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; Macpherson, 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 mentioned 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=esthag&vol=49&issue=13

Authors Lead 

Institution Title Link 

Harriss et al. EDF 

Using Multi-Scale Measurements to Improve Methane Emissions 

Estimates from Oil and Gas Operations in the Barnett Shale, Texas: 

Campaign Summary 

http://pubs.acs.org/doi/abs/10.10

Karion et al. NOAA 

/ CIRES

Aircraft-based Estimate of Total Methane Emissions from the Barnett 

Shale Region http://pubs.acs.org/doi/abs/10.10

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/10.10

Johnson et al. WVU Methane Emissions from Leak and Loss Audits of Natural Gas 

Compressor Stations and Storage Facilities http://pubs.acs.org/doi/abs/10.10

Nathan et al. UT-Dallas / 

Princeton 

Near field characterization of methane emissions from a compressor 

station using a model aircraft http://pubs.acs.org/doi/abs/10.10

Lavoie et al. Purdue Aircraft-Based Measurements of Point Source Methane Emissions in 

the Barnett Shale Basin http://pubs.acs.org/doi/abs/10.10

Yacovitch et al. Aerodyne Mobile Laboratory Observations of Methane Emissions in the Barnett 

Shale Region http://pubs.acs.org/doi/abs/10.10

Lan et al. U. Houston Characterizing fugitive methane emissions in the Barnett Shale area 

using a mobile laboratory http://pubs.acs.org/doi/abs/10.10

Rella et al.* Picarro Measuring Emissions from Oil and Natural Gas Well Pads Using the 

Mobile Flux Plane Technique 

http://pubs.acs.org/doi/abs/10.10

*published in earlier issue of ES&T

Townsend-Small et al. U. Cincinnati 

/ UC-Irvine

Integrating source apportionment tracers into a bottom-up inventory 

of methane emissions in an urban natural gas producing region http://pubs.acs.org/doi/abs/10.10

Zavala-Araiza et al. EDF Towards a Functional Definition of Methane Super-Emitters: 

Application to Natural Gas Production Sites http://pubs.acs.org/doi/abs/10.10

Lyon et al. EDF Constructing a Spatially Resolved Methane Emission Inventory for the 

Barnett Shale Region http://pubs.acs.org/doi/abs/10.10

Amy Hambrick 

U.S. Environmental Protection Agency 

(919)541-0964 
2

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; Macpherson, Alex; Thompson, Lisa; Spells, Charlene; Witosky, Matthew; 

Eck, Janet; Rush, Alan 

Subject: EO12866 O&G 2060 AS30 Revised TSD 

Aaron, 

Please see the RLSO of the TSD. These edits were added as a result of the interagency comments and also 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; Macpherson, 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 and response to interagency comments 

Aaron, 

Please see the attached revised NSPS and response to 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)541-0964 
1

Thompson, Lisa

From: Hambrick, Amy

Sent: Wednesday, August 12, 2015 8:09 PM

To: Szabo, Aaron

Cc: Hambrick, Amy; Cozzie, David; Tsirigotis, Peter; Gilbreath, Jan; Moore, Bruce; 

Macpherson, Alex; Thompson, Lisa; Howard, Jodi; Eck, Janet; Rush, Alan

Subject: Summary of Interagency Comments under EO12866 and 13563: Oil and Natural Gas 

Sector: Emission Standards for New and Modified Sources

Attachments: EO12866_O&GNSPS 2060 AS30 RIA_20150812_clean.docx; EO12866_O&GNSPS 2060 

AS30 RIA_20150812_RLSO.docx; EO12866_O&GNSPS 2060 AS30 RIA Spreadsheet_

20150812.xlsx; EO12866_O&G NSPS 2060 AS30 NPRM_ 20150812_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 Clean) 

- 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 programs and found a range of methods for incentivizing 

good behavior. Some states used a very low number of leaks to increase the frequency of surveys. Based

on our evaluation of the number of components at our model plants, we decided that it is important to 

account for the number of potential leaking components and therefore chose a percentage based on 

the number of leaking components relative to the total number of components at a site. 

o We recognize that there are different ways to incentivize good behavior and therefore are soliciting 

comment on other approaches such as the number of leaks. 

