1 

### Thompson, Lisa

From: Hambrick, Amy Sent: Thursday, August 06, 2015 12:21 PM To: Aaron_L_Szabo@omb.eop.gov Cc: Gilbreath, Jan; Cozzie, David; Moore, Bruce; Macphe rson, Alex; Thompson, Lisa; Spells, Charlene; Witosky, Matthew; Eck, Janet; Rush, Alan Subject: re: EO12866 O&G 2060 AS30

Aaron,

Below are links to the recent studies that were men tioned on our follow up call this morning.

Barnett Shale Coordinated Campaign papers published in Environmental Science & Technology ES&T Volume 49, Issue 13 cover: http://pubs.acs.org/action/showLargeCover?jcode=est hag&vol=49&issue=13

Authors Lead

Institution Title Link

Harriss et al. EDF Using Multi-Scale Measurements to Improve Methane E missions Estimates from Oil and Gas Operations in the Barnet t Shale, Texas: Campaign Summary http://pubs.acs.org/doi/abs/10.1021/acs.est.5b02305

Karion et al. NOAA

/ CIRES Aircraft-based Estimate of Total Methane Emissions from the Barnett

Shale Region http://pubs.acs.org/doi/abs/10.1021/acs.est.5b00217

Smith et al. U. Michigan Airborne ethane observations in the Barnett shale: Quantification of ethane flux and attribution of methane emissions http://pubs.acs.org/doi/abs/10.1021/acs.est.5b00219

Johnson et al. WVU Methane Emissions from Leak and Loss Audits of Natu ral Gas Compressor Stations and Storage Facilities http://pubs.acs.org/doi/abs/10.1021/es506163m

Nathan et al. UT-Dallas /

Princeton Near field characterization of methane emissions fr om a compressor

station using a model aircraft http://pubs.acs.org/doi/abs/10.1021/acs.est.5b00705

Lavoie et al. Purdue Aircraft-Based Measurements of Point Source Methane Emissions in the Barnett Shale Basin http://pubs.acs.org/doi/abs/10.1021/acs.est.5b00410

Yacovitch et al. Aerodyne Mobile Laboratory Observations of Methane Emissions in the Barnett Shale Region http://pubs.acs.org/doi/abs/10.1021/es506352j

Lan et al. U. Houston Characterizing fugitive methane emissions in the Ba rnett Shale area using a mobile laboratory http://pubs.acs.org/doi/abs/10.1021/es5063055

Rella et al.* Picarro Measuring Emissions from Oil and Natural Gas Well P ads Using the Mobile Flux Plane Technique http://pubs.acs.org/doi/abs/10.1021/acs.est.5b00099 *published in earlier issue of ES&T

Townsend-Small et al. U. Cincinnati

/ UC-Irvine Integrating source apportionment tracers into a bot tom-up inventory

of methane emissions in an urban natural gas produc ing region http://pubs.acs.org/doi/abs/10.1021/acs.est.5b00057

Zavala-Araiza et al. EDF Towards a Functional Definition of Methane Super-Em itters: Application to Natural Gas Production Sites http:// pubs.acs.org/doi/abs/10.1021/acs.est.5b00133

Lyon et al. EDF Constructing a Spatially Resolved Methane Emission Inventory for the Barnett Shale Region http://pubs.acs.org/doi/abs/10.1021/es506359c



### Amy Hambrick U.S. Environmental Protection Agency (919)541-09642 From: Hambrick, Amy Sent: Wednesday, August 05, 2015 6:04 PM To: 'Aaron_L_Szabo@omb.eop.gov' Cc: Gilbreath, Jan; Cozzie, David; Moore, Bruce; Macph erson, Alex; Thompson, Lisa; Spells, Charlene; Wito sky, Matthew; Eck, Janet; Rush, Alan Subject: EO12866 O&G 2060 AS30 Revised TSD

Aaron,

Please see the RLSO of the TSD. These edits were ad ded as a result of the interagency comments and als o reflect minor editorial changes for clarification purposes.

