where is produced gas monitored?” to
include an offsite option.
|
-0061,
68
|
‘Where
is gas or oil/condensate monitored?’ should be removed.
|
Companies
should provide metered data where available, otherwise use best
available data when responding to the ICR.
EPA
has expanded “Where is produced gas monitored?” to
include an offsite option.
|
-0061
|
Early
production data (i.e., rates, GOR, and gas composition) is often
not available for new wells. At a minimum, an option for ‘Not
Available’ is needed. If it is available, the month/year of
the data should be reported.
|
Companies
should provide best available data when responding to the ICR.
|
-0061
|
Only
the ‘Most Recent Measurement of Produced Gas Composition’
should be included.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should designate a method based on technical feasibility for
determining GOR after flowback or change the request to indicate
an “estimated” GOR value for periods after the first
30 days of production.
|
Companies
should provide best available data when responding to the ICR.
|
-0064,
48
|
The
Part 2 “Well Sites” section requires three different
GOR and produced gas composition values for each well. Some
explanation should be provided to clarify how this value should
be determined. It is unlikely that this data will be readily
available for each well.
|
Companies
should provide best available data when responding to the ICR.
|
-0068
|
The
composition of gas typically does not change drastically within a
year, therefore asking for current gas composition is
unwarranted. Remove the following from Table 2:
Current
Produced Gas Composition - CO2 (% by vol)
Current
Produced Gas Composition - CH4 (% by vol)
Current
Produced Gas Composition - C2H6 (% by vol)
Current
Produced Gas Composition - VOC (% by vol)
Current
Gas to Oil Ratio
|
EPA
has amended Table 2 to request “Produced Gas Composition in
first 30 days production” and “Produced Gas
Composition in calendar year 2015 or last year of operation.”
|
-0049
|
EPA
ask first if an extended gas analysis has been performed from a
particular well and if so, then an operator can provide that
analysis.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should remove the request to produce ethane % by volume from the
ICR. Ethane is not considered a VOC.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Table
2: Remove reference to “Oil” from “Oil
Producing Wells Only - API gravity of produced oil.”
Replace with “liquids”.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
In
Table 2. General Well Information, a column should be added,
‘Reason for gas venting or flaring’. If an oil well
identities that ‘Disposition of casing head gas’ is
vented to atmosphere or vented to flare, then operators should
identify a reason for why gas is not sold. The pick list should
be limited to the following options:
No
permit for pipeline to tie well to system
Insufficient
gas quantity/pressure
Poor
gas quality/Does not meet specifications
No
contract in place
Right-of-way
acquisition
Transmission
line approval
Transmission
line construction
Exploration
Well
Pipeline
and/or plant capacity constraints
Other,
specify
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Add
the following questions to Table 2:
Age
of the well (years)
Is
gas metered on or off of the well site?
Is
oil metered on or off of the well site?
Average
Produced Gas Composition in first 30 days production - CO2 (% by
vol)
Average
Produced Gas Composition in first 30 days production - CH4 (% by
vol)
Average
Produced Gas Composition in first 30 days production - C2H6 (%
by vol)
Average
Produced Gas Composition in first 30 days production - VOC (% by
vol)
Average
Produced Gas Composition in first 30 days production – HAP
(% by vol)
Average
Produced Gas Composition in first 30 days production - Inerts (%
by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation - CO2 (% by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation – H2S (% by vol)
Annual
average wellhead pressure during first year of production (psig)
Annual
average wellhead pressure in the last year of production (psig)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation - CH4 (% by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation - C2H6 (% by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation - VOC (% by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation – HAP (% by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation - Inerts (% by vol)
Average
Produced Gas Composition in calendar year 2015 or last year of
operation – H2S (% by vol)
|
EPA
has amended Table 2 to include “Well pressure in first 30
days production (psig)” and has expanded gas compositions.
|
|
Table
3: Well Completion and Workover Information
|
|
-0061,
49, 59
|
Table
3 will provide limited or redundant information and should be
removed from the Part 2 Survey.
The
information on well completions for hydraulically fractured and
refractured wells is already covered under NSPS OOOOa;
therefore, this request for information is redundant.
Workovers
are typically intended for maintenance of downhole equipment.
There is typically no venting associated with workovers since
the well cannot be active for safety purposes during maintenance
and the data requested may not be readily available.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049,
48, 59
|
Well
completion data requested could likely be obtained through the
appropriate state records.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0050,
49, 48, 59, 61
|
EPA
should remove “date of next workover” from ICR, as it
requires operators to predict reservoir conditions, market
conditions, availability of equipment, availability of capital,
etc.
|
EPA
has removed “Anticipated date of next workover.”
|
-0068
|
Add
the following questions to Table 3:
Average
duration of completion (hours)
Number
of workovers in last 5 years
Average
duration of workover (hours)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
4: Well Testing, Venting, and Liquids Unloading Information
|
-0061,
59, 68
|
At
a minimum, EPA should delete ‘/venting’ from the
column title ‘Date of last well testing/venting’.
This will help eliminate confusion between well capacity testing
and ‘liquids unloading’, which is covered in other
columns of Table 4. Well testing does not directly equate to
venting.
|
EPA
has removed “/venting” from the title of Table 4.
|
-0068
|
Table
4 “Controls used for well testing”:
Change
question to “Controls used for last
well testing”
It
is unclear what the difference between “Vent to other
control” and “Capture for recovery/sales” is,
suggest only keeping the latter; also add “Capture and
recovery/use at site”
|
EPA
has amended Table 4 to request “Controls used for last well
testing.”
|
-0061
|
Include
‘Other’ in the pick list for ‘Controls used for
well testing’. While EPA has included the obvious choices
in the pick list for Column E, the variety of operations in the
oil and gas industry makes it likely that a different control
option exists.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
59
|
The
information included in the draft ICR on liquids unloading will
not provide EPA with adequate information to estimate methane
emissions. Well engineers and operators must have the flexibility
to employ the appropriate tools at the appropriate times to
manage wellbore liquids. If the information remains in the Part 2
Survey, numerous changes are required:
The
current format implies that liquids unloading occurs for every
well, which is not the case.
‘Primary
technique used for liquids unloading?’ should not include
‘Artificial lift’ and ‘Swabbing well’ in
the pick list.
The
list of ‘Primary technique for liquids unloading’
should be expanded. Techniques that should be added to the
picklist include ‘Surfactants and foaming agents’,
‘Installing wellhead compression’, and
‘Combination/Other’.
EPA’s
pick list for ‘Controls for venting of liquids unloading’
incorrectly characterizes unloading operations. EPA should add
‘Attended venting only’ as a control option for
venting.
The
parameters ‘Year Installed (for plunger lift, velocity
tubing, or other assist method)’, ‘Total Capital
Installed Cost ($)’, and ‘Annual Operating and
Maintenance Costs ($/yr in 2015)’ currently require cost
data for systems other than controls for manual venting.
Furthermore, depending on the age of the system, much of this
information will probably not be available or feasible to track
down in the time allotted to answer the survey. An option needs
to be provided for ‘Not available.’
|
EPA
has amended Table 4 to add “Surfactants and foaming agents”
to the picklist for “Primary technique used for gas well
liquids unloading?”
|
-0068
|
Table
4 “Primary technique used for liquids unloading?”:
More
options need to be added: foaming agents, manual plunger lift,
automated (timed) plunger lift, and plunger lift with smart
automation
|
EPA
appreciates the comment and will implement as suggested.
|
-0068
|
Table
4 " Controls used for well venting for liquids unloading”:
|
EPA
appreciates the comment and will implement as suggested.
|
-0068
|
Add
the following questions to Table 4:
Is
the well vented or flared during testing? (vented or flared)
What
is the purpose for venting or flaring during testing, as opposed
to routing to a sales line or gathering system?
Annual
number of tests
Average
time taken for unloading (hours)
If
uncontrolled, reason for no control in place
If
uncontrolled, do personnel always remain on site during venting
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0061
|
EPA
should add instructions stating that ‘Not Applicable’
should be listed if periodic testing is not required or if
historical data does not exist for older and acquired wells.
|
Companies
should provide best available data when responding to the ICR.
|
-0064
|
The
Part 1 and Part 2 spreadsheets envisions a maximum of
approximately 20 wells at a facility. As established above, a
facility can consists of hundreds or thousands of wells. If a
facility has more than the 20 wells associated with a facility,
will the Part 1 and Part 2 spreadsheets be unprotected?
|
EPA
has amended Table 2 to allow for 50 wells. If additional
rows/columns are required, facilities should contact EPA to
request a larger/additional spreadsheet.
|
-0064
|
The
ICR appears to include several sources that do not contribute to
greenhouse gas emissions nor useful in determining potential
control strategies. The EPA needs to explain why data is needed
on every permanently sealed/abandoned production well. The term
“permanently sealed” demonstrates that these wells
are not sources of greenhouse gases.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
Companies
inject steam and water to enhance the oil recovery process by
maintaining the reservoir. The EPA should exempt water and steam
injection wells from reporting as there are no methane emissions
in these streams.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Should
EPA choose to add storage well requirements to the “Well
Sites” worksheet, then stakeholders should be allowed an
additional opportunity to comment.
|
EPA
has added the Injection-Storage Wells Tab to account for storage
operations.
|
|
Tanks
Separators Tab
|
|
|
Table
1: Facility Information
|
|
-0061,
54
|
The
‘Number of Separators at the Facility’ should be
removed from Table 1 Facility Information for Tanks and
Separators.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Both
the ‘Number of Atmospheric Storage Tanks <10 bbl/day at
the facility’ and ‘Number of Atmospheric Storage
Tanks ≥10 bbl/day’ should be removed. Average
hydrocarbon throughput or water throughput are already included
in Table 2. General Tank / Separator Information, so these data
parameters are redundant.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
1. Facility Information
For
number of atmospheric storage tanks with throughput greater than
10bbl/day, EPA should clarify the requirement. 40 CFR part 98
Subpart W is based on 10 bbl/day through a separator, and it is
not clear if EPA’s intention is that this should be the
same requirement. In any case, this is a repeat of information
collected in Sub-Section 2. One of the two requests should be
deleted as superfluous.
Define
‘water’ throughput. It is unclear if produced water
falls under “hydrocarbon” or “water”
throughput category.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
2: General Tank/Separator Information
|
|
-0046
|
Revise
“Tank/Separator ID” to read “Tank ID.”
Also, the cell appears to be set to ‘number’ in Excel
and should be set to ‘text.’ This will avoid issues
with leading/trailing zeros.
|
EPA
appreciates the comment and will implement as suggested.
|
-0054
|
Row
7 Column A - 2. General Tank / Separator Information - Complete
for each Tank / Separator:
If
separators are included, Table 2 should only apply to ≥ 10
bbl/day.
Black
out for T&S. Include a trigger in the row for Separators ≥
10 bbl/day to provide information in Table 2.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day. However, for transmission and storage
facilities that do not have separators that have 10 bbl/day
liquids, EPA is requesting that parent companies sample one
separator.
|
-0061
|
The
scope of Table 2. General Tank / Separator Information should be
limited to atmospheric storage tanks. These suggested changes to
Table 2. General Tank / Separator Information limit the scope to
collect information on crude oil, condensate or produced water
atmospheric storage tanks only, where the bulk of gas emissions
occur:
Pressurized
separators should be removed by modifying the heading for the
first column to ‘Atmospheric tank/separator IDs’.
Pressurized separators have no atmospheric emissions except for
fugitives, so the data has no practical use in this survey.
‘Vessel
types’ should be limited to fixed roof atmospheric storage
vessels or floating roof atmospheric storage vessels.
Is
there continuous monitor for Vessel Operating Pressure’
should be eliminated from Table 2 General Tank / Separator
Information. Only atmospheric storage vessels should be
considered within scope of the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Multiple
tank IDs should be entered into a single row, when a single feed
stream is stored in multiple tanks.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
For
the column “Vessel Type,” one of the drop down
selections is “Heater/treater.” However, the defined
term is “Heater treater.” One of these should be
changed to align with the other.
“Vessel
Type” options are confusing. For example, a heater treater
is a gas-liquid separator with heat, but “heater treater”
and “gas-liquid separator” are both options. EPA
should eliminate one of these options.
EPA
lists two options for “ambient storage tank.” This
term is not defined and is confusing. All storage tanks are
ambient tanks, as tanks are not heated, and pressurized tanks
are excluded from this portion of the survey. These two
categories should be deleted as they have no relevance, and they
are redundant of other categories (i.e. Condensate storage tank
and fixed roof storage tank).
|
“Heater/treater”
has been corrected to “heater treater”.
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
Ambient
storage tanks have been corrected to say “atmospheric
tanks.”
|
-0061
|
The
regulatory column header should specify that the list of
regulations apply to the tank only and New Source Review Permits
should be added as a separate option for selection.
|
The
regulations that apply have been adjusted.
|
-0054
|
Row
8-58 Column C - List current environmental regulations to which
the well site must comply.
Select
all that apply.
This
should be consolidated in the facility tab and answered once for
the facility.
Move
to Facility tab. Change “well site” within column
title to “facility” or appropriate term. Include 40
CFR 98 in the list of regulations.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
2. General Tank/Separator Information – Complete for each
Tank/Separator
“List
current environmental regulations to which the well site must
comply”
|
“Other”
has been added to the spreadsheet.
|
-0061,
54
|
‘Vessel
height (ft)’ and ‘Vessel Diameter (ft)’should
be removed..
|
Vessel
height and vessel diameter have been removed and vessel capacity
has been added.
|
-0054
|
Row
8 Column F and G - Average vessel hydrocarbon (F) or water (G)
throughput (bbl/day)
For
all or most facilities, hydrocarbon throughput is only available
for the atmospheric storage tanks not for each separator
vessel/filter separator.
Black
out for T&S. If included, establish a hydrocarbon threshold.
Throughput volume available for T&S would include
hydrocarbons and water (if any).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
information on ‘Continuous Monitoring’ is not related
to emissions and should be removed in its entirety. Typically,
there is no measurement occurring to or from a storage vessel at
production facilities.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“Is
there a continuous monitor for the following:”
Cells
K7, L7, and M7 should be merged with cell H7:J7 to clarify that
H8 through M8 are all under the section “Is there a
continuous gas monitor for the following.”
“Is
there a continuous monitor for the following: Gaseous flow rate
to the vessel?” It would be extremely unlikely to have a
gaseous flow meter to liquid storage tanks.
“Is
there a continuous monitor for the following: Liquid feed flow
rate to the vessel?” Continuous monitors like these are
very rare, but to the extent they exist, GPA Midstream does not
see how this information will be helpful for rulemaking.
“Is
there a continuous monitor for the following: Liquid flow rate
from the vessel” –there should be a note saying that
if vessel type is a tank, then this question is not applicable,
because liquids removed from the tank during intermittent
liquids unloading would not count as continuously monitored.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Add
“Total days of operation” to Table 2.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
3: Feed Material Characteristics
|
|
-0061
|
‘Type
of feed material’ should be restricted to atmospheric
storage tanks accumulating crude oil, condensate, intermediate
hydrocarbon liquids, or produced water only.
|
EPA
appreciates the comment but we desire to collect information on
separators in this section to better understand flashing
measurements in Table 4. We have limited the dropdown options to
eliminate storage tanks that are not included in the ICR (amine,
glycol or fuel storage tanks).
|
-0046
|
Sub-Section
3. Feed Material Characteristics – Complete for each
Tank/Separator
“Tank/Separator
ID”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Column
A is auto-filled from Table 2; therefore, EPA should delete
‘/separator ID’ in the heading to match the Table 2
heading.
|
EPA
instead revised Table 2 heading to be “Tank/Separator ID”
so the column headings match between tables.
|
-0054
|
Row
77-86 Column A-B - Separator ID/Tank ID
Unique
IDs may not be available for each tank separator, meaning that
respondents would likely make up IDs solely for the purpose of
responding to this item.
Remove
question. If applicable to T&S, correct pull down links for
IDs.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
61 Column B - Type of feed material
Condensate
and natural gas streams may contain trace amounts of water and
“definitions” for pull down menu are not clear. The
pull down menu does not include all of the possible options for
stream types.
Black
out for T&S. If included, EPA must clarify how to
characterize tank/separator streams and select from menu;
definitions, guidance, and instructions are needed and
additional stream options may be needed.
|
Other
(specify) is included.
|
-0061
|
‘Reid
vapor pressure of feed material (psig)’ is not useful for
unstabilized hydrocarbon streams and should be removed from Table
3. Feed Material Characteristics.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
EPA
should clarify that the desired temperature and pressure should
be at the separator. Separator temperature and pressure at the
time any pressurized sample is taken is critical for running a
process simulation to calculate flash emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
3. Feed Material Characteristics – Complete for each
Tank/Separator
“Pressure
of feed material (psig) and Temperature of feed material (°F)”
|
EPA
appreciates the comment and will implement as suggested.
|
-0061
|
Specific
gravity of the pressurized sample per ‘Specific Gravity of
feed material (relative to water at 4 C)’ has no practical
meaning and should be removed from Table 3. Feed Material
Characteristics.
|
EPA
appreciates the comment and will implement as suggested.
|
-0061
|
The
average temperature and pressure are assumed to be of the
atmospheric storage tank. This should be clarified and the
atmospheric storage tank pressure should be in inches of water
column.
|
EPA
appreciates the comment and will implement as suggested.
|
-0046
|
Sub-Section
3. Feed Material Characteristics – Complete for each
Tank/Separator
“Average
temperature of liquids in vessel (°F)”
|
EPA
appreciates the comment and will implement as suggested.
|
-0046
|
Sub-Section
3. Feed Material Characteristics – Complete for each
Tank/Separator
“Average
operating pressure of vessel (psi)”
EPA
needs to specify either “psia” or “psig”.
