EPA RESPONSE TO 8/17/2015 COMMENTS

Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

1

Environmental Protection Agency (EPA): Proposed Rule

Oil and Natural Gas Sector: Emission Standards for New and Modified Sources

RIN 2060-AS30

Comments:

1. Reviewer recommends having a single threshold of 1% for fugitive emissions for moving 

between quarterly, semiannual, and annual surveys.

EPA RESPONSE:

“We solicit comment on the proposed metrics of one percent and three percent and 

whether these thresholds should be specific numbers of components rather than 

percentages of components for triggering change in survey frequency discussed in this 

action. We also solicit comment on whether a performance-based frequency or a fixed 

frequency is more appropriate.”

2. In line edits to align with RIA. Also recommend adding that the requirement for 

compressor stations includes those in the transmission and storage segment. In an earlier 

version, EPA added the following in response to a comment. However, it was placed in 

the section on the White Papers, not a section summarizing the rule. Please also add the 

same language here so it is clear these are a covered, sources. Reviewer recommends 

clarifying whether the standards apply to gather and boosting stations, specifically in 

relation to fugitive emissions.

EPA RESPONSE: 

EPA agrees and has clarified this text.

“We are proposing that new and modified well sites and compressor stations (which 

include the transmission and storage segment and the gathering and boosting segment) 

conduct fugitive emissions surveys semiannually with optical gas imaging (OGI) 

technology and repair the sources of fugitive emissions within 15 days that are found 

during those surveys.”

3. Reviewer recommends “We are also co-proposing OGI monitoring surveys on an annual 

and quarterly basis for new and modified well sites, and requesting comment on OGI 

monitoring surveys on a quarterly basis for compressor stations.”

EPA RESPONSE: 

We determined that quarterly monitoring is not the BSER and not cost effective. 

However, EPA is taking the following comment, “...we solicit comment on an alternate 

option for the fugitive emission monitoring program based on setting the initial 

monitoring frequency to an annual or quarterly frequency.”
EPA RESPONSE TO 8/17/2015 COMMENTS

Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

2

4. Reviewer recommend adding the following text: “We recognize that subpart W already 

requires annual fugitives reporting for compressor stations, and requests comments on the 

overlap of these reporting requirements. Further, EPA is continuing to review the 

INGAA proposal for specific recommendations for a directed inspection and maintenance 

program for natural gas transmission and storage compressor stations.”

EPA RESPONSE: 

The following text is added, “We recognize that subpart W already requires annual 

fugitives reporting for certain compressor stations that exceed the 25,000 Metric Ton 

CO2e threshold, and request comments on the overlap of these reporting requirements.”

5. Reviewer recommend deleting the following text: “Building on the 2012 NSPS, the EPA 

intends to encourage corporate-wide efforts to achieve emission reductions through 

transparent and verifiable voluntary action that would obviate the burden associated with

NSPS applicability.”

EPA RESPONSE: 

EPA believes that deleting this text would change the intention of the paragraph and has 

therefore not deleted this text. 

6. Reviewer recommend adding the following edit: “In this action, we propose to set 

emission standards for methane and VOC for certain new, modified and reconstructed 

emission sources across the oil and natural gas source category. For some of these 

sources, there are VOC requirements currently in place that were established in the 2012 

NSPS, that we are expanding to include methane.”

EPA RESPONSE: 

EPA has made this edit. 

7. Reviewer recommend editing the following text to read, “That said, EPA acknowledges 

that there is no additional methane reductions from the proposed methane standards for 

those already subject to VOC standards, if they are meeting the standards for both. EPA 

is also aware that, depending on the segment of the industry, the VOC emissions may be 

high while methane emissions are low and vice versa. In light of the above, The EPA is 

soliciting comment on whether the 2012 NSPS standards for VOC should be modified 

further than we are proposing here to allow for additional methane reductions.”

