### 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

- A S30

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 metric s of one percent and three percent and

whether these threshold s should be specific number s 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 a lso 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 agr ees and has cla rified 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 imag ing (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, a nd 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 recommendati ons 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 compresso r stations that exceed the 25,000 Metric Ton

CO 2 e 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 effo rts to achieve emission reductions through transparent and verifiable voluntary action that would obviate the burden associated with

NSPS applicability

. ”

EPA RESPONSE:

EPA believes that deleti ng this text would change the intention of the paragraph and h as 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 t o 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 f or 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 control s 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 i s 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 edit s 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 compresso rs regulated in the 2012 rule.”

EPA RESPONSE:

We do not think these edit s are appr opr iate. The BSER is the basis for the requirement opposed to representing the actual requirement. We prefer to retain these sentence s as they were written.

9. Reviewer rec ommend 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. Howev er, 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 requiri ng 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. Re viewer 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 per cent 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 surve ys 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 ”