GPA Midstream suggests “psig” to be consistent with
other data items.
If
EPA makes the decision to limit this data collection form to
tanks only, this should be eliminated as EPA not collecting
information from pressurized storage tanks.
|
EPA
appreciates the comment and will implement as suggested.
|
|
Table
4: Feed Material Composition
|
|
-0046
|
Sub-Section
4. Feed Material Composition
|
EPA
appreciates the comment and will implement as suggested.
|
-0046
|
In
midstream gathering operations, not all separators feed directly
to storage tanks, so this table could result in correct or
misleading information.
|
EPA
appreciates the comment and will implement as suggested.
|
-0061
|
EPA
should change the table name of Table 4. Feed Material
Composition to Table 4. Feed Material Flash Gas Properties to be
consistent with the data they are interested in collecting.
Unless the operator is familiar with the CARB Method, the current
title (Feed Material Composition) will lead to reporting of the
composition of the pressurized liquid instead of the flash gas
properties.
|
EPA
appreciates the comment and will implement as suggested.
|
-0061
|
The
current instructions for Table 4. Feed Material Composition does
not provide the flexibility needed to determine flash emissions
for the variety of domestic oil and gas operations that exist
nationwide.
Recommendation:
“Complete
the following table with flash gas emission data for each feed
material sent to an atmospheric tank using pressurized sample
collection from each separator and flash emission analysis
(either laboratory measurement or process simulation). The
California Environmental Protection Agency Air Resources Board's
Test Procedure for Determining Annual Flash Emission Rate of
Methane from Crude Oil, Condensate, and Produced Water1 (CARB
Method) or other peer reviewed, consensus method is acceptable.
If you have performed testing of the feed material composition
within the last 5 years, complete the following table based on
the test results in-hand. The results of a representative sample
may be reported for a feed material if the separator pressures
are within 50 psig or 10%, whichever is greater, and the
operator has knowledge supporting the similarity of the feed
materials. If you have not performed testing of the feed
material composition or have a representative feed material
analysis, you must sample and analyze the pressurized separator
fluid (storage vessel feed material) and report the results of
the test in the following table.”
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day.
|
-0061
|
Samples
should only be required from separators that directly feed
atmospheric storage vessels and that have a significant pressure
drop between the separator and storage vessel.
The
CARB method is only applicable to the first separator that dumps
into an atmospheric tank. Table 4 instructions should be amended
as revised below to eliminate atmospheric storage tank feed
samples that do not have a significant pressure drop from
separator pressure.
Tank
feed streams with very low pressure separators should be exempt
from sampling requirements. Many operators have installed two
stage separation, with the separator feeding the atmospheric
storage tank having very low operating pressure (i.e., <15
psig) and the vapors from that separator recovered to sales gas.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Eliminate
‘Separator ID’ from the column heading of Table 4.
Feed Material Composition. As discussed above, separator
information should not be collected. Thus, the separator ID has
no utility.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Add
a ‘Flash Emission Determination Method’ column to
Table 4. Feed Material Composition. The pick list options should
be:
The
CARB Method
Other
Peer reviewed, consensus method
Pressurized
liquid compositions and process simulation
Combined
natural gas and crude oil/condensate production volume and
composition data, using process simulation
Representative
sample
Direct
measurement (See Table 6 Direct Emissions Measurements for
results)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Label
the compositions in addition to the individual components in
Table 4. Feed Material Composition.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
VOC column should be eliminated from Table 4. Feed Material
Composition.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
GLR column should be labeled ‘Gas Liquid Ratio of Flashed
Pressurized Sample’ in Table 4. Feed Material Composition.
|
EPA
appreciates the comment and will implement as suggested.
|
-0066
|
EPA
should also collect composition information via direct analysis
of the feed material in the liquid phase that is stored,
processed or passed through tanks and separators for all HAPs,
including VOCs and SVOCs.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
CARB
Method/Feed Composition Sampling Method
|
|
-0061,
49, -54, 48
|
The
Draft CARB Method is an appropriate method of determining flash
emissions in heavy oil service, but it is not applicable in all
situations and concerns still exist.
The
draft CARB Method is not expected to be finalized until 2017 and
has not had adequate peer review to be valid for a broad range
of separator pressures and feed compositions.
It
has been applied primarily for produced heavy oil sampled at low
pressure separators.
Determining
whether the pressurized sample was representative is not
possible from the flash analysis alone.
Only
four laboratories have been located that are familiar with the
CARB Method, and only three laboratories in California currently
perform the CARB Method. Specifying the use of only this method
will limit the amount of data that can be collected in the very
short time frame proposed.
Discussion
with laboratory representatives have identified that the CARB
Method is not appropriate for areas such as the Uintah Basin and
the Denver-Julesburg Basin.
There
may be issues associated with analytical lab support because the
CARB method is not broadly practiced.
This
method is undergoing review and comment during an ongoing
rulemaking.
The
CARB method is not well-established nationally nor has it been
validated.
Many
analytical labs are not familiar with this method.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0061
|
Obtaining
a representative sample for the CARB Method is often difficult,
as indicated by using process simulation based on the composition
of the pressurized liquid sample as a check.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0054,
49, 61
|
Analytical
lab resources may be strained to complete analysis of thousands
of samples during the limited time available with a 120-day
schedule. This issue is compounded if analysis is limited to the
CARB method. Additional time should be allowed to complete feed
material sampling and flash analysis. EPA should extend the
response time to at least 180 days to respond to both parts of
the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0027,
50, 58, 49, 59
|
High
cost of performing CARB tests.
Install
ports = $5,000/separator
Sample
cost = $3,700 – $8,700/sample
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
EPA
should reduce the scope of sampling due to the significant cost
of gathering these data. The pressurized liquid sampling should
be limited to sufficient number of facilities that would provide
a representative composition analysis for a particular basin.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day.
|
-0061,
54, 48
|
EPA
should allow any peer reviewed, consensus method. Laboratory
methods should not be limited to those referenced by the CARB
Method.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0050,
49, 46
|
EPA
should allow industry to calculate storage tank flash gas by
using Gas Processors Association 2186M methodology, or any other
methodology advanced by the GPA, as these methods are standard
within the industry.
|
EPA
is limiting flexibility of the extended analysis. The acceptable
GPA methods are listed in CARB. See the Comments Response Memo
for more information.
|
-0061
|
Operators
should be allowed to use the results of process simulations for
gas composition, GLR and MW.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0061
|
EPA
should allow operators to use an alternate approach in lieu of
pressurized samples for hydrocarbon liquids. Some existing
systems cannot obtain a representative, pressurized sample with
existing equipment (i.e., very high pressures [>600 psig]
and/or inadequate ports to access liquid).
Operators
should be allowed to use alternative approaches to pressurized
samples when completing Table 4. Feed Material Composition for
produced water tanks. Produced water tanks have very low
emissions of methane due to the low solubility of methane in
water. As such, the pressurized liquid sampling and flash gas
analytical methods (i.e., draft CARB Method and peer-reviewed
consensus methods) are not designed to address pressurized
produced water samples.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day. However, for transmission and storage
facilities that do not have separators that have 10 bbl/day
liquids output need to complete the separator sampling for one of
their separators on site. See the Comments Response Memo for more
information.
|
-0061
|
Atmospheric
storage vessels that have similar feed material compositions and
separator pressures as other atmospheric storage vessels should
be able to reference similar feed stream results within the same
field as being representative.
EPA
should allow a single sample to represent the feed material to
multiple tanks, as long as the separator pressures are within 50
psig or 10%, whichever is greater, of each other and operators
have knowledge supporting that the feed materials are similar.
The
ability to report results of representative analyses would be
invaluable to the operator and the Agency in the instance that a
sample shows indications that it is not representative during
either laboratory analysis or process simulation quality checks
(see below for further information). Reporting representative
sample results from another location would be more accurate than
reporting sample results that are suspect.
EPA
should clarify that sites are not required to install a
temporary separator for the sole purpose of collecting a
pressurized liquid sample.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0054
|
Multiple,
similar streams may be present at a T&S facility because
there is little variability in the streams at these facilities as
all streams are associated with pipeline quality natural gas.
Therefore, EPA should allow the use of a single analysis of feed
material for the facility.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day. However, for transmission and storage
facilities that do not have separators that have 10 bbl/day
liquids output need to complete the separator sampling for any
one of their separators on site. See the Comments Response Memo
for more information.
|
-0027
|
EPA
should only require sampling and analysis at the final separator
leading into a tank, which should be representative for all
separators before it.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0027,
58
|
ICR
should only require sampling from a subset of separators at 25%
of the facilities targeted. (Attachment 2F question 4 regarding
Feed Material Composition)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0050
|
Remove
collection of pressurized samples of liquid streams to perform
flash analysis request completely from ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0050
|
EPA
should allow operators to provide a representative sample from a
nearby well in the case of inability to sample at a given well
(i.e. well is shut in and awaiting workover, maintenance issues,
low liquid production volumes, etc.).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0058
|
Eliminate
the requirement to sample tanks located downstream of initial
separators associated with natural gas production.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0058
|
Eliminate
the requirement to sample tanks that are not already equipped to
be sampled.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action. See the Comments
Response Memo for more information.
|
-0066
|
The
analysis of the flash gas should be expanded to include all VOCs.
|
The
extended analysis is already required.
|
-0054
|
EPA
should allow the use of available information from previous
sampling. For example, a facility may have been required to
conduct an analysis for a state or permitting requirement. If a
T&S facility has such an analysis, it should be able to use
it because gas composition at T&S facilities does not
significantly change over time.
|
EPA
agrees that if the CARB method was completed within the last 12
months, then those results may be submitted.
|
-0049
|
Based
on industry experience, many upstream samples tested with this
CARB test will come back with 0 or null results due to inadequate
pressure. In order to address this issue, the CARB testing
methodology is currently being updated but will not be available
by the time respondents begin work on the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
CARB
sampling poses logistical challenges, as shipments are classified
as hazardous material and require sample containers to be filled
to 90% of capacity when many of these containers are designed to
be filled to 80% capacity.
|
With
the new version of the CARB method, 80% capacity is allowed.
|
|
Table
5: Leakage, Controls and Inspection
|
|
-0046
|
Sub-Section
5. Leakage, Controls and Inspection – Complete for each
Tank/Separator
“Disposition
of natural gas (or other off-gas)”
Unassisted
candlestick flare
Air-assisted
candlestick flare
Steam-assisted
candlestick flare
Enclosed
flare/combustor
Thermal
oxidizer/incinerator
Fuel
/ firebox
Recovered
to facility inlet/process - Include place to indicate vapor
recovery downtime/maintenance percentage
Captured
for sales
Other
control (specific) - Include a place to write in the other
control device/process
|
EPA
has added Control Device ID.
|
-0046
|
Sub-Section
5. Leakage, Controls and Inspection – Complete for each
Tank/Separator
“Thief
hatch inspection frequency”
EPA
should explain whether simple visual checks are considered an
inspection, or whether the term is referring to a full
inspection of gasket conditions, operation, etc.
|
EPA
appreciates the comment and will implement as suggested.
|
-0061
|
‘Pressure
release setting for thief hatch or other pressure relief device,
as applicable (psig)’ in Table 5.
Leakage,
Controls, and Inspection should be removed from the table. The
pressure relief setting of the thief hatch or relief valve is
typically higher than the operating pressure provided in Table
3. Feed Material Characteristics for ‘Average operating
pressure of vessel (psig)’. Since the operating pressure
is already provided, the pressure release setting is not needed
and has no utility in quantifying emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
5. Leakage, Controls and Inspection – Complete for each
Tank/Separator
“Pressure
release setting for thief hatch or other pressure relief device,
as applicable (psig)”
A
tank may have multiple pressure relief devices including a thief
hatch and each device may have different pressure relief set
points. EPA does not request information on the types of
pressure relief devices, and EPA does not request information on
the disposition of emissions from pressure relief devices. EPA
appears to be concerned about emissions from overpressure events
(stuck dump valves), however, the EPA also does not ask about
inspection of pressure of relief devices after an overpressure
event.
|
EPA
has separated to ask thief hatch and PRD separately.
|
-0046,
54
|
Sub-Section
5. Leakage, Controls and Inspection – Complete for each
Tank/Separator
“Hours
dump valve stuck in 2015”
This
data is not tracked and is not available for many facilities.
If
EPA decides to require this information, a “Not Available”
option should be allowed.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0067
|
EPA
should amend Table 5 2F by adding the
following
instructions and questions:
a.
A vapor recovery unit,
b.
An internal thermal combustor,
c.
A flare,
d.
Venting to the atmosphere (i.e., without combustion or recovery),
e.
Other (please describe).
|
EPA
has added Control Device ID.
|
-0067
|
Add
the following questions to Table 5 2F:
1.
What is the pressure of the liquid in the final vessel before it
reaches the storage tank?
2.
What is the diameter of the piping that conveys material from the
separator(s) to the storage tank(s)?
3.
What is the diameter of the piping that conveys material from the
storage tank(s) to a control device?
4.
Is the piping sized sufficiently to prevent back pressure during
peak flow emissions? (Back pressure may cause gases to flow out
relief valves or the
thief
hatch to the atmosphere)
5.
What measures have been taken to ensure that dump valves do not
stick open leaving natural gas or other off gases to overwhelm
the emission control devices?
6.
Please select any of the following options regarding maintenance
plans for relief valves on storage vessels equipped with emission
control equipment.
7.
What is the set point for each pressure relief valve?
8.
What is the set point for each thief hatch?
9.
Please identify the gasket material for each thief hatch? Please
describe any criteria considered in selecting the gasket
material.
10.
Is there a procedure in place that ensures that thief hatches are
closed after unloading liquids or gauging occurs? If yes, please
provide a description of the procedure.
11.
What kinds of alarms exist to let operators know that the thief
hatch is open?
12.
Please provide the name of the manufacturer and the installed
cost of the alarming device.
13.
How many times was the alarm triggered in 2015?
14.
If the alarm was installed after January 1, 2015, please provide
the installation date and number of times the alarm was triggered
since installation.
|
EPA
has added some of these questions, some are already being asked,
and the rest the EPA has considered and evaluated the impacts of
this comments and has decided not to pursue any further action.
|
-0068
|
Add
the following questions to Table 5:
Number
of times pressure relief valves are tested per year for their
proper pressure release settings
Hours
of improper release via PRV or thief hatch (due to failure to
reseat, failure to close thief hatch, misaligned gasket, etc.)
in 2015
Number
of instances of improper release via PRV or thief hatch (due to
failure to reseat, failure to close thief hatch, misaligned
gasket, etc.) the 2015 calendar year (count)
Number
of instances of stuck dump valves in the 2015 calendar year
(count)
Type
of control measure in place; vapor recovery compressor, eVRU,
ejector, enclosed combustor, open flare, other?
If
other, list the type of other control
If
vapor recovery compressor, list the type of compressor;
reciprocating, centrifugal, scroll, screw, vane, other?
Capacity
of recovery/ control option (Mscf/day)
Maximum
liquid production per day at the well site in the 2015 calendar
year
Minimum
liquid production per day at the well site in the 2015 calendar
year
Operating
hours of recovery/ control option (Mscf/day)
Does
the tank use blanket gas?
If
blanket gas is used, what type?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
EPA
is asking for the number of releases via PRV or thief hatch.
Questions
on dump valves similar to thief hatches and PRDs have been added.
Types
of control measures in place are in compressor and controls tab.
|
|
Table
6: Direct Emission Measurements
|
|
-0046
|
EPA
should expand the instructions or add a column (measurement
date/year) to address tanks that were measured multiple times
over the last 5 years.
|
EPA
appreciates the comment and will implement as suggested.
|
-0046
|
Sub-Section
6. Direct Emission Measurements – Complete for each
Tank/Separator, as applicable, for which emissions measurements
data are available
“Source
Description”
|
Source
description means where emissions are being measured.
|
-0068
|
Add
the following to Table 6:
Flashing,
working, and standing emissions
Dump
valve emissions
Flashing,
working, and standing emissions measurement equipment
Dump
valve emissions measurement equipment
Date
of measurement (month and year)
|
Table
6 has been unconnected. Multiple tests per tank are allowed now.