Thank you,

Amy


### Amy Hambrick U.S. Environmental Protection Agency (919)541-0964

From: Hambrick, Amy Sent: Monday, August 03, 2015 9:52 PM To: 'Aaron_L_Szabo@omb.eop.gov' Cc: Gilbreath, Jan; Cozzie, David; Moore, Bruce; Macph erson, Alex; Thompson, Lisa; Hambrick, Amy; Spells, Charlene; Witosky, Matthew; Eck, Janet; Rush, Alan Subject: Email 2 of 2: EO12866 O&G 2060 AS30 Revised NSPS a nd response to interagency comments

Aaron,

Please see the attached revised NSPS and response t o interagency comments.

The following documents are attached:

- Revised NSPS RLSO

- Revised NSPS clean

- Response to interagency comments

- Response to additional interagency comments

Thank you,

Amy



### Amy Hambrick U.S. Environmental Protection Agency (919)541-09641 

### Thompson, Lisa

From: Hambrick, Amy Sent: Wednesday, August 12, 2015 8:09 PM To: Szabo, Aaron Cc: Hambrick, Amy; Cozzie, David; Tsirigotis, Peter; Gi lbreath, Jan; Moore, Bruce; Macpherson, Alex; Thompson, Lisa; Howard, Jodi; Eck , Janet; Rush, Alan Subject: Summary of Interagency Comments under EO12866 and 1 3563: Oil and Natural Gas Sector: Emission Standards for New and Modified Sou rces Attachments: EO12866_O&GNSPS 2060 AS30 RIA_20150812_clean.docx; EO12866_O&GNSPS 2060 AS30 RIA_20150812_RLSO.docx; EO12866_O&GNSPS 2060 A S30 RIA Spreadsheet_ 20150812.xlsx; EO12866_O&G NSPS 2060 AS30 NPRM_ 201 50812_CLEAN.docx; EO12866_O&G NSPS 2060 AS30 NPRM_ 20150812_RLSO.docx

Good Evening Aaron,

Please see the attached:
-revised NSPS (RLSO compared to 8/11 version and Cl ean) - revised RIA (RLSO and clean versions) - RIA associated ROCIS sheet.

Follow-up to our phone conversations with you this morning: Fugitives:

- Percentages for moving between frequencies:

o We looked at various state fugitive emission progra ms and found a range of methods for incentivizing good behavior. Some states used a very low number o f leaks to increase the frequency of surveys. Based on our evaluation of the number of components at ou r model plants, we decided that it is important to account for the number of potential leaking compone nts and therefore chose a percentage based on the number of leaking components relative to the to tal number of components at a site.

o We recognize that there are different ways to incen tivize good behavior and therefore are soliciting comment on other approaches such as the number of l eaks.

- Quarterly monitoring:

o Please see the email I sent yesterday. We are takin g comment on this.

Liquids Unloading:

- Added “Furthermore, questions remain concerning the difficulty of effective control for these high-emi tting events in many cases and the applicability and limi tations of specific control technologies such as pl unger lift systems for supporting a new source performance sta ndard.”

Well Sites:

- Added “We are also retaining the provision from the 2012 NSPS, now at §60.5365a(a)(1), that a well tha t is refractured, and for which the well completion oper ation is conducted according to the requirements of §60.5375a(a)(1) through(4), is not considered a mod ified well and therefore does not become an affecte d facility under the NSPS. We point out that such an exclusion of a “well” from applicability under the NSPS has no effect on the affected facility status of the “well site” for purposes of the proposed fugitive emissi ons standards at §60.5397a.”2 Thank you,