EPA RESPONSE: 

EPA has edited this paragraph as follows: 

“For the reasons explained in section V, EPA believes that the proposed methane 

standards are warranted, even for those already subject to VOC standards under the 2012 

NSPS. Further, as shown in the analyses in section VIII, there are cost effective controls 

that achieve simultaneous reductions of methane and VOC emission. That said, EPA 

acknowledges that there are no additional methane reductions from the proposed methane 
EPA RESPONSE TO 8/17/2015 COMMENTS

Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

3

standards for those already subject to VOC standards. In light of the above, the EPA is 

soliciting comment on whether it is appropriate to rely on VOC standards, as established 

in 2012, for sources in the production and processing segment. For example, based on 

methane and VOC emissions from pneumatic controllers, this approach could result in 

just a VOC standard for pneumatic controllers in the production segment and a VOC and 

methane standard in the transmission and storage segment.”

8. Reviewer recommend similar edits to the following sections: 

“We are, therefore, not proposing any change in the BSER to the current requirements for 

emission sources addressed under the 2012 NSPS.”

“These proposed methane standards would require no change to the BSER requirements 

for currently regulated affected facilities. However, EPA is taking comment on the 

finding that the available controls for VOC achieve the same levels of reduction for both 

VOC and methane.”

“These BSER is the same as for centrifugal compressors regulated in the 2012 final rule.”

“These BSER the same as for reciprocating compressors regulated in the 2012 rule.”

EPA RESPONSE:

We do not think these edits are appropriate. The BSER is the basis for the requirement 

opposed to representing the actual requirement. We prefer to retain these sentences as 

they were written. 

9. Reviewer recommend editing the following text to read: “We are also co-proposing 

monitoring surveys on an annual and a quarterly basis for new and modified well sites. “

EPA RESPONSE: 

We determined that quarterly monitoring is not the BSER nor cost effective. However, 

EPA is taking the following comment, “...we solicit comment on an alternate option for 

the fugitive emission monitoring program based on setting the initial monitoring 

frequency to an annual or quarterly frequency.”

10. Reviewer recommend editing the following text to read: We believe it provides the 

greatest emission reductions of the options we considered in our analysis in Section 

VIII.H, and that the costs are reasonable. However, we are also taking comment on 

requiring additional measures to reduce fugitive emissions are natural gas processes 

plants, for example, those stated above. 

EPA RESPONSE:

We believe that the VVa will adequately reduce emissions. 
EPA RESPONSE TO 8/17/2015 COMMENTS

Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

4

11. Reviewer recommend editing the following text to read: “For convenience, in this 

rulemaking, we will use reasonable describe our evaluation of costs well within the 

boundaries established by this case law.”

EPA RESPONSE: 

We believe that is it is legally stronger to retain the sentence as it was written. 

12. Reviewer recommend editing the following text to read: We believe that drilling of a low 

production well may be unintentional and may be infrequent, but production may 

nevertheless proceed due to economic reasons.

EPA RESPONSE: 

EPA has made this edit. 

13. Reviewer recommend editing the following text to read: “The monitoring frequency shall 

return to semiannual if a survey detects fugitive emissions between 1.0 percent and 5.0 

percent of the fugitive emissions components at the well site, or between 1.0 percent and 

5.0 percent of the fugitive emissions components at the compressor station, and shall 

return to quarterly if a survey detects fugitive emissions at greater than 5.0 percent of the 

fugitive emissions components at the well site, or greater than 5.0 percent of the fugitive 

emissions components at the compressor station.”

EPA RESPONSE: 

“(h) The monitoring frequency specified in paragraph (g) of this section shall be 

increased to quarterly in the event that two consecutive semiannual monitoring surveys 

detect fugitive emissions at greater than 3.0 percent of the fugitive emissions components 

at a well site or at greater than 3.0 percent of the fugitive emissions components at a 

compressor station.

(i) The monitoring frequency specified in paragraph (g) of this section may be decreased 

to annual in the event that two consecutive semiannual surveys detect fugitive emissions 

at less than 1.0 percent of the fugitive emissions components at a well site, or at less than 

1.0 percent of the fugitive emissions components at a compressor station. The monitoring 

frequency shall return to semiannual if a survey detects fugitive emissions between 1.0 

percent and 3.0 percent of the fugitive emissions components at the well site, or between 

1.0 percent and 3.0 percent of the fugitive emissions components at the compressor 

station”