Date of measurement and speciation has also been added.
|
|
Other/General
|
|
-0061
|
Operators
should be exempted from completing Table 4. Feed Material
Composition if Table 6. Direct Emission Measurement is completed.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Operators
should be exempted from completing Table 4. Feed Material
Composition if pressurized liquid sample and analysis was done
within the past 5 years, consistent with the direct measurement
allowance.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0031
|
Explicitly
list as exempt from the ICR survey tanks that store the following
materials: unused triethylene glycol, lube oil, used lube oil,
wastewater with negligible hydrocarbon content (e.g. floor
cleanup wastewater), odorant, and diesel and gasoline for
facility use. Also, exempt tanks with capacity <500 gallons
from the ICR. These tanks have negligible GHG and VOC emissions.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day. However, for transmission and storage
facilities that do not have separators that have 10 bbl/day
liquids output need to complete the separator sampling for any
one of their separators on site.
|
-0058
|
EPA
needs to clarify what types of facilities would be expected to
respond to Tanks/Separators Sheet worksheet 2F (appears to call
for information about tanks and separators at production well
sites only). This worksheet should be limited to upstream tanks
in production operations. In transmission and storage facilities
downstream of gas processing, natural gas is pipeline quality,
the potential emissions from tanks with separators are
insignificant, and sampling is not warranted. (worksheet 2F
(“Tanks Separators”) question 4 (rows 73 – 75))
|
Tanks
sheet is applicable to all sites with storage tanks. EPA has
reduced the scope of sampling for separators with liquids output
below 10 bbl/day. Transmission and storage facilities that do not
have separators that have 10 bbl/day liquids output need to
complete the separator sampling for any one of their separators
on site.
|
-0066
|
EPA
should collect specific information on the disposition of all
liquids (injected and recovered) and/or wastewater and the volume
sent to open-air impoundments, percolation pits, and surface
discharged.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064,
46
|
The
facilities extending over large contiguous properties will have
more than 10 tanks/separators. The number of tanks/separators
will likely exceed 100. Will these sections be unprotected for
additional entries?
|
More
rows have been provided.
|
-0054
|
Separator
and atmospheric tank flashing emissions are trivial in the T&S
segment because the natural gas has already been processed.
Therefore, the tank reporting form should not be required for
T&S. If required, the Part 2 “Tanks Separators”
form should be modified for T&S.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
The
source of emissions in T&S tanks are from a malfunctioning
scrubber dump valve and not working / breathing /flashing losses
(consistent with Subpart W). Subpart W data to date confirms this
is an insignificant emissions source. In addition, questions may
be appropriate for tanks and not separators (or vice versa), but
delineation is not provided. Black out for T&S.
If
retained for T&S, add clarification regarding applicability
of questions for tanks, separators, or both. Or, provide separate
fields or separate forms for tanks and separators.
|
EPA
has adjusted the spreadsheets as appropriate.
|
-0054
|
Compressor
stations may include small separators that are used to protect
equipment (e.g., compressor drivers) from small amounts of
liquids that may accumulate along a pipeline, and those small
separators should be excluded. In this case, detailed
information, including flash analysis sampling, would not be
required for T&S tanks. If a request for more detailed
information (including sampling) is retained, EPA should
establish a throughput threshold.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day. Transmission and storage facilities that
do not have separators that have 10 bbl/day liquids output need
to complete the separator sampling for any one of their
separators on site.
|
-0054
|
EPA
should only require equipment details, feed material sampling and
flash analysis if the separator or tank throughput is greater
than or equal to 10 barrels per day.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day.Transmission and storage facilities that
do not have separators that have 10 bbl/day liquids output need
to complete the separator sampling for any one of their
separators on site
|
-0046
|
Request
only information regarding those tanks and vessels meeting the
current description found on the definitions tab.
|
EPA
has reduced the scope of sampling for separators with liquids
output below 10 bbl/day. Transmission and storage facilities that
do not have separators that have 10 bbl/day liquids output need
to complete the separator sampling for any one of their
separators on site
|
-0046
|
In
midstream, separators are always flow through process vessels
where the overhead gas is contained within the process. Midstream
operators are focused on moving the customer’s gas to
market. GPA Midstream member companies would never have a
separator designed to route gas to the atmosphere or to a control
device. Gathering and boosting facilities typically have a
facility inlet separator (or two) (also called the inlet receiver
or slug catcher) which receives all the gas the facility will
process. Any liquids that accumulate in the vessel are sent to a
tank or a stabilizer unit. The gas continues through the process,
which almost always includes compression.
|
EPA
appreciates the comment.
|
-0046
|
During
compression of the gas, some liquids may “drop out”
of the gas stream as the pressure is increased. This being the
case, compressors have interstage separator (also called knock
out pots) that receive the compressed gas/liquid mixture and drop
out any liquid after each stage of compression (compressors can
have one stage or multiple stages). The small amounts of liquids
that accumulate in these vessels are either sent to a tank,
stabilizer unit, or back to the inlet receiver.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Some
midstream facilities have stabilizer units (also called
stabilization units) which receive liquids from the inlet
separator and drive off flash gas either through pressure drop
and/or heat. The stabilized liquids are then sent to tanks. The
gases are either captured for sale or combusted. At these
facilities, the stabilizer liquid composition, temperature, and
pressure have little bearing over the tank liquid composition,
temperature, and pressure. As such, EPA should clarify that
liquid samples should be taken at the location that best
represents the liquids received by the tank.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
In
production, separators that do have emissions (typically the low
pressure separators, which are sometimes heated and would
therefore also be defined as heater treaters) are controlled
differently than tanks, and they need to be evaluated separately
in this ICR. The primary difference is that the gas volume
emitted from the production low pressure separator is much higher
than flashing/working/breathing losses from tanks. Thus,
different control technologies would need to be applied. For
example, an enclosed vapor combustor might be adequate control
for a tank, but multiple enclosed vapor combustors may be
required to handle the volumes from a low pressure separator.
Likewise, recovery might be a good option for low pressure
separators due to large gas volumes, but recovery might not work
for tanks because the volumes might be too low to keep a vapor
recovery unit running efficiently. Thus, even in the production
segment where separators can be emission sources, the profile of
their emissions and their controls are very different than tanks;
therefore, it does not make sense for EPA to treat separators and
tanks in the exact same manner in the survey.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Tank
color is not being requested, but this may be a necessary data
point to understand tank temperature fluctuations which lead to
breathing losses (EPA asks for average operating temperature,
which does not assess these fluctuations). Alternatively, EPA
should clarify that only flashing losses are being assessed.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0048
|
The
“Tanks Separators” worksheet titles is a confusing
term not used in the oil and natural gas industry. EPA should
clarify if this is referring to Separation Equipment.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Pneumatics
Tab
|
|
|
Table
1: Facility Information
|
|
-0046
|
Provide
a dropdown or check box to communicate that the facility is on
supplied/instrument air.
Instrument
air driven devices should be exempted from the ICR altogether
rather than a dropdown for the whole facility.
|
Companies
should provide best available data when responding to the ICR.
|
|
Table
2: Pneumatic Controllers/Devices/Pumps Inventory
|
-0054
|
Row
6-15 Column A - Type of Pneumatic Device
Provide
definitions and ensure definitions are consistent with Subparts
W and OOOOa.
Clarify:
service type is mixed with bleed type.
Carry
revised definitions through entire pneumatic tab, tables and
pull downs.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
6-15 Column B - Number of Natural-Gas Driven Devices
There
are safety concerns with requiring field counting and data
gathering because it is difficult to access some pneumatic
actuators to locate the nameplate.
Allow
sufficient time to collect data, which would provide the ability
to address potential safety hazards. Or allow use of a surrogate
count of the number of pneumatic devices per compressor or tank.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Classification
of intermittent vent controllers into throttling or snap-acting
should be removed from Table 2. Pneumatic
Controllers/Devices/Pumps A.Inventory.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
6-15 Column C - Number of Air-Driven Devices
The
number of air-driven devices is not pertinent to the
identification of the types and prevalence of VOC or GHG
emission controls or emission reduction measures and potential
costs for the measures and controls. Air driven pneumatic
actuators are not a source of VOC or GHG emissions.
Remove
question. If field is retained, recommend alternative question:
Is there an air system available for pneumatics at the facility?
[Y/N]
|
EPA
has added a separate column for air driven devices.
|
-0061,
31, 64
|
Remove
information collection of air driven pneumatics counts from Table
2. Pneumatic Controllers/Devices/Pumps Inventory.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Remove
rotary vane and turbine actuators from Table 2. Pneumatic
Controllers/Devices/Pumps Inventory.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Remove
information on Kimray pumps from Table 2. Pneumatic
Controllers/Devices/Pumps Inventory.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Add
2015 operating hours for liquid circulation pneumatic pumps.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENT
Add
the following questions to Table 2 FOR
EACH PNEUMATIC CONTROLLER/ACTUATOR:
Device
No.
Vented
Controller (Gas-driven pneumatic) (Continuous Bleed or Three-way
Valve)
Vented
Actuator (Gas-driven pneumatic) (Snap Acting or Throttling)
Instrument
Air PD
Electric
controllers
Year
of installation
Supply
Line Pressure (psig)
Equipment
Associated with?
Function
(level control, temp control, etc.)
Measured
Emissions Rate (scfh, whole gas)
Manufacturer
Make and Model Number
If
measured emissions rate not available, estimated emissions rate,
if available (scfh)
In
the determination of the operator, is this a high bleed, low
bleed, intermittent bleed device?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENT
Add
the following questions to Table 2:
Electricity
driven actuators – Number of Electricity-Driven Devices
What
type(s) of electricity-drive actuator(s) (e.g., electronic;
instrument air; solar powered; VRU; etc.)?
How
is electricity generated (e.g., connected to the grid; solar
panels; on-site generation)?
Chemical/liquid
injection/circulation piston pumps - Number routed to process
Chemical/liquid
injection/circulation diaphragm pumps - Number routed to process
Chemical/liquid
injection/circulation piston pumps - Number routed to control
Chemical/liquid
injection/circulation diaphragm pumps - Number routed to control
Electric
pumps – Number of Electricity-Driven Devices
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENT
Remove
the following questions from Table 2:
Snap
acting, intermittent bleed controllers - Number of Air-Driven
Devices
Throttling
low continuous bleed controllers - Number of Air-Driven Devices
Throttling
high continuous bleed controllers - Number of Air-Driven Devices
Throttling
intermittent bleed controllers - Number of Air-Driven Devices
Throttling
no-bleed controllers (discharge to downstream gas line) - Number
of Air-Driven Devices
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Replace
Table 2 references to “Chemical injection” pumps with
"Chemical/liquid
injection/circulation”
pumps. Stating liquid covers all types of pumps
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Kimray
pumps are only used for glycol circulation. Replace Table 2
references to “Liquid” Kimray pumps with “Glycol
Assist” Kimray pumps.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0068
|
Kimray
pumps cannot be air driven. Remove question “Liquid Glycol
Circulation (Kimray) pumps - Number of Air-Driven Devices.”
|
EPA
has requested information on “liquid circulation (Kimray)
pumps.”
|
|
Table
3: General Pneumatic Controllers/Devices/Pumps Information
|
-0061
|
Revise
pick list selections for ‘How does the facility determine
if a device is intermittent or continuous bleed?’ to the
following:
Manufacturers’
data sheet based calculation,
Instrumentation
design knowledge, or
|
The
picklist options have been added.
|
-0054
|
Row
18 Column A-B - How does the facility determine if a device is
intermittent or continuous bleed?
The
pull down options are not complete. For example, manufacturer
information may be used, but it may not be the minimum or
maximum rate (which are menu options).
Remove
question. If field is retained, add options such as
“manufacturer specification” to current pull-down
menu.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Revise
pick list selections for ‘How does the facility determine
if a continuous bleed device is high or low?’ in Table 3.
General Pneumatic Controllers/Devices/Pumps. The Pick list
options should be changed to:
Manufacturer
information based calculation,
Model
number and supply pressure,
Measured
gas supply rate
Measured
gas vent rate, or
Other
design considerations.
|
Picklist
options have been updated.
|
-0054
|
Row
19 Column B - How does the facility determine if a continuous
bleed device is high or low bleed?
If
available, response would be based on manufacturer information.
Since pneumatic device emissions are relatively low for T&S
segments, respondent should be allowed to use a default option
of “high bleed.”
This
is a not a significant source for T&S. Allow selection of
higher bleed if bleed rate cannot be easily discerned.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
20 Column B - What work practices does the facility employ to
identify malfunctioning controllers (e.g., intermittent devices
continuously venting)?
|
Audio/visual
has been added to the picklist.
|
-0046
|
Sub-Section
3. General Pneumatic Controllers/Devices/Pumps Information
The
question, “What work practices does the facility employ to
identify malfunctioning controllers (e.g., intermittent devices
continuously venting)?” should allow for multiple
selections (versus a single drop-down selection).
|
Picklist
options and other has been added.
|
-0054
|
Row
21 Column A - How many controllers were found malfunctioning in
the past year?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
22 Column A - What is the natural gas supply pressure for the
pneumatic devices (psig)?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Add
parameter ‘List current environmental regulations to which
the pneumatic controllers must comply. Select all that apply.’
to Table 3. General Pneumatic Controllers/Devices/Pumps. The
picklist options should be limited to:
|
EPA
appreciates the comment and has implemented as suggested.
|
-0061
|
Add
‘Does facility use practices to minimize natural gas
emissions from pneumatic devices or pumps?’ to Table 3.
General Pneumatic Controllers/Devices/Pumps. Pick list options
should be limited to the following:
Pumps
connected to closed vent system (CVS),
Pumps
routed to control device,
Air
supplied to controllers,
Solar/electric
valves, or
Other,
specify.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0061
|
Remove
‘What is the natural gas supply pressure for the pneumatic
devices (psig)?’ from Table 3. General Pneumatic
Controllers/Devices/Pumps.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
4: Isolation Valve Actuations in 2015
|
|
-0061
|
Revise
heading from ‘Isolation valve actuation’ to
‘Pneumatic driven, motorized actuators’ in Table 4.
Isolation Valve Actuations in 2015.
|
Table
4 has been adjusted to, “Pneumatically driven isolation
valve actuations.”
|
-0054
|
Row
28-36 Column B - Isolation Valve Actuator Type
|
EPA
appreciates the comment and has implemented as suggested.
|
-0054
|
Row
27 Column C - Actuator Size (include description, if “other”
selected for type)
It
is not clear what information EPA expects to receive in response
to this question or its value. Actuators may have missing or
illegible nameplates making it very difficult to accurately
identify the size of the actuator.
Remove
question. Any related question retained requires clarification
and a description of the value EPA hopes to gain from this data,
and EPA estimates of additional costs to gather this data.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
What
does the EPA means by “actuator size” and how to
appropriately count the cumulative number of actuations? What is
this based upon? Engineering estimates?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
27 Column D - Cummulative [sic] Number of Actuation Cycles in
2015 (or most recent operating year).
The
information on actuations is not available and is indeterminate.
Gathering surrogate information on Operations (unit Blowdowns)
would not be accurate and would be very labor intensive.
Remove
question. If this field is retained, correct typo “cumulative.”
If this item is retained, EPA should allow the use of
engineering estimates.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
31
|
Records
are not typically kept on isolation valve actuation and will
typically be an operator’s best estimate. The parameter in
Table 4. Isolation Valve Actuations in 2015 should be amended to
explicitly state estimation is appropriate for clarity on
required level of accuracy: ‘Estimated Number of Actuation
Cycles in 2015’.
|
Companies
should provide best available data when responding to the ICR.
|
-0054
|
Row
27 Column E - Estimated Device Consumption Rate (scf/actuation)
These
records are not readily available and will likely require
contacting the device manufacturer. If the device is missing the
name plate or if it is not legible, it may not be possible to
accurately obtain the consumption rate.
Remove
question. If retained, EPA should allow the use of engineering
estimates or default to a conservative consumption rate of >
6 scf/hr.
|
Companies
should provide best available data when responding to the ICR.
|
|
Table
5: Direct Measurements
|
|
-0046
|
“Source
Description”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
41-49 Column B - Pneumatic Device Type
|
EPA
appreciates the comment and has implemented as suggested.
|
-0068
|
Add
the following questions to Table 5:
Measurement
Method (high-flow
sampler, bagging, temporary flow meter installation, other)
Duration
of measurement
Number
of actuations during measurement
|
EPA
has added measurement method, however for duration of measurement
and number of actuations during measurement EPA has considered
and evaluated the impacts of this comments and has decided not to
pursue any further action.
|
|
Other/General
|
|
-0061,
48
|
The
information collected on Intermittent Vent Controllers could not
reliably be used to determine vented emissions due to the
variability of the exhaust rate caused by the unique site
operations.
Emissions
are highly dependent on operational conditions.
It
would be inappropriate for EPA to use the Part 2 request to draw
industry-wide conclusions about hundreds of thousands of
pneumatic controllers.
Intermittent
devices are purpose-built for individual facilities, and it is
inappropriate to assume that actuation rates on one facility’s
controllers are representative of industry operations.
Variability
is further compounded by the fact that pneumatic controllers
will often actuate at different rates seasonally.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0031,
46
|
If
the intent of the proposed data is to determine if instrument air
is available, ask a ‘yes/no’ question, e.g. whether
any air-driven devices are in use at the facility. EPA should
clarify how sources should respond if company records are not
available. If the answer is yes and a number of devices are
provided for gas-driven pneumatics, then the question would be
answered without an unnecessary count of air-driven devices.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should simplify the request for instrument air pneumatic,
electronic, and mechanical controllers. If facilities are able to
use instrument air, they will generally do so for all
controllers. Therefore it is unnecessary to gather additional
information on actuation rates, snap acting versus throttling
controllers, etc. for these devices.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0031
|
Provide
limits for companies, such that they are only required to perform
a count of equipment components and pneumatic devices for half of
their surveyed facilities or a maximum of 5 facilities
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0031
|
For
facilities that are designed with identical equipment, allow the
use of one physical count for each similar facility rather than
requiring separate physical counts.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0050
|
Clarify
if EPA is only seeking information relating to pneumatic
controllers and does not need information related to pneumatic
valves or actuators that do not have the potential to emit.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0050
|
Limit
requested data to pneumatic controllers (not pneumatic pumps) as
this is the only aspect of a pneumatic device that actually emits
natural gas.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0058,
54
|
EPA
should clarify that the pneumatic device worksheet does not need
to be completed for transmission pipelines.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
The
ICR introduces new terms and device categories (“snap
acting” intermittent controllers and “throttling”
low continuous bleed, throttling intermittent bleed, and
throttling high continuous bleed controller categories) that are
not consistent with Subpart W. As a result, respondents cannot
use existing Subpart W device counts and they will need to expend
additional effort to understand the Proposed ICR categories, and
develop plans to collect data according to those categories.