Amy


### Amy Hambrick U.S. Environmental Protection Agency (919)541-09641 

### Thompson, Lisa

From: **Hambrick, Amy** Sent: **Friday, August 14, 2015 6:07 PM** To: **Szabo, Aaron** Cc: **Cozzie, David; Tsirigotis, Peter; Gilbreath, Jan; M oore, Bruce; Macpherson, Alex;**  **Thompson, Lisa; Howard, Jodi; Eck, Janet; Rush, Ala n; Hambrick, Amy**  Subject: **RE: Summary of Interagency Comments under EO12866 a nd 13563: Oil and Natural Gas**  **Sector: Emission Standards for New and Modified Sou rces**  Attachments: **EO12866_O&GNSPS 2060 AS30 RIA Spreadsheet_20150814. xlsx; EO12866_O&GNSPS**  **2060 AS30 RIA_20150814_clean.docx; EO12866_O&GNSPS 2060 AS30 RIA_20150814**  **_RLSO.DOCX; EO12866_O&G NSPS 2060 AS30 NPRM_2015081 4_RLSO.docx; EO12866**  **_O&G NSPS 2060 AS30 NPRM_20150814_clean.docx; EO128 66_OG NSPS 2060 AS30**  **TSD 201500812_ RLSO.docx**

Hi Aaron,

First, please see the revised documents:

- Preamble/Reg clean and RLSO

- RIA clean and RLSO + ROCIS spreadsheet

- TSD RLSO

Second, regarding the specific comment that was rai sed in your email today on page 228, to add a footn ote at the end of the sentence that states “Additionally, we solicit comment on all aspects of our proposal to regulate methane and VOC emissions from hydraulically fractured oil well com pletions[]” to state the following: “DrillingInfo contains data on drilling direction, well depth, production, and well site location at t he formation, basin, and oil field level that has been reviewed b y EPA. EPA is interested in comments on how analys es of these parameters or other relevant parameters may h elp develop a threshold based on well characteristi cs which may exhibit little to no gas recovery potenti al. These comments will help EPA determine if cert ain oil wells should be phased in or exempt from completion requirements. “

EPA RESPONSE: We do not agree to the addition of th is footnote.

Thank you,

Amy


### Amy Hambrick U.S. Environmental Protection Agency (919)541-0964

From: Szabo, Aaron [mailto:Aaron_L_Szabo@omb.eop.gov] Sent: Friday, August 14, 2015 4:18 PM To: Hambrick, Amy; Cozzie, David Subject: Summary of Interagency Comments under EO12866 and 13563: Oil and Natural Gas Sector: Emission Standar ds for New and Modified Sources2 Please find below the summary of interagency commen ts under EO 12866 and 13563 on the proposed rule fo r the EPA proposed rule entitle d Oil and Natural Gas Sector: Emission Standards for New and Modified Sources

. Specific Comment:

On page 228, add a footnote at the end of the sente nce that states “Additionally, we solicit comment o n all aspects of our proposal to regulate methane and VOC emissions from hydraulically fractured oil well completions[] ” to state the following: DrillingInfo contains data on drilling direction, w ell depth, production, and well site location at th e formation, basin, and oil field level that has been reviewed b y EPA. EPA is interested in comments on how analys es of these parameters or other relevant parameters may h elp develop a threshold based on well characteristi cs which may exhibit little to no gas recovery potenti al. These comments will help EPA determine if cert ain oil wells should be phased in or exempt from completion requirements.

Please let me know if you have any questions.

Aaron L. Szabo Policy Analyst Office of Management and Budget 202-395-3621 Aaron_L_Szabo@omb.eop.gov1 

### Thompson, Lisa

From: **Hambrick, Amy** Sent: **Monday, August 17, 2015 6:23 PM** To: **Szabo, Aaron** Cc: **Tsirigotis, Peter; Gilbreath, Jan; Cozzie, David; M acpherson, Alex; Moore, Bruce;**  **Thompson, Lisa; Howard, Jodi; Spells, Charlene; Eck , Janet; Rush, Alan**  Subject: **RE: Summary of Interagency Comments under EO12866 a nd 13563: Oil and Natural Gas**  **Sector: Emission Standards for New and Modified Sou rces**  Attachments: **EO12866_O&G NSPS 2060 AS30 NPRM_20150817_v3_CLEAN.d ocx** 

Aaron- Please see the change on p133 which reads “F or convenience, in this rulemaking, we will use rea sonable to

describe our evaluation of costs well within the bo undaries established by this case law.”