- Quarterly monitoring: 

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

Liquids Unloading: 

- Added “Furthermore, questions remain concerning the difficulty of effective control for these high-emitting 

events in many cases and the applicability and limitations of specific control technologies such as plunger lift 

systems for supporting a new source performance standard.” 

Well Sites: 

- Added “We are also retaining the provision from the 2012 NSPS, now at §60.5365a(a)(1), that a well that is 

refractured, and for which the well completion operation is conducted according to the requirements of

§60.5375a(a)(1) through(4), is not considered a modified well and therefore does not become an affected 

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 emissions standards 

at §60.5397a.” 
2

Thank you, 

Amy 

Amy Hambrick 

U.S. Environmental Protection Agency 

(919)541-0964 
1

Thompson, Lisa

From: Hambrick, Amy

Sent: Friday, August 14, 2015 6:07 PM

To: Szabo, Aaron

Cc: Cozzie, David; Tsirigotis, Peter; Gilbreath, Jan; Moore, Bruce; Macpherson, Alex; 

Thompson, Lisa; Howard, Jodi; Eck, Janet; Rush, Alan; Hambrick, Amy

Subject: RE: Summary of Interagency Comments under EO12866 and 13563: Oil and Natural Gas 

Sector: Emission Standards for New and Modified Sources

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_20150814_RLSO.docx; EO12866

_O&G NSPS 2060 AS30 NPRM_20150814_clean.docx; EO12866_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 raised in your email today on page 228, to add a footnote 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 completions[]” to state the following: 

“DrillingInfo contains data on drilling direction, well depth, production, and well site location at the formation, 

basin, and oil field level that has been reviewed by EPA. EPA is interested in comments on how analyses of 

these parameters or other relevant parameters may help develop a threshold based on well characteristics 

which may exhibit little to no gas recovery potential. These comments will help EPA determine if certain oil 

wells should be phased in or exempt from completion requirements. “ 

EPA RESPONSE: We do not agree to the addition of this 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 Standards 

for New and Modified Sources 
2

Please find below the summary of interagency comments under EO 12866 and 13563 on the proposed rule for the EPA 

proposed rule entitled 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 sentence that states “Additionally, we solicit comment on 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, well depth, production, and well site location at the formation, 

basin, and oil field level that has been reviewed by EPA. EPA is interested in comments on how analyses of 

these parameters or other relevant parameters may help develop a threshold based on well characteristics 

which may exhibit little to no gas recovery potential. These comments will help EPA determine if certain 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.gov
1

Thompson, Lisa

From: Hambrick, Amy

Sent: Monday, August 17, 2015 6:23 PM

To: Szabo, Aaron

Cc: Tsirigotis, Peter; Gilbreath, Jan; Cozzie, David; Macpherson, Alex; Moore, Bruce; 

Thompson, Lisa; Howard, 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

Attachments: EO12866_O&G NSPS 2060 AS30 NPRM_20150817_v3_CLEAN.docx

Aaron- Please see the change on p133 which reads “For convenience, in this rulemaking, we will use reasonable to 

describe our evaluation of costs well within the boundaries 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; Howard, 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; Howard, Jodi; 

Spells, Charlene; Eck, Janet; Rush, Alan 
2

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 today’s interagency comments. Also, please see the RLSO and clean versions of the 

rule package. Note, the RLSO compares to last version 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 Standards 

for New and Modified Sources 

Attached please find the summary of interagency comments under EO 12866 and 13563 on the proposed rule for the 

EPA proposed rule entitled 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.gov
1

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; Cozzie, David; Macpherson, Alex; Moore, 

Bruce; Thompson, Lisa; Howard, Jodi; Eck, Janet; Rush, Alan

Subject: Conclusion of EO 12866 and 13563 Review: Emission Standards 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 Management and Budget (OMB) has concluded its review under Executive 

Orders 12866 and 13563 of the U.S. Environmental Protection 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 comments. Thank you. 

Aaron L. Szabo 

Policy Analyst 

Office of Management and Budget 

202-395-3621 

Aaron_L_Szabo@omb.eop.gov