Black out for T&S.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049,
48
|
The
survey should collect pneumatic controller data on high-bleed,
low-bleed, and intermittent-bleed devices only. The request for
rotary vane isolation valve actuators, snap-acting vs. throttling
intermittent-bleed controllers, and turbine operated isolation
valve operators would not meaningfully improve the quality of
data collected and is not commensurate with the substantial
burden on respondents.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
The
Intro worksheet instructions for pneumatics states, “You
must complete the pneumatic device counts in Section 2 of this
form based on actual counts at the facility if natural gas-driven
pneumatic devices are used.” EPA Supporting Statement at
33. This statement would imply (correctly) that pneumatic devices
operating on supplied air systems are not required to be counted.
However, on the pneumatics tab in section 2, a count is required
for all air-driven devices. EPA Supporting Statement at 52.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should add a section to the Part II pneumatics section to allow
operators the ability to designate whether a pump, valve or
controller is controlled by a control device. To be consistent
with industry best practices, operators often vent these
pneumatics to a control device or re-capture the gas.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
General
support for section 3 information collection on work practices
and malfunctions, as it will provide EPA with useful context for
evaluating work practice standards to ensure the controllers are
operating as designed.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
AGRU
Tab
|
|
|
Table
2: General AGRU Information
|
|
-0061
|
The
‘AGRU Type’ selections in Table 2 should be modified
to include commonly used amine absorbers.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0061
|
The
regulations listed should be limited to those applicable to AGRUs
in Table 2.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0061
|
‘Relative
selectivity of H2S over CH4 (Mass ratio)’ and ‘Relative
selectivity of CO2 over CH4 (Mass ratio)’ should be removed
from Table 2. General AGRU Information. The “relative
selectivity ratio” is not a valid predictor of methane in
the off-gas stream, since the amine is not saturated with all
three gases.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
EPA
should only require operators to provide either ‘Average
volumetric flow rate of feed natural gas (scfm)’ or
‘Average volumetric flow rate of treated natural gas
(scfm),’ in Table 2. General AGRU Information, but not
both. Volumetric flowrate is typically available only for either
feed or treated gas, not both. ‘Type Natural Gas Volume
Provided’ should also be added to specify correct
application of the volumetric flowrate per the above recommended
change; with pick list options of ‘feed gas’ or
‘treated gas’.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
disposition of off-gas must be treated the same for H2S and CO2.
These columns in Table 2 should be combined.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
‘Contactor
Tower Pressure (psig)’ and ‘Circulation Rate of
Solution (gallon/minute)’ should be added to Table 2.
General AGRU Information. The contactor tower pressure and
temperature, the type of amine used, and the circulation rate
define the rate (pounds/hr) that methane is absorbed into the
amine.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0061
|
Add
operating hours in 2015 to Table 2.
|
EPA
appreciates the comment and has implemented as suggested.
|
|
Other/General
|
|
-0061
|
EPA
should request the methane mass rate in the off-gas from the most
recent process simulation. Natural gas flowrate and compositions
of methane, CO2 and H2S are not pertinent to the calculation of
methane emissions. Type of amine, amine circulation rate, contact
tower pressure and temperature are the primary factors
determining methane in AGRU off-gas.
|
Facilities
can take process simulations, but we still believe this
information is pertinent.
|
-0046
|
Are
there limitations on what is considered a direct emissions
measurement? Some AGRUs have a volumetric flow meter on the acid
gas vent and/or may also have an online gas chromatograph on the
acid gas. EPA should clarify as to whether EPA would consider
data from these to be a “Direct Emissions Measurement.”
|
Yes,
and the emissions would be whole gas flow rate.
|
-0046
|
EPA
should allow respondents the option to upload an AMINECalc model
in lieu of providing information on the AGRU tab. This will
provide EPA the composition, equipment configuration, and
emissions information it needs in a readily-usable format.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Dehyd
Tab
|
|
|
Table
1: Facility Information
|
|
|
Table
2: General Dehydrator Information
|
|
-0046
|
Sub-Section
2. General Dehydrator Information – Complete for each
Dehydrator
“Dehydrator
Type”
|
EPA
appreciates the comment and has implemented as suggested.
|
-0054
|
Row
8-43 Column D - List current environmental regulations to which
the well site must comply.
Select
all that apply.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
46
|
Volumetric
flowrate is typically available only for either feed or treated
gas, not both. Only one parameter should be required in the
survey.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0054
|
Row
8-43 Column E-L - Feed Gas and Treated Gas column headers
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“H2O
concentration in feed gas (% by vol)”
GPA
Midstream recommends that this match GlyC GlyCalc, which
includes two options: “Gas is saturated” or “Gas
is subsaturated.” If the latter option is selected, the
use can input the water content in units of ‘lb H2O/MMSCF’
rather than ‘% by vol’ as requested in the ICR
spreadsheet.
|
EPA
has revised the units of H2O concentration in feed gas.
|
-0061
|
Composition
in and out of the unit should not be collected. Trying to
calculate mass rates of methane and CO2 by measurement and mass
balance is impractical due to low solubility and measurement
error.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
EPA
should request ‘Contactor tower pressure’, ‘Glycol
circulation rate’, ‘Circulation pump type’,
‘Runtime hours’, and ‘Stripper gas consumption
rate’, and ‘Stripper gas methane composition’.
Contactor tower pressure and glycol circulation rate are primary
factors in calculating methane emissions from dehydrators.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0068
|
Add
the following questions to Table 2:
Temperature
of feed gas stream (°F)
Pressure
of feed gas stream (psig)
Is
the gas saturated or subsaturated?
Hours
of operation in the 2015 calendar year
|
EPA
appreciates the comment and has implemented as suggested.
|
|
Table
3: Glycol Dehydrator Information
|
|
-0054,
46
|
Row
47 Column C - If yes, provide methane recovery efficiency
(percent)
For
information on natural gas recovery efficiency, EPA should allow
the use of GLYCalc runs instead.
Change
“methane” to “natural gas”
|
EPA
appreciates the comment and has implemented as suggested.
|
-0046
|
Sub-Section
3. Glycol Dehydrator Information - Complete for each Glycol
Dehydrator
“Disposition
of reboiler/regenerator exhaust”
EPA
is inappropriately combining two emission points (reboiler
exhaust and the regenerator still vent); these should be
separated.
For
the regenerator still vent, EPA needs to account for multiple
controls (condenser to combustion), which is a very common
configuration. EPA should also take the opportunity to request
more granular information about how the regenerator still vent
gas is controlled (i.e., type of flare, thermal oxidizer, vapor
combustor, etc), versus the generic “flare or thermal
oxidizer).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
Average
fuel gas rate should not be requested. Methane emissions from
regenerator still reboilers are insignificant because methane is
combusted to CO2 and these reboilers have low heat requirements.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054,
46
|
Row
47 Column H - Glycol reboiler/regenerator fuel gas consumption
rate (scfm)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
‘Source of fuel’ is not tied to emissions and should
be removed. If the ‘Source of fuel’ parameter is not
removed, ‘indirect heat’ should be added as an option
to cover gas processing plants that utilize steam in the
regenerator still reboiler.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
48 Column K - Emission reduction work practices used
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
3. Glycol Dehydrator Information - Complete for each Glycol
Dehydrator
“Emission
reduction work practices used”
‘Reboiler
condenser gas’ is very unclear and could be mistaken for
multiple streams within a dehydrator unit.
These
columns should be removed from the spreadsheet due to the
ambiguity and based on the fact that other columns address the
configuration of the dehydrator including emission control
devices.
EPA
is not requesting sufficiently granular information about NESHAP
HH/HHH that would truly inform EPA about the emission sources
and their current control requirements. EPA should add the
following:
Is
the dehydrator at an area source or major source?
Is
the dehydrator a large glycol dehy, existing small glycol dehy,
or new small glycol dehydrator?
For
area source TEG dehydrators, does the dehydrator meet with <3
mmscfd throughput exemption, the < 1 ton per year (tpy)
actual emissions exemption, neither or both?
For
non-exempt area source TEG dehydrators, is the dehydrator
located within a UA plus offset and UC boundary14?
For
major sources, large dehydrators, are dehydrators complying with
the 95% HAP reduction requirement or the 1 tpy benzene emission
requirement?
For
major source small dehydrators, what is the BTEX emission limit?
EPA
does not request the glycol circulation rate, which is an
operating data point that directly relates to emissions.
EPA
does not ask if the glycol pump is electric or natural-gas
driven pneumatic, which also impacts dehydrator emissions
(pneumatic pump emissions are part of dehydrator process and
emitted from the regenerator still vent)
If
EPA pursues information about desiccant dehydrators, EPA needs
to ask about vessel opening frequency (once/year, once/two
years, once/three years) and emissions during opening.
|
EPA
has revised the Glycol dehydrator information tab to include
information on:
Area
Source/Major Source status of facilities
“actual
annual average nat gas flow rate
date
of construction/reconstruction”
Exemption
criteria
Circulation
rate of solution” which is the same as glycol circulation
rate.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENT
Add
the following questions to Table 3:
If
yes, flash tank pressure
If
yes, flash tank temperature
If
yes, is flash gas captured?
Number
of absorber stages
Lean
glycol water content
Lean
glycol recirculation ratio
Is
stripper gas used in the regenerator?
If
yes, the flow rate of stripper gas (scf/min)
If
yes, the methane volume percent in stripper gas (0% if nitrogen)
Is
there a condenser on the regenerator/reboiler?
If
reboiler/regenerator/condenser exhaust is controlled, type of
control (vapor recovery to sales, vapor recovery for use on
site, to flare)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Remove
“Disposition of reboiler/regenerator exhaust” from
Table 3.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
4: Direct Emissions Measurements
|
|
-0054
|
Row
57-63 Column C-F - 4. Direct Emissions Measurements - Complete
for each dehydrator for which emissions measurement data are
available.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0068
|
Add
“Measurement equipment used (temporary meter, hi flow
sampler, calibrated bag)” to Table 4.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0046,
61
|
EPA
should allow respondents the option to upload a GLYCalc, Version
3.0 or higher file in lieu of providing information on the
Dehydrator Units Tab. Many responders already must prepare a
GLYCalc run to comply with NESHAP requirements under Subpart HH,
permit requirements, and/or emission inventory reporting. In
addition, the GLYCalc runs will provide EPA the composition,
equipment configuration, and emissions information it needs in a
readily-usable format.
|
GRI-GLYCalc
or other modeling software runs can be used, but must be inserted
into database.
|
-0061
|
Separate
control devices are typically required for dehydration units. EPA
has not included the cost to control dehydration units.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046,
61
|
EPA
should remove desiccant dehydrators from the ICR as they are an
extremely small source of emissions (as GHGRP data shows). Or, at
the very least, EPA should limit the ICR to desiccant dehydrators
that directly emit their regeneration gas to atmosphere. EPA
should also ask, for each glycol dehydrator, if the unit is
treating process gas or desiccant dehydrator regeneration gas.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0066
|
Characterization
of emissions from glycol dehydrators should include an expansion
of the composition analysis of feed and treated gas to include
data on individual HAPs and other VOCs, as opposed to just
relying on estimation of total VOCs.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0046
|
Glycol
dehydrators that route all emissions back to the process should
also be excluded from this ICR as they are not an emissions
source.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Eq
Leaks Tab
|
|
|
Table
1: Facility Information
|
|
-0046
|
EPA
should change “well site” to “facility”
in rows 3-7.
|
EPA
appreciates the comment and has implemented as suggested.
|
-0054
|
Row
3-7 Column B – List current environmental regulations to
which the well site must comply.
Select
all that apply.
|
EPA
has corrected “well site” references and added 40 CFR
98 to the regulatory picklist. Regulations remain in the EqLeak
Tab.
|
-0054
|
Row
8 Column A - Does the facility conduct routine inspections to
identify leaking equipment components?
The
question as stated will not lead to a clear and concise answer.
To clarify, suggest differentiating frequent “walk
through” from regulatory driven surveys and eliminate
“routine” as this is subject to interpretation.
Insert
question: Does the facility conduct regular
audio-visual-olfactory (AVO) inspections for leaks? [Y/N]
Restate
original question: Does the facility conduct “other”
inspections using instrumentation/regulatory methods to identify
leaking equipment? If YES, complete Table 2.
|
EPA
has clarified that “routine inspections” are
“regulatory driven inspections.” EPA has also added
the question “Does the facility conduct regular
audio-visual-olfactory (AVO) inspections for leaks? [Y/N].”
|
-0046
|
EPA
should divide the question “Does the facility conduct
routine inspections to identify leaking equipment components”
into at least two parts (or otherwise redraft the section)
because, as drafted, this section allows only one frequency and
monitoring method. In reality, a company may perform camera
inspections, M21 inspections, and AVO inspections each on
different frequencies.
|
EPA
has amended the Section 1 to allow for multiple monitoring
methods.
|
-0054
|
Row
11 Column B - Monitoring method used.
In
the pull down, one of the options is Method 21/OVA. The acronym
OVA (organic vapor analyzer) is not defined and could easily be
confused with the acronym AVO. Define OVA (organic vapor
analyzer) in acronyms to differentiate from AVO (audiovisual-
olfactory) or spell out.
There
are occasions when multiple methods are used. Add “multiple”
to pull down.
|
EPA
has added a definition of “OVA” and “AVO”
to the Acronym List.
EPA
has amended the Section 1 to allow for multiple monitoring
methods.
|
-0046
|
EPA
should add Audible, Visual, Olfactory (“AVO”) to the
monitoring method options list.
|
EPA
has added the question “Does the facility conduct regular
audio-visual-olfactory (AVO) inspections for leaks? [Y/N].”
|
-0058
|
Pick
list 38 (monitoring method) should allow an operator to pick more
than one method, as sometimes more than one method can be used to
detect and/or measure methane emissions.
|
EPA
has amended the Section 1 to allow for multiple monitoring
methods.
|
-0058
|
Hi-Flow
equipment should be added to pick list 38 (monitoring method), as
this is sometimes used to measure flow rate of a detected leak.
EPA should also retain the option to pick “other” and
allow the operator to specify another method.
|
EPA
has added “Hi-Flow Sampler” and “Other
(Specify)” to the monitoring method picklist.
|
-0049
|
Under
the monitoring method selections, one choice is “Method
21/OVA”. This seems to imply these methodologies are
equivalent, which is simply not the case. Suggest separating
these into two different selections. At some locations operators
may perform OVA inspections and not perform Method 21
inspections.
|
EPA
has edited “Method 21/OVA” to “Method 21.”
|
-0054
|
Row
12 Column A - If Other method, specify.
|
EPA
has added “Other (Specify)” to the monitoring method
picklist.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENTS
Add
the following questions to Table 1:
Was
the inspection performed comprehensive for all components across
the facility?
If
not, what percentage of components were surveyed?
What
is the frequency of inspections per year?
What
is the monitoring method used for the leak survey?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENTS
Remove
the following questions from Table 1:
If
yes, provide the following information by component type: Gas or
Light Liquid Valves - Frequency of inspections.
If
yes, provide the following information by component type: Gas or
Light Liquid Connectors - Frequency of inspections.
If
yes, provide the following information by component type: Gas or
Light Liquid Pressure-relief Valves - Frequency of inspections.
If
yes, provide the following information by component type: Pumps
- Frequency of inspections.
If
yes, provide the following information by component type: Other
components in gas or light liquid service - Frequency of
inspections.
If
yes, provide the following information by component type: Heavy
liquid components - Frequency of inspections.
If
yes, provide the following information by component type: Gas or
Light Liquid Valves - Monitoring method used.
If
yes, provide the following information by component type: Gas or
Light Liquid Connectors - Monitoring method used.
If
yes, provide the following information by component type: Gas or
Light Liquid Pressure-relief Valves - Monitoring method used.
If
yes, provide the following information by component type: Pumps
- Monitoring method used.
If
yes, provide the following information by component type: Other
components in gas or light liquid service - Monitoring method
used.
If
yes, provide the following information by component type: Heavy
liquid components - Monitoring method used.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
2: Equipment Leak Inventory Information
|
|
-0046
|
Eliminate
distinction of component counts by “Gas Service,”
“LNG Service,” “Light Crude Service” and
“Heavy Crude Service.” This type of distinction is
not made in OOOOa for new well sites and compressor stations as
it isn’t appropriate for the natural gas industry. GPA
Midstream questions the practical utility of EPA collecting
information for components at gas plants that are already subject
to NSPS.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
To
get insight on the appropriate frequency of monitoring, EPA
should ask about the total number of components found leaking
during the first monitoring survey (if within the last 3 years).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
16-45 Column A - Service / Component Type
These
do not match with Subpart W component types. There are
differences in the component types listed depending on the
service.
Consistent
definitions and nomenclature with Subpart W and NSPS Subpart
OOOOa. If retained, there is a significant burden to gather
information using new categories.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
16-45 Column B - Total Number of Components contacting a process
fluid that contains 5 percent by weight of any of the following
pollutants: VOC, CH4, CO2
Subpart
W and NSPS Subpart OOOOa at compressor stations do not require
this information. This is not applicable for T&S.