Thank you,

Amy



### Amy Hambrick U.S. Environmental Protection Agency (919)541-0964

From: Hambrick, Amy Sent: Monday, August 17, 2015 5:41 PM To: 'Szabo, Aaron' Cc: Tsirigotis, Peter; Gilbreath, Jan; Cozzie, David; Macpherson, Alex; Moore, Bruce; Thompson, Lisa; How ard, Jodi; Spells, Charlene; Eck, Janet; Rush, Alan Subject: RE: Summary of Interagency Comments under EO12866 and 13563: Oil and Natural Gas Sector: Emission Standards for New and Modified Sources

Aaron- Please see the addition of footnote 89. This is the only change. Thank you.

Amy


### Amy Hambrick U.S. Environmental Protection Agency (919)541-0964

From: Hambrick, Amy Sent: Monday, August 17, 2015 4:53 PM To: 'Szabo, Aaron' Cc: Tsirigotis, Peter; Gilbreath, Jan; Cozzie, David; Macpherson, Alex; Moore, Bruce; Thompson, Lisa; How ard, Jodi; Spells, Charlene; Eck, Janet; Rush, Alan2 Subject: RE: Summary of Interagency Comments under EO12866 and 13563: Oil and Natural Gas Sector: Emission Standards for New and Modified Sources

Hi Aaron,

Please see the attached responses to tod ay’s interagency comments. Also, please see the RLS O and clean versions of the rule package. Note, the RLSO compares to last versi on that we sent you.

Thank you,

Amy


### Amy Hambrick U.S. Environmental Protection Agency (919)541-0964

From: Szabo, Aaron [ mailto:Aaron_L_Szabo@omb.eop.gov ] Sent: Monday, August 17, 2015 11:59 AM To: Hambrick, Amy; Cozzie, David Subject: Summary of Interagency Comments under EO12866 and 13563: Oil and Natural Gas Sector: Emission Standar ds for New and Modified Sources

Attached please find the summary of interagency com ments under EO 12866 and 13563 on the proposed rule for the EPA proposed rule entitle d Oil and Natural Gas Sector: Emission Standards for New and Modified Sources . To note, the interagency comments are made on top of a previous RLSO version so the interagency comments are noted by an “Author” comment bubble that states “Recommendation .”

Thanks and let me know if you have any questions.

Aaron L. Szabo Policy Analyst Office of Management and Budget 202-395-3621 Aaron_L_Szabo@omb.eop.gov1 

### Thompson, Lisa

From: Szabo, Aaron <Aaron_L_Szabo@omb.eop.gov> Sent: Monday, August 17, 2015 7:51 PM To: Hambrick, Amy; Spells, Charlene; Vetter, Cheryl Cc: Laity, Jim; Tsirigotis, Peter; Gilbreath, Jan; Cozz ie, David; Macpherson, Alex; Moore, Bruce; Thompson, Lisa; Howard, Jodi; Eck, Janet; Ru sh, Alan Subject: Conclusion of EO 12866 and 13563 Review: Emission S tandards for New and Modified Sources, Source Determination for Certain Emissions Units, and Control Techniques Guidelines -- Oil and Natural Gas Sector

This email serves as notice that the Office of Mana gement and Budget (OMB) has concluded its review un der Executive Orders 12866 and 13563 of the U.S. Environmental Pr otection Agency’s (EPA) proposed rule titled Emission Standards for New and Modified Sources in the Oil and Natural Gas Sector , the proposed rule titled Source Determination for Certain Emissions Units in the Oil and Natural Gas Sector , and the draft guidance titled Control Techniques Guideline for the Oil and Natural Gas Sector (RINs 2060-AS30, 2060-AS06, 2060-ZA22).

Please let me know if you have any questions or com ments. Thank you.

Aaron L. Szabo Policy Analyst Office of Management and Budget 202-395-3621 Aaron_L_Szabo@omb.eop.gov