Remove
question for T&S. If retained for T&S, 120 days is not
enough time to complete this task given the number of facilities
that will require a site survey.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Change
the language in cells B15 and C15 to read “Total Number of
Components contacting a process fluid or gas that contains at
least 5 percent by weight of any of the following pollutants:
VOC, CH4, CO2” and "For natural gas processing plants
only: Total Number of Components contacting a process fluid or
gas that is at least 10 percent VOC by weight,"
respectively.
|
EPA
appreciates the comment and will implement as suggested.
|
-0054
|
Row
16-45 Column D - Total Number of Components Monitored for Leaks
During Most Recent Monitoring
Survey
Subpart
W and NSPS Subpart OOOOa at compressor stations do not require
this information. This is not applicable for T&S.
The
term “most recent monitoring survey” could be
confusing and the responses left to judgment and individual
interpretation. More specific answers can be obtained by
clarifying the question, see suggested rewording to include
“using instrumentation/regulatory methods to identify....”
Remove
question. If retained for T&S, 120 days is not enough time
to complete this task given the number of facilities that will
require a site survey. If retained for T&S, the recommended
header revision: Total Number of Components Monitored for Leaks
during most recent inspections using instrumentation/regulatory
methods to identify leaking equipment.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
16-45 Column F - Definition of Leak used for Monitoring
Components
There
may be other leak definitions. In addition, GHGRP exempts tubing
< ½ inch in diameter. Consistency with existing
regulations is warranted.
Add
“other” to pull down options. Add a column to
specify. Include exemption for small diameter tubing consistent
with Subpart W.
|
EPA
has added “Other (Specify)” to the Definition of Leak
Used for Monitoring Components list.
|
-0031
|
Provide
an exemption for equipment component counts for tubing lines
<1/2” diameter
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
EPA
should either make the leak definition a multiple choice list, or
EPA should change cell F15 to “Lowest definition of leak
using for Monitoring Components”.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0058
|
The
pick list options for “leak definition” (pick list
number 39) are currently limited to parts per million volume
(ppmv) levels from 500 ppmv up to 10,000 ppmv, plus “any
visible emissions using OGI.” An option should be added
allowing a facility operator to pick 12,500 ppmv if they used a
methane detector set to alarm (for safety purposes) at 25% of the
lower explosive limit (LEL), which is equivalent to 12,500 ppmv.
In case an operator has data based on Hi-Flow measurements, AGA
suggests adding a pick list option for cubic feet per second or
minute (i.e. a flow rate measured with a Hi-Flow device).
|
EPA
has added “Other (Specify)” to the Definition of Leak
Used for Monitoring Components list.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENTS
Add
the following to Table 2 FOR
EACH NATURAL GAS STREAM:
Respondents
need to fill the tables below only for streams that contain 5
percent or greater by weight of any of the following pollutants
individually or cumulatively: VOC, CH4, CO2.
Methane
(vol%)
CO2
(vol%)
HAPs
(vol%)
VOCs
(vol%)
Inerts
(vol%)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENTS
Clean
Air Task Force proposed new Tables for component counts (see
Attachment 2J in CATF Comments).
Proposed breaking out component counts by sector (Production,
Processing, etc.) and collecting the following counts for typical
equipment types (compressor, tank, meter, dehy, regulator, etc.):
Valve
Isolation
Valve
Blowdown
Valve
Dump
Valve
Flanged
Connector
Screwed
Connector
Pressure
Relief Valve
Open
Ended line
Non
compressor seal
Surface
crack/hole
Other
The
component count table format should be repeated to collect
information on number of components monitored during the last
survey and again for the number of components found leaking
during the last survey.
Remove/Replace
all questions in Table 2.
|
EPA
appreciates the comment we have added equipment component counts
by major equipment types, except that we did not distinguish
between different types of valves.
|
|
Table
4: Direct Emissions Measurements
|
|
-0046
|
EPA
should install a cap on how far back operators need to collect
direct emissions data. The title of Table 4 needs to be clarified
with the time period.
|
EPA
has amended the Table 4 to request most recent direct emissions
measurement data per source.
|
-0054
|
Row
61 Column A - 4. Direct Emissions Measurements - Complete for
each component or equipment type, as applicable, for which
emissions measurement data are available.
Row
59 inquires about emissions testing, and should be linked to
item 4. However, row 59 is only applicable to onshore petroleum
and natural gas production facilities. The form should also
inquire about data availability for other segments and the
question should be linked to the table in item 4.
Clarify
applicability to all segments or only production facilities,
include the appropriate question(s) and link a “yes”
answer to the Direct Emissions Measurements table. If “no,”
the table should be blacked out
|
EPA
has requested leak emissions testing data for all sectors.
|
-0061
|
Direct
emissions measurements should only include methods that quantify
emissions. For Method 21 operations, a direct measurement is not
obtained as there is no flow rate information.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“Measurement
Method”
|
EPA
has amended Table 4 to remove all “Screening/…”
options from the Measurement Method picklist.
|
-0046
|
“Measurement
Cost”
Direct
quantitative measurements are unusual for leaking components,
and EPA should not anticipate receiving a substantial amount of
data here. These measurements are likely only conducted for
special studies.
EPA
should allow (but not require) respondents to submit leak
detection program cost information. EPA should add a Sub-Section
5 for leak detection program information, which should request
“Annual leak detection program cost”, “Inspection
type (dropdown option of In House or Third Party), “Equipment
Ownership” (dropdown options of In House, Third Party or
Rented). EPA should specify in the workbook or in a supplemental
instruction that “Annual leak detection program cost”
should include all equipment, transportation, recordkeeping
software, inspection, component inventory maintenance, and
repair costs.
|
EPA
will include the ability to upload additional data (process
simulations, supplemental data, etc.) in e-GGRT.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENTS
Add
the following questions to Table 4:
Month
and Year of last survey performed
Frequency
of surveys per year in the last three years
Survey
equipment used
Emissions
from Valves (scf CH4/hr)
Emissions
from Isolation Valves (scf CH4/hr)
Emissions
from Blowdown valves (scf CH4/hr)
Emissions
from Dump Valves (scf CH4/hr)
Emissions
from Flanged Connectors (scf CH4/hr)
Emissions
from Screwed Connectors (scf CH4/hr)
Emissions
from Pressure Relief Valves (scf CH4/hr)
Emissions
from Open Ended Lines (scf CH4/hr)
Emissions
from Non compressor seals (scf CH4/hr)
Emissions
from Surface crack/hole (scf CH4/hr)
Emissions
from Other components (scf CH4/hr)
Was
the measurement performed by the operator or a contractor?
If
contractor, total leak survey and
Measurement cost ($)
Total
time needed for survey and measurement (hours)
Approximate
average time between survey and repair of leak (days)
Approximate
average cost to repair leaks ($)
Number
of leaks repaired
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
***SEE
CLEAN AIR TASK FORCE COMMENTS
Remove
the following questions from Table 4:
This
information is already captured in the revised tables provided by
Clean Air Task Force.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0061,
59
|
The
addition of providing prior leak data should be a voluntary
option if data is available. Providing data for only the most
recent survey will not allow the agency to evaluate the declining
rate of leaks over time.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
The
proposed response time does not adequately allow for collection
of data included in the draft ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0027
|
Should
use the same Service/Component Type categories as Subpart W.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0058,
54
|
EPA
should clarify that the equipment leak worksheet does not need to
be completed for transmission pipelines.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0066
|
Expand
compositional analysis of produced gas to include data on
individual VOC and SVOC fractions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
There
is no guidance on how to complete the component counts or leak
data. Does the count stop at the well location or continue
through the central processing facilities? For a facility
consisting of hundreds of wells, the component counts will take a
substantial number of hours to complete.
|
Component
counts should be completed for the facility based on the
“facility” definition provided in the Definitions
Tab.
|
-0049
|
Asking
for LDAR to be done on existing sources simultaneously is
extremely burdensome and counterproductive to coming into
compliance with OOOOa. Strongly recommend that EPA delay this
portion of the ICR until after June 3rd.
|
EPA
has considered and evaluated the impacts of this comments and has
decided not to pursue any further action.
|
|
Comp
Tab
|
|
|
Table
1: Facility Information
|
|
-0046
|
EPA
should add more rows in order to allow operators to appropriately
respond.
|
EPA
has added several rows to allow responders to account for all
compressors.
|
|
Table
2: General Compressor Information
|
|
-0061
|
EPA
should remove ‘Engine Type’, ‘Fuel Type’,
and ‘Emission Tier’ since these parameters relate to
engine combustion emissions, not compressor emissions. These
three data elements alone are insufficient to determine engine
methane emissions with any accuracy (i.e., within an order of
magnitude).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
9-48 Column D - List current environmental regulations to which
the well site must comply.
Select
all that apply.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
7 Column F - Engine Type
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
9-48 Column F - Engine Type
|
EPA
has added “Turbine” to the Engine Type list.
|
-0046
|
Sub-Section
2. General Compressor Information – Complete for each
Compressor
“Engine
Type”
“Electric”
is not an engine type. Electric is a type of driver, or motor,
for a compressor. EPA should change the column heading to
“driver type.”
EPA
should add “turbine” to the driver type drop-down
menu.
EPA
should exclude Columns E (Power output compressor driver (hp)),
F (Engine Type) and G (Fuel Type) as each column pertains to
drivers and not compressors.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
EPA
has added “Turbine” to the Engine Type list.
|
-0054
|
Row
9-48 Column G - Fuel Type
|
EPA
has added “Electricity” as a fuel type.
|
-0046
|
Sub-Section
2. General Compressor Information – Complete for each
Compressor
“Fuel
Type”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
9-48 Column H - Emissions Tier
It
is not clear what emissions tiers are referred to here. The
purpose is unclear; generally, the Proposed ICR is concerned
with the compressor not the driver. EPA should provide further
clarification in the final ICR and explain the purpose of this
request.
Clarify;
eliminate requirement for natural gas-fired engines (and other
engines using fuel other than diesel).
|
EPA
has clarified that “Emission Tier” is found from 40
CFR 98 Subpart C reporting data for each engine.
|
-0046
|
Sub-Section
2. General Compressor Information – Complete for each
Compressor
“Emissions
Tier”
Is
column H is asking for the site-wide emissions tier or engine
emission tier? If engine tier, this would refer to diesel
engines (compression ignition) and not natural gas driven
engines. If this column was only intended to apply to
compression ignition engines only, the column should be blacked
out when anything other than compression ignition is selected as
the engine type.
|
EPA
has clarified that “Emission Tier” is found from 40
CFR 98 Subpart C reporting data for each engine.
EPA
has corrected Table 2 to black out “Emission Tier”
for spark ignition engines.
|
-0054
|
Row
9-48 Column M - Were direct emissions measurements made for
compliance with the GHGRP in 40 CFR part 98, Subpart W?
Column
headings M-Q invite confusion, so EPA should simply request
operating time in modes. If Q is yes, then EPA should populate
using Subpart W data.
If
the answer is “yes” then the EPA should populate the
Operating Time Fields. If the answer is “no,” then
column N should be negated.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Sub-Section
2. General Compressor Information – Complete for each
Compressor
“Were
direct emissions measurements made for compliance with the GHGRP
in 40 CFR part 98, subpart W? If no, please provide the total
time the compressor was in standby-pressurized mode in RY2015.”
Specify
that the time frame of the direct emissions measurements
question is 2015.
The
availability of run time in standby pressurized and
depressurized modes at sites not subject to 40 CFR Part 98
Subpart W in reporting year 2015 will most likely not be
available as it is not required to be tracked and does not
provide beneficial data to operators for optimization or
maintenance.
|
EPA
has specified the reporting year for each column.
Companies
should provide best available data when responding to the ICR.
|
-0054
|
Row
9-48 Column O - If no, please provide the total time the
compressor was in operating-mode in RY 2015. (hours)
Columns
O-Q can be simple requests for operating time in mode. However,
if this is not a Subpart W applicable facility, then this
information is not readily available and there will be a high
cost associated with gathering this information.
Per
item above (row 9-48, column M), negate this field (black out)
for non-Subpart W facilities. Rephrase question: “Total
time in operating mode in RY 2015 (hrs)” and prepopulate
with Subpart W data.
If
retained, allow engineering estimate for facilities that do not
report under Subpart W.
|
Companies
should provide best available data when responding to the ICR.
|
-0054
|
Row
9-48 Column P - If no, please provide the total time the
compressor was in standby-pressurized-mode in RY 2015 (hours)
Columns
O-Q can be simple requests for operating time in mode. However,
if this is not a Subpart W facility, then this information is
not readily available and there will be a high cost associated
with gathering this information.
Negate
for non-Subpart W facilities. Rephrase question: “Total
time in standby-pressurized mode in RY 2015 (hrs)” and
pre-populate with Subpart W data.
If
retained, allow engineering estimate for facilities that do not
report under Subpart W.
|
Companies
should provide best available data when responding to the ICR.
|
-0054
|
Row
9-48 Column Q - If no, please provide the total time the
compressor was in not-operating-depressurized mode in RY 2015
(hours)
Columns
O-Q can be simple requests for operating time in mode. However,
if this is not a Subpart W facility, then this information is
not readily available and there will be a high cost associated
with gathering this information.
Negate
for non- Subpart W facilities. Rephrase question: “Total
time in not-operating-depressurized mode in RY 2015 (hrs)”
and pre-populate with Subpart W data.
If
retained, allow engineering estimate for facilities that do not
report under Subpart W.
|
Companies
should provide best available data when responding to the ICR.
|
-0068
|
Remove
the following questions from Table 2:
Number
of reciprocating compressors at the facility
Number
of centrifugal compressors at the facility
If
yes, identify the compressor sources controlled/recovered.
If
yes, what types of controls?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0068
|
Add
“Are the starter motors electric or gas driven?” to
Table 2.
|
EPA
appreciates the comment and will implement as suggested.
|
|
Table
3: Direct Emissions Measurements
|
|
-0054
|
Row
51
Measurements
are associated with an emission source, but there is no column
for specifying the equipment type measured (e.g., rod packing,
blowdown valve, unit isolation valve, etc.) Add column for this
data element.
|
EPA
has amended Table 3 to include “Point of Measurement.”
|
-0054
|
Row
51 Column G/H - Emission Rate (scf/hr)
|
EPA
appreciates the comment and will implement as suggested.
|
-0068
|
Add
the following questions to Table 3:
Point
of Measurement
Volume
% CO2 in emissions stream, if available
Volume
% VOC in emissions stream, if available
Split
table by Point of Measurement (Blowdown Vent Stack(s) and Seal
Vent Stack(s))
|
EPA
has amended Table 3 to include “Point of Measurement.”
|
|
Table
4: Centrifugal Compressor Specific Information
|
|
-0046
|
EPA
should not assume that existing wet seal compressors can be
converted to dry seal compressors, and should therefore collect
information about whether it is technically feasible. As an
optional reporting option, respondents should be allowed to
provide a cost estimate for doing the conversion
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
67 Column D - If wet seals were replaced with dry seals on or
after 1/1/2010, provide the cost. ($)
|
EPA
has amended this table to clarify the need for total cost (both
equipment and labor).
|
-0068
|
Add
the following questions to Table 4:
Compressor
suction pressure (psig)
Compressor
discharge pressure (psig)
How
many vents are connected to the seal oil separator(s)?
How
many vents are connected to the seal oil sump/ tank?
Is
seal oil separator vent(s) open to atmosphere or routed to
suction or captured for other use?
If
captured for other use, state where the gas is routed
Is
seal oil tank vent(s) open to atmosphere or flared or captured
for other use?
If
captured for other use, state where the gas is routed
Seal
oil circulation rate
Seal
oil pressure
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Table
5: Reciprocating Compressor Specific Information
|
-0046
|
The
form should ask about rod replacement (versus rod packing
replacement), programs to monitor and manage compressor
emissions, and whether low emissions packing technology is used.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
Unclear
if owner/operators should leave the ‘Date of last rod
packing replacement’ field blank for new compression
|
EPA
has amended this table to clarify that “N/A” should
be selected if rod packing has not been replaced, which will
negate the cost field. EPA has also amended this table to
request “Hours Since Last Rod Packing Replacement.”
EPA
has amended Table 2 to request “Date of Installation”
for each compressor.
|
-0054
|
Row
76 Column B - Date of last rod packing replacement
|
EPA
has amended this table to clarify that “N/A” should
be selected if rod packing has not been replaced, which will
negate the cost field.
|
-0054
|
Row
76 Column C - Cost of last rod packing replacement ($)
Cost
definition required. For example, Equipment and Labor.
A
new rod packing seal may not yet have been replaced; therefore,
include “or installation” to this header.
“Cost
of last rod packing replacement or installation ($).”
Clearly indicate that respondents may provide an engineering
estimate.
|
EPA
has amended this table to clarify the need for total cost (both
equipment and labor).
EPA
has amended this table to clarify that “N/A” should
be selected if rod packing has not been replaced, which will
negate the cost field.
Companies
should provide best available data when responding to the ICR.
|
-0061,
59
|
In
Table 5. Reciprocating Compressor Specific Information, under
‘Frequency of rod packing replacement’, update the
pick list to the following options:
Never
Semi-Annually
Annual
Bi-Annual
Less
Frequent than Bi-Annual
Based
on operating hours (company maintenance procedure),
Based
on leakage indicator (company maintenance procedure), and
Per
compliance with applicable regulations.
|
EPA
has amended this table to allow for more options in the
“Frequency of rod packing replacement” picklist.
|
0046
|
The
‘Frequency of rod packing replacement’ drop down
should include more options or include an “other”, as
the current options are very limiting. For instance, many
replacements are based on run hours, or other factors, such as
when high rod packing vent rates are observed.
|
EPA
has amended this table to allow for more options in the
“Frequency of rod packing replacement” picklist.
|
-0054
|
Row
77-82 Column D - Frequency of rod packing replacement
Include
“other” as an option in the pull down, and a column
to specify. For example, the NSPS Subpart OOOOa criteria is
26,000 operating hours or 36 months.
|
EPA
has amended this table to allow for more options in the
“Frequency of rod packing replacement” picklist.
|
-0061
|
EPA
should add a new column to Table 5. Reciprocating Compressor
Specific Information for ‘Approximate operating hours
between replacements.’ Compressors may not run full-time
and this will allow an operator to optionally specify replacing
packing based on operating hours, either per company policy or
per applicable regulations.
|
EPA
has amended this table to request “Hours Since Last Rod
Packing Replacement.”
|
-0068
|
Add
the following questions to Table 5:
Is
rod packing replacement based on a fixed schedule or emissions
rate?
If
based on emissions rate, emissions threshold to trigger
replacement (scf-CH4/hr)
If
based on emissions rate, frequency of measurement (months)
If
based on emissions rate, frequency of measurement (hours of
operation)
Frequency
of rod packing replacement (months)
Frequency
of rod packing replacement (hours of operation)
Number
of compressor stages
Suction
pressure of stage 1 (psig)
Discharge
pressure of stage 1 (psig)
Suction
pressure of stage 2 (psig)
Discharge
pressure of stage 2 (psig)
Suction
pressure of stage 3 (psig)
Discharge
pressure of stage 3 (psig)
Suction
pressure of stage 4 (psig)
Discharge
pressure of stage 4 (psig)
Rod
packing material type
Number
of cups in the rod packing
Number
of rings in each cup
Is
the rod packing vent gas captured?
If
captured, state where the gas is routed (sales, for use on site,
flared, other)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0066
|
EPA
should specifically request submission of any HAP emissions
testing data submitted by the responder to another agency as a
requirement of state or local permits, or as a result of a
compliance or enforcement action.
|
EPA
has amended the ICR to request information on additional air
toxics, when applicable.
|
-0066
|
EPA
must ensure that any HAP emission estimates utilizing data
collected as part of the ICR are based on the most up-to-date
emission factors that include all the relevant HAPs beyond BTEX.
|
EPA
appreciates the comment and will be using the most current
emission factors.
|
-0046
|
EPA
should exclude vapor recovery compressors from this ICR. Vapor
recovery compressors similarly operate at low pressures and/or
low volumes. EPA must at least add a column to Sub-Section 2 for
“Operational Service” with selection options of
“Process Gas, Vapor Recovery, Refrigeration, Other”.
|
Vapor
Recovery compressors should be included in Compressor service.
Add
Operational Service Column.
|
-0046
|
EPA
should provide a compressor driver horsepower threshold, below
which, the compressor would not have to be included in the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Blowdown
Tab
|
|
|
Table
1: Facility Information
|
|
-0027
|
Add
category “Blowdowns associated with the storage field
(outside the compressor station)” to avoid confusion or
lack of information from storage operations. Make this
consistent with Subpart W to avoid undue burden.
|
EPA
appreciates the comment and will implement as suggested.
|
-0054
|
Row
5-12 Column B-J - Blowdown information
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“Cumulative
volume of natural gas blown down (scf)”
|
EPA
appreciates the comment and will implement as suggested.
|
-0046
|
The
category “Recovered for sale” is confusing. A common
practice is for the majority of gas in a compressor to be routed
back into the process (usually to the facility inlet), and then
the small amount of gas remaining in the compressor is blown
down. This would not necessarily be considered “recovered
for sale.” EPA should simply title this category
“Recovered.”
|
For
the purposes of this ICR, “recovered for sale” means
that the gas is routed back into the process.
|
-0054
|
Row
14-22 Column A-D - Hot taps or other practices
If
used, these “practices” most likely apply for
pipeline and not the compressor stations, etc. Clarification of
action is needed. Example operations could include: isolating
customers to conduct a maintenance blowdown; taps for new
costumers or suppliers. What is covered by this item?
Black
out these cells if Compressor station, storage, etc. is
selected. Should only be filled in if “Pipeline”
facility.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
19 Column A - Use pipeline pump down techniques
|
EPA
appreciates the comment and will implement as suggested.
|
-0054
|
Row
20 Column A - Use flexible membrane liners (pipelines)
|
EPA
appreciates the comment and will implement as suggested.
|
-0054
|
Row
21 Column A - Inspect/repair leaking (not fully sealed) PRD and
blowdown valves
This
is a “leak” question (i.e., valve not sealed) and
not a “blowdown” event question. In addition,
inspection and repair frequency may differ.
Delete
question (Leaks are addressed in other form). If retained, move
this to the equipment leaks form. Differentiate frequency of
inspection and frequency of repair.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
“Inspect/repair
leaking (not fully sealed) PRD and blowdown valves”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Row
22 Column A - Other (specify)
|
EPA
appreciates the comment and will implement as suggested.
|
-0068
|
Add
the following questions to Table 1:
If
yes, provide the operator pressure of the equipment: Facility
piping (except gathering or transmission pipelines).
If
other method used, specify method.
If
yes, provide the operator pressure of the equipment: Gathering
or Transmission Pipeline venting.
If
other method used, specify method.
If
yes, provide the operator pressure of the equipment:
Compressors.
If
other method used, specify method.
If
yes, provide the operator pressure of the equipment:
Scrubbers/strainers.
If
other method used, specify method.
If
yes, provide the operator pressure of the equipment: Pig
launchers and receivers.
If
other method used, specify method.
If
yes, provide the operator pressure of the equipment: Emergency
shutdowns (regardless of equipment).
If
other method used, specify method.
If
yes, provide the operator pressure of the equipment: Other
equipment not specified.
If
other method used, specify method.
Cost
of hot taps per event ($)
Cost
of pipeline pump down per event ($)
Cost
of flexible membrane liners (pipelines) per event ($)
Cost
of inspection/repair of leaking (not fully sealed) PRD and
blowdown valves per event ($)
Cost
of other (specify) per event ($)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0061
|
EPA
should explicitly allow for engineering estimates to be applied
for sources collecting blowdown data (i.e. Subpart W) and should
not require estimates for those facilities that have not
collected data.
|
Companies
should provide best available data when responding to the ICR.
|
-0046
|
Many
facilities are not currently required to track blowdowns and
otherwise, have no reason to do so. Facilities newly subject to
Subpart W will be reporting blowdowns for the first time in 2017,
and can use BAMM for 2016 blowdown calculation inputs. Thus, EPA
should add a note that best available/engineering estimates are
allowed for all items on this tab where data is not actually
tracked.
|
Companies
should provide best available data when responding to the ICR.
|
-0048
|
While
most operators will likely certify that blowdowns occurred at
some time during 2015, that may be the only information known. We
are unaware of any state or federal regulations requiring oil and
natural gas operators to keep records of blowdown events or
cumulative volumes for oil wells.
|
Companies
should provide best available data when responding to the ICR.
|
-0061,
46
|
The
definition of blowdowns should exclude de minimis reporting
consistent with B.40 CFR Part 98, Subpart W.
The
ICR should follow the GHGRP and exclude all blowdowns of
equipment that is less than 50 actual cubic feet.
|
Companies
should provide best available data when responding to the ICR.
|
-0061
|
Blowdown
events routed to atmosphere or a flare should be the only events
for which EPA is requesting data. Equipment depressurization
events that are not released to atmosphere or routed to a flare
do not provide meaningful information for evaluating emission
impacts and should not be included within scope of the ICR.
|
EPA
has amended the definition of “Blowdown” to clarify
that equipment depressurization events that are not released to
atmosphere or routed to a control device are not to be included
in the ICR.
|
-0061
|
For
pipeline blowdowns, it is unclear which pipelines or sections of
pipelines would be required to be reported for a facility.
Pipelines can span great distances and connect gathering and
boosting to gas processing. To parse out the pipeline blowdowns
for a specific facility would not be a straightforward data
collection.
|
EPA
has amended Table 2 to request blowdown information from all
Transmission Pipeline Facilities and Gathering and Boosting
Facilities per the definitions provided in the ICR.
|
-0058
|
Blowdown
reporting should apply only to “Natural Gas Transmission
Pipeline Facilities.”
|
EPA
has amended Table 2 to request blowdown information from all
Transmission Pipeline Facilities and Gathering and Boosting
Facilities per the definitions provided in the ICR.
|
-0046
|
Blowdowns
are only routed to atmosphere, flare, or back to the process. GPA
Midstream is not aware of blowdowns being routed to a thermal
oxidizer, incinerator, or used as fuel.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should ask whether operators keep records of blowdown events for
the various equipment types. If the answer is “yes,”
then the additionally requested information should switch from
black to a cleared cell where the information can be provided.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
Only
Blowdown reporting should be required for Transmission Pipeline
Facilities in the Part 2 survey as the 2015 amendments to the
GHGRP focus on pipeline blowdown emissions only.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
ControlDevice
Tab
|
|
|
Table
1: Facility Information
|
|
-0054
|
Row
3 Column A - Number of control devices at the facility
|
EPA
has amended the Definitions Tab to include “Control
Device.”
|
|
Table
2: General Control Device Information
|
|
-0054
|
Each
control device is employed with a piece of equipment as a system.
The context or application of a control device is essential to
assessing the control device. Include information on the reason
for the device installation and the equipment it is tied to.
|
EPA
has amended each tab in the ICR to allow equipment to be linked
to a control device listed in the ControlDevice Tab.
|
-0054
|
Change
Heading to “2. General Control Device Information -
Complete for each Control Device/Equipment Pairing:”
|
EPA
has amended each tab in the ICR to allow equipment to be linked
to a control device listed in the ControlDevice Tab.
|
-0061
|
EPA
should use waste gas in lieu of natural gas when referring to the
control device feed gas in Table 2. General Control Device
Information.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
EPA
should delete ‘Release height’ and ‘Stack
diameter’ from Table 2. General Control Device Information.
This data is only a small fraction of the information needed to
accurately determine ground level concentrations.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
Tab
includes request for “Typical NG Flow to Device.” EPA
should define what “typical” means. Recommend
revising this request to average flow rate over the last 30 days.
|
EPA
has amended Table 2 to remove “Typical NG Flow to Device.”
|
-0061
|
EPA
should remove ‘Fraction of time control device is operated
(lit) while NG flow is present’ from Table 2. General
Control Device Information. It is unclear what “fraction of
time” is being requested.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061
|
For
thermal control devices, EPA needs to add the pilot and purge gas
flow rate as a data element in Table 2. General Control Device
Information. Since the pilot and purge, if utilized, is natural
gas (methane) and results in more waste of natural gas (methane)
and creation of CO2 and NOX emissions, the pilot and purge flow
rate will be needed to evaluate whether there is a benefit
associated with the thermal control, or more harm caused.
|
EPA
has amended Table 2 to request pilot and purge gas flow rate.
|
-0061
|
EPA
should include a new column in Table 2. General Control Device
Information identifying the source of waste gas fed to the flare.
Flares must be designed for the waste gas being burned and not
all waste gas sources are compatible with an existing flare.
|
EPA
has amended each tab in the ICR to allow equipment to be linked
to a control device listed in the ControlDevice Tab.
|
-0061
|
EPA
should request an ‘Estimated Volume of Waste gas fed to the
control device in 2015’ instead of the ‘Typical NG
Flow to Device (scf/hr)’ in Table 2. General Control Device
Information. Waste gas fed to control devices is not typically
measured. The flow is typically inconsistent and turbulent making
measurement difficult, if not impossible. It is also not clear
whether EPA wants the waste gas, the pilot and purge gas or all
gas in this question. In combination with the “fraction of
time” column, it is unclear what period of time the
flowrate should be given. The volume of waste gas changes from
year to year, primarily in proportion to liquid production
volumes (this assumes tank vapors are the primary feed source).
|
EPA
has amended Table 2 to request “Estimated Cumulative Volume
Of Waste Gas fed to Device in 2016 (including purge gas) (scf).”
|
-0061
|
EPA
should ask for ‘Maximum heat input capacity to the control
device (MMBtu/hr)’ as an alternative to ‘Maximum flow
capacity for device’ in Table 2. General Control Device
Information since control devices are typically limited not by
the flow but by the heat input they can handle which is dependent
upon the flow and heating value of the waste gas. If the ‘Maximum
flow capacity for device’ is not available, the ‘Maximum
heat input capacity to device’ can be provided.
|
EPA
has amended Table 2 to additionally request “Maximum Heat
Input Capacity to the Control Device (MMBtu/hr).”
|
-0068
|
Add
the following questions to Table 2:
Typical
NG Flow to Device,
including pilot gas in flares (scf/hr)
If
control device is a combustion devices, what type of device is
it? (open flare, enclosed flare, thermal combustor, open pit
flare, other)
If
combustion device is a flare, does it have a continuous pilot or
electronic ignition device?
If
control device is a combustion devices, does it have a monitor
to ensure a continuous flame?
Do
operators collect continuous data on flow volumes to the flare?
Does
the control device have monitoring to indicate when the device
malfunctions or shuts down?
If
the control device has a monitor to ensure continuous operation/
flame, describe the device used.
|
EPA
has amended Table 2 to request “Purge Gas Flow Rate”
and “Pilot Gas Flow Rate.”
EPA
has requested “Type of Ignition Source” for thermal
devices.
EPA
has requested information on continuous monitoring of control
device parameters.
|
|
Table
3: Control Device Cost Information
|
|
-0054
|
Costs
may not be available in the event of acquired assets. Allow the
use of engineering estimates.
|
Companies
should provide best available data when responding to the ICR.
|
-0061
|
In
Table 3. General Control Device Cost Information, EPA should
clarify that total installed capital expenditure includes labor
costs, engineering costs, or costs associated with necessary pad
expansions. The year the control device was installed, the
purchase cost of the equipment, and the total capital cost of the
control device is not always available. The option should be
given to state this information is not available.
|
Companies
should provide best available data when responding to the ICR.
|
-0054
|
Row
28-45 Column D - Total Capital Installed Cost
For
older equipment, this may not be available. Older equipment
would also not provide an accurate cost estimate compared to
current costs.
This
question should only apply to certain control devices
constructed after a defined date.
|
Companies
should provide best available data when responding to the ICR.
|
-0054
|
Row
28-45 Column E - Annual Operating and Maintenance Cost ($/yr in
2015)
|
Companies
should provide best available data when responding to the ICR.
|
-0068
|
Add
“Administrative cost to size and source the control device
($)” to Table 3.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other/General
|
|
-0050,
49
|
Modify
to focus on current control device costs as opposed to both
current and historical.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0067
|
EPA
should amend Part 2M (Control Device Tab) to include the
additional following question:
• If
an internal thermal combustor/thermal oxidizer or flare is used,
what methods are used to check the status of the pilot, keep the
pilot burning, and/or reignite the pilot if it goes out? (mark
all that apply)
Monitoring
Options:
a.
Thermocouple
b.
Flame Ionization Detector
c.
Periodic checks with an IR Camera
d.
Alarm that notifies when no flame in the pilot is present
e.
Duplicate/redundant pilots
f.
Liquid knockout scrubber to prevent quenching of the pilot flame
g.
Flare/Combustor is designed to reignite automatically
h.
Other (please describe):
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
The
intro tab instructions state to “complete this sheet only
if flares, combustors, vapor recovery units, or other ‘add-on’
control devices are used at the facility.” EPA Supporting
Statement at 34. This instruction and the “control device
type” drop-down menu on the equipment tab for control
devices seem to assume that only control devices that control a
hydrocarbon stream should be listed.
|
EPA
has amended the Definitions Tab to include “Control
Device.”
|
-0046
|
EPA
does not collect any information on the primary driver for
installation of controls, which will be important when EPA
determines whether and where controls should be required on
existing equipment.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
The
form does not accurately account for acid gas flares, which may
have assist gas because the form does not distinguish between
waste gas and the total combusted gas (which includes waste gas
and assist gas).
|
EPA
has amended the ICR to include a definition for “Waste
Gas.”
|
-0046
|
Several
of the columns use the term “NG stream,” but more
clarity is required. It is not clear, for example, whether an
acid gas stream be reported in these columns. If so, EPA should
clarify this, as respondents might not consider the acid gas
stream to be an “NG stream.”
|
EPA
has amended the ControlDevice Tab to specify “waste gas”
rather than NG.
|
-0046
|
EPA
should ask whether there is a waste gas meter or continuous
parameter monitoring, and if so, what types of parameters are
monitored. Those would be essential facts to understanding
whether further control would be required.
|
EPA
appreciates the comment and will implement as suggested.
|
-0049
|
EPA
should seek installation cost estimates to better understand the
full cost of new emission control requirements.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
Cost
data cannot always be extrapolated from one basin to another.
Costs for installation of the same control device may be
significantly more in remote areas than in basins closer to
metropolitan areas due to differences in the availability, or
lack of availability, of manpower and equipment, and additional
transportation or travel charges.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should also be aware that economic impacts are often considered
on a well-by-well basis.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
Asset
sales and trades will complicate the collection of control device
cost data. Without proper context around whether a control device
was added as a retrofit, repurposed from another facility, or
part of new construction, and the approximate date of
installation, it is difficult to make any useful conclusions
about control cost data.
|
EPA
has amended Table 3 to request “Was Control Device
Installation Part of New Construction?”
|
-0049
|
Tab
contains a request for the, “Fraction of time control
device is operated while NG flow is present,” which is an
inappropriate request as operators are not required to
continuously monitor the flow of natural gas to a control device
in all areas. EPA should revise the request to “Fraction of
time control device is operated and the well is producing.”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Part
2 – General/Other/Missing Sources
|
|
-0061
|
EPA
should allow for an operator to voluntarily report additional
information.
|
EPA
will include the ability upload additional data (process
simulations, supplemental data, etc.) in e-GGRT.
|
-0050,
49, 48
|
Modify
“Applicable Environmental Regulations” to clarify
that EPA is requesting applicable state rules which apply only to
air regulations. EPA should also include an option to write in
other applicable requirements such as Tribal Federal
Implementation Plan (FIP) regulations or requirements from a
federal Consent Decree. It is inappropriate for EPA to use this
effort to gather information on, for example, noise ordinances,
road traffic requirements, or stormwater permitting.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
The
current format includes “applicable regulations”
checklists in most of the individual source-specific forms. This
inquiry is redundant, and instead should include a single
checklist in the “Facilities” worksheet. This
simplifies the request, eliminates redundancies, and provides a
single point of reference regarding facility regulatory
applicability.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
EPA
should develop descriptions for many of the data fields/survey
questions to improve clarity, provide context, etc.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0022
|
Where
emissions data are collected, should also collect information on
the test methods used.
|
EPA
appreciates the comment and will implement as suggested.
|
|
Other/General
|
|
|
CBI
Protection
|
|
-0036,
41, 70, 65, 46, 49, 52, 59
|
EPA
should allow operators to request CBI protection for any/all
aspects of the ICR (Part 1 and Part 2).
The
nature of the collection of all of this data in one location and
the fact that not all business competitors in this industry
segment will be required to provide this information creates a
unique situation that EPA can and should address for this ICR.
Any
information that can be gained about available capacity in a gas
processing plant or a pipeline, or about the quality of gas
treated or transported, could place competitors at an advantage
or a corresponding disadvantage when negotiating contracts.
EPA
should appreciate the competitive nature of the natural gas
industry and maintain confidentiality of company- and
facility-identifying information in this ICR process.
EPA's
actions in effect could create winners (companies who will enjoy
access to a comprehensive data set on competitors while
revealing no information themselves) and losers (companies
required to disclose data).
Company-
and facility-identification data, which we urge EPA to keep
confidential, does not constitute emission data. Congress
excluded "emission data" from confidentiality
protection under Clean Air Act Section 114(c) but did not define
the term.
In
their current state, the proposed ICR and EPA's attendant
"not-CBI" designations could have the unintended
consequence of presenting serious national security concerns
because the ICR would require companies to provide substantial
amounts of information - wrapped up in a single package easily
accessible to members of the public and including specific
information on the name, address, and geographic coordinates of
the facility to which the data pertains - regarding facilities
that are part of the critical infrastructure of the United
States as designated by the Department of Homeland Security
("DHS").
The
data that EPA is currently proposing to leave as unprotected
information is the same sort of information that competitors are
generally prohibited from sharing under the Sherman Act.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0058
|
Company
data subject to non-disclosure agreement in academic studies
should be protected as Confidential Business Information (CBI).
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0052
|
Specific
CBI data concerns:
General
Category: Facility; Data Element; Number of months the facility
operated in 2015:
The
number of months the facility operated in a given year, i.e.
uptime / downtime, is a data element that could bear on the
reliability of the pipeline or midstream operator - or it could
be unfairly portrayed by a competitor as an indicator of
reliability.
General
Category: Tanks Separators: Data Element: Reid vapor pressure of
feed material (psig):
Public
disclosure of data regarding the quality or other specific
aspects of the product could lead a company to target the better
quality gas sources on a competitor's system for acquisition,
leaving that competitor to deal with greater quantities of
off-specification gas and higher transaction costs.
General
Category: Tanks Separators: Data Elements; Specific gravity of
feed material (relative to water at 4° C); Gas Liquid Ratio
(scf/bbl):
The
public disclosure of data regarding overall product quality
could work to the disadvantage of the disclosing company because
it would allow companies to target the better quality gas
sources on competitors' systems for acquisition, once again
leaving the competitor to deal with greater quantities of
off-specification gas and higher transaction costs.
General
Category: AGRU\a Elements: H2S concentration in feed gas (% by
volh CO2 concentration in feed gas (% by vol): H2S concentration
in treated gas (% by vol): CO2 concentration in treatedsas (% by
vol):
5.
General Category; Dehvd: Data Elements; H2O concentration in
feed sas (% by volh CO2 concentration in feed sas (% by vol);
CH4 concentration in feed sas (% by vol); H2O concentration in
treated sas (% by vol): CO2 concentration in treated sas (% by
vol): CH4 concentration in treated sas (% by vol):
General
Category: Corny; Data Elements: If no, please provide the total
time the compressor was in operating-mode in RY2015. (hours); If
no, please provide the total time the compressor was in
standby-pressurized-mode in RY2015. (hours); If no, please
provide the total time the compressor was in
not-operating-depressurized-mode in RY2015. (hours):
General
Category: Control Device; Data Element: Net Heating Value of NG
Stream (btu/scf):
General
Category: Control Device; Data Elements: Purchased Equipment
Costs ($}; Total Capital Installed ($h Annual Operating and
Maintenance Cost ($/yr in 2015:
Companies
strive to keep cost data private because companies in a
competitive industry do not want the competition to gain a
glimpse into their cost structure. Cost data can be used in
negotiations with potential customers, who can argue that a
facility with lower costs should provide services at a lower
price. Competitors seeking a company's business can paint the
same picture to potential customers in order to take business
away. Public disclosure of cost data would be used against the
disclosing company by customers and competitors.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0070
|
To
the extent that some of the material submitted pursuant to the
ICR may contain trade secrets, geological and geophysical data on
wells, or information that is otherwise confidential or
privileged, and therefore exempt from public disclosure under
FOIA, EPA should clearly establish procedures in the ICR on how
to submit these materials.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0070
|
EPA
should make further accommodation for companies and facilities
whose ICR-responsive data may be the subject of discovery in
relation to pending civil litigation or unrelated enforcement
action. This is because some of this data may not easily fit into
any of the FOIA exemptions that would withhold its disclosure to
the public. In some cases, the data itself may be actual subject
of the litigation and the issue of its accuracy or completeness
may not be resolved until the litigation itself is resolved.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0046,
52
|
GPA
Midstream requests full CIPSEA protection for the information
requested by the ICR. At a minimum, EPA must take the “CIPSEA
Pledge” to protect the identity of the company and facility
responding to the ICR. For Data That Are Not Protected From
Disclosure Under CIPSEA, the Scope of Data Elements Protected as
Confidential Business Information Should be Expanded.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0052
|
Either
the entirety of the identity of the responding company and the
facility that is the subject of the ICR should be protected so
that no connection can be made between the data and the company
or facility at issue, or if such company or facility identifier
information is not protected from disclosure as CBI, then EPA
should expand additional data elements as CBI to provide
additional protections to the responding company's competitive
position.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
-0052
|
EPA
should take a fresh look at CBI issues as they are presented
within the particular context of the ICR, rather than simply rely
upon the conclusions reached in connection with the GHGRP. The
GHGRP is conducted on an industry-wide basis, which is not the
case for the ICR questionnaires. Also, information collected
under Subpart W is on an aggregate basis.
|
See
“Summary of Comments and Responses” memo for
responses to all CBI-related comments.
|
|
e-GGRT
|
|
-0061,
27, 42, 54, 46
|
Commenters
expressed general concern about using the e-GGRT system for
responding to the ICR.
EPA
should perform full scale testing of the submittal process to
ensure the system is working adequately
Ensure
that e-GGRT can support the number of users that will be using
e-GGRT at around the same timeframe as GHG reporting under the
GHGRP.
Allow
other options for ICR submittals instead or in addition to the
use of e-GGRT
EPA
must provide a “sandbox testing” time of at least 60
days for e-GGRT. Data collection interpretations may be made
during the programming of e-GGRT which conflict with EPA’s
written requirement or are otherwise incorrect. The public will
need an opportunity to review e-GGRT to ensure it aligns exactly
with the final Excel data collection templates for the ICR.
|
EPA
has conducted full scale testing of the submittal process to
ensure that the e-GGRT system is working as it should.
|
-0031
|
EPA
should establish a help desk email/line that will respond timely
to questions and report submittal problems.
|
EPA
will establish a help desk email/line for respondents of the ICR.
|
-0046
|
Simplify
e-GGRT Reporting Requirements. EPA should review the facility
registration process to see how it can be streamlined before
asking industry to register thousands of facilities.
|
EPA
has optimized the e-GGRT system to ease the registration process
for facilities.
|
|
Legal
|
|
-0068
|
EPA
has ample authority under Section 114 of the CAA to issue a broad
and detailed ICR.
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0020,
36, 41, 63, 46, 49, 52
|
Commenters
suggested that EPA should not proceed with the ICR.
It
does not provide the agency with information of practical
utility and does not support EPA’s function.
Additional
costs of retrofitting pursuant to a new rule reduce the amount
of money operators have to drill new wells which deprives States
of additional revenue.
EPA
should engage production companies to develop a new survey which
captures the emission data EPA is seeking and does not
overburden respondents.
EPA
is not authorized under the CAA to promulgate national standards
of performance for existing oil and gas emission sources because
these existing sources are in categories that are currently
regulated under Section 112 of the CAA. The EPA does not have
the authority to proceed with an ICR that will impose added
burden on a segment of the industry that is already regulated.
The promulgation of this ICR is neither in the spirit of nor in
legal step with the CAA.
There
is no need for a separate and unique regulatory process beyond
that already established through the state and local governments
under the authority of the CAA.
Methane
does not appear to be, and should not be considered, a factor in
the global climate change problem as a greenhouse gas (GHG).
Therefore, it is not in the best interests of the American
economy or the American people to create a special rule to
control a gas that has not been considered a priority pollutant
in the past and has just recently become an issue as a GHG.
EPA
is not authorized to regulate methane emissions from existing
oil and natural gas facilities under Section 111(d).
EPA
is not authorized to regulate existing oil and natural gas
facilities under Section 111(d), because the oil and gas sector
is already a regulated “source category” under
Section 112 through regulations promulgated at 40 CFR Part 63,
Subpart HH (regulating oil and natural gas production
facilities) and Subpart HHH (regulating natural gas transmission
and storage facilities).
EPA
has neglected to do a proper endangerment finding on methane in
general and from the oil and natural gas industry. A full,
honest endangerment finding would likely reveal that the small
amount of methane emissions from the wellhead is more than
offset by the significant greenhouse gas reductions delivered by
natural gas at the consumer side and especially in the power
sector.
At
a minimum, EPA should delay issuance of the ICR, and the Section
111 (d) rulemaking process, until the Supreme Court has ruled on
the Section 112 Exclusion issue.
A
valid Section 111(b) NSPS for methane emissions must be in place
before EPA may promulgate an ESPS for methane emissions under
Section 111(d), but a valid 111(b) NSPS does not exist in this
case.
EPA
failed to make the requisite finding to expand the oil and gas
source category. EPA failed to make the requisite endangerment
and cause-or-contribute findings for the single GHG, methane, as
emitted by stationary oil and gas sources.
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0060
(dup 62), 41, 51, 46, 59
|
Numerous
data requests in the ICR are problematic from a legal aspect per
the requirements in the Paperwork Reduction Act, including:
Limited
or no practical utility;
Duplicative
to other agency or state data requests;
And/or
would place an undue cost and administrative burden.
This
was not accounted for in EPA’s estimates on respondents in
violation of the Paperwork Reduction Act.
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0046
|
EPA
should make additional changes to the ICR to ensure the practical
utility of the information requested as required by the Paperwork
Reduction Act.
Acid
gas removal units (“AGRUs”) are included in the ICR,
however they are not a significant source of methane or VOC
emissions and have been subject to an NSPS since January 20,
1984 under Subpart LLL. GPA Midstream questions the practical
utility of having industry spend time and capital to collect
this information when the source has been recently evaluated for
emissions under NSPS Subpart OOOOa and when there will be very
few existing AGRUs.
Dehydration
units are not included in NSPS Subpart OOOOa; existing
dehydration units are already regulated directly under NESHAP
Subpart HH/HHH. GPA Midstream questions the utility of industry
spending time and capital providing this information to EPA.
Control
devices on gathering and processing facilities are commonly used
to control streams from multiple emission sources, however the
control device tab does not connect the control device with the
specific sources they are controlling.
The
proposed deadline for responding to Part 2 of the ICR will lead
to EPA receiving outdated information.
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0029,
40, 41, 51, 59
|
Several
requested items do not apply to the stated mission of the ICR.
Delete the following sections that do not apply to the stated
mission of the ICR:
Attachment
2G Part 1
Attachment
2H
Attachment
2I Parts 2 and 4
Attachment
2J Part 2
All
references to: produced water management, ownership of land,
well depth and length, shut in pressure, casing or tubing
diameter, and Reid Vapor Pressure of feed material.
Only
15 of 580 requested items are applicable in Attachment 2D
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0037,
39, 43, 68
|
Consistent
with section 114 of the Clean Air Act, EPA should make data
broadly publicly available.
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0034
|
EPA
should design the ICR to be policy-neutral. The current ICR
appears to be narrowly crafted to provide answers to a
pre-determined outcome of regulating existing sources under
§111(d) that mirrors the recently finalized NSPS OOOOa
regulations. EPA must be open to all policy tools available to
reduce methane emissions (i.e. Gas STAR, Methane Challenge, etc).
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0040,
48
|
The
following information is outside of EPA’s regulatory
authority under CAA and should be eliminated:
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0070
|
EPA
should assure that information submitted pursuant to the ICR will
be used only for standard setting or rulemaking by the Agency
pursuant to Section lll(d) of the Clean Air Act ("CAA").
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0046
|
EPA
is not authorized to issue emission guidelines for methane from
existing oil and natural gas facilities under 111(d), because
before EPA may issue guidelines to the States under Section
111(d) for existing oil and natural gas facilities, the agency
first must properly issue new source performance standards for
the oil and natural gas source category under Section 111(b).
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0046
|
The
language of Section 111 makes plain that it is the States that
are authorized to establish standards of performance under
Section 111(d).
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0046
|
If
EPA proceeds to propose a final ICR, EPA should be clear in
expressing that the ICR would not be used to develop standards of
performance under 111(d) that are more stringent than final
standards of performance for new sources under Section 111(b).
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
-0048
|
Under
Section 111, EPA has the authority to create and use
subcategorization to focus regulations that are suited to
appropriate elements of the industry. EPA needs to utilize this
authority in the context of existing source regulation under
Section 111(d) because of the significant diversity of the
American oil and natural gas production industry.
|
See
“Summary of Comments and Responses” memo for
responses to all legal-related comments.
|
|
General
Support/Clarification
|
|
-0033,
19, 24, 25, 32, 37, 39, 43, 47, 55, 56, 69
|
Commenters
provided general support for EPA’s methane efforts/ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0060
(dup 62), 61
|
Commenters
requested general clarification of instructions for Part 1 and
Part 2.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0060
(dup 62)
|
General
request for clarification and further detail in Part 1 and Part 2
definitions
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0045
|
Commenter
expressed general concern about the impact of regulations on U.S.
industry.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Edits/Deletes/Additions
|
|
-0027,
28, 36, 38, 41, 50, 51, 58, 54, 49, 48
|
EPA
should integrate information already available through other
reporting programs (ex. GHGRP, state and federal air permits,
etc.) and use the ICR to collect supplemental information. In
some cases, existing data should be sufficient.
EPA
indicates that data available from the
GHGRP,
including 40 CFR Part 98 Subpart W data, will not be duplicated
in ICR Supporting Statement.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
49
|
Many
of the terms defined are different between Part 1 and Part 2.
Differences in definitions should be minimized and if they are
different; the definitions should be compatible and the
differences explained with any boundaries defined amongst
industry segments.
|
EPA
has reviewed Part 1 and Part 2 definitions to ensure continuity
of definitions throughout the ICR.
|
-0058,
54
|
Definitions
should be consistent with Methane NSPS and GHGRP. Because GHGRP
information will be a key resource in completing the ICR, GHGRP
definitions should be used unless there is a compelling reason
otherwise. If there is not a GHGRP definition, but Subpart
OOOO(a) provides a definition, that definition should be used.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0020
|
Remove
Part 2 of the ICR, or, if not, select a representative sample of
marginal well operators to be included in the distribution of the
survey
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0028,
51, 48
|
EPA
needs to obtain information that reflects varying emissions
throughout the year.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0020
|
Request
cost data for emission reduction technologies and retrofits
|
EPA
has requested cost data from emission reduction technologies and
retrofits in the ControlDevice Tab in Part 2 of the ICR.
|
-0020
|
Request
only information which is contained within an operator’s
current records
|
Companies
should provide best available data when responding to the ICR.
|
-0037,
39, 43, 56
|
EPA
should gather data on more sources (i.e. sources that do not
already have existing standards). EPA should add the following
sources:
Leaks
from all aboveground facilities, including “city gates”
and other facilities in the distribution segment of the natural
gas industry.
Pneumatic
controllers and pumps of all types, including intermittent-bleed
controllers, “low-bleed” pneumatic controllers, and
gas-assist glycol dehydrator pumps.
Tanks
of all types, including tanks that store oil, condensate, or
produced water, at all sites and including tanks that have lower
expected emissions.
Reciprocating
compressors at all sites, including well pads.
Centrifugal
compressors at all sites, including well pads.
Offshore
oil and gas production platforms.
Liquids
unloading operations from vertical and horizontal wells.
Blowdown
events from wells or other equipment.
Venting
and flaring of associated gas from oil wells.
Open
impoundments for handling produced water, and disposal
facilities for produced water utilizing evaporation and/or
percolation.
Compressor
engine exhaust, where methane is likely present from incomplete
combustion of fuel gas.
Acid
gas removal units and dehydrators throughout the sector.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0034
|
Add
the following questions:
1)
What are the total voluntary reductions achieved by companies
through EPA Gas STAR, EPA Methane Challenge and other voluntary
programs? What voluntary reductions have been achieved by
companies since 2012?
2)
What fraction of a company’s assets are included in the EPA
Greenhouse Gas Reporting Program (GHGRP)?
3)
Does the company have a corporate or asset level methane
monitoring program? What is the monitoring frequency of such
programs?
4)
Considering advances in methane emissions monitoring, including
continuous emissions monitoring, has the company applied any
advanced monitoring technologies (beyond approved methods in NSPS
OOOOs)?
5)
Has the company developed corporate-wide or large-scale directed
inspection and maintenance (DI&M) or predictive analytical
that can aid in identification and minimization of methane
emissions?
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0036
|
All
information requests within the ICR which are has plant or
transmission based be removed from those surveys that are
intended to be submitted to production companies. Examples
include:
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0036
|
Add
request for installation cost estimates to better understand the
full cost of new emission control requirements within the ICR.
|
EPA
has requested cost data from emission reduction technologies and
retrofits in the ControlDevice Tab in Part 2 of the ICR.
|
-0044,
54
|
EPA
should adopt OOOOa/OOOO/Subpart W applicability language for the
final ICR. The survey adds unnecessary complexity by failing to
use definitions, equipment categories, etc., that are already
available or established in other regulations.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0031,
42, 54, 46
|
EPA
should clarify how sources should respond to questions if company
records are not available (Should cells be left blank or should
“not available” be entered? Will there be spaces for
comments allowed?). Divestitures and acquisitions can raise
significant challenges regarding access to data. EPA should
acknowledge that there may be instances where respondents cannot
answer survey questions because historical information is
unavailable.
Tabs
that require a “not available” or “not
applicable” response option are the following:
Control
Device Equipment tab where the respondent is asked to provide
the year a control device is installed, purchased equipment
costs and total capital installed cost. Depending on the age of
the facility, the owner or operator will not have this
information. This will be especially true if the facility has
been a part of any divestiture or acquisition, as is common in
the oil and gas industry.
Facility
Tab, Sub-Sections 1 and 2, “Contact Phone 2” and
“Contact Email 2” should be allowed be left blank.
Tanks
Separator Tab, Sub-Section 5, Hours dump valve stuck in 2015?
Gathering and boosting facilities were not required to track
this in 2015 and the data will not be available for many
facilities.
Pneumatics
Tab, Sub-Section 3, How many controllers were found
malfunctioning in the past year? Gathering and boosting
facilities were not required to track this information and
therefore may not have the requested data available for many
facilities.
Equipment
Leaks Tab, Sub-Sections 2, Total number of components monitored
for Leaks during the most recent monitoring survey? There are
state programs that require IR camera monitoring, but do not
require the facility to keep an actual component count.
Equipment
Leak Tab, Sub-Section 4, Measurement Cost. Gathering and
boosting facilities were not required to track this information
and therefore may not have the requested data available for many
facilities.
Control
Device Tab, Sub-Section 3, Natural Gas Consumption Rate.”
Sub-Section 2, “Release height (ft)” and “Stack
diameter (ft)”; these are Not Applicable for Vapor
Recovery Units.
Blowdowns
Tab, Source-specific information sheet for equipment/pipeline
blowdowns. Complete form based on available information for
2015. If your facility is first required to track this
information in 2016, you may estimate 2015 blowdown
events/emissions as twice the events/emissions determined in
January through June 2016. EPA does not consider that the
facility may not be required to track blowdowns or may be using
BAMM for January – June 2016.
|
Companies
should provide best available data when responding to the ICR.
|
-0058
|
Eliminate
component counts from ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0067
|
EPA
should amend the verification statement with the
following
text: I certify that I have read and understand the best
practices associated with developing an inventory as described in
EPA’s ICR and that the statements and information are to
the best of my knowledge and belief true, accurate, and complete.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0066
|
EPA
should request findings from inspection reports or other routine
maintenance programs, documenting leaks, direct venting of tanks,
open thief hatches or valves, and other events linked to emission
events.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0066
|
EPA
should request process diagrams of equipment trains, particularly
describing the routing of multiple sources to individual control
units to evaluate the potential for flow volume to exceed the
capacity of control equipment.
|
EPA
will include the ability upload additional data (process
simulations, supplemental data, etc.) in e-GGRT.
|
-0066
|
EPA
should request the compliance status for each compressor station
with applicable environmental permits, including state and local,
for the past 5 years and a description of the nature of any
violations, if relevant to emissions.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
The
survey should clearly indicate the applicable year upon which the
response should be based.
|
EPA
has indicated that companies should provide 2016 data (when
applicable).
|
-0049,
59
|
“Storage
Tank” and “Vessel” are used interchangeably,
which could create confusion. Suggest instead using “Tank”
for storage equipment (e.g., storage tank) and “Vessel”
reserved for process equipment (e.g., separator).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0054
|
The
reporting tool should be flexible and allow rows, etc., to be
added to accommodate facility equipment counts. The draft Part 2
survey is “locked,” does not allow the addition of
rows (e.g., to include all of the compressors located at a
facility), and inter-related tables sometime do not allow the
same number of data entries.
|
EPA
has added more rows to the ICR to allow for all necessary data to
be reported.
|
-0046
|
Several
of the equipment tabs have a section where the respondent is
required to check applicable regulations.
For
each tab with this section the column header uses the words
“well site.” That should be changed to “facility”
to avoid confusion.
Each
tab with this section also lists 43 CFR Part 3100 Subpart 3179
which is the proposed methane rule for the Bureau of Land
Management. Since this rule is proposed and not yet effective,
it should be removed from the list.
A
check box should be added for “enforceable permit limits,”
which would be used by facilities that have enforceable limits
or monitoring/recordkeeping requirements under synthetic minor
permits.
On
the Dehydrator Unit Equipment tab, 40 CFR Part 60 Subpart OOOO
and OOOOa are listed as regulations that could apply. Neither
regulation has requirements for dehydrator units and should be
removed.
On
the Acid Gas Removal Unit Equipment tab, 40 CFR Part 60 Subpart
KKK is listed under regulations that could apply. This should be
changed to 40 CFR Part 60 Subpart LLL which is the rule for
sweetening units.
On
the Tanks Separators Equipment tab, 40 CFR Part 60 Subpart Kb
should be added to the list.
On
the Compressor Equipment tab, 40 CFR Part 60 Subpart KKK should
be added to the list.
|
EPA
appreciates the comment and will implement as suggested.
|
|
Marginal
Wells/Production/Low Emitting Facilities
|
|
-0061,
49
|
Adding
controls to reduce or eliminate methane emissions from existing
oil and gas production operations is not a “one-size-fits-all”
proposition. EPA must consider many direct and indirect factors
before developing an accurate cost estimate for installing and
operating methane controls.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0028,
35, 51, 57, 48, 49
|
EPA
must understand the economic impact of additional regulations on
marginal wells. EPA must assess the implications of regulations
on the remaining useful life of marginal wells.
|
EPA
has requested Production Well Point Costs in Table 1B of the
ProdnWell Tab.
|
-0028,
41, 50, 51, 48
|
O&G
production starts at an initial production rate and then begins
to decline as the resource is extracted from its reservoir. EPA
needs to have a thorough understanding of this in order to
provide a structure to assure that American O&G resources are
developed and maintained. The ICR should provide the information
needed to create this level of understanding.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0057
|
EPA
should revisit the small producer exemption in any further
methane rulemaking.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0034
|
The
EPA should exclude low-emitting facilities from the ICR,
considering the fact that peer-reviewed science supports the
relation of methane emissions to throughput.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0034
|
EPA
should employ the de minimis exception to any of the affected
sites/facilities with a potential to emit less than the values
derived from the potential uncontrolled rates from the Technical
Support Document (TSD)
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0057
|
Failure
to understand this pricing structure and the market challenges
facing small producers by
EPA
will have a devastating impact on producer’s ability to
stay in business. EPA fails to understand that most marginal well
producers get prices significantly below the posted WTI price.
Most marginal operators sales are based off a lower, regional
market price, and the products are discounted below the regional
price. Often contracts are for as much as $6-10 per barrel below
the regional price.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0058
|
EPA
should reduce reporting for low-emitting Liquefied Natural Gas
(LNG) facilities. More than 95% of existing LNG peak shaving
storage facilities will be excluded from the source category
subject to the NSPS, because they are inside the LDC custody
transfer station, and this type of facility (when new or
modified) is excluded from the source category subject to the
111(b) NSPS. Due to their inherent operations as well as
stringent requirements under federal pipeline safety regulations,
greenhouse gas emissions from both LNG peak shaving storage
facilities and LNG import/export terminals are already extremely
low
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
|
Other
Comments
|
|
-0061,
42, 46, 49, 48
|
Limit
ICR to facilities that are not subject to NSPS OOOO or OOOOa, or
other NSPSs (facilities built after September 18, 2015).
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
59
|
EPA
should publish the emission calculation methodologies intended to
be used and allow the public time to provide comments on the
appropriateness and accuracy of the proposed calculations.
The
data collected in the proposed ICR appears to imply an emission
calculation method that is not appropriate for the emission
source and pollutant for which it is proposed
Subpart
W emission factors would not be satisfactory for regulatory
purposes and urges EPA to define the set of emission
calculations it intends on utilizing before surveys are
distributed
EPA
should not utilize the Direct Emissions Measurement Data
collected with the ICR to estimate emissions, unless they have
sufficient data to assure that it is accurate and representative
Considering
the primary variables that impact the emissions from each type
of equipment will enable the model plant approach to establish
more cost effective boundaries
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0061,
60
|
EPA
should clarify that each owner/operator is only responsible to
report for their equipment that is owned and operated at each
location as of December 31, 2015.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0023
|
NC
WARN’s filed complaint with the EPA
(www.ncwarn.org/wp-content/uploads/EPA-OIG_NCWARN_Complaint_6-8-16.pdf)
calls into question several of the studies relied upon by EPA in
its assessment of methane leaking and venting from natural gas
production/distribution.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0029,
48, 59
|
Recommended
that EPA reach out to the EPA’s enforcement group currently
working on CAA Section 114 requests to get an accurate
understanding of the magnitude of the ICR/amount of time that
will be required.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0037,
39, 43
|
Commenters
urge EPA to continue to assess
effective
policy-design approaches to minimize emissions from existing
sources relying on the
significant
information already available and that the administration used to
develop previous New
Source
Pollution Standards, the BLM rule, and the control techniques
guidelines for oil and gas sources in ozone-constrained areas.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0039
|
EPA
should pay specific attention to data collection relevant for
evaluating the impact of oil and gas operations in communities
already overburdened with pollution. EPA should implement all
elements of its “Guidance on Considering Environmental
Justice During the Development of a Regulatory Action.”
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0034
|
EPA
should carefully evaluate emission control experiences and
cost-estimates to account for regional variations. Any cost data
received by the operators must be analyzed carefully and we
highly recommend any average cost-estimates must be evaluated on
a regional basis and must be weighted or normalized in an
appropriate manner.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0034
|
ONE
Future had commissioned ICF International (ICF) to conduct an
analysis of the marginal abatement cost (MAC) of various methane
emission abatement technologies and work practices for the
natural gas industry. The study was released in June 2016 and can
be found at
http://www.onefuture.us/wp-content/uploads/2016/06/ONE-Future-MAC-Final-6-1.pdf.
This analysis represents the most updated average cost estimates
for various emission control technologies and work-practices.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0040
|
Reduce
the scope of the proposed ICR by performing it in three parts as
follows:
a.
ICR 1 should consist of Attachment lA name, address, contact,
number of facilities, and number of producing wells, and should
be sent to all 22,500 operators. No less than 60-120 days should
be allowed for operators to complete and return the survey.
b.
ICR 2 should consist of Attachment lA parts 1-3 and should be
sent to a statistically representative number of operators based
upon an evaluation of ICR
1.
No less than 180 days should be allowed for operators to complete
and return the survey.
c.
ICR 3 should consist of Attachment 20; Attachment 2E parts 3 and
4; Attachment 2F parts 1, 2, 3, 5, and 6; Attachment 2G,
Attachment 21, Attachment 2J, Attachment 2K, Attachment 2L, and
Attachment 2M and should be sent to a statistically
representative number of operators based upon an evaluation of
ICR 2. No less than 180 days should be allowed for operators to
complete and return the survey.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0041,
51
|
States
should be allowed to decide what additional emission control
measures should be required, if any.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0041,
50, 51
|
The
draft ICR and potential future regulation at existing sources are
unlikely to result in any reduction in emissions to the
atmosphere because the potential emissions at these sources are
in decline or nonexistent. Cost of implementation outweighs the
emission benefits.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0047
|
EPA
should collect information on operations known to contribute to
emissions such as, but not limited to, inadequately-sized control
equipment and direct venting of tanks through open thief hatches.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0047,
69
|
EPA
should collect both methane and additional air toxics data
together in the ICR. It would be more efficient and timely to
seek this information now to inform regulatory action, and to do
so promptly and expeditiously, rather than delaying air toxics
data collection and the protections for public health that such
data will enable.
|
EPA
has amended the ICR to request information on additional air
toxics, when applicable.
|
-0067
|
Require
all industry respondents to develop and submit a Quality
Assurance Plan that incorporates certain best practices with
their ICR responses. EPA must require operators to use best
practices to conduct counts of process and pollution control
equipment in response to Part 1 and 2 EPA’s ICR.
Recommended Best Practices:
Designate
a lead individual who is responsible for completing the ICR on
behalf of the company and who is accountable for the accuracy of
the responses.
Designate
key personnel, other than the lead individual, who will gather
the requested information. These individuals should have
knowledge of the processes, the equipment and their respective
locations.
Develop
a written plan that describes where the counting will take
place, for example: at the production sites, at field offices,
and/or at central locations that have access to detailed
records. Also specify when the counting should start and when it
needs to be completed. Finally, indicate how the counting will
be done (e.g., by review of company equipment lists, piping and
instrumentation diagrams (P&IDs), original purchase orders
or equipment design documents, field counts, etc.).
Where
actual field counts are not performed, review the accuracy of
responses using one or more of the following company records:
Company asset lists; Original and/or modified construction
specification documents; Purchase orders for equipment or other
purchasing documentation; Equipment lists maintained for leak
detection and repair programs or maintenance/turn-around
planning.
Review
the most up-to-date P&IDs. This review is an addition to the
review of other company records described above and any field
counts performed by the operator.
Perform
field counts at a representative sample of facilities to
identify any equipment that may have been missed or
decommissioned and to identify any systemic problems with counts
derived through other methods.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0064
|
The
EPA should divulge the number of facilities that exist within a
basin for each operator and how that number was derived. The
number of facilities by operator should be then divided by
industry segment. That data should be distributed for public
review and comment.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046,
52
|
EPA
Should Rescind Part 98, Subpart W. In light of its inadequacy in
achieving its original purpose, GPA Midstream recommends EPA
amend its request to OMB to renew the GHGRP to remove Subpart W.
(EPA ICR No. 2300.17, OMB Control No. 2060-0629). In the
alternative, EPA should at least revise this ICR to conform with
the scope of data previously collected through the GHGRP. If a
facility has already submitted data through the GHGRP for 2015
(processing plants under Subpart W), EPA should not be requiring
additional data collection beyond the already burdensome and
expansive GHGRP.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0046
|
EPA
should include a separate document either with the ICR, or in the
docket, that explains the expected scope of the response for the
questionnaire.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
EPA
should include data requests that help it determine not just the
emissions from a particular source, but also the cost of
controls.
|
EPA
has requested cost data from emission reduction technologies and
retrofits in the ControlDevice Tab in Part 2 of the ICR.
|
-0049
|
Using
the information gathered through the ICR and the Emerging
Technology Request for Information, EPA could develop engineering
scenarios and further outline its proposed control methods, while
giving industry and other stakeholders the opportunity to
evaluate the technical feasibility of EPA’s approach.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0049
|
Operators
who have received Clean Air Act Section 114 requests for
information on facility operations and emissions data in North
Dakota and elsewhere should be exempted from Part II of the ICR.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|
-0026
|
It
appears that EPA policy is being shaped by research organized by
the Environmental Defense Fund (EDF Fact Sheet, undated) as well
as by data from the EPA Subpart W Greenhouse Gas Mandatory
Reporting Rule (MRR). However, both of these programs may have
under reported methane emissions due to critical and well
documented measurement problems.
|
EPA
has considered and evaluated the impacts of this comment and has
decided not to pursue any further